UNITED STATES PATENT AND TRADEMARK OFFICE
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`Case IPR2016-00999
`Patent No. 8,311,582
`Issue Date: November 13, 2012
`Title: ASYMMETRICAL BEAMS FOR SPECTRUM EFFICIENCY
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`COMMSCOPE REQUEST FOR RECONSIDERATION
`UNDER 37 C.F.R. § 42.71(c)
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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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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`
`
`Case IPR2016-00999
`Patent No. 8,311,582
`Issue Date: November 13, 2012
`Title: ASYMMETRICAL BEAMS FOR SPECTRUM EFFICIENCY
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`COMMSCOPE REQUEST FOR RECONSIDERATION
`UNDER 37 C.F.R. § 42.71(c)
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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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`TABLE OF CONTENTS
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`TABLE OF AUTHORITIES .................................................................................... ii
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`I.
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`INTRODUCTION ........................................................................................... 1
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`II. APPLICABLE LEGAL STANDARDS .......................................................... 2
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`III. BASIS FOR RELIEF REQUESTED .............................................................. 3
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`A.
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`B.
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`C.
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`D.
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`The Board Misapprehended or Overlooked that the Same Asymmetry
`is Shown on Both Linear and Logarithmic Scales ................................ 3
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`The Board Misapprehended or Overlooked that Patent Owner’s Plot
`Shows the Same Asymmetry ................................................................. 7
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`The Board Misapprehended or Overlooked that Figures 4 and 8 are
`Radiation Patterns Verified by Measurements .................................... 10
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`The Board Overlooked or Misapprehended the Facts Showing that All
`Steered Planar Array Antennas Inherently Result in Radiation Patterns
`Having At Least One Asymmetrical Beam ......................................... 13
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`IV. CONCLUSION ..............................................................................................15
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`TABLE OF AUTHORITIES
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`Page(s)
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`Cases
`Arnold P’ship v. Dudas,
` 362 F.3d 1338, 1340 (Fed. Cir. 2004) .................................................................... 3
`
`In re Gartside,
` 203 F.3d 1305, 1315-16 (Fed. Cir. 2000) ............................................................... 3
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`Star Fruits S.N.C. v. U.S.,
` 393 F.3d 1277, 1281 (Fed. Cir. 2005) .................................................................... 3
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`Other Authorities
`Daicel Corp. v. Celanese Int’l,
` IPR2015-00173, Paper 15 (June 26, 2015) ......................................................3, 10
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`Genband U.S. LLC v. Metaswitch Networks Ltd.,
` IPR2015-01457, Paper 17 (Feb. 22, 2016) ...........................................................10
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`Merial Ltd. v. Virbac,
` IPR2014-01279, Paper 18 (April 15, 2015) .........................................................10
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`Rules
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`37 C.F.R. § 42.71 ....................................................................................................... 1
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`37 C.F.R. § 42.71(c) ...............................................................................................2, 9
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`37 C.F.R. § 42.71(d) .................................................................................................. 2
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`ii
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`I.
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`INTRODUCTION
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`On November 3, 2016, the Board issued a Decision (“Decision”) denying
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`institution of Inter Partes Review (“IPR”) of U.S. Patent No. 8,311,582
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`(“the ‘582 Patent”). Paper 9. The Decision was based on a single issue: whether
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`Petitioner sufficiently established that the prior art discloses asymmetry of at least
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`one beam of a split-sector antenna. Id., at 15, 22. This Request seeks
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`reconsideration, is authorized under 37 C.F.R. § 42.71, and prior authorization for
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`filing is not required. This Request is timely as it is being filed within 30 days of
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`the entry of a decision not to institute a trial. Id.
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`The Decision relied on Patent Owner’s incorrect statements to find that
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`Petitioner “has not explained why the shapes shown in the linear scale drawings of
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`Figure 4 [of Yea] would show similar shapes when converted to a logarithmic
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`scale.” Id., at 15. Petitioner could not have anticipated that Mr. Cosgrove would
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`erroneously testify that the asymmetry of a beam radiated from an antenna on a
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`cell tower changes depending on whether a person chooses to plot that beam on a
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`linear or logarithmic scale. In fact, the asymmetry of a main beam radiated from a
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`split-sector antenna – which is what the ‘582 patent is directed to – does not
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`change based on the scale on which it is plotted. Yet, the Board misapprehended
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`and relied on this based on the Patent Owner’s incorrect argument.
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`The Decision also relied on Mr. Cosgrove’s testimony that “asymmetrical
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`1
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`characteristics exhibited in the [steered beam planar array antennas] prior art were
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`viewed as a distortion” and were “undesired.” Id., at 20-21. Based on this
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`testimony, the Board found: “Petitioner has established only that asymmetrical
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`beams may be used in a planar array antenna, but not that a person of ordinary skill
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`in the art would have understood steered beams of a planar array antenna are
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`necessarily asymmetrical.” Id., at 22. However, the Board overlooked that there is
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`no credible dispute that steering planar array antennas always inherently result in
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`asymmetrical beams. Moreover, Mr. Cosgrove’s characterization of the prior art is
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`incorrect; the prior art acknowledges and accepts this inherent asymmetry.
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`II. APPLICABLE LEGAL STANDARDS
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`37 C.F.R. § 42.71(d) provides in relevant part: “The burden of showing a
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`decision should be modified lies with the party challenging the decision. The
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`request must specifically identify all matters the party believes the Board
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`misapprehended or overlooked, and the place where each matter was previously
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`addressed in a motion, an opposition, or a reply.” (Emp. added).
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`37 C.F.R. § 42.71(c) provides in relevant part, “[w]hen rehearing a decision
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`on petition, a panel will review the decision for an abuse of discretion.” In cases
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`involving the USPTO, the Federal Circuit has stated “[a]n abuse of discretion
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`occurs where the decision is based on an erroneous interpretation of the law, on
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`factual findings that are not supported by substantial evidence, or represents an
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`2
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`unreasonable judgment in weighing relevant factors.” Star Fruits S.N.C. v. U.S.,
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`393 F.3d 1277, 1281 (Fed. Cir. 2005); Arnold P’ship v. Dudas, 362 F.3d 1338,
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`1340 (Fed. Cir. 2004); In re Gartside, 203 F.3d 1305, 1315-16 (Fed. Cir. 2000);
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`Daicel Corp. v. Celanese Int’l, IPR2015-00173, Paper 15, at 2 (June 26, 2015).
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`III. BASIS FOR RELIEF REQUESTED
`A. The Board Misapprehended or Overlooked that the Same
`Asymmetry is Shown on Both Linear and Logarithmic Scales
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`The fundamental misapprehension in the Decision is the erroneous idea that
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`plotting a given beam pattern on a logarithmic scale versus a linear scale will alter
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`the symmetry or asymmetry of the beam pattern. Because it is factually incorrect,
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`Petitioner could not have anticipated that Patent Owner would represent to the
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`Board that varying the scale on which data is plotted changes the beam asymmetry.
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`The Decision misapprehended a fundamental point: if a beam generated by
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`an antenna is asymmetrical, it will be asymmetrical regardless of the scale in which
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`it is plotted (i.e. logarithmic vs. linear). There is no dispute that the asymmetry of
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`a beam is determined by measuring and comparing the angle (i.e., degree of offset)
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`from the center of the beam to a common signal level on both the left and right
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`sides of the beam.1 Petition, at 10-11, 15, 19-20. Significantly, the angle from the
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`1 An example illustrating the angular measurements that determine asymmetry is
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`provided at the end of this section.
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`3
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`center of the beam to any particular signal level at either side of the beam will not
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`be altered whether the beam is plotted on a linear scale or on a logarithmic scale.
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`The angle will and must be the same regardless of what scale is used to plot the
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`beam pattern. This is a basic mathematical principle that cannot be disputed.
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`The Patent Owner’s own evidence, a textbook entitled Antenna Theory
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`Analysis and Design (EX2005), which is already in the record, takes pains to
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`emphasize this mathematical property of polar beam plots: that the angle to any
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`particular signal level along a beam pattern will be the same whether plotted on a
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`linear scale or a logarithmic scale. Exhibit 2005 both illustrates and explains that
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`the same radiation pattern when plotted on either a linear scale or a logarithmic
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`(dB scale), has precisely the same angular measurements for a given reference
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`signal level even though the plotted curves appear different on the page. EX2005,
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`at p.29 and Fig. 2.2 (“All three patterns yield the same angular separation
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`between the two half-power points, 38.64°, on their respective patterns,
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`referred to as HPBW and illustrated in Figure 2.2.”).
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`Figures 2.2 (b) and (c) from
`EX2005 plotting the same pattern
`using linear and logarithmic scales.
`Note that the angle to any
`particular signal level (e.g., the
`half-power point) on the plots is the
`same. Compare the angle between
`the dotted lines of the beam in
`Figure 2.2(b) to the angle between
`the dotted lines of the beam in
`Figure 2.2(c).
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`4
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`Exhibit 2005 uses Figure 2.2 to show the same radiation pattern plotted on
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`both linear and logarithmic scales. Id., at p.29. Using dotted lines, Figure 2.2
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`shows that in each plot, the points representing the same signal levels on both
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`scales have exactly the same degree of angular separation regardless of the scale
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`(logarithmic vs. linear) used to plot the antenna pattern.2 Thus, there can be no
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`dispute that the asymmetry of a beam is the same and can be measured regardless
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`of whether the plot of the beam is on a linear or logarithmic scale.
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`Patent Owner is simply wrong in its unsupported argument that if Figure 4 is
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`shown on a linear scale, the plot cannot be used to determine asymmetry and rather
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`must be converted to a logarithmic scale. Response, at 30. To the contrary, it is a
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`mathematical certainty that the same asymmetry is determined from a pattern
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`plotted on either scale by measuring the angles from the beam center to a common
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`signal level on either side of the beam. See e.g., EX2005, Fig. 2.2.
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`Example asymmetry determination
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`As a reminder and aid in understanding how asymmetry is determined,
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`consider the following example which was presented and discussed in the Petition
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`at 10-11. The Patent Owner applied the same method of EX2005 and made
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`angular measurements from the beam centerline to accuse Petitioner’s steered
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`2 Note that when plotted on a linear scale, the half-power point has a value of 0.5
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`and that when plotted on a logarithmic scale, that point has a value of -3 dB.
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`5
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`planar array antenna product of producing asymmetrical beams. Note that the third
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`row of Patent Owner’s table reproduced in the Petition (i.e., for an attenuation
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`level of -15) stated that the “Left Hand Beam” of Petitioner’s Product had 16°
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`(or 20.0%) of asymmetry because the angle of the beam’s left side at the
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`-15 attenuation level (see green line below) is offset from the centerline of the
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`beam by 48° while the angle of the beam’s right side the same power level -15 (see
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`blue line below) is only offset from the centerline by 32°.3 Thus, the difference
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`between these offsets is 16° of asymmetry (i.e., 48° - 32°). A symmetrical beam
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`would have the same offset on both sides (a difference of 0°). Petition, at 10-11.
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`Note that the concentric circles of the radial scale provide clear reference points on
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`both sides of the beam at which the signal level is, by definition, the same.
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`Example illustrating angular
`measurements Patent Owner used to
`determine asymmetry. The left hand
`beam is asymmetric (at -15
`attenuation) because the two offset
`angles from the max signal level at the
`center of the beam are not the same.
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`
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`3 Patent Owner’s table states the offset assuming the beam peak defines 0°. Thus,
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`to match the table with the plot it should be kept in mind that the center of the left
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`hand beam is located at 334°. Thus, a 312° offset from a 334° centerline (red line)
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`results in a line at 286° (green line) as shown in the figure from EX1012, p. 21-22.
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`6
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`As set forth in the Petition, Mr. Collins measured the asymmetry of the
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`beams shown on the right side of Figure 4 of Yea in precisely the same manner and
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`found that the beams are asymmetrical, ranging between 5° to 12° of asymmetry
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`per beam. Petition, at 15, 41-42, 45, 46; EX1017; and EX1024, ¶122. It does not
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`matter what scale is used to plot the beam; the same asymmetry will be present at
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`the same signal level points along the sides of the beam.4
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`B.
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`The Board Misapprehended or Overlooked that
`Patent Owner’s Plot Shows the Same Asymmetry
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`Correcting this basic misapprehension regarding the alleged difference
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`between linear and logarithmic plots is sufficient to warrant the institution of this
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`IPR. However, Patent Owner expanded on its misstatements to lead the Board
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`down a path of increasingly incorrect assumptions. Even if the plot of Figure 4 of
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`Yea uses a linear scale, and even if the plot were to be converted to a logarithmic
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`scale as suggested by Mr. Cosgrove, it would still show the same asymmetry in
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`exactly the same degree as measured by Mr. Collins. EX2005, Fig. 2.2.
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`4 Although the Decision was premised solely on the claim element relating to
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`asymmetry, Petitioner notes that this same principle will also apply when
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`comparing coverage areas for other claim limitations. Coverage areas are
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`expressed in terms of angles (see e.g., EX1001, col. 4:45-50), and the angles do not
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`change on a polar plot when converting between linear and logarithmic scales.
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`7
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`Mr. Cosgrove asserts that he “converted” the green beam from Figure 4 of
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`Yea (i.e., the beam that has 7° at its beam center) into what he claimed was a
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`logarithmic scale without any explanation as to how he performed this
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`“conversion.” EX2001, ¶¶127, 129. His resulting plot is shown below next to
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`Figure 4. Based on his conversion, Mr. Cosgrove argued that the different shape of
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`his plot shows that asymmetry cannot be determined. Id., ¶129.
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`Assuming for the sake of argument that Mr. Cosgrove’s conversion is
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`correct, what is important in determining asymmetry, as discussed above, is the
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`measurements of angular separation between two points at a constant signal level
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`on either side of the beam peak. Those angular measurements on Figure 4 and
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`Mr. Cosgrove’s plot of the same beam will show exactly the same asymmetry.
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`As shown below, the same beam is being depicted in both plots. The points
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`indicated in green and blue on Figure 4 of Yea are the same signal levels that are
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`indicated on Mr. Cosgrove’s converted logarithmic plot (in green and blue).5
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`As can be seen, the angular degree of separation between the green and blue points
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`on either side of the beam peak in both plots is exactly the same, showing that both
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`plots have the same 9° of asymmetry (i.e., 46° - 37°). Petition, at 15; EX1017;
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`5 The points marked on Figure 4 are on the circle marked 294. Petition at 14. Mr.
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`Cosgrove converted 294 to 1.8 on his alleged logarithmic scale. EX2001, at ¶112.
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`8
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`EX1024, at ¶122. Thus, even if Patent Owner’s logarithmic plot is correct, it
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`confirms that at least one beam of Figure 4 is asymmetric.
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`The Decision misapprehended or overlooked that linear and logarithmic
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`representations of the same beam pattern always maintain the same angular
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`separation from the center of the beam to a common signal level on the left and
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`right sides of the beam and, therefore, will always show the same amount of
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`asymmetry for a given beam.
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`
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`In reliance on Patent Owner’s erroneous factual arguments, the Board
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`overlooked or misapprehended this significant fact. Thus, even if Yea’s Figure 4 is
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`on a linear scale, it discloses asymmetry because the same asymmetry is shown on
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`linear and logarithmic scales. Indeed, even accepting Mr. Cosgrove’s plot, the
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`same degree of asymmetry is shown.6 The necessary abuse of discretion required
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`by Rule 42.71(c) therefore has been established and this IPR should be instituted.
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`6 Petitioner does not agree that Figure 4 is on a linear scale (Petition, at 13-15), but
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`assumes here that it is for purposes of argument.
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`9
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`Genband U.S. LLC v. Metaswitch Networks Ltd., IPR2015-01457, Paper 17 at 2-4
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`(Feb. 22, 2016) (granting request for reconsideration where, in reliance on Patent
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`Owner’s erroneous arguments, the Board misapprehended Petitioner’s evidence
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`showing why a person of ordinary skill in the art would understand a limitation to
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`be present in the prior art); see also Daicel, IPR2015-00173, Paper 15 at 4-5
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`(granting request for reconsideration where the Board overlooked factual evidence
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`in the record); Merial Ltd. v. Virbac, IPR2014-01279, Paper 18 at 8, 14-15 (April
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`15, 2015) (granting request for reconsideration where the Board “misapprehended
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`or overlooked a significant fact, [and thus] the necessary abuse of discretion
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`required by Rule 42.71(c) has been established”).
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`C. The Board Misapprehended or Overlooked that Figures
`4 and 8 are Radiation Patterns Verified by Measurements
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`The Decision also held (1) that “Petitioner here does not identify any portion
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`of Yea disclosing that Figures 4 and 8 are drawn accurately enough to determine
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`an asymmetrical nature of the radiation patterns”; and (2) “Petitioner also fails to
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`cite to any disclosure in Yea that identifies or describes an asymmetrical nature of
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`the radiation patterns.” Id., at 14-15. To the contrary the Petition shows that
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`Figures 4 and 8 are plots verified by measured data, and the Figures themselves
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`show the asymmetric nature of the radiation patterns.
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`Yea was authored by an electrical engineer and was published in a technical
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`journal, RF Design, not a marketing paper as alleged by Patent Owner. Petition, at
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`10
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`12-14. Yea expressly states that the antenna patterns of Figure 4 are verified by
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`measurements representing real-world test data:
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`The cell where the deployment occurred is a busy suburban site in
`the network of a major U.S. cellular operator. . . Before and after
`ERP plots of the two configurations are shown in Figure 4. The
`footprint of the six-sector pattern was also verified through drive
`testing; the six-sector strongest serving pilot PN offset plot is shown
`in Figure 5.
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`EX1016, at 5 (emp. added); see also Petition, at 12-13 and EX1024 ¶¶114, 116-
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`117. Figure 4 of Yea is not a drawing devoid of size and proportions. Figure 4 is a
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`radiation plot that was verified as accurate through testing. Petition, 12 (“Yea
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`discloses results of a field trial of the SpotLight 2000 system . . . and at Figs. 4 and
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`8 showing radiation patterns from the tested SpotLight 2000 system”).
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`Moreover, Yea’s Figure 4 expressly states that it shows “ERP plots
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`comparing antenna patterns” of the three-sector and the six-sector configuration.
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`See Petition, at 13-14 and EX1024 ¶¶117-118. The plots show a recognized value
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`(ERP) used for describing the strength of the signal radiated in different directions,
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`as well as the concentric circles of each plot which each define equal signal points
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`along the radial scale. The Petition and Mr. Collins Declaration explained that
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`“ERP is a standard acronym for Effective Radiated Power, so the patterns shown
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`in Figure 4 are radiation patterns, as usually defined: the radial scale is in
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`effective radiated power (ERP) rather than being scaled as the gain of the
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`antennas or scaled relative to the maximum of the radiation patterns.” EX1024
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`11
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`
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`¶117 (emp. added) and Petition at 13. The concentric circles provided on each plot
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`clearly and conveniently provide accurate points of reference for finding the same
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`signal level on both the left and right sides of a single beam for determining beam
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`asymmetry.
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`Moreover, Yea Figure 8 represents antenna patterns by Ec/Io on a
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`logarithmic scale: “Figure 8. Ec/Io plots of the baseline three-sector
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`configuration (left) and the new six-sector configuration (right) reveal similar
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`total handoff overhead.” Id., at 15 (emp. added); Petition, at 14-15; EX1024, ¶120,
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`121. This is confirmed by Patent Owner’s exhibits. EX2009, at 150 (“Ec/Io
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`effectively determines the forward coverage area of a cell or sector. . .”) and
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`EX2007, at 327 (Figure 13.1 showing “Ec/Io plots” in “dB”) (emp. added).
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`Patent Owner also is incorrect that “the left and right plots use different
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`linear scales and hence cannot be simply overlaid on each other.” Response, at 29.
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`First, there is no need to compare the left and right plots to determine asymmetry.
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`Asymmetry is determined by a single plot of a beam (see above), not comparing
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`two different plots. Second, the Petition recognized that in order to compare
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`radiation patterns, they must be plotted on scales that span the same relative radial
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`scale. EX1024 ¶117; Petition at 13. Here, there is no dispute that the radial scale
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`of the plots of Figure 4 each are in “decreasing rings of 50” (Response, at 33).
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`Thus, the figures may be overlaid on each other. Indeed, Figure 4 itself expressly
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`12
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`invites such a comparison by stating that the plots are “comparing” the sector and
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`split-sector configurations, which confirms that they are on the same relative scale.
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`Patent Owner also incorrectly stated that “radiation patterns extending from
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`an antenna span around 40 dB’s of coverage,” which it then uses to criticize Yea as
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`allegedly only showing 4dB of coverage. Response at 30-31.7 Yet the ‘582 patent
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`shows that radiation patterns do not need to “span around 40 dB’s of coverage.”
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`Figure 6 of the ‘582 Patent shows a radiation pattern that spans only 21 dB’s of
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`coverage. EX1001, Fig. 6. Moreover, the claims of the ‘582 Patent do not require
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`a 40 dB range or a logarithmic scale.
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`In sum, the Board overlooked that the plots in Figure 4 (and Figure 8) are
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`antenna patterns verified by measurements having concentric circles defining equal
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`signal levels and, thus, disclose more than sufficient data to determine asymmetry.
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`D. The Board Overlooked or Misapprehended the Facts Showing
`that All Steered Planar Array Antennas Inherently Result in
`Radiation Patterns Having At Least One Asymmetrical Beam
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`There is no credible dispute that all steered planar array antennas inherently
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`result in radiation patterns that have at least one asymmetrical beam. Mr. Collins
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`7 Figure 4 does not show only 4 dB of coverage - - it is of an entire radiation
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`pattern and, thus, itself shows that Patent Owner is wrong. As discussed above,
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`whether Figure 4 is on a logarithmic or linear scale is irrelevant and no conversion
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`to a different scale is needed to determine asymmetry.
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`13
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`provided a detailed technical tutorial that establishes why this is so. Petition, at 18-
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`20; EX1024, ¶¶45, 136-139. Moreover, Mr. Cosgrove acknowledged that such
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`beam steering results in inherent asymmetry of the beams. EX2001, ¶¶26, 71.
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`In finding that that Petitioner had not established that steered planar array
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`antennas necessarily result in asymmetric beams, the Board relied on
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`Mr. Cosgrove’s erroneous testimony that five prior art references allegedly teach
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`that this inherent asymmetry is undesirable. Decision, at 20-22. The Board
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`overlooked or misapprehended the fact that the prior art does not include such a
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`teaching:
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`• Four of the patents sought to reduce unacceptably high sidelobes, and do not
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`teach to eliminate the inherent asymmetry of the main beam (which is the
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`beam required in the claims of the ‘582 Patent). See EX2010 (Fig. 4 and its
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`discussion); EX2011 (Fig. 3 and its discussion); EX2013 (which has
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`teachings similar to EX2011); EX1007 (no objection to the asymmetry
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`provided by the Butler matrix as shown in Fig. 18).
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`• The fifth patent, EX2012, discloses that steering a planar array results in
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`beams having approximately the same overall beamwidth (Col. 4:37-5:36).
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`As shown in EX2011 and EX2010, a steered planar array necessarily
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`produces asymmetrical beams.
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`14
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`The Board thus overlooked or misapprehended Petitioner’s evidence that
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`steered planar array antennas inherently result in asymmetrical beams.8
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`IV. CONCLUSION
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`In view of the foregoing, Petitioner respectfully requests that the Board
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`authorize Inter Partes Review on all grounds.
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`Date: December 2, 2016
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`8 The Board also found the Petition does not sufficiently set forth “why a person of
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`Respectfully submitted,
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`By: /s/ Lynne A. Borchers
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`Lynne A. Borchers (Reg. No. 49,090)
`Lead Counsel for Patent Owner
`Peter D. Siddoway (Reg. No. 56,443)
`Backup Counsel for Patent Owner
`Myers Bigel, P.A.
`P.O. Box 37428
`Raleigh, North Carolina 27627
`Telephone: (919) 854-1400
`Facsimile:
`(919) 854-1401
`lborchers@myersbigel.com
`psiddoway@myersbigel.com
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`ordinary skill in the art would use the asymmetrical beams of the prior art with the
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`disclosure of Yea.” Decision, 22. The Board overlooked that the Petition relies on
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`Yea’s disclosure of asymmetrical beams (Fig. 4), as well as on the Metawave
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`Website’s teaching that the Yea system uses a steered planar array antenna, which
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`inherently produces asymmetrical beams, to reduce overlap in the handover zone
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`while maintaining the original coverage area. Petition, at 35-38, 39-43.
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`15
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`CERTIFICATE OF SERVICE
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`Pursuant to 37 C.F.R. §§ 42.8(e) and 42.105(b), the undersigned certifies
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`that on December 2, 2016, a complete and entire copy of the foregoing Request for
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`Reconsideration, was served via email tojoesofer@soferharoun.com and
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`jdimatteo@hsgllp.com identified in Patent Owner’s Mandatory Notice.
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`Dated: December 2, 2016
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` By: /s/ Lynne A. Borchers
`Lynne A. Borchers (Reg. No. 49,090)
`Myers Bigel, P.A.
`P.O. Box 37428
`Raleigh, North Carolina 27627
`Telephone: (919) 854-1400
`Facsimile: (919) 854-1401
`lborchers@myersbigel.com
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`16
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