`UNITED STATES PATENT AND TRADEMARK OFFICE
`_____________
`
`BEFORE THE PATENT TRIAL AND APEAL BOARD
`_____________
`
`DALI WIRELESS INC.,
`Petitioner,
`
`v.
`
`COMMSCOPE TECHNOLOGIES LLC,
`Patent Owner
`____________
`
`Case IPR2017-01324
`Patent No. 7,848,747
`Issued: December 7, 2010
`Filed October 27, 2009
`____________
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`PRELIMINARY RESPONSE BY PATENT OWNER
`UNDER 37 C.F.R. § 42.107
`____________
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`Preliminary Response by Patent Owner
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`Case No.: IPR2017-01324
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`TABLE OF CONTENTS
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`Page
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`Introduction .............................................................................................. 1
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`I.
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`II.
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`Background .............................................................................................. 3
`A.
`Introduction to the ‘747 Patent ....................................................... 3
`B. Declaration from Dr. Anthony Acampora ..................................... 6
`C.
`Foundation to the technology ......................................................... 8
`D.
`The RF transport system of the ‘747 patent ................................. 13
`E.
`Understanding the distinction between: (1) transport
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`systems that receive RF spectrum and digitize for transport,
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`and (2) transport systems that receive information signals
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`and digitize for transport .............................................................. 20
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`III. Petitioner’s Claim Construction ............................................................. 22
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`IV. Preliminary Response to Petitioner’s Invalidity Arguments ................. 22
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`A.
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`Bellers in view of Farhan ............................................................. 22
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`1.
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`2.
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`3.
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`4.
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`Overview of Bellers (Ex. 1006) ........................................ 22
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`Overview of Farhan ........................................................... 34
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`There is no reasonable likelihood of claims 7-17, and
`2 being found obvious based on Bellers (Ex. 1006) in
`view of Farhan (Ex. 1007) ................................................. 42
`
`There is no reasonable likelihood of claims 1, 3-6
`being found obvious based on Bellers (Ex. 1006) in
`view of Farhan (Ex. 1007) ................................................ 46
`
`B.
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`Bellers in view of Grace ............................................................... 48
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`
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`1.
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`Overview of Grace ............................................................. 48
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`Preliminary Response by Patent Owner
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`C.
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`There is no reasonable likelihood of claims
`7-11, 13-17 being found obvious based on
`Bellers (Ex. 1006) in view of Grace (Ex. 1008) ................ 59
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`2.
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`
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`Ichiyoshi in view of Farhan .......................................................... 62
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`1.
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`2.
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`3.
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`Overview of Ichiyoshi ........................................................ 62
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`There is no reasonable likelihood of claims 7, 8, 10,
`11, 14 being found obvious based on Ichiyoshi
`(Ex. 1009) in view of Farhan (Ex. 1007) ........................... 67
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`There is no reasonable likelihood of claim 1 being
`found obvious based on Ichiyoshi (Ex. 1009)
`in view of Farhan (Ex. 1007) ............................................. 69
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`Preliminary Response by Patent Owner
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`EXHIBITS
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`Exhibit No.
`2001
`2002
`2003
`
`Description
`Declaration Under 37 CFR § 42.53 of Dr. Anthony Acampora
`Curriculum Vitae of Dr. Anthony Acampora
`Notice of Intent to Issue Ex Parte Reexamination Certificate in
`Reexamination Control No. 90/010,362
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`Preliminary Response by Patent Owner
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`I.
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`Introduction
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`Case No.: IPR2017-01324
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`The petition asserts that the claims of ‘747 patent are unpatentable on three
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`grounds. In Ground 1, the petition alleges that claims 1-17 are obvious over a
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`combination of Bellers (Ex. 1006) and Farhan (Ex. 1007). In Ground 2, the
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`petition alleges that claims 7-11, 13-17 are obvious over a combination of Bellers
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`(Ex. 1006) and Grace (Ex. 1008). In Ground 3, the petition alleges that claims 1,
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`7, 8, 10, 11, 14 are obvious over a combination of Ichiyoshi (Ex. 1009) and Farhan
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`(Ex. 1007).
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`As will be further explained below, for at least the following reasons, the
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`Board should deny the Petition.
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`First, the Petition is procedurally defective because it fails the requirements
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`under Graham to identify the differences between the claims and the primary
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`references (e.g., Bellers and Ichiyoshi) before turning to secondary references
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`(Farhan and Grace). Frustratingly, the Petitioner and its declarant avoid
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`affirmatively admitting any differences between the claims and any of the asserted
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`references (primary and secondary). The Petitioner, instead, leaves that task to the
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`Board and CommScope to divine what missing elements or what changes to the
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`primary references Petitioner believes would have been obvious to POSA in view
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`of the asserted combinations.
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`Preliminary Response by Patent Owner
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`Second, multiple elements are missing even if one were somehow to
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`combine the asserted references under Grounds 1, 2, or 3.
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`Third, as to each of the asserted references, the missing elements are the
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`result of significant design drivers and objectives that are in direct conflict with the
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`design drivers and objectives behind the RF transport invention of the ‘747 patent.
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`This conflict in underlying design drivers is not only a form of teaching away from
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`the claimed invention, but also leads to fundamentally different principles of
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`operation and incompatible technologies. As a result of this conflict, a POSA
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`would not have been motivated to modify any of the asserted references in way
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`that has all the elements of the claims.
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`Lastly, Petitioner fails to provide any plausible “rational underpinning” to
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`support the conclusory opinion by Petitioners declarant that POSA would have
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`been motivated to modify the primary references in a way that has all the elements
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`of the claims. This required articulation of a rational explanation is not possible, of
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`course, in view of Petitioners effort to obfuscate and avoid identifying any
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`differences or discuss the underlying design objectives that drove those
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`differences. The unsupported conclusions of Petitioner’s declarant are entitled to
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`little or no weight.
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`Preliminary Response by Patent Owner
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`II. Background
`A.
`Introduction to the ‘747 Patent
`The ‘747 patent relates to extending cellular radio frequency (RF) service
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`into difficult-to-reach coverage areas, such as within buildings. The specification
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`discloses an RF transport system for transporting a wireless service provider’s RF
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`spectrum to remote antenna units positioned within the difficult-to-reach coverage
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`areas, where the antenna units are better able to communicate wirelessly with
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`mobile devices. Such systems are commonly known as distributed antenna
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`systems (DAS). The abstract provides a useful description of the digital RF
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`transport system disclosed in the ‘747 patent:
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`A system and method for enhancing the performance of wide
`band digital RF transport systems is disclosed, which enables the
`transport of different bandwidth segments on a plurality of
`wideband channels by selecting an optimal clock sample rate for
`each bandwidth segment to be transported. Thus, the bandwidth
`segments are proportionally allocated so that an optimum
`amount of bandwidth can be transported at the serial bit rate.
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`Solely for the purposes of this Preliminary Response, the claims are
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`discussed in two groups. The first group includes claims 7-17, and 2. Notably,
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`claims 7, 8, and 10 fall within this group and are the asserted claims in currently
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`pending litigation between the Petitioner and the Patent Owner in U.S. District
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`Court for the Northern District of Texas, CommScope Technologies LLC v. Dali
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`Preliminary Response by Patent Owner
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`Wireless, Inc., Case No. 3:2016cv447. There are three independent claims in this
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`first group, claims 7, 11, and 14. Each of claims 7, 11, and 14 recites a wideband
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`digital RF transport system or host unit for wideband digital RF transport. In
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`claims 7, 11, and 14 the recited host units include a plurality of inputs that each
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`receive a broadband RF input or RF bandwidth segments. Claims 7 and 11 also
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`recite analog to digital converter circuits that each generating a sample rate that is
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`related to or based on the bandwidth of its associated RF input signal. Claim 14
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`similarly recites a remote unit that converts multiple digital RF segments into
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`multiple analog RF bandwidth segments using a sample rate based on the
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`bandwidth of the associated RF bandwidth segment. Finally, each of these claims
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`requires multiplexing digitized input signals into one serialized bit stream.
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`Claim 7, the only independent claim at issue in the pending litigation, is as
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`follows:
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`7. A host unit for wideband digital RF transport, the unit comprising:
`a plurality of inputs, each input coupled to receive a broadband
`RF signal;
`a plurality of analog to digital converter circuits, each coupled
`to a selected one of the plurality of inputs, each analog to
`digital converter circuit generating a sample stream, wherein
`each analog to digital converter circuit operating at a sample
`rate related to a signal bandwidth of its associated broadband
`RF signal; and
`a multiplexer circuit for multiplexing together the plurality of
`sample streams into one serial bit stream at a fixed bit rate.
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`The second group includes claims 1 and 3-6. These claims are directed to a
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`method and require receiving multiple inputs and sampling to generate a sampling
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`rate based on the bandwidths of the associated inputs. Unlike the prior group of
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`claims, claims 1 and 3-6 do not specifically recite that the inputs are broadband RF
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`signals. Instead, these claims recite that the inputs each have “an associated
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`bandwidth containing an arbitrary number of channels.” Dependent claim 2,
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`however, adds the limitation that the inputs are analog RF bands from a plurality of
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`base stations. Therefore, claim 2 is included in the first group, not the second
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`group
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`Claim 1, the only independent claim in the second group, is as follows:
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`1. A method, comprising:
`receiving a plurality of analog inputs each having an associated
`bandwidth containing an arbitrary number of channels;
`sampling each of the plurality of analog inputs with a selected
`sample rate, the selected sample rates selected based on the
`bandwidth of the associated one of the plurality of analog
`inputs;
`combining the samples of the plurality of analog inputs;
`converting the combined samples to a serial data stream; and
`transmitting the serial data stream over a communication
`medium.
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`B. Declaration from Dr. Anthony Acampora
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`Patent Owner submits a declaration from Dr. Anthony Acampora which
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`provides a more detailed introduction to RF transport systems used to distribute RF
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`spectrum into hard to reach coverage areas. See Declaration of Dr. Anthony
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`Acampora (Ex. 2001).
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`Dr. Acampora explains an important distinction that must be kept in mind
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`when analyzing the claims of the ‘747 patent and the prior art. The distinction is
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`between digitzing broadband RF signals for transport vs. digitizing information
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`signals for transport. See Ex. 2001, ¶¶ 56-60 and 39-55. Specifically, systems that
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`do not address or disclose multiple broadband RF inputs or that base
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`analog-to-digital conversion schemes on characteristics of an information signal
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`instead of the bandwidth of the RF signal should be clearly distinguished from the
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`claims that require generating sample rates based on or related to the bandwidths of
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`RF input signals or input signals.
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`The distinction represents the difference between materially different design
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`objectives and operating principles. The ‘747 patent, for example, is directed to a
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`digital RF transport system that has multiple inputs, each to receive a different
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`bandwidth segment of broadband RF spectrum, and for each input of RF spectrum,
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`the transport system employs bandwidth-dependent sampling rates. This
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`combination of features is based on a balance of various design objectives.
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`One design objective is that, for each of multiple inputs of different
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`bandwidth segments of RF spectrum, the transport system generates a digital
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`representation of that entire RF spectrum, without the need to know: whether the
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`RF frequencies within the spectrum are encoded with any information signals; or
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`whether RF frequencies carry only noise; or whether the RF frequencies carry any
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`particular type of data. On the one hand, this digitized RF spectrum feature
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`preserves a design objective of maintaining the wireless service provider’s
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`confidence that the transport system will not disturb the encoded information
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`signals or how such information signals are packaged or encoded within the RF
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`spectrum. On the other hand, this transport feature forfeits maximum efficiency in
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`bandwidth transport. Maximum efficiency would require a transport system that
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`unpacks or demodulates the information signals and then samples or digitizes only
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`the actual information signals instead of the entire segment of RF spectrum.
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`Having access to the information signals or original data (i.e., no longer encoded
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`on RF carrier frequencies), the transport system could tailor the sample rates based
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`on the amount or type of information signals to be transported. Of course, doing
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`so, would sacrifice all DAS product sales because neither the service provider nor
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`its customers would accept such a transport system. See Ex. 2001, ¶¶ 43, 51-52
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`57-59.
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`Significantly, three of the four asserted references, including Bellers (Ex.
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`1006), Grace (Ex. 1008) and Ichiyoshi (Ex. 1009), are systems having inputs that
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`only receive information signals (i.e., not RF signals including a range of RF
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`frequencies that may or may not be encoded with information signals). See Ex.
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`Preliminary Response by Patent Owner
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`2001, ¶¶ 61, 63-64, 68, 75, 81-84, 104, 108. Bellers, Grace and Ichiyoshi disclose
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`digitizing information signals and thus employ operating principles in direct
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`conflict with the design objectives and operating principles underlying the
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`transport system of the ‘747 patent. Id.
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`Another design objective to be balanced relates to the multiple inputs of
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`different RF bandwidth segments. Here, the ‘747 patent introduces some measure
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`of bandwidth efficiency while forfeiting some system flexibility and ease of
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`deployment. The disclosed system receives multiple wideband RF input signals
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`and digitizes the signals using different sample rates depending on the bandwidth
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`of the RF input signals to avoid oversampling of the smaller bandwidth RF signals
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`which would otherwise result in inefficient use of the optical transport medium.
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`Ex. 2001, ¶¶48, 53-55.
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`C.
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`Foundation to the technology
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`Some foundation in the concepts of RF spectrum, RF carrier frequencies
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`within RF spectrum, encoding or modulating information signals onto RF carrier
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`frequencies, and RF transport systems that employ distributed antennas to expand
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`the reach of wireless networks is appropriate and is provided in the Decalaration of
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`Dr. Anthony Acampora. See Ex. 2001, ¶¶39-60.
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`Information signals or original data signals. An information signal or
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`original data signal (also known as original baseband signal, e.g., voice, video,
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`Preliminary Response by Patent Owner
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`computer data) refers to the signal before it has been encoded or modulated onto an
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`RF frequency carrier. So that the information can be transmitted wirelessly, the
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`base station will encode or modulate information signals onto RF carrier
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`frequencies. Regardless of which, if any, RF frequencies have been encoded with
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`information signals, the composite of all the RF frequencies within the licensed
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`spectrum is transported to the co-located RF antenna where it is wirelessly
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`propagated throughout the radio cell. Illustrated below is the downstream path
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`from the information signals received by the base station to the RF antenna which
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`wirelessly transmits the RF spectrum to the mobile device that receives the RF
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`spectrum and unpacks or demodulates the information signals from the RF
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`spectrum. Ex. 2001 ¶42.
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`Between the base station and mobile device, the service provider generally
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`allows no access to the information signals encoded or carried on the RF spectrum.
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`Thus, whether the RF spectrum carries video or voice information on any
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`particular RF frequency, or no information, is known only to base station that
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`packages the data and the cell phones that receive and unpack any data from the
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`RF spectrum. Ex. 2001 ¶43.
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`Distributed Antenna Systems. For difficult-to-reach coverage areas, such
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`as within buildings, a service provider or building owner may employ a transport
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`system for transporting the RF spectrum to multiple distributed remote antennas.
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`Such systems are commonly known as distributed antenna systems (DAS). The
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`two drawings below illustrate a RF transport system that employs distributed
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`remote antennas to expand the reach of wireless networks. The first drawing
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`illustrates the general concept. The second drawing illustrates how such a system
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`may be deployed within a building. Ex. 2001 ¶44.
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`In the downstream direction, the job of the host unit is to accept the RF
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`spectrum as it is presented by the base station (which would include all modulated
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`RF carriers, if any) and convert it into a format appropriate for distribution to each
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`Remote Antenna Unit (RAU) over cabling. At each RAU, the original RF
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`spectrum, as it was presented by the base station, is recreated and radiated by that
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`RAU’s antenna. Ex. 2001 ¶45.
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`In the uplink direction, the entire RF spectrum is received by each RAU
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`antenna is converted by the corresponding RAU into a format appropriate for
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`Preliminary Response by Patent Owner
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`transmission over the cabling back to the host unit, which creates a composite RF
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`spectrum from that which is received by each RAU for presentation back to the
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`base station. Ex. 2001 ¶46.
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`Distributed Antenna
`System Deployed
`within a Building
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`D.
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`The RF transport system of the ‘747 patent
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`The ‘747 patent is directed to an RF transport system, which may be used
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`within a DAS system for accepting multiple RF inputs (each of which occupies
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`some known RF spectrum) and converting these RF inputs into a binary stream of
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`logical “1s” and “0s” suitable for delivery to a remote location via cabling (which
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`may be an optical fiber cable). Ex. 2001 ¶47. Each arriving RF input is digitized
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`at an appropriately high rate (which depends on the bandwidth or spectral range of
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`that RF input). Then these digital sample streams, each corresponding to one of
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`the RF inputs, are time-multiplexed into a composite digital sample stream which
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`is then formatted into repetitive time-slotted frames and converted into a serial
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`Preliminary Response by Patent Owner
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`time-multiplexed bit stream. The remote unit receives and processes this bit
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`stream to recreate each individual RF input. Ex. 2001 ¶47.
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`Bandwidth dependent sampling in RF transport systems receiving
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`multiple broadband RF inputs for digital transmission. In the context of
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`extending wireless networks, the ‘747 patent discloses and claims an RF transport
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`system that employs bandwidth dependent sampling rates (different sample rates
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`applied to different received bandwidths of RF signals) to the transport digitized
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`representations of RF spectrum. The abstract provides a useful description of the
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`‘747 disclosed RF transport system. Ex. 1001, Abstract; Ex. 2001 ¶48.
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`Fig. 1 of the ‘747 patent is reproduced below with annotations (red) and
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`color coding (yellow to identify host unit and blue to identify remote unit) to assist
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`the reader. Ex. 2001 ¶49. Fig. 1 illustrates an embodiment of a wideband digital
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`RF transport system (100) which can be used to implement the claimed invention.
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`The RF transport system is to be inserted into a wireless network to assist in
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`transporting broadband RF spectrum into difficult-to-reach coverage areas such as
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`within buildings. On the left side of Fig. 1, the RF transport system includes a host
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`unit (101) having multiple inputs. Each input receives a different segment of
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`broadband RF spectrum from a wireless network. Each of the received broadband
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`RF signals occupies a different portion or segment of the RF spectrum. These
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`Preliminary Response by Patent Owner
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`segments of RF spectrum may be received from one or more base station(s). Ex.
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`1001, 3:9-11 and Fig. 1.
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`Ex. 1001, 2:55-67 and Fig. 1. Note that the background section of the ‘747 patent
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`discloses the use of a system of this type as part of a DAS (Ex. 1001, 1:23-34); a
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`depiction of how this would be accomplished is shown below. As indicated below,
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`a copy of the binary stream created by the host unit is sent to each of several
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`remote units (one per floor of a building, for example).
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`The host unit generates a digital representation of the received segments
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`of broadband RF spectrum. For each input of broadband RF spectrum, the host
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`includes analog to digital circuitry (“ADC circuitry”). Ex. 2001 ¶50. In Fig. 1, see
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`for example the box labeled “A/D DDC,” the output of which is a stream of digital
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`samples that represent the received RF spectrum. Ex. 1001, 3:22 to 4:8, Fig. 1.
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`The RF frequencies within the RF spectrum may, or may not, carry
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`information signals, such as analog baseband voice or data signals. In
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`assessing the prior art and what would have been obvious to a person of ordinary
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`Preliminary Response by Patent Owner
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`skill in the art at the time of the invention, it is important to understand that the
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`digital RF transport system of the ‘747 patent receives RF spectrum having a range
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`of RF carrier frequencies which may, or may not, carry information signals, such
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`as analog baseband voice or data signals. Ex. 2001 ¶51.
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`The RF transport system of the ‘747 patent does not receive information
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`signals directly as inputs, nor does it demodulate or unpack any information signals
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`encoded on the RF carrier frequencies within the received spectrum. Ex. 2001 ¶52.
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`In other words, the claimed host unit of the ‘747 patent employs a transport system
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`that relies on neither access to, nor awareness of the type, of any data carried on
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`the RF spectrum, nor how any information signals (if present) have been formatted
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`and modulated onto the RF carrier frequencies within the spectrum. Ex. 2001 ¶52.
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`The ADC circuitry simply samples a composite RF spectrum at some sampling
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`rate, converts each sample from an analog value to a digital value corresponding to
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`that analog value, and outputs a stream of digital values (that is, parallel bit
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`streams) representing that segment of RF spectrum presented at the input of the
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`ADC, which will include any modulated signals inside that spectrum as well as any
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`other noise or interference in the spectrum. Ex. 2001 ¶52. As explained above,
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`after time multiplexing with other digital samples and framing, a serial bit stream
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`is created and sent to the remote unit.
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`Preliminary Response by Patent Owner
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`Sample rate is bandwidth dependent. The sampling rate employed by the
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`RF transport system of the ‘747 patent is bandwidth dependent, and does not rely
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`on access to, or awareness of the type of any data carried on the RF spectrum. Ex.
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`2001 ¶53. For two received segments of RF spectrum that have different
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`bandwidths, the resultant sample rate of the ADC circuitry is bandwidth dependent,
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`i.e., so that the larger bandwidth segment will have more samples (and more bits)
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`in a fixed period of time. Ex. 1001, 1:65 to 2:6; 2:49-51; 5:66 to 6:36; and Fig. 2.
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`The disclosed host unit in the ‘747 patent also includes multiplexer circuitry
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`that receives and combines the multiple streams of samples (one stream for each
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`RF segment) for serial transport using frames with a fixed number of slots wherein,
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`because the sampling rate is tailored to the bandwidth, the samples from larger
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`bandwidth spectrum segments will occupy more slots in the frames (because more
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`samples must be sent per frame or per unit time). Ex. 1001, Fig. 2. This results in
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`more efficient digital transport of the multiple RF spectra as compared to a system
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`which simply allocates the same number of time slots per frame to each RF
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`spectrum, in which case some of the time slots would be sent empty (there simply
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`being no bits to send because more space was allocated to those RF spectrum than
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`is actually needed). Ex. 2001 ¶54.
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`Fig. 2 from the ‘747 patent illustrates that samples of an RF spectrum with a
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`larger bandwidth will be allocated more slots in the frame used for serial transport
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`Preliminary Response by Patent Owner
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`of the combined data (all slots carrying the same number of bits). Fig. 2 is
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`Case No.: IPR2017-01324
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`reproduced below with blue and yellow highlighting so the frame slots allocated
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`between two of the broadband RF signals (5 MHz (yellow) and 40 MHz (blue))
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`can be more easily compared. Ex. 2001 ¶55. As shown, since the bandwidth of
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`the B signal is wider than that of the D signal, it is sampled more frequently (i.e.,
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`more samples are generated per a unit of time by the corresponding A/D-DDC
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`shown in Fig. 1). Since each digitized sample contains the same number of bits,
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`more bits per unit time (or per frame) are created for the B signal than for the D
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`signal. Accordingly, the B signal is allocated more time slots per frame.
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`Preliminary Response by Patent Owner
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`E. Understanding the distinction between: (1) transport systems that
`receive RF spectrum and digitize for transport, and (2) transport
`systems that receive information signals and digitize for
`transport.
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`The difference between (1) transport systems that receive RF spectrum and
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`digitize for transport, and (2) transport systems that receive information signals and
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`digitize for transport must be understood and considered in the analysis of whether
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`a person of skill in the art would have found the invention obvious in view of the
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`asserted prior art combinations. Ex. 2001 ¶56.
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`As discussed above, in the disclosed and claimed RF transport system of the
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`‘747 patent, the information signals are not demodulated or unpacked from the RF
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`carriers. Instead, a digital representation of the spectrum is generated regardless of
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`what, if any, information signals are carried on the RF frequencies or what
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`communication protocol was used. Ex. 2001 ¶57.
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`While it may be more efficient to unpack or demodulate the information
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`signals and transport only that information (as opposed to digitizing the RF
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`spectrum which would include the information modulated RF carriers), that would
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`require having access to the wireless service provider’s communication protocols
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`and signal content (for both information signals and control or overhead signals).
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`Ex. 2001 ¶58. The transport system of the ‘747 patent transports a digital
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`representation of the RF spectrum which does not involve either demodulation of
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`any encoded information signals or any awareness of the nature of the information
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`Preliminary Response by Patent Owner
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`(e.g., voice, video, data). Ex. 2001 ¶58. Such transport systems are agnostic to the
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`wireless communication protocols and signal content and can be deployed, for
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`example, by building owners to transport licensed RF spectrum for multiple
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`wireless service providers. Ex. 2001 ¶58. For each service provider, such
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`transport systems are invisible to its wireless network.
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`In this regard, the operation of the ‘747 host unit is somewhat analogous to
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`the following. Consider an online retailer that receives an order for a pair of
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`fragile, expensive wine glasses (analogous to an information signal). Following its
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`packing protocol, the retailer carefully packs the wine glasses using tape, styro-
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`foam, bubble-rap and multiple boxes. After packaging, the wine glasses occupy
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`less than 10% of the final package. The retailer then retains a third party service
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`(analogous to the ‘747 patent’s system) to assist in delivering the package to the
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`customer. While the delivery service could fit more items on its trucks if it could
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`unpack and deliver only the wine glasses without the packaging, neither the retailer
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`nor customer would approve of such a delivery service. Instead, the package is
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`delivered, as is, without knowing what product is being delivered and in a way that
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`does not break the unknown cargo or the packaging surrounding the cargo. Ex.
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`2001 ¶59.
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`In short, the digital RF transport system of the ‘747 patent, is designed to be
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`invisible. This design objective should not be lost in assessing whether a person of
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`Preliminary Response by Patent Owner
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`skill in the art would have found the claimed invention to be obvious. Ex. 2001
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`¶60.
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`III. Petitioner’s Claim Construction
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`Patent owner believes that at this stage the Board does not need to construe
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`these terms because they are irrelevant to the contested issues below. Should trial
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`be instituted, Patent Owner reserves the right to propose constructions for these
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`terms.
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`IV. Preliminary Response to Petitioner’s Invalidity Arguments
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`A.
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`Bellers in view of Farhan
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`As described below, and in the supporting declaration of Dr. Acampora (Ex.
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`2001 at ¶¶61-74, 92-103, and 114-123), neither Bellers nor Farhan disclose (i)
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`multiple broadband RF input signals or (ii) generating sample rates based on the
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`associated bandwidths of each of the multiple RF input signals.
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`1.
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`Overview of Bellers (Ex. 1006)
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`The Bims declaration regarding Bellers, concerns a transport system that
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`relies on knowing that an input signal is a video signal and having access to that
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`input video signal. Ex. 1006, FIG. 1; Ex. 2001, ¶61. In Bellers, the input
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`information signal has not been encoded onto an RF carrier frequency. Id. The
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`transport system disclosed in Bellers only works with video information signals.
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`Id. Bellers does not concern or disclose a wideband digital RF transport system
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`having inputs to receive multiple segments of broadband RF spectrum. Id. Bellers
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`Preliminary Response by Patent Owner
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`discloses a receiver unit with a single input that receives a video signal, i.e., an
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`information signal or original data signal. The single input to the Beller’s receiver
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`is not a broadband RF signal. Ex. 2001, ¶61; Ex. 1006, FIG. 1.
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`Referring to FIG. 1, Bellers discloses “a video receiver 101 having an input
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`102 receiving an analog video signal.” Ex. 1006, 2:56-59 and FIG. 1. Bellers says
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`such a unit may be “a digital television” or “cable broadcast receiver for
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`connection to a television” (i.e., the cable box that connects to TV). Ex. 1006,
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`2:62-64; Ex. 2001, ¶62.
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`Ex. 1006, FIG.1.
`The disclosed receiver in Bellers only works for video signals. Ex. 2001,
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`¶63. All disclosed embodiments of receiver 101 employ content-dependent
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`frequency sampli