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`Paper No. 7
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`UNITED STATES PATENT AND TRADEMARK OFFICE
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`____________________
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`____________________
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`DALI WIRELESS INC.
`Petitioner
`
`v.
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`COMMSCOPE TECHNOLOGIES LLC
`Patent Owner
`
`____________________
`
`Case IPR2017-01324
`U.S. Patent No. 7,848,747 B2
`Issued: December 7, 2010
`Filed: October 27, 2009
`____________________
`
`PETITIONER’S REQUEST FOR REHEARING
`PURSUANT TO 37 C.F.R. § 42.71
`____________________
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`Case IPR2017-01324
`U.S. Patent No. 7,848,747
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`TABLE OF CONTENTS
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`Page
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`I.
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`II.
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`INTRODUCTION ........................................................................................... 1
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`APPLICABLE RULES ................................................................................... 1
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`III. REQUESTED RELIEF ................................................................................... 2
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`IV. CLAIM LIMITATIONS AT ISSUE ............................................................... 2
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`V.
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`ARGUMENT ................................................................................................... 4
`A.
`Broadest Reasonable Interpretation of “Selecting the Sample
`Rate Based On Bandwidth” ................................................................... 4
`Ichiyoshi and Farhan ............................................................................. 6
`Bellers and Farhan ...............................................................................10
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`B.
`C.
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`VI. CONCLUSION ..............................................................................................15
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`VII. CERTIFICATE OF SERVICE ......................................................................16
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`Case IPR2017-01324
`U.S. Patent No. 7,848,747
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`I.
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`INTRODUCTION
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`The undersigned, on behalf of and acting in a representative capacity for
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`petitioner Dali Wireless (“Petitioner”), hereby respectfully requests rehearing of
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`the November 1, 2017, Decision (“Decision”) denying institution of trial. In
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`particular, Petitioner requests rehearing of the Board’s decision not to institute
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`review with regard to claims 1-5, and 7-17. In rendering its Decision, the Board did
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`not interpret the claimed “sample rate selected based on the bandwidth” and
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`similar limitations under the Broadest Reasonable Interpretation standard, and as a
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`result misapprehended the Petition’s application of the Bellers and Ichiyoshi
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`references to this claim limitation. In addition, the Board did not fully analyze the
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`evidence provided by Petitioner that supports the motivation to combine. As a
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`result, the Board inadvertently overlooked evidence provided by the Petition that
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`supports a finding of a motivation to combine these references.
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`II. APPLICABLE RULES
`37 C.F.R. § 42.71 (d) states:
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`(d) Rehearing. A party dissatisfied with a decision may file a request for
`rehearing, without prior authorization from the Board. The burden of
`showing a decision should be modified lies with the party challenging the
`decision. The request must specifically identify all matters the party believes
`the Board misapprehended or overlooked, and the place where each matter
`was previously addressed in a motion, an opposition, or a reply. A request
`for rehearing does not toll times for taking action. Any request must be filed:
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`(1) Within 14 days of the entry of a non-final decision or a decision to
`institute a trial as to at least one ground of unpatentability asserted in the
`petition; or
`(2) Within 30 days of the entry of a final decision or a decision not to
`institute a trial.
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`In accordance with 37 C.F.R. § 42.71 (d)(2), this request is being filed
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`within 30 days of the entry of a decision not to institute a trial.
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`III. REQUESTED RELIEF
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`Petitioner respectfully requests reconsideration of the Board’s decision not
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`to institute a review of claims 1-5 and 7-17 of U.S. Patent No. 7,848,747 as being
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`rendered obvious by the combination of Bellers in view of Farhan and of claims 1,
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`7, 8, 10, 11, and 14 as being rendered obvious by the combination of Ichiyoshi and
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`Farhan. Petitioner submits that Ichiyoshi in view of Farhan, and similarly Bellers
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`in view of Farhan, render obvious at least the claimed “selecting the sample rate
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`based on the bandwidth” and similar limitations, and respectfully requests that the
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`Board institute review of claim 1-5 and 7-17 on at least one of these grounds.
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`IV. CLAIM LIMITATIONS AT ISSUE
`The Board determined that neither Ichiyoshi and Farhan nor Bellers and
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`Farhan render obvious the claimed invention. The Board made this determination
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`because, in its view, none of the references disclosed or taught or suggested the
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`claimed “selecting the sample rate based on bandwidth,” or variants of this
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`limitation. See Decision, at p. 9-13. This determination used an improperly narrow
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`construction of the phrase that fails to meet the “Broadest Reasonable
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`Interpretation” standard. See Cuozzo Speed Techs., LLC v. Lee, 136 S. Ct. 2131,
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`2144–45, 195 L. Ed. 2d 423 (2016) (affirming Broadest Reasonable Interpretation
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`standard for IPR proceedings); In re Smith Int'l, Inc., 871 F.3d 1375, 1382–83
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`(Fed. Cir. 2017) (“The correct inquiry in giving a claim term its Broadest
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`Reasonable Interpretation in light of the specification is not whether the
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`specification proscribes or precludes some broad reading of the claim term adopted
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`by the examiner. And it is not simply an interpretation that is not inconsistent with
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`the specification. It is an interpretation that corresponds with what and how the
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`inventor describes his invention in the specification, i.e., an interpretation that is
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`‘consistent with the specification.’”)(citations omitted).
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`The following claims contain claim language directly implicated by the
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`Board’s improperly narrow construction, with the language at issue emphasized.
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`Independent claim 1 recites:
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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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`Dependent claim 6 recites (emphasis added), “[t]he method of claim 1,
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`wherein the sample rate is proportional to the bandwidth of the associated one of
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`the plurality of analog inputs.”
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`Independent claim 7 recites (emphasis added), “each analog to digital
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`converter circuit operating at a sample rate related to a signal bandwidth of
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`its associated broadband RF signal.”
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`Independent claim 11 recites (emphasis added), “the selected sample rates
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`selected based on the bandwidth of the analog signal.”
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`Independent claim 14 recites (emphasis added), “each output has an
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`associated sample clock with a sample rate selected based on the bandwidth
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`of the associated RF bandwidth segment.”
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`Dependent claim 16 recites (emphasis added), “each analog to digital
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`converter circuit has an associated sample clock with a sample rate selected
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`based on the bandwidth of the associated RF bandwidth segment.”
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`V. ARGUMENT
`A. Broadest Reasonable Interpretation of “Selecting the Sample Rate
`Based On Bandwidth”
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`The Board, without ever offering an explicit construction, required that
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`“sample rate selected based on the bandwidth” means that the sample rate must be
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`directly related to the bandwidth. Decision at p. 9-11. There is no such requirement
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`in claims 1, 7, 11, or 14. The phrase “selecting a sample rate based on bandwidth”
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`and variants thereof, only requires that the sample rate is somehow related to the
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`bandwidth. The claim language does not require a direct or exclusive relationship
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`between the sample rate and the bandwidth.
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`For example, under the proper broadest reasonable reading of the claims, the
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`sample rate can be based on a variable that itself is based on the bandwidth. In such
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`an example, the sample rate is based on the bandwidth, although indirectly through
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`the intermediary variable. This, however, clearly satisfies the “based on” claim
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`language requirement.
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`Petitioner’s construction of this phrase is consistent with the plain language
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`of the claim interpreted to the broadest reasonable extent. Namely, that the sample
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`rate only needs to be “based on” or “related to” the sample rate. In contrast, the
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`Board’s construction is not consistent with the actual language of the claim, and is
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`not consistent with the requirement that the claim language be given its Broadest
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`Reasonable Interpretation.
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`Further evidence that Petitioner’s construction is both broader and more
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`reasonable than the Board’s adopted construction is found in claim differentiation.
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`Claim 6 requires a more defined relationship between the sample rate selection and
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`bandwidth, specifically, that the “sample rate is proportional to the bandwidth,”
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`which is arguably more consistent with the Board’s narrow construction, than the
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`appropriate broader construction proffered by Petitioner.
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`Claim 6’s narrower description of the interplay between sample rate and
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`bandwidth necessarily requires that claim 1 be broader. If the Applicant wanted
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`claim 1 to require a direct or proportional relationship, that language would be in
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`claim 1 and not in a dependent claim. As a result, “the sample rate selected based
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`on the sample rate” as recited in at least claim 1, under the Broadest Reasonable
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`Interpretation, does not require a direct correspondence to bandwidth, as the
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`Board’s Decision presumes.
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`As discussed below, under the proper Broadest Reasonable Interpretation of
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`this claim limitation, as set forth in the Petition, there is a reasonable likelihood
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`that the Petitioned claims are obvious in view of the art identified by Patent Owner
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`and discussed herein.
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`Ichiyoshi and Farhan
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`B.
`The Board failed to apply the Broadest Reasonable Interpretation to the
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`claimed “sample rate selected based on the bandwidth,” and as a result,
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`misapprehended Petitioner’s arguments and evidence with respect to Ichiyoshi
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`teaching this claim limitation of claims 1, 7, 11, and 14.
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`In addition, by construing this claim limitation more narrowly than
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`supported by the ’747 Patent, the Board misapprehended the evidence and
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`explanations presented in the Petition, including citations to the Bims Declaration,
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`for making the factual determinations required by Graham concerning the prior art
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`and its teaching of this claim limitation. When examined in light of the Broadest
`
`Reasonable Interpretation adopted in the Petition, the arguments and evidence
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`provided enable the Board to determine the differences between the claimed
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`subject matter and the combination of Ichiyoshi and Farhan, as required by
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`Graham.
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`1.
`
`Ichiyoshi Teaches “Selecting the Sample Rate Based On
`Bandwidth” Under BRI
`As presented in the Petition, Ichiyoshi “discloses a variable-bandwidth
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`communication network where the bandwidth is an integer multiple of a step
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`channel frequency interval and a signal combining circuit that comprises a signal
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`branching circuit for channels with wider frequency bands than the step channel
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`frequency interval. Ex.1009: 3:17-28; Ex.1002: ¶¶114-115.” Pet. at p. 9.
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`As also presented in the Petition, Ichiyoshi describes:
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`The sampling frequency fs is normally set to fs = N∆f where ∆f represents a
`channel frequency interval. The sampling frequency fs is generated
`independently in the transmission device 81 and the reception device 82.
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`Pet. at p. 82, citing Ex.1009: 6:3-6.
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`… signal combining circuit 91 includes a sampling timing generator 1 for
`generating a signal of the sampling frequency fs, and N A/D converter 3 for
`sampling N independent information signals with the sampling frequency fs .
`. .
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`Pet. at p. 82, citing Ex.1009: 6:9-13. Ichiyoshi describes that the channel frequency
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`interval is based on the bandwidth, i.e., that the bandwidth is an integer multiple of
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`the channel frequency interval. Ex.1009: 4:35-42.
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`As stated above, the Broadest Reasonable Interpretation requires that some
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`relationship exist between the bandwidth and the sample rate that is used for that
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`signal, but not that the sample rate be solely selected directly from the bandwidth.
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`Under the correct interpretation, Ichiyoshi describes “sample rates selected based
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`on the bandwidth. More specifically, Ichiyoshi describes that the frequency
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`interval is directly related to the bandwidth and that the sample rate is based on the
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`frequency interval. Therefore, Ichiyoshi indirectly teaches that the sampling rate is
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`based on the bandwidth via the frequency interval. Ex. 1002 [Bims Dec.], at ¶260;
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`Pet. at p. 9. The Petition, as supported by the declaration of Dr. Bims, under the
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`Broadest Reasonable Interpretation, properly explains that the above-cited portions
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`of Ichiyoshi teach selecting a sample rate “based on” bandwidth.
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`Combining Ichiyoshi and Farhan
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`2.
`As described in the Bims Declaration, and cited by the Petition, there are
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`two primary ways to combine Ichiyoshi and Farhan to teach the entire claim
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`limitation: (1) multiple fixed sample rate ADCs or (2) at least one flexible sample
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`rate ADC. Bims Dec. at ¶ 260, cited by Pet. p. 95, and referring to Ex.1009
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`-8-
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`[Ichiyoshi] at 6:3-6 and 6:9-13. Regardless, the disclosure of Ichiyoshi, when
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`combined with Farhan, teaches the disputed claim limitations when interpreted
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`under the Broadest Reasonable Interpretation described above. Id.
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`3. Motivation to Combine Ichiyoshi and Farhan
`The Board indicated that the sections of the Bims Declaration cited in the
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`Petition supporting the motivation to combine these references did not provide
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`adequate evidence to find a motivation to combine. Decision at p. 15, citing Pet. at
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`p. 12, citing Bims Dec. (Ex. 1002) at ¶ 254. Paragraphs ¶¶ 255-258 of the Bims
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`Declaration, however, provide the requested additional detail and evidence. These
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`paragraphs provide further support that the motivation to combine these references
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`is to increase bandwidth efficiency in RF transport systems.
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`Ichiyoshi in View of Farhan Render the Claims Obvious
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`4.
`As discussed above, Ichiyoshi in view of Farhan, using the proper Broadest
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`Reasonable Interpretation standard and fully considering the evidence provided by
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`Petitioner shows that a person of ordinary skill would be motivated to combine
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`Ichiyoshi and Farhan and that all elements are taught by this combination. As a
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`result, the Petitioner respectfully requests that the Board institute a Trial on Claims
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`1-5 and 7-17 based on the combination of Ichiyoshi in view of Farhan.
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`C. Bellers and Farhan
`As discussed above, the Board failed to apply the Broadest Reasonable
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`Interpretation to the claimed “selecting the sample rate based on the bandwidth,”
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`and as a result, misapprehended Petitioner’s arguments and evidence with respect
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`to Bellers teaching this claim and related limitations of claims 1, 7, 11, 14, and 16.
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`In addition, by construing this claim limitation more narrowly than
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`supported by the ‘747 Patent, the Board misapprehended the evidence and
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`explanations presented in the Petition, including citations to the Bims Declaration,
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`for making the factual determinations required by Graham concerning the prior art
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`and its teaching of this claim limitation. When examined in light of the Broadest
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`Reasonable Interpretation adopted by the Petition, the arguments and evidence
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`provided enable the Board to determine the differences between the claimed
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`subject matter and the combination of Bellers and Farhan, as required by Graham.
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`1.
`
`Bellers Teaches “Selecting the Sample Rate Based On
`Bandwidth” Under BRI
`
`As presented in the Petition at p. 14-15, Bellers teaches:
`
`Receiver 101 includes a sampling mechanism 104 which samples the
`analog video input signal at a frequency modulated by or dependent
`upon the spatial frequency of the sampled content.
`
`
`Ex.1006: 3:11-20.
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`FIG.2A, a number . . .of analog filters 201 are employed by sampling
`mechanism 104 to separate the input signal's frequency spectrum. . . .A
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`number of corresponding analog-to-digital (A/D) converters 202 each
`having different settings for the various filtered signals are employed to
`generate different digital representations having different sampling
`rates. . . .
`
`Ex.1006: 3:32-40.
`
`
`The present invention employs a sampling rate which is modulated based
`upon the spatial frequencies of the content being sampled. Higher
`sampling rates, and larger sample densities, are employed for content having
`high spatial frequencies while lower sampling rates are employed for content
`having low spatial frequencies.
`
`Ex.1006: 4:14-19.
`
`The Bims Declaration explains how these sections of Bellers would render
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`obvious the claimed selecting a sample rate based on the bandwidth:
`
`“The above passage of Bellers plainly teaches “each analog to digital
`converter circuit operating at a sample rate related to a signal bandwidth of
`its associated broadband RF signal” as claimed. The analog filters first filter
`according to spatial frequencies. Then, the various ADC’s each having
`different settings for the various filtered signals generate different digital
`representations having different sampling rates. In this way each of the
`ADC’s are “operating at a sample rate related to a signal bandwidth” as
`claimed.”
`
`Bims Dec. (Ex. 1002) at ¶109. This paragraph is cited in the Petition, explaining
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`how the cited sections of Bellers describe this limitation. See e.g., Pet. at p. 14-15
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`(in analysis of claim element 1[b]); Pet. at p. 25-26 (in analysis of claim element
`
`6), Pet. at 31-32 (in analysis of claim element 7[d]); Pet. at p. 39-40 (in analysis of
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`claim element 11[b], referring back to analysis of claim elements 1[b], 6, and 7[d]).
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`As a result, the petition clearly sets forth evidence and explanation as to how
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`Bellers teaches the claimed “sample rate selected based on bandwidth.”
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`
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`Because the Board interpreted “the sample rate selected based on the
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`bandwidth” narrowly, the Board improperly concluded that the above passages of
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`Bellers, and the explanation provided by Dr. Bims, did not provide an adequate
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`basis to find that Bellers discloses this claim limitation. Under the Broadest
`
`Reasonable Interpretation adopted by the Petition, however, selecting a sample rate
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`based on spatial frequency renders obvious this claim limitation.
`
`The Board correctly identified that Bellers refers to “[t]he spatial frequency
`
`or frequencies of an image are the rates of pixel change per unit distance, usually
`
`expressed in cycles per degree or radian.” Exhibit 1006, at 1:11–13. As also stated
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`in Bellers, higher spatial frequencies correspond to larger sample densities, and are
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`therefore sampled at a higher rate to capture the increases amount of data. Ex.1006:
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`4:14-19. As described below and in Dr. Bims’ declaration, disclosure of sampling
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`based on spatial frequency also amounts to disclosure of adjusting the sample rate
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`“based on” bandwidth.
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`Bandwidth, as used in the ‘747 Patent, refers to the size of the frequency
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`band of an input signal or channel (e.g., 5, 25, 40 MHz). See ’747 Patent, 6:9-6:16.
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`The amount of data or information that is contained in a signal is proportional to
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`the bandwidth. In other words, a higher bandwidth enables the transmission of
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`more data over a given time period, when compared to a lower bandwidth. As a
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`result, a higher bandwidth is associated with a higher rate of data transfer.
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`Similarly, a higher spatial frequency is associated with a higher rate of data
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`transfer, as described by Bellers. See Ex.1006: 4:14-19. Changing the sampling
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`rate based on spatial frequency or based on the bandwidth of a signal are both
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`“based on” the content of the signal, and more specifically the amount of data
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`contained in the signal. As presented by Dr. Bims, selecting a sample rate based on
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`bandwidth is obvious in light of selecting a sample rate based on spatial
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`frequencies, as both correspond to how much data is contained in the respective
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`signal. Bims Dec. (Ex. 1002) at ¶109.
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`The Petition did not adopt, nor contemplate, the Board’s narrow reading of
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`the sample rate selected based on the bandwidth. As a result, the above description
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`is not explicitly identified, as it should not have been necessary. Under the
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`Broadest Reasonable Interpretation of this claim limitation, however, as adopted
`
`by the Petition, there is a reasonable likelihood that Bellers will be found to render
`
`this claim limitation obvious.
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`Combining Bellers and Farhan
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`2.
`As described in the Bims Declaration, and cited by the Petition, there are
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`two primary ways to combine Bellers and Farhan to teach the entire disputed claim
`
`limitation: (1) multiple fixed sample rate ADCs and (2) at least one flexible sample
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`rate ADC. Bims Dec. at ¶ 109, cited by Pet. p. 14, and referring to Ex.1006
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`[Bellers] at 3:11-20,3:32-46, 4:14-19, and Ex. 1007 [Farhan] at FIG. 5. Either way,
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`the disclosure of Bellers, when combined with Farhan, teaches this and other
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`similar claim limitations. Id.
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`3. Motivation to Combine Bellers and Farhan
`The Board indicated that the sections of the Bims Declaration cited in the
`
`Petition supporting the motivation to combine these references did not provide
`
`adequate evidence to find a motivation to combine. Decision at p. 14, citing Bims
`
`Dec. (Ex. 1002) at ¶ 117-120. Paragraphs ¶¶ 104-107 of the Bims Declaration
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`however, provide the requested additional detail and evidence. These paragraphs
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`provide further support that the motivation to combine these references.
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`Bellers in View of Farhan Render the Claims Obvious
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`4.
`As discussed above, Bellers in view of Farhan, using the proper Broadest
`
`Reasonable Interpretation standard and fully considering the evidence provided by
`
`Petitioner shows that a person of ordinary skill would be motivated to combine
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`Bellers and Farhan and that all elements are taught by this combination. As a
`
`result, the Petitioner respectfully requests that the Board institute a Trial on Claims
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`1-5 and 7-17 based on the combination of Bellers in view of Farhan.
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`VI. CONCLUSION
`For the foregoing reasons, Petitioner respectfully requests rehearing of
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`claims 1-5 and 7-17 of the ’747 Patent and respectfully request that inter partes
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`review be instituted for these claims.
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`Dated : December 1, 2017
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`Respectfully submitted,
`
`By: /Richard T. Black/
`Richard T. Black (Lead Counsel)
`Registration No.: 40,514
`Tel:
`(206) 447-6251
`Fax: (206) 749-2062
`Email: Rich.Black@foster.com
`
`Attorneys for Dali Wireless LLC
`FOSTER PEPPER PLLC
`1111 Third Avenue, Suite 3000
`Seattle, WA 98101
`
`
`
`By: /Benjamin J. Hodges/
`Benjamin J. Hodges (Back-Up Counsel)
`Registration No.: 69,500
`Tel:
`(206) 447-6282
`Fax: (206) 749-1940
`Email: Ben.Hodges@foster.com
`
`By: /Kevin S. Ormiston/
`Kevin S. Ormiston (Back-Up Counsel)
`Registration No.: 75,003
`Tel: (206) 447-6271
`Fax: (206) 749-2025
`Email: Kevin.Ormiston@foster.com
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`VII. CERTIFICATE OF SERVICE
`
`Pursuant to 37 C.F.R. §§ 42.6(e) and 42.105(a), the undersigned
`hereby certifies that on December 1, 2017, a true and correct copy of the foregoing
`Petitioner’s Request for Rehearing Pursuant to 37 C.F.R. § 42.71 was served via
`email on Patent Owner’s counsel as follows:
`
`
`
`
`Philip P. Caspers
`Samuel A. Hamer
`CARLSON CASPERS VANDENBURGH LINDQUIST & SCHUMAN PA
`225 South Sixth Street
`Suite 4200
`Minneapolis, MN 55402
`Email: pcaspers@carlsoncaspers.com
`Email: shamer@carlsoncaspers.com
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`By: /Richard T. Black/
`Richard T. Black (Registration No. 40,514)
`Lead Counsel for Petitioner
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`
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`-16-
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