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`Petitioner Huawei - Ex. 1010 p. 170
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`(cid:40)(cid:59)(cid:43)(cid:44)(cid:37)(cid:44)(cid:55)(cid:3)(cid:26)(cid:3)
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`Petitioner Huawei - Ex. 1010 p. 171
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`Petitioner Huawei - Ex. 1010 p. 172
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`(cid:40)(cid:59)(cid:43)(cid:44)(cid:37)(cid:44)(cid:55)(cid:3)(cid:27)(cid:3)
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`Petitioner Huawei - Ex. 1010 p. 175
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`Petitioner Huawei - Ex. 1010 p. 178
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`(cid:40)(cid:59)(cid:43)(cid:44)(cid:37)(cid:44)(cid:55)(cid:3)(cid:20)(cid:20)(cid:3)
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`Petitioner Huawei - Ex. 1010 p. 183
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`Michael J. Bettinger (SBN 122196)
`mbettinger@sidley.com
`Irene Yang (SBN 245464)
`irene.yang@sidley.com
`SIDLEY AUSTIN LLP
`555 California Street, Suite 2000
`San Francisco, California 94104
`Telephone: (415) 772-1200
`Facsimile: (415) 772-7400
`Attorneys for Huawei Technologies Co., Ltd.,
`Huawei Device USA, Inc., Huawei Technologies
`USA, Inc., and HiSilicon Technologies Co. Ltd.
`
`David T. Pritikin (Pro Hac Vice)
`dpritikin@sidley.com
`David C. Giardina (Pro Hac Vice)
`dgiardina@sidley.com
`Douglas I. Lewis (Pro Hac Vice)
`dilewis@sidley.com
`John W. McBride (Pro Hac Vice)
`jwmcbride@sidley.com
`SIDLEY AUSTIN LLP
`One South Dearborn
`Chicago, Illinois 60603
`Telephone: (312) 853-7000
`Facsimile: (312) 853-7036
`
`UNITED STATES DISTRICT COURT
`NORTHERN DISTRICT OF CALIFORNIA
`SAN FRANCISCO DIVISION
`
`HUAWEI TECHNOLOGIES CO., LTD.,
`HUAWEI DEVICE USA, INC. and
`HUAWEI TECHNOLOGIES USA, INC.
`Samsungs/ Counterclaim-
`Huaweis,
`
`v.
`SAMSUNG ELECTRONICS CO., LTD.,
`SAMSUNG ELECTRONICS AMERICA,
`INC.,
`
`Huaweis/Counterclaim-
`Samsungs,
` and
`
`
`SAMSUNG RESEARCH AMERICA,
`
`
` Huawei,
`v.
`HISILICON TECHNOLOGIES CO., LTD.,
`
`
` Counterclaim-Huawei.
`
`
`
`
`
`
`Case No. 16-cv-02787-WHO
`
`HUAWEI’S INVALIDITY
`CONTENTIONS
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`HUAWEI’S INVALIDITY CONTENTIONS
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`Petitioner Huawei - Ex. 1010 p. 184
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`Case 3:16-cv-02787-WHO Document 140-1 Filed 05/19/17 Page 155 of 302
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`Huawei Technologies Co., Ltd., Huawei Device USA, Inc., Huawei Technologies USA,
`Inc. and HiSilicon Technologies Co., Ltd. (“Huawei”) by and through its counsel, hereby serves its
`Invalidity Contentions pursuant to Patent Local Rule 3-3 on Samsung Electronics Co., Ltd.,
`Samsung Electronics America, Inc., and Samsung Research America (“Samsung”) regarding:
`claims 9-14 of U.S. Patent No. 8,228,827 (“the ’827 patent”); claims 9-12, 14, 15, 25-28, 30, and
`31 of U.S. Patent No. 8,315,195 (“the ’195 patent”); claims 28-32 and 38-42 of U.S. Patent No.
`RE44,105 (“the ’RE105 patent”); claims 1-12 of U.S. Patent No. 8,457,588 (“the ’588 patent”);
`claims 1-14 of U.S. Patent No. 8,509,350 (“the ’350 patent”); claims 1-10 of U.S. Patent No.
`9,113,419 (“the ’419 patent”); claims 1, 3, 11, and 13 of U.S. Patent No. 8,619,726 (“the ’726
`patent”); claims 9-16 of U.S. Patent No. 8,761,130 (“the ’130 patent”); and claims 1-2 and 4-5 of
`U.S. Patent No. 9,288,825 (“the ’825 patent”) (collectively the “Asserted Claims” of the “Asserted
`Patents”).
`These Invalidity Contentions are served under Pat. L.R. 3-3 and pursuant to the Case
`Management Order issued by the Court on Sept. 13, 2016 (see D.I. 75 at 1), and the parties’
`proposed case management schedule filed with the Court on Sept. 6, 2016 (see D.I. 67 at 23).
`Pursuant to Pat. L.R. 3-4, Huawei also serves herewith the document production accompanying
`these disclosures. These contentions set forth Huawei’s initial Invalidity Contentions with respect
`to the claims currently asserted by Samsung and reflect Huawei’s knowledge, thinking, and
`contentions as of this early date in this action. Discovery is ongoing and Huawei reserves the right
`to amend and/or supplement these Invalidity Contentions as the case proceeds pursuant to Pat. L.R.
`3-6.
`I.(cid:3) INVALIDITY CONTENTIONS
`The following contentions are served in view of Huawei’s current understanding of the
`Asserted Claims as applied in Samsung’s Infringement Contentions, served October 25, 2016,
`without the benefit of claim construction and with only limited discovery in the present litigation.
`Claim construction discovery in this action has not yet commenced, and Huawei will provide its
`claim construction positions at the appropriate time pursuant to the Patent Local Rules and the
`Court’s scheduling order. Accordingly, these Invalidity Contentions may reflect various potential
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`and alternative positions regarding claim construction and scope. In many instances, Huawei’s
`contentions as stated may reflect or imply a certain claim scope or claim interpretation, which is set
`forth in view of positions or interpretations suggested by Samsung’s submissions to date, and in
`many instances Huawei’s contentions may suggest different alternative claim interpretations. To
`the extent these contentions state, reflect, or suggest a particular interpretation or reading of any
`claim element, Huawei does not adopt, advocate, or acquiesce to such an interpretation or reading.
`Huawei’s contentions therefore should not be relied upon as a statement of Huawei’s claim
`interpretations and should not be relied upon as any admission regarding the proper scope of the
`claims. Huawei’s claim construction positions will be provided at a later appropriate time in this
`case, as noted above. Nor do these Invalidity Contentions constitute any admission by Huawei that
`any accused products or services, including any current or past versions of those products or
`services, are covered by any Asserted Claim. Huawei does not take any position herein regarding
`the proper scope or construction of the Asserted Claims.
`These Invalidity Contentions try to take into account and apply Samsung’s apparent
`interpretations of the Asserted Claims. Accordingly, any assertion herein that a particular
`limitation is disclosed by a prior art reference or references may be based in part on Samsung’s
`apparent interpretation and is not intended to be, and is not, an admission by Huawei that any such
`construction is supportable or correct. To the extent the contentions herein reflect constructions of
`claim limitations consistent with or implicit in Samsung’s Infringement Contentions, no inference
`is intended, nor should any be drawn, that Huawei agrees with or concedes those claim
`constructions. Huawei expressly does not do so, and reserves its right to contest them.
`To the extent that prior art cited for a particular limitation discloses functionality that is the
`same as or similar in some respects to the alleged functionality in the accused products and/or
`services as set forth in Samsung’s Infringement Contentions, Huawei does not concede that those
`limitations are in fact met by those accused functionalities. However, to the extent Samsung
`accuses the same or similar functionality as that disclosed in the prior art, Huawei contends such
`functionality is evidence of invalidity.
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`Huawei further reserves the right to supplement and amend these disclosures and associated
`document production based on further
`investigation, analysis, and discovery, Huawei’s
`consultation with experts and others, and contentions or court rulings on relevant issues such as
`claim construction and priority dates. For example, since discovery is in the early stages, deposing
`the alleged inventor(s) may reveal information that affects the disclosures and contentions herein.
`Also, Huawei has not completed discovery from third parties who may have information
`concerning the prior art cited herein and possible additional art, including additional evidence
`regarding prior art systems disclosed herein. Furthermore, Samsung did not finally provide
`specific alleged conception dates for all of its asserted patents until January 10, 2017. During the
`vast majority of time that Huawei was conducting its initial investigation of prior art, Samsung had
`not provided specific alleged conception dates and contended that its asserted patents were
`conceived “no later than” their filing dates. Huawei has relied on Samsung’s assertions in
`identifying and selecting prior art in connection with these Invalidity Contentions. Huawei
`reserves the right to move to amend these Invalidity Contentions for good cause and/or modify its
`selection of prior art references to the extent Samsung provides a different date of alleged
`conception and corroborating evidence or to the extent that discovery and/or events in the case
`reveal that Samsung is not entitled to its claimed conception and/or priority dates. Huawei also
`reserves the right to move to amend these Invalidity Contentions and/or to modify its selection of
`prior art references in the event that Samsung serves supplemental or modified infringement
`contentions. Huawei reserves the right to amend these Invalidity Contentions in the event that the
`applicable legal standard changes.
`Because Huawei is continuing its search for and analysis of relevant prior art, Huawei
`reserves the right to revise, amend, and/or supplement the information provided herein, including
`identifying, charting, and/or relying upon additional prior art references, relevant disclosures, and
`bases for Invalidity Contentions. Additional prior art, disclosures, and invalidity grounds, whether
`or not cited in this disclosure and whether known or not known to Huawei, may become relevant as
`investigation, analysis, and discovery continue, and following claim construction proceedings in
`this case. Huawei is currently unaware of the extent, if any, to which Samsung will contend that
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`Petitioner Huawei - Ex. 1010 p. 187
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`limitations of the Asserted Claims are not disclosed in the prior art identified by Huawei. To the
`extent that such an issue arises, Huawei reserves the right to identify and rely upon other references
`or portions of references regarding the allegedly missing limitation(s).
`Additionally, because discovery has only recently commenced, Huawei reserves the right to
`present additional prior art references and/or disclosures under 35 U.S.C. §§ 102(a), (b), (e), (f),
`and/or (g), and/or § 103, located during the course of such discovery or further investigation, and to
`assert invalidity under 35 U.S.C. §§ 102(c), (d), or (f), to the extent that such discovery or
`investigation yields information forming the basis for such invalidity.
`A.(cid:3)
`Level of Ordinary Skill in the Art
`Subject to Huawei’s reservation of rights, Huawei contends that a person having ordinary
`skill in the art (POSITA) in the relevant time frame would have a Bachelor’s degree in EE or CS
`with a telecommunications focus and 2-4 years of experience in telecommunications or the
`equivalent. A person having ordinary skill in the art would also be familiar with the prior art
`systems described in the “Background of the Invention” section of the Asserted Patents.
`B.(cid:3)
`Identity of Each Item of Prior Art
`Subject to Huawei’s reservation of rights, Huawei identifies each item of prior art that
`anticipates or renders obvious one or more of the Asserted Claims in the attached Prior Art Index
`submitted herewith. (See Appendix A, infra.) To the extent that the references listed in Appendix
`A are not identified as items of prior art that anticipate or render obvious an Asserted Claim,
`Huawei intends to rely on these references as background and as evidence of the state of the art at
`the time of Samsung’s alleged invention.
`Additionally, many of the prior art references are related patent applications and issued
`patents that contain substantially the same subject matter (e.g., published U.S. patent applications,
`and issued U.S. patents, foreign applications or issued patents). Any citation to or quotation from
`any of these patent applications or patents, therefore, should be understood as encompassing any
`parallel citation to the same subject matter in other related or corresponding applications or patents.
`Huawei also reserves the right to later rely upon all references or portions of references provided in
`Appendix A to supplement or amend its disclosures contained herein. Also, to the extent not
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`Petitioner Huawei - Ex. 1010 p. 188
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`expressly mentioned herein, Huawei incorporates by reference (1) any and all prior art contained or
`identified in documents produced thus far by Samsung to Huawei in this case; (2) any and all
`additional materials regarding invalidity that should have been produced to Huawei but have not
`been produced to date, to the extent that any exist; and (3) any prior art of which the named
`inventor(s) of the Asserted Patents are aware and/or on which they contend the alleged invention of
`the Asserted Patents build upon or improve.
`Each disclosed item of prior art is evidence of a prior invention and making of the invention
`in the United States by another under 35 U.S.C. § 102(g), as evidenced by the named inventor,
`authors, organizations, and publishers involved with each such reference, with the circumstances
`described and reflected in each reference including publications and system implementation
`references. Huawei further intends to rely on admissions of the named inventors concerning the
`prior art, including statements found in the Asserted Patents, their prosecution histories, related
`patents and/or patent applications, any deposition testimony, and the papers filed and any evidence
`submitted by Samsung in conjunction with this litigation.
`C.(cid:3) Whether Prior Art Anticipates or Renders Obvious
`Subject to Huawei’s reservation of rights, Huawei identifies in the attached Prior Art
`Invalidity Charts prior art references that anticipate the Asserted Claims under at least 35 U.S.C.
`§§ 102(a), (b), (e), and/or (g), either expressly or inherently, and/or render obvious the Asserted
`Claims under 35 U.S.C. § 103 either alone or in combination with other references. Each Asserted
`Claim is anticipated by, and/or obvious in view of, one or more items of prior art identified in these
`disclosures, alone or in combination. Tables identifying ways in which the prior art references
`cited herein anticipate and/or render obvious the Asserted Claims are provided below.
`Much of the art identified in the attached exhibits/charts reflects common knowledge and
`the state of the art at the time of the earliest filing date of the Asserted Patents. Huawei may rely
`on additional citations, references, expert testimony, fact testimony and other corroborating
`evidence, and other material to provide context and background illustrating the knowledge of a
`person of ordinary skill in the art at the time of the claimed inventions and/or to aid in
`understanding the cited portions of the references and/or cited features of the systems. Huawei
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`may also rely on expert testimony explaining relevant portions of references, relevant hardware or
`software products or systems, and other discovery regarding these subject matters. Additionally,
`Huawei may rely on other portions of any prior art reference for purposes of explaining the
`background and general technical subject area of the reference.
`Where an individual reference is cited with respect to all elements of an Asserted Claim,
`Huawei contends that the reference anticipates the claim under 35 U.S.C. §§ 102(a), (b), (e), and/or
`(g) and also renders obvious the claim under 35 U.S.C. § 103, both by itself in view of the
`knowledge of a person of ordinary skill in the art and in combination with the other cited
`references to the extent the reference is not found to disclose one or more claim elements. A single
`prior art reference, for example, can establish obviousness where the differences between the
`disclosures within the reference and the claimed invention would have been obvious to one of
`ordinary skill in the art. For example, “[c]ombining two embodiments disclosed adjacent to each
`other in a prior art patent does not require a leap of inventiveness.” Boston Scientific Scimed, Inc. v.
`Cordis Corp., 554 F.3d 982, 991 (Fed. Cir. 2009). To the extent Samsung contends that an
`embodiment within a particular item of prior art does not fully disclose all limitations of a claim,
`Huawei accordingly reserves its right to rely on other embodiments in that prior art reference, or
`other information, to show single reference obviousness under 35 U.S.C. § 103(a).
`Where an individual reference is cited with respect to fewer than all elements of an
`Asserted Claim, Huawei contends that the reference renders obvious the claim under 35 U.S.C. §
`103(a) in view of each other reference and combination of references that discloses the remaining
`claim element(s), as indicated in the claim charts submitted herewith and in the discussion below.
`“Under § 103, the scope and content of the prior art are to be determined; differences between the
`prior art and the claims at issue are to be ascertained; and the level of ordinary skill in the pertinent
`art resolved. Against this background, the obviousness or nonobviousness of the subject matter is
`determined.” KSR Int’l Co. v. Teleflex Inc., 550 U.S. 398, 406 (2007), quoting Graham v. John
`Deere Co. of Kansas City, 383 U.S. 1, 17 (1966). Exemplary motivations to combine references
`are discussed below and/or in the accompanying charts. Huawei reserves the right to rely upon any
`references or assertions identified herein in connection with Huawei’s contention that each
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`Asserted Claim is invalid under 35 U.S.C. § 103 and to rely upon expert testimony addressing such
`references and assertions. The fact that prior art is identified to anticipate the Asserted Claims
`presents no obstacle in also relying on that reference as a basis for invalidity based on obviousness.
`It is established that “a rejection for obviousness under § 103 can be based on a reference which
`happens to anticipate the claimed subject matter.” In re Meyer, 599 F.2d 1026, 1031 (C.C.P.A.
`1979). To the extent any prior art item cited above may not fully disclose a limitation of an
`Asserted Claim or is alleged by Samsung to lack disclosure of the limitation, such limitation is
`present and identified in another prior art item as shown in the attached claim charts.
`Many of the cited references cite or relate to additional references and/or products, services,
`or projects. Many of the cited references also cite software, hardware, or systems. Huawei may
`rely upon such cited additional references and copies or exemplars of such software, hardware, or
`systems. Huawei will produce or make available for inspection any such cited references,
`software, hardware, or systems that it intends to rely upon. Huawei may also rely upon the
`disclosures of the references cited and/or discussed during the prosecution of the Asserted Patents
`and/or the assertions presented regarding those references.
`Huawei reserves the right to further streamline and reduce the number of anticipation or
`obviousness references relied upon with respect to a given Asserted Claim and to exchange or
`otherwise modify the specific references relied upon for anticipation and within each obviousness
`combination for each Asserted Claim. Discovery is at an early stage and Samsung has not
`provided any contentions or documentation with respect to claim limitations that are allegedly
`lacking or not obvious in the prior art. Each limitation of the Asserted Claims was well-known to
`those of ordinary skill in the art before the filing dates of the respective non-provisional
`applications from which each Asserted Patent claims priority, as detailed below. As explained in
`detail throughout these Contentions, the Asserted Claims of the Asserted Patents are anticipated by,
`and/or obvious in view of, the prior art references listed in Appendix A.
`1.(cid:3)
`Obviousness and Motivations to Combine
`Each prior art reference may be combined with one or more other prior art references to
`render obvious the Asserted Claims in combination, as explained in more detail below. The
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`Petitioner Huawei - Ex. 1010 p. 191
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`

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`disclosures of these references also may be combined with information known to persons skilled in
`the art at the time of the alleged invention, and understood and supplemented in view of the
`common sense of persons skilled in the art at the time of the alleged invention, including any
`statements in the intrinsic record of the asserted patents and related applications.
`A person of ordinary skill would have been motivated to combine the identified prior art
`based on the nature of the problem to be solved, the teachings of the prior art, and the knowledge
`of persons of ordinary skill in the art. The identified prior art references, including portions cited
`in the Prior Art Invalidity Charts, address the same or similar technical issues and suggest the same
`or similar solutions to those issues as the Asserted Claims. On such basis, on an element-by-
`element basis, Huawei expressly intends to combine one or more prior art items identified in
`Appendix A with each other to address any further contentions from Samsung that a particular
`prior art item supposedly lacks one or more elements of an Asserted Claim. In other words,
`Huawei contends that each charted prior art item can be combined with other charted prior art
`items when a particular prior art item lacks or does not explicitly disclose an element or feature of
`an Asserted Claim. The suggested obviousness combinations described below are not to be
`construed to suggest that any reference included in the combinations is not anticipatory. Further, to
`the extent that Samsung contends that any of the anticipatory prior art fails to disclose one or more
`limitations of the Asserted Claims, Huawei reserves the right to identify other prior art references
`that, when combined with the anticipatory prior art, would render the claims obvious despite an
`allegedly missing limitation. Huawei will further specify the motivations to combine the prior art,
`including through reliance on expert testimony, at the appropriate later stage of this lawsuit.
`A person of skill in the art would have been motivated to combine the identified prior art
`items. As the United States Supreme Court held in KSR Int’l Co. v. Teleflex, Inc., 550 U.S. 398,
`416 (2007): “The combination of familiar elements according to known methods is likely to be
`obvious when it does no more than yield predictable results.” The Supreme Court further held that,
`“[w]hen a work is available in one field of endeavor, design incentives and other market forces can
`prompt variations of it, either in the same field or a different one. If a person of ordinary skill can
`implement a predictable variation, § 103 likely bars its patentability. For the same reason, if a
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`Petitioner Huawei - Ex. 1010 p. 192
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`technique has been used to improve one device, and a person of ordinary skill in the art would
`recognize that it would improve similar devices in the same way, using the technique is obvious
`unless its actual application is beyond his or her skill.” Id. at 417.
`To the extent not explicitly disclosed by the prior art, the Asserted Claims of the patents-in-
`suit are nothing more than a combination of standard, conventional elements already existing and
`well-known at the time of the purported invention, combined according to known methods to
`achieve predictable results. The Supreme Court has further held that “in many cases a person of
`ordinary skill will be able to fit the teachings of multiple patents together like pieces of a puzzle.”
`Id. at 420. It is sufficient that a combination of elements was “obvious to try” holding that,
`“[w]hen there is a design need or market pressure to solve a problem and there are a finite number
`of identified, predictable solutions, a person of ordinary skill has good reason to pursue the known
`options within his or her technical grasp. If this leads to the anticipated success, it is likely the
`product not of innovation but of ordinary skill and common sense.” Id. at 421. “In that instance
`the fact that a combination was obvious to try might show that it was obvious under § 103.” Id.
`Finally, the Supreme Court recognized that “[g]ranting patent protection to advances that would
`occur in the ordinary course without real innovation retards progress and may, in the case of
`patents combining previously known elements, deprive prior inventions of their value or utility.”
`Id. at 419. All of the following rationales recognized in KSR support a finding of obviousness:
`1)
`Combining prior art elements according to known methods to yield predictable
`results;
`Simple substitution of one known element for another to obtain predictable
`results;
`3) Use of known technique to improve similar devices (methods, or products) in
`the same way;
`4) Applying a known technique to a known device (method, or product) ready for
`improvement to yield predictable results;
`“Obvious to try”—choosing from a finite number of identified, predictable
`solutions, with a reasonable expectation of success;
`
`2)
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`5)
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`Petitioner Huawei - Ex. 1010 p. 193
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`Case 3:16-cv-02787-WHO Document 140-1 Filed 05/19/17 Page 164 of 302
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`7)
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`6) Known work in one field of endeavor may prompt variations of it for use in
`either the same field or a different one based on design incentives or other
`market forces if the variations would have been predictable to one of ordinary
`skill in the art; and
`Some teaching, suggestion, or motivation in the prior art that would have led
`one of ordinary skill to modify the prior art reference or to combine prior art
`reference teachings to arrive at the claimed invention.
`Certain of these rationales are discussed more specifically below. The fact that others are
`not discussed more specifically should not be interpreted as an admission or concession that it does
`not apply. To the contrary, the discussion below simply provides more explanation of these
`specific rationales.
`Huawei further contends that the prior art identified in these Invalidity Contentions is
`evidence of simultaneous or near-simultaneous independent invention by others of the alleged
`invention as recited in one or more of the Asserted Claims. Huawei reserves its right to rely on the
`simultaneous or near-simultaneous independent invention by others as further evidence of the
`obviousness of the Asserted Claims.
`Each limitation of the Asserted Claims was well known to those of ordinary skill in the art
`before the filing dates of the respective non-provisional applications to which each Asserted Patent
`claims priority, as detailed below and in the attached charts.
`The elements recited in the Asserted Claims are mere combinations and modifications of
`these well-known elements. A person of ordinary skill in the art would be able, and motivated, to
`improve the existing technology in the same or similar manner by combining or modifying the
`individual elements that were already known in the art to yield predictable results.
`Subject to the foregoing, Huawei identifies below certain exemplary reasons that skilled
`artisans would have combined elements of the prior art to render obvious the Asserted Claims. The
`fact that others are not discussed more specifically should not be interpreted as an admission or
`concession that they do not apply. To the contrary, the discussion below simply provides more
`explanation of these specific rationales. Moreover, Patent Local Rule 3-3(b) does not require the
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`Petitioner Huawei - Ex. 1010 p. 194
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`Case 3:16-cv-02787-WHO Document 140-1 Filed 05/19/17 Page 165 of 302
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`disclosure of motivations to combine references and any such motivations to combine provided
`herein are by of illustration and not limitation, and Huawei reserves the right to provide additional,
`alternative, and/or revised motivations to combine as discovery in the case continues. See Fujifilm
`Corp. v. Motorola Mobility LLC, No. 12-CV-03587-WHO, 2015 WL 757575, at *31 (N.D. Cal.
`Feb. 20, 2015).
`
`a.(cid:3)
`Motivations Identified During Prosecution
`Huawei hereby expressly incorporates by reference any statements or reasons set forth by
`the Examiner during prosecution of the Asserted Patents and related patent applications as to why
`it would have been obvious to modify or combine references to achieve the limitations of the
`Asserted Claims.
`
`b.(cid:3)
`Combinations of References Through Citations
`Numerous prior art references cite to, discuss, or build upon other references. Where one
`reference cites or discusses another reference, a person of ordinary skill in the art would have been
`motivated to consider their teachings in combination, as they would be understood to provide
`related teachings in a similar field.
`c.(cid:3)
`Obviousness Combination Groups and Further Motivations to
`Combine
`In addition to combinations of references and motivations to combine identified elsewhere
`herein, including within claim charts, Huawei identifies combinations and motivations to combine
`based on references grouped by subject matter, in the manner approved by courts applying the
`Northern District of California Patent Local Rules regarding invalidity contentions. See, e.g.,
`Avago Techs. Gen IP PTE Ltd. v. Elan Micro. Corp., No. C04-05385 JW (HRL), 2007 U.S. Dist.
`LEXIS 97464, at *10-11 (N.D. Cal. Mar. 28, 2007) (organizing prior art references into “groups”
`an