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`UNITED STATES PATENT AND TRADEMARK OFFICE
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`Ericsson Inc.
`
`Petitioner
`
`v.
`
`Electronics and Telecommunications Research Institute
`
`Patent Owner
`
`
`Patent No. 8,270,354
`Filing Date: May 3, 2007
`Issue Date: September 18, 2012
`
`Title: METHOD FOR TRANSMITTING UP LINK CONTROL SIGNAL IN
`MOBILE COMMUNICATION SYSTEM
`
`Inter Partes Review No. IPR2020-00249
`
`
`PETITION FOR INTER PARTES REVIEW
`UNDER 35 U.S.C. §§ 311-319 AND 37 C.F.R. § 42.100 ET SEQ.
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`

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`IPR2020-00249 (8,270,354)
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`TABLE OF CONTENTS
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`Page
`TABLE OF CONTENTS .............................................................................................
`LIST OF EXHIBITS ................................................................................................. V
`I.
`PRELIMINARY STATEMENT ..................................................................... 1
`II.
`IDENTIFICATION OF CHALLENGE AND RELIEF REQUESTED ......... 2
`III. TECHNOLOGICAL BACKGROUND .......................................................... 2
`A.
`The ’354 Patent ..................................................................................... 3
`B.
`Challenged Claims ................................................................................ 5
`C.
`Prosecution History ............................................................................... 8
`D.
`Claimed Priority Date ..........................................................................15
`IV. LEVEL OF ORDINARY SKILL IN THE ART ...........................................16
`V.
`CLAIM CONSTRUCTION ..........................................................................16
`VI. PRIOR ART ...................................................................................................17
`A.
`R2-060866 ...........................................................................................19
`B.
`Jung ......................................................................................................22
`VII. CLAIMS 1, 3, 5, AND 7 ARE UNPATENABLE ........................................25
`A. Ground 1: R2-060866 Anticipates and/or Renders Obvious
`Claims 1, 3, 5, and 7. ...........................................................................26
`1.
`Claim 1: [1.pre] “A method for transmitting response for
`random access in a base station of a mobile
`communication system, the method comprising:” ....................26
`[1.1] “generating a response for random access received
`from a terminal;” .......................................................................27
`[1.2] “allocating the response for random access to
`downlink-shared radio resource for transmitting packet
`data; and” ..................................................................................29
`[1.3] “transmitting to the terminal an identifier indicating
`transmission of the response for random access through a
`channel carrying downlink scheduling information, and
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`2.
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`3.
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`4.
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`IPR2020-00249 (8,270,354)
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`6.
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`7.
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`5.
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`transmitting to the terminal the response for random
`access through the downlink-shared radio resource for
`transmitting packet data, wherein responses for random
`access for a plurality of terminals are addressed using the
`identifier.” .................................................................................30
`Claim 3: “The method as recited in claim 1, wherein the
`identifier is reserved and allocated among scheduling
`identifiers used in the mobile communication system.” ...........35
`Claim 5: “The method as recited in claim 1, further
`comprising receiving, from the terminal, uplink
`transmission using information on allocation of radio
`resource block to be used when uplink transmission is
`performed, the information being included in the
`response for random access.” ....................................................37
`Claim 7: “The method as recited in claim 1, wherein the
`response for random access is dynamically allocated to
`the downlink shared radio resource.” .......................................40
`B. Ground 2: Jung in combination with R2-060866 Renders
`Obvious Claims 1, 3, 5, and 7. ............................................................41
`1. Motivation to Combine Jung and R2-060866 ..........................42
`2.
`Claim 1: [1.pre] “A method for transmitting response for
`random access in a base station of a mobile
`communication system, the method comprising” .....................45
`[1.1] “generating a response for random access received
`from a terminal;” .......................................................................47
`[1.2] “allocating the response for random access to
`downlink-shared radio resource for transmitting packet
`data; and” ..................................................................................47
`[1.3] “transmitting to the terminal an identifier indicating
`transmission of the response for random access through a
`channel carrying downlink scheduling information, and
`transmitting to the terminal the response for random
`access through the downlink-shared radio resource for
`transmitting packet data, wherein responses for random
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`3.
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`4.
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`5.
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`IPR2020-00249 (8,270,354)
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`7.
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`8.
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`6.
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`access for a plurality of terminals are addressed using the
`identifier.” .................................................................................49
`Claim 3: “The method as recited in claim 1, wherein the
`identifier is reserved and allocated among scheduling
`identifiers used in the mobile communication system.” ...........52
`Claim 5: “The method as recited in claim 1, further
`comprising receiving, from the terminal, uplink
`transmission using information on allocation of radio
`resource block to be used when uplink transmission is
`performed, the information being included in the
`response for random access.” ....................................................55
`Claim 7: “The method as recited in claim 1, wherein the
`response for random access is dynamically allocated to
`the downlink shared radio resource.” .......................................56
`VIII. CONCLUSION ..............................................................................................58
`IX. MANDATORY NOTICES UNDER 37 C.F.R. §42.8 ..................................58
`A.
`Real Parties-In-Interest ........................................................................58
`B.
`Related Matters ....................................................................................59
`CERTIFICATION UNDER 37 C.F.R. §42.24(D) ........................................59
`X.
`XI. PAYMENT OF FEES ...................................................................................59
`XII. TIME FOR FILING PETITION....................................................................60
`XIII. GROUNDS FOR STANDING ......................................................................60
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`IPR2020-00249 (8,270,354)
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`TABLE OF AUTHORITIES
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` Page(s)
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`Cases
`Dow Chem. Co. v. Sumitomo Chem. Co.,
`257 F.3d 1364 (Fed. Cir. 2001) .......................................................................... 16
`Phillips v. AWH Corp.,
`415 F.3d 1303 (Fed. Cir. 2005) (en banc) .................................................... 16, 17
`Sol, IP, LLC v. AT&T Mobility LLC,
`Case No. 2:18-cv- 526-RWS-RSP (E.D. Tex.) .................................................. 59
`Sol, IP, LLC v. Cellco Partnership d/b/a Verizon Wireless,
`Case No. 2:18-cv- 528-RWS-RSP (E.D. Tex.) ...........................................passim
`Sol, IP, LLC v. Sprint Corporation, Sprint Communications Co. L.P.,
`Sprint Solutions, Inc., Sprint Spectrum, L.P.,
`Case No. 2:18-cv- 527-RWS-RSP (E.D. Tex.) .................................................. 59
`Statutes
`35 U.S.C. § 102(a) ................................................................................... 8, 16, 19, 22
`35 U.S.C. § 311 .......................................................................................................... 2
`35 U.S.C. §§ 311-319................................................................................................. 1
`Other Authorities
`37 C.F.R. §42.8 .................................................................................................. 58, 59
`37 C.F.R. § 42.10(b) ................................................................................................ 59
`37 C.F.R. §42.24(D)................................................................................................. 59
`37 C.F.R. § 42.100(b) .............................................................................................. 16
`37 C.F.R. § 42.100 et seq. .......................................................................................... 1
`37 C.F.R. §42.101(b) ............................................................................................... 60
`37 C.F.R. §42.104(a) ................................................................................................ 60
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`IPR2020-00249 (8,270,354)
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`IPR2020-00249 (8,270,354)IPR2020-00249 (8,270,354)IPR2020-00249 (8,270,354)
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`iViViV
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`IPR2020-00249 (8,270,354)
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`LIST OF EXHIBITS
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`Description
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`U.S. Patent No. 8,270,354 to Kim et al. (“the ’354 Patent”)
`U.S. Patent No. 8,270,354 Prosecution History
`Declaration of Sumit Roy, Ph.D in Support of Petition for Inter
`Partes Review
`Tdoc R2-060866 titled “Random Access Procedures for LTE” by
`Ericsson (“R2-060866”)
`Declaration of Craig Bishop (“Bishop Declaration”)
`WO 2005/057822 A1 to Jung et al. (“Jung”)
`CV of Dr. Sumit Roy
`Sol IP, LLC v. AT&T Mobility First Amended Complaint for Patent
`Infringement
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`Exhibit
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`1001
`1002
`1003
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`1004
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`1005
`1006
`1007
`1008
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`v
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`I.
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`IPR2020-00249 (8,270,354)
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`PRELIMINARY STATEMENT
`Petitioner Ericsson Inc. (“Ericsson”) respectfully requests inter partes review
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`and cancellation of claims 1, 3, 5, and 7 of U.S. Patent No. 8,270,354 (“the ’354
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`Patent”) under 35 U.S.C. §§ 311-319 and 37 C.F.R. § 42.100 et seq.
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`The ’354 Patent relates to the wireless communication between cellular
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`devices and base stations, and in particular, a concept called random access. Patent
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`Owner Electronics and Telecommunications Research Institute (“ETRI”), by and
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`through its licensing agent Sol IP, LLC (collectively “Patent Owner”), allege that
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`claims 1, 3, 5, and 7 of the ’063 Patent are essential to LTE Release 8. 1 Ex. 1008, ¶
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`100. However, ETRI did not contribute what it now claims as its invention to the
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`LTE standard. Instead, all of the concepts claimed in the ’354 Patent were developed
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`during the 4G LTE standard-setting process by others, and included in printed
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`publications that were submitted to the standard-setting body and made publically
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`available via an email reflector. Ex. 1005, ¶¶ 19-35. Shortly thereafter, ETRI filed
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`a patent application on these ideas in South Korea. Ex. 1001, p.1.
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`1 Petitioner disagrees. Nevertheless, the invalidity analysis herein is based on
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`Patent Owner’s allegation that practicing the LTE Release 8 standard infringes the
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`Challenged Claims.
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`IPR2020-00249 (8,270,354)
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`This Petition, supported by the Declaration of Dr. Sumit Roy, explains why
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`there is a reasonable likelihood that claims 1, 3, 5, and 7 of the ’354 Patent are
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`unpatentable as obvious to a person of ordinary skill in the art (“POSITA”) in view
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`of the prior art cited herein, the knowledge and understanding of a POSITA, and the
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`’354 Patent itself. Accordingly, claims 1, 3, 5, and 7 of the ’354 Patent should be
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`cancelled.
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`II.
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`IDENTIFICATION OF CHALLENGE AND RELIEF REQUESTED
`Ericsson requests review under 35 U.S.C. § 311 of Challenged Claims 1, 3, 5,
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`and 7 of the ’354 patent, and that the Board cancel the same as being unpatentable
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`in view of the cited prior art and the Grounds described below.
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`Ground 1: Claims 1, 3, 5, and 7 are anticipated and/or obvious over R2-
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`060866.
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`Ground 2: Claims 1, 3, 5, and 7 are obvious over Jung in view of R2-060866
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`(to the extent necessary).
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`III. TECHNOLOGICAL BACKGROUND
`The technology at issue in this petition was developed by members of the
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`Third Generation Partnership Project (“3GPP”) during the 4G standard setting
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`process. To create the 4G standard, 3GPP held standard setting meetings at which
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`3GPP members proposed technology to include in the standard. These proposals
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`were typically submitted in documents called “contributions.” The 3GPP members
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`IPR2020-00249 (8,270,354)
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`emailed their contributions to a 3GPP email list and posted them to the publicly
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`available 3GPP FTP site before each meeting. Ex. 1005, ¶¶ 24-33. Notably, R2-
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`060866 was contributed by Ericsson.
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`A. The ’354 Patent
`The ’354 Patent relates to random access procedures, as used in mobile
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`communication systems. See, e.g., Ex. 1001, 2:60-3:9. Random access procedures
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`are a mechanism used in cellular communications that allows a mobile device (e.g.,
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`a smartphone, also referred to as a terminal, user equipment or “UE”) to request
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`access to a base station (also referred to as a eNodeB), in order to, for example, for
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`the mobile device to initiate a phone call. Ex. 1003, ¶ 32. The general concept of
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`random access procedures far predates the ’354 patent. Id.
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`The ’354 Patent notes that in a conventional circuit based mobile
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`communication system, a base station transmits a control signal to a user terminal
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`using a downlink-dedicated channel. Id., 1:18-20. However, it argues that this
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`method is difficult to apply to a long term evolution (LTE) system which is packet
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`based. Id., 1:21-26. This is because, “[u]nlike the circuit based system that fixedly
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`allocates radio resources to a terminal, a plurality of terminals share radio resources
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`for transmitting packet service data in mobile communication systems for providing
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`a packet service.” Id., 1:27-30. Thus, “the packet based mobile communication
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`system needs a method for providing uplink control information to a plurality of
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`IPR2020-00249 (8,270,354)
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`terminals in order to enable each of the terminals to distinguish allocated radio
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`resources from the other and to access the allocated radio resources at a scheduling
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`time.” Id., 1:31-35.
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`The ’354 Patent purports to enable this solution through a method for
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`transmitting uplink control information which includes the steps of: (a) generating
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`uplink control information; (b) allocating the uplink control information to
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`downlink-shared radio resources for packet data transmission based on downlink
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`scheduling information; and (c) transmitting the radio resource to a terminal. Id.,
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`2:15-23.
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`The patent describes the advantage of this purported invention as being the
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`ability to “efficiently form [] uplink control information to be transmitted through a
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`downlink from a base station to a terminal … and transmitting the uplink control
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`information with minimum radio resources occupied.” Id., 2:26-32. Fig. 1 depicts
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`a flowchart illustrating a method for transmitting such uplink control information in
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`a mobile communication system, and is reproduced below:
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`IPR2020-00249 (8,270,354)
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`B. Challenged Claims
`This Petition challenges claims 1, 3, 5, and 7 of the ’354 Patent. Claim 1 is
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`representative and is reproduced below and emphasized for reference in the
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`following discussion:
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`1. A method for transmitting response for random access in a base station of
`a mobile communication system, the method comprising:
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`generating a response for random access received from a terminal;
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`allocating the response for random access to downlink-shared radio
`resource for transmitting packet data; and
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`transmitting to the terminal an identifier indicating transmission of the
`response for random access through a channel carrying downlink
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`IPR2020-00249 (8,270,354)
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`scheduling information, and transmitting to the terminal the response
`for random access through the downlink-shared radio resource for
`transmitting packet data, wherein responses for random access for a
`plurality of terminals are addressed using the identifier.
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`As shown, claim 1 describes a random access method that involves a base
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`station (i) generating a response for a random access request received from a
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`terminal, (ii) allocating the response to downlink-shared radio resource and
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`transmitting the response on this downlink-shared radio resource, (iii) transmitting
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`an identifier that indicates transmission of the response through a channel carrying
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`downlink-scheduling information, and (iv) wherein responses for random access
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`requests for a plurality of terminals are addressed using the identifier.
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`With respect to Fig. 1, the patent describes the steps as follows. At step S110,
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`“a base station generates uplink control information to transmit to a terminal.” Id.,
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`2:64-65. The uplink control information may include both uplink scheduling
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`information and uplink random access response information or one of the two. See
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`id., 2:66-3:9. “After the step S110, a base station allocates the uplink control
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`information to downlink-shared radio resources for transmitting packet data at step
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`S120.” Id., 4:12-14. “After the step S120, a base station transmits a downlink radio
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`resource with allocated uplink control information to a terminal at step S130.” Id.,
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`4:37-39.
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`The uplink control information may include “radio resource allocation
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`information,” which itself may include, a “scheduling identifier.” Id., 3:10-15. The
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`patent describes the scheduling identifier as “information about a terminal or a
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`terminal group where [an] allocated radio resource belongs to.” Id., 3:15-17. The
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`scheduling identifier, also characterized by the patent as a “group identifier” (id.,
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`2:47-49) is depicted in Fig. 4, reproduced below:
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`As the patent contends, there was a demand for “developing a method for
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`effectively forming uplink control information using a downlink from a base station
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`to a terminal and transmitting the uplink control information with minimum radio
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`resources occupied in packet based mobile communication systems developed based
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`on a 3rd generation partnership project (3GPP) system so as to improve the utilization
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`of limited radio resources.” Id., 1:53-61.
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`IPR2020-00249 (8,270,354)
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`However, such a method was already developed by 3GPP participants before
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`the filing date of the application that led to the ’354 Patent. As explained below, the
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`claimed methods were well known in the art.
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`Prosecution History
`C.
`During prosecution of the ’354 Patent, what are now claims 1, 3, 5, and 7 were
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`repeatedly rejected as being anticipated by WO 2005/057822 to Jung (“Jung”).
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`On June 21, 2011 numerous claims were rejected under 35 U.S.C. 102(a) as
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`being anticipated by Jung. For instance, the examiner found that Jung teaches a
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`method for transmitting/receiving random access response information of a mobile
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`communication system, involving a base station and a mobile station.
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`Ex. 1002, 178.
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`The examiner also found that Jung teaches random access response
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`information including downlink scheduling information.
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`IPR2020-00249 (8,270,354)
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`Ex. 1002, 178.
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`The examiner additionally found that Jung teaches that the scheduling
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`information denotes a terminal or terminal group to receive the random access
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`response information.
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`Ex. 1002, 179.
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`The examiner further found that Jung teaches that the random access response
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`information includes a terminal identifier (a scheduling ID) as well as timing
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`alignment information (timing information), and uplink radio resource location
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`information (frequency information).
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`Ex. 1002, 179.
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`Lastly, examiner found Jung teaches the response information includes uplink
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`radio resource block location information (i.e., ACK/NACK information granting or
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`denying a radio resource block location on an uplink frame).
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`Ex. 1002, 178.
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`After this rejection, the applicant canceled claims 1-18 and added new claims
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`19-37. Ex. 1002, 200. Specifically, claim 19 was drafted to include additional
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`language as underlined below.
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`Ex. 1002, 201.
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`The applicant argued that Jung failed to disclose two elements of claim 19.
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`First, applicant argued that Jung did not teach “allocating the response for random
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`access to the download-shared [sic] radio resource”. Ex. 1002, 201-02. Second, the
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`applicant argued that “Jung fails to disclose any identifier to indicate transmission
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`of the response for the random access and address the response for the random
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`access.” Ex. 1002, 203.
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`In response, however, the examiner disagreed with the applicant’s arguments
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`and rejected the claims again in view of the Jung reference.
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`Ex. 1002, 212-13.
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`The examiner specifically rejected applicant’s argument that Jung does not
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`disclose the downlink-shared radio resource.
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`Ex. 1002, 217.
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`The examiner also rejected the argument that Jung failed to teach the identifier
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`that is used to indicate transmission of the response for random access and address
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`the response for the random access. The examiner noted that “Jung clearly teaches
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`that a specific scheduling ID is provided for each preamble, assigned to the mobile
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`station, and transmitted with an access grant on the preamble received from the
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`mobile station.” Ex. 1002, 217-18 (reproduced below).
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`In response, the applicant amended the claims as shown below:
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`Ex. 1002, 235.
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`The applicant argued that the “identifier” in Jung was “terminal-specific” and
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`thus did not disclose “using the identifier to address responses for random access for
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`a plurality of terminals” as recited in the claims. Id., 236. Furthermore, the applicant
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`argued that “Jung fails to disclose that the identifier is transmitted through a channel
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`carrying downlink scheduling information while the response for random access is
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`transmitted through the downlink-shared radio resource for transmitting packet
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`data.” Id., 236. According to the applicant, “[t]his is consistent with the notion that
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`the scheduling ID of Jung is a terminal-specific one.” Id.
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`The claims were later allowed. However, as shown herein, use of an
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`“identifier” that was not “terminal-specific” was well known in the art and disclosed
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`by 3GPP before the filing date of the application that led to the ’354 Patent.
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`D. Claimed Priority Date
`The application leading to the ’354 Patent was filed on May 3, 2007 and
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`claims priority to two foreign Korean applications filed on May 3, 2006 and
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`February 28, 2007 respectively. For the purposes of this Petition, May 3, 2006 is
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`IPR2020-00249 (8,270,354)
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`presumed as the priority date of the ’354 patent. Based on this presumed priority
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`date, the references presented in this Petition are prior art under at least 35 U.S.C. §
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`102(a) or (e).
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`IV. LEVEL OF ORDINARY SKILL IN THE ART
`A person of ordinary skill in the art would have (i) an undergraduate degree
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`in Electrical Engineering, Computer Science, or Computer Engineering, or a related
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`field, and around two years of experience in the theory, design, and/or development
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`of cellular technology, or a person with a master’s degree in one of the foregoing
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`with a focus on cellular networks, or (ii) a Master’s degree in one of the foregoing
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`fields with a focus on cellular technology. See Ex. 1003, ¶ 31. Someone with less
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`or different technical education but more relevant practical experience, or more
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`relevant education but less practical experience, could also be considered a
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`POSITA. Id.
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`V. CLAIM CONSTRUCTION
`Claim construction in inter partes review is governed by the same standard as
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`it would be in a district court. 37 C.F.R. § 42.100(b). Terms should be interpreted in
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`view of “their ordinary and accustomed meaning as understood by one of ordinary
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`skill in the art.” Dow Chem. Co. v. Sumitomo Chem. Co., 257 F.3d 1364, 1372 (Fed.
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`Cir. 2001); Phillips v. AWH Corp., 415 F.3d 1303, 1312-13 (Fed. Cir. 2005) (en
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`banc). “The construction that stays true to the claim language and most naturally
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`IPR2020-00249 (8,270,354)
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`aligns with the patent’s description of the invention will be, in the end, the correct
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`construction.” Phillips, 415 F.3d at 1316. For this proceeding, Petitioner does not
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`propose any terms for an express construction.
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`VI. PRIOR ART
`As a matter of general background, random access technology has been used
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`for many decades and is well known in wireless and wired networking such as in
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`WiFi (802.11), WCDMA, and Long Term Evolution (LTE). Ex. 1003, ¶ 42. Given
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`a limited communication channel, the network protocol manages access and use of
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`the channel by have a node grant access to terminals.
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`In LTE, random access is used in a variety of scenarios. For instance, random
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`access is used when a mobile device initially accesses a base station of the network
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`or when a mobile device is moving and needs to connect to a new base station
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`(commonly referred to as a “handover”). Ex. 1003, ¶ 43. Random is also used for
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`downlink (DL) and uplink (UL) data arrival between the mobile device and the base
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`station. Id.
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`The primary purpose of the random access procedure on LTE (and other
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`networks) is to register the mobile device (also referred to as “UE” or “user
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`equipment”) on the network and synchronize it. Ex. 1003, ¶ 44. In other words, the
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`mobile device must be synchronized with the base station both in terms of time and
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`frequency. Id.
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`Broadly speaking, there are two modes of random access: one where a mobile
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`station starts the process (sometimes referred to as contention based random access)
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`and one where the base station starts the process (sometimes referred to as and non-
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`contention based random access). Ex. 1003, ¶¶ 45-46. These two modes are
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`depicted in the illustration below.
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`The challenged claims generally relate to the mode where the mobile station
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`starts the process. Ex. 1003, ¶ 47. For example, the first element in claim 1 recites
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`the base station generating a response for random access received from a terminal,
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`i.e., the terminal started the process by sending the base station a random access
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`
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`request. Id.
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`As evidenced by the prior art and explained by Dr. Roy in the attached expert
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`declaration (Ex. 1003), all of the limitations of claim 1 and dependent claims 3, 5,
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`and 7 were well known before the ’354 Patent’s claimed priority date. In addition
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`to the extensive background knowledge that a POSITA would have brought to bear
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`IPR2020-00249 (8,270,354)
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`on the subject matter discussed in the ’354 Patent, the following prior art
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`demonstrates that the challenged claims would have been obvious.
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`A. R2-060866
`“Random Access Procedures for LTE” is a written contribution, by Ericsson,
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`submitted to 3GPP at the Joint RAN1/RAN2 meeting on LTE that occurred in
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`Athens, Greece between March 27-31, 2006 (“R2-060866”, Exhibit 4). This
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`document is a submission to the 3GPP standards body for consideration in
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`developing the LTE cellular system. Ex. 1005, ¶¶ 36-43. R2-060866 is a printed
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`publication prior art reference under at least 35 U.S.C. 102(a) as it was accessible
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`and available via 3GPP’s publicly available website on March 23, 2006 before the
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`’354 Patent’s priority date of May 3, 2006. R2-060866 was not considered during
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`prosecution of the ’354 Patent application. Id.
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`As the contribution explains, discussions regarding “initial and random access
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`procedures for LTE” had been ongoing even prior to the document submission. Ex.
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`1004, 1. Building off that, the “contribution propose[s] efficient procedures for
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`initial and random access with low resource usage.” Id. It does so because, as it
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`notes, “[t]ransmitting user data on a non-synchronized uplink or in a contention-
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`based manner is not spectrally efficient due to the need for guard periods and
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`retransmissions respectively.” Id., 2.1.
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`IPR2020-00249 (8,270,354)
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`The general description of the contribution proposes “to separate the
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`transmission of the random access burst, whose purpose is to obtain uplink
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`synchronization, from the transmission of data. In the first step, the UE2 obtains
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`uplink synchronization and is assigned resources for uplink transmission. In the
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`second step, the UE transmits information on the scheduled resource, e.g.
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`information necessary for further scheduling or setting up a connection (RRC
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`connection request message).” Id., 2.1. This is further depicted in Figure 1,
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`reproduced below and annotated:
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`Id.
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`2 UE refers to “User Equipment” or a terminal device such as a cellular phone. Ex.
`1003, ¶ 49.
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`IPR2020-00249 (8,270,354)
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`Shown as (3) in Figure 1 above, the “Node B3 will correlate the received signal
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`with the set of possible sequences in a cell” and if a preamble is detected, “the Node
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`B will transmit a response (4), including the ID of the signature the UE selected.”
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`Id., 2.2. Then, “[o]nce the UE has received the acknowledgement from the Node B
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`and adjusted its uplink timing (5), the remaining signaling required for connection
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`setup is transmitted on the assigned resources in a synchronized fashion using the
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`same procedures as normal data transmission (6).” Id., 2.3.
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`Like the ’354 Patent, the contribution explains that this procedure is intended
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`to work in a system where a plurality of terminals may attempt to access the system
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`resources. For instance, it notes that “[d]ue to the inherently uncoordinated nature
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`of random or contention based access, multiple UEs may simultaneously try to
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`access the system, possibly with non-unique preamble sequences.” Id., 2.4. Similar
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`to the ’354 Patent, R2-060866 proposes a “contention resolution mechanism” to
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`address this issue, a “very short Random Access ID (RA ID) for resource efficient
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`random access, a slightly longer Cell-specific ID to identify a UE uniquely within a
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`cell and a Global ID which identifies a UE uniquely within SAE/LTE.” Id. (italics
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`retained).
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`3 Node B (or “eNode B”) refers to a base station. Ex. 1003, ¶ 49.
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`IPR2020-00249 (8,270,354)
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`Jung
`B.
`Jung has an International Filing Date of September 8, 2004, was published on
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`June 23, 2005, and is therefore prior art under 35 U.S.C. 102(a). Ex. 1006. Jung
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`discloses a random access system. Ex. 1006, ¶ 3. Jung discloses that the random
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`access system uses a preamble and “scheduling ID” for random access. Ex. 1006,
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`Abstract. Using this scheduling identifier, random access data is correctly
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`transmitted through an assigned channel.” Id. Jung was considered during
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`prosecution of the ’354 Patent application, but the specific combination discussed
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`herein was not considered.
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`Jung discloses that methods for random access in wireless communication
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`systems existed prior to the Jung reference. Ex. 1006, ¶¶ 2-5. These prior methods
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`for transmitting random access data allow both a preamble and data to be transmitted
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`through a common random access channel (RACH) by making resource
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`assignments.
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` Ex. 1006, ¶ 5.
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` Jung
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`teaches
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`transmitting ACK/NACK
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`(acknowledgement no-acknowledgment) information in such a random access
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`procedure, including a scheduling identifier (assigned by a base station) for
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`transmitting data through the channel between a base station and a mobile station.
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`Ex. 1006, ¶¶ 2-5.
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`The random access procedure of Jung is depicted in Fig. 1, reproduced below.
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`The first box in Fig. 1 shows a mobile station (100) which is capable of transmitting
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`IPR2020-00249 (8,270,354)
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`random access data to a base station (200) represented by the second box. Ex. 1006,
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`¶ 26. Among other things, the base station (200) teaches an ID manager (220), which
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`assigns a specific scheduling ID to each mobile station for random access. Ex. 1006,
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`¶ 40.
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`
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`Ex. 1006, Fig. 1.
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`This random access procedure between a mobile station and base stat