throbber
UNITED STATES PATENT AND TRADEMARK OFFICE
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`SAMSUNG ELECTRONICS CO., LTD., and
`SAMSUNG ELECTRONICS AMERICA, INC.,
`
`Petitioners
`
`v.
`
`JAWBONE INNOVATIONS, LLC,
`
`Patent Owner
`
`Case IPR2022-00213
`
`U.S. Patent No. 8,280,072
`
`DECLARATION OF CHRIS KYRIAKAKIS, PH.D.
`IN SUPPORT OF PETITION FOR INTER PARTES REVIEW
`OF U.S. PATENT NO. 8,280,072
`
`Samsung Exhibit 1002
`Page 001 of 151
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`

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`IPR2022-00213
`U.S. Patent No. 8,280,072
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`Table of Contents
`
`I.
`II.
`
`INTRODUCTION ........................................................................................... 1
`BACKGROUND AND QUALIFICATIONS ................................................. 2
`A.
`Relevant Academic Experience ............................................................ 2
`B.
`Relevant Professional Experience ......................................................... 4
`III. MATERIALS REVIEWED ............................................................................ 6
`IV. LEVEL OF ORDINARY SKILL IN THE ART .............................................. 9
`V.
`RELEVANT LEGAL STANDARDS ...........................................................10
`VI.
`SUMMARY OF OPINIONS .........................................................................13
`VII. BRIEF DESCRIPTION OF TECHNOLOGY ..............................................13
`VIII. OVERVIEW OF THE ’072 PATENT ..........................................................21
`A.
`Disclosure of the ’072 Patent ..............................................................21
`IX. OVERVIEW OF THE PRIMARY PRIOR ART REFERENCES ................32
`A.
`Zhang ...................................................................................................32
`B.
`Arndt ....................................................................................................40
`CLAIM CONSTRUCTION ..........................................................................48
`SPECIFIC GROUNDS FOR CHALLENGE ................................................49
`A.
`Grounds Challenging Claims 1-9 of the ’072 Patent ..........................49
`B.
`Ground 1A: Zhang Discloses All of the Features of Claims 1-6, and 9
` .............................................................................................................50
`1.
`Claim 1 ......................................................................................50
`2.
`Claim 2 ......................................................................................64
`
`X.
`XI.
`
`i
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`Claims 3 and 4 ...........................................................................70
`3.
`Claim 5 ......................................................................................71
`4.
`Claim 6 ......................................................................................73
`5.
`Claim 9 ......................................................................................74
`6.
`Ground 1B: Zhang Discloses or Suggests All of the Features of
`Claims 1-9 ...........................................................................................76
`1.
`Claim 1 ......................................................................................76
`2.
`Claims 2 and 9 ...........................................................................78
`3.
`Claims 3, 4, and 6......................................................................78
`4.
`Claim 5 ......................................................................................79
`5.
`Claim 7 ......................................................................................79
`2.
`Claim 8 ......................................................................................92
`Ground 2A: Zhang Discloses All of the Features of Claims 2 and 6-8
` .............................................................................................................93
`1.
`Claim 2 ......................................................................................93
`2.
`Claims 6 and 7 ...........................................................................99
`3.
`Claim 8 ....................................................................................100
`Ground 2B: Zhang Discloses or Suggests All of the Features of
`Claims 2 and 6-8 ................................................................................101
`1.
`Claim 2 ....................................................................................101
`2.
`Claims 6 and 7 .........................................................................101
`1.
`Claim 8 ....................................................................................101
`Ground 3A: Arndt Discloses All of the Features of Claims 1-6, and 9
` ...........................................................................................................101
`
`C.
`
`D.
`
`E.
`
`F.
`
`ii
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`IPR2022-00213
`U.S. Patent No. 8,280,072
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`G.
`
`Claim 1 ....................................................................................101
`1.
`Claim 2 ....................................................................................125
`2.
`Claims 3 and 4 .........................................................................132
`3.
`Claim 5 ....................................................................................133
`4.
`Claim 6 ....................................................................................133
`5.
`Claim 9 ....................................................................................134
`6.
`Ground 3B: Arndt Discloses or Suggests All of the Features of Claims
`1-6, and 9 ...........................................................................................136
`1.
`Claim 1 ....................................................................................136
`2.
`Claims 2 and 9 .........................................................................137
`3.
`Claims 3-6 ...............................................................................137
`Ground 4A: Arndt Discloses All of the Features of Claims 2 and 6-8
` ...........................................................................................................138
`1.
`Claim 2 ....................................................................................138
`2.
`Claims 6 and 7 .........................................................................145
`3.
`Claim 8 ....................................................................................146
`Ground 4B: Arndt Discloses or Suggests All of the Features of Claims
`2 and 6-8 ............................................................................................146
`1.
`Claim 2 ....................................................................................146
`2.
`Claims 6-8 ...............................................................................147
`XII. CONCLUSION ............................................................................................147
`
`H.
`
`I.
`
`iii
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`IPR2022-00213
`U.S. Patent No. 8,280,072
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`I, Chris Kyriakakis, declare as follows:
`
`I.
`
`INTRODUCTION
`
`1.
`
`I have been retained by Samsung Electronics Co., Ltd. and Samsung
`
`Electronics America, Inc. (“Samsung” or “Petitioners”) as an independent expert
`
`consultant in this proceeding before the United States Patent and Trademark Office
`
`(“PTO”).
`
`2.
`
`I am being compensated at a rate of $525/hour for my services in this
`
`proceeding, which is my regular and customary rate.
`
`3.
`
`My compensation is in no way contingent on the nature of my findings,
`
`the presentation of my findings in testimony, or the outcome of this or any other
`
`proceeding. I have no other interest in this proceeding.
`
`4.
`
`I have been asked to consider whether certain references disclose or
`
`suggest the features recited in the claims of U.S. Patent No. 8,280,072 (“the ’072
`
`patent”) (Ex. 1001).1 My opinions are set forth below.
`
`1 Where appropriate, I refer to exhibits I understand will be attached to the petition
`
`for inter partes review of the ’072 patent (the “Petition”).
`
`1
`
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`II.
`
`BACKGROUND AND QUALIFICATIONS
`
`5.
`
`I am an independent consultant. All of my opinions stated in this
`
`declaration are based on my own personal knowledge and professional judgment. In
`
`forming my opinions, I have relied on my education, experience, and knowledge
`
`regarding electrical engineering, computer science, and audio and acoustic sciences.
`
`6.
`
`I am over 18 years of age and, if I am called upon to do so, I would be
`
`competent to testify as to the matters set forth herein. A copy of my current
`
`curriculum vitae, which details my education and professional and academic
`
`experience, as well as a list of all publications I have authored in the past ten years,
`
`is included as Ex. 1003 in this proceeding. The following provides an overview of
`
`some of my experience that is relevant to the matters set forth in this declaration.
`
`A.
`7.
`
`Relevant Academic Experience
`I earned my Bachelor of Science degree in Engineering and Applied
`
`Science from the California Institute of Technology (Caltech) in 1985. I received my
`
`Master of Science degree in Electrical Engineering in 1987 and my Ph.D. in
`
`Electrical Engineering in 1993, both from the University of Southern California
`
`(“USC”).
`
`8.
`
`Since 2002, I am a tenured Associate Professor in the Electrical
`
`Engineering Department at USC. My research interests lie at the intersection of
`
`acoustics, psychoacoustics (the science that studies human perception of sound), and
`
`2
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`audio signal processing. My recent research has focused on the study of audio
`
`systems in challenging environments including automobiles and mobile devices, as
`
`well as algorithms for enhancing the performance of voice recognition engines. I
`
`have published nearly 100 technical papers, including several peer reviewed papers.
`
`I have published a book entitled Immersive Audio Signal Processing, and hold
`
`several patents in acoustic measurement of loudspeakers in rooms and cars,
`
`loudspeaker crossover optimization, and loudspeaker response correction using
`
`signal processing. My publications examine various aspects of sound measurement,
`
`how sound interacts with the acoustical elements of the environment, novel methods
`
`for surround sound recording and reproduction, and the perception of sound by
`
`human listeners.
`
`9.
`
`A major focus of my recent research has been the study of microphone
`
`arrays for applications in enhanced far field voice recognition. This includes
`
`methods for Direction of Arrival finding and beam forming from linear and circular
`
`microphone arrays. I have also investigated methods for noise removal and
`
`reverberation reduction from microphone signals. In addition, over the past year I
`
`have worked on methods for echo cancellation for applications in wearable devices.
`
`Previous work includes loudspeakers and how they interact with their acoustical
`
`environment. In particular, I have researched the role of sound reflections,
`
`absorption, and diffusion in the performance of loudspeakers. I have also published
`3
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`several technical papers on acoustical measurement methods in rooms and device
`
`enclosures and developed novel signal processing algorithms for optimizing sound
`
`system performance. Other topics I have researched include multichannel audio
`
`acquisition and rendering, virtual microphones and virtual speakers, hybrid
`
`headphone-loudspeaker rendering methods, and advanced signal processing
`
`techniques for optimizing sound quality from small portable devices.
`
`B.
`10.
`
`Relevant Professional Experience
`I am the founding Director of the USC Immersive Audio Laboratory
`
`with facilities for experimental work in room acoustics, multichannel audio, and
`
`psychoacoustics. This laboratory also serves as a unique teaching facility for my
`
`undergraduate course in Introduction to Digital Audio and my graduate course in
`
`Immersive Audio Signal Processing. Both courses have a major acoustics
`
`component that examines the interaction of sound with the acoustical environment
`
`(e.g., home, movie theater, car). The graduate course was developed through a two-
`
`year grant I received from the National Science Foundation entitled “Collaborative
`
`Learning in Engineering Using Immersive Environments,” and was the first of its
`
`kind to assess the impact of audio immersion in student learning. In addition to the
`
`courses I teach, I have also supervised and served on Ph.D. dissertation committees
`
`for more than 30 students.
`
`4
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`11.
`
`In 2019, I joined Syng as the Chief Audio Scientist. Syng creates
`
`innovative products for next generation spatial audio and my role there includes
`
`research and development of audio algorithms for sound capture using microphone
`
`arrays to measure the acoustics of the room and loudspeaker beamforming for
`
`rendering sound in various directions.
`
`12.
`
`From 2003 to 2018, I was the co-founder and Chief Technology Officer
`
`of Audyssey Laboratories, a USC spin-off company that develops and licenses audio
`
`technology to leading automotive, professional and consumer electronic companies
`
`around the world. As part of my work at Audyssey, I have developed audio
`
`algorithms and designed speakers. These speakers were novel acoustical designs that
`
`used a combination of unique enclosures, and audio signal processing to optimize
`
`their performance and overcome limitations that arise from small drivers and
`
`enclosures. For example, we used signal processing technologies combined with
`
`novel acoustical design to extend the bass response of small woofers and passive
`
`radiators beyond what was previously possible in small speaker enclosures. The
`
`innovations in these designs have received awards, including Popular Science’s
`
`“Best of What’s New.”
`
`13.
`
`In April 2018 I was elected as Senior Member of the Institute of
`
`Electrical and Electronic Engineers (IEEE) in recognition of my contributions to the
`
`5
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`field of engineering. I am also a member of the Audio Engineering Society (AES),
`
`an association for professionals in the audio industry.
`
`14.
`
`In 2006, I received a World Technology Network Award. This
`
`organization presents awards to innovators in several areas in which technology can
`
`foster a paradigm change. My award was for innovations in immersive audio that
`
`enable new capabilities in media and journalism. Other award recipients at that event
`
`included Vice President Al Gore, Google, and Space-X. In addition, my work has
`
`been featured in multiple news articles, including pieces by The Atlantic, the BBC
`
`World Service, the New York Times, and National Public Radio.
`
`15.
`
`In the late 1990s and early 2000s, I was a faculty researcher and later
`
`Deputy Director of the National Science Foundation’s engineering research center
`
`established at USC. I was studying the fundamental and technological limitations of
`
`immersive audio and the role of acoustics on the performance of loudspeakers and
`
`audio systems in homes and cars. In 2003, together with one of my graduate students,
`
`I received the award for Best Paper at the Institute of Electrical and Electronics
`
`Engineers (“IEEE”) Conference on Signals, Systems and Computers.
`
`III. MATERIALS REVIEWED
`
`16.
`
`The opinions contained in this declaration are based on the documents
`
`I reviewed, my professional judgment, as well as my education, experience, and
`
`6
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`knowledge regarding electrical engineering, computer science, and audio and
`
`acoustic sciences.
`
`17.
`
`In forming my opinions expressed in this declaration, I reviewed the
`
`following materials:
`
` the ’072 patent (Ex. 1001);
`
` the file history of the ’072 patent (Ex. 1004);
`
` Excerpts from the File History of U.S. Application No. 12/139,333 (Ex.
`
`1005);
`
` Excerpts from the File History of U.S. Application No. 11/805,987 (Ex.
`
`1006);
`
` Excerpts from the File History of U.S. Application No. 10/667,207 (Ex.
`
`1007);
`
` Excerpts from the File History of U.S. Application No. 10/400,282 (Ex.
`
`1008);
`
` the File History of U.S. Provisional Application No. 60/937,603 (Ex. 1009);
`
` U.S. Patent Application Publication 2008/0170716 (“Zhang”) (Ex. 1010);
`
` U.S. Patent Application Publication 2005/0041824 (“Arndt”) (Ex. 1011);
`
` U.S. Patent Application Publication 2002/0193130 (“Yang”) (Ex. 1013);
`
` U.S. Patent No. 5,982,906 (“Ono”) (Ex. 1014);
`
`7
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` Stephen C Thompson, “Tutorial on Microphone Technologies for Hearing
`
`Aids”, The Hearing Journal (November, 2003) (“Thompson”) (Ex. 1015);
`
` Excerpts from John Eargle, Handbook of Recording Engineering (2003)
`
`(“Eargle”) (Ex. 1016);
`
` Excerpts from John Eargle, The Microphone Book (2d ed. 2005)
`
`(“Microphone Book”) (Ex. 1017);
`
`and any other materials I refer to in this declaration in support of my opinions.
`
`18. All of the opinions contained in this declaration are based on the
`
`documents I reviewed and my knowledge and professional judgment. My opinions
`
`have also been guided by my appreciation of how a person of ordinary skill in the
`
`art would have understood the claims and the specification of the ’072 patent at the
`
`time of the alleged invention, which I have been asked to initially consider as no
`
`earlier than June 27, 2007 (the filing date of U.S. Provisional Patent Application
`
`60/937,603). My opinions reflect how one of ordinary skill in the art would have
`
`understood the ’072 patent, the prior art to the patent, and the state of the art at the
`
`time of the alleged invention.
`
`19. Based on my experience and expertise, it is my opinion that certain
`
`references disclose and/or suggest, alone or in combination, all the features recited
`
`in claims 1-9 (“challenged claims”) of the ’072 patent, as I discuss in detail below.
`
`8
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`IV. LEVEL OF ORDINARY SKILL IN THE ART
`
`20.
`
`I have been informed and understand that, in the context of an invalidity
`
`analysis, a person having ordinary skill in the art is a hypothetical person who looks
`
`to prior art at the time of the invention. I further understand that the factors that may
`
`be considered in determining the level of ordinary skill include: (1) the problems
`
`encountered in the art; (2) the prior art solutions to the problems encountered in the
`
`art; (3) the rapidity of innovation; (4) the sophistication of the technology; and (5)
`
`the education level of active workers in the field. I understand that these factors need
`
`not all be considered for the analysis and that one or more of these factors may
`
`control.
`
`21.
`
`I was asked to provide my opinion on the level of one of ordinary skill
`
`in the art with respect to the alleged invention of the ’072 patent as of June 27, 2007.
`
`Based on my consideration of the factors above, I believe a person of ordinary skill
`
`in the art would have had a bachelor’s degree in electrical engineering, computer
`
`science, audio engineering or a similar field and two years of experience in designing
`
`microphone arrays. More education could have been used to supplement practical
`
`experience and vice versa.
`
`22. As of June 27, 2007, I met, and in fact exceeded, the qualifications of a
`
`person of ordinary skill in the art. To be clear, all of my opinions in this declaration
`
`9
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`are from the perspective of one of ordinary skill in the art as I have defined it here
`
`during the relevant timeframe.
`
`V.
`
`RELEVANT LEGAL STANDARDS
`
`23.
`
`I am not an attorney and offer no legal opinions, but in the course of
`
`my work, I have had experience studying and analyzing patents and patent claims
`
`from the perspective of a person skilled in the art.
`
`24.
`
`For the purposes of this declaration, I have been informed about certain
`
`aspects of the law that are relevant to forming my opinions. My understanding of the
`
`law is as follows:
`
`25.
`
`Petitioners’ counsel have informed me that a patent claim is anticipated
`
`and therefore invalid under 35 U.S.C. section 102, if, among other things, (a) the
`
`alleged invention was patented or described in a printed publication in the United
`
`States or a foreign country before the alleged invention thereof by the patent's
`
`applicant(s), or (b) the alleged invention was patented or described in a printed
`
`publication in this or a foreign country more than one year prior to the priority date
`
`of the application for patent in the United States, or (e) the invention was described
`
`in a patent granted on an application for patent by another filed in the United States
`
`before the individuals named on the ’072 patent allegedly made their invention.
`
`26.
`
`Petitioners’ counsel have informed me that references or products that
`
`fall into one or more of these categories are called “prior art,” and that to anticipate
`
`10
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`a patent claim a single reference must contain all of the elements and limitations
`
`recited in the claim either expressly or inherently.
`
`27.
`
`Petitioners’ counsel has informed me that for the prior art to inherently
`
`disclose a claimed limitation, the prior art need not expressly disclose the limitation,
`
`so long as the claimed limitation necessarily flows from a disclosure in the prior art.
`
`28.
`
`Petitioners’ counsel has informed me that a patent claim can be
`
`considered to have been obvious to a person of ordinary skill in the art at the time
`
`the application was filed in view of the prior art. This means that, even if all of the
`
`requirements of a claim are not found in a single prior art reference, the claim is not
`
`patentable if the differences between the subject matter in the prior art and the
`
`subject matter in the claim would have been obvious to a person of ordinary skill in
`
`the art at the relevant time, which I have been informed in this case is June 27, 2007.
`
`29.
`
`Petitioners’ counsel has informed me that a determination of whether a
`
`claim would have been obvious should be based upon several factors, including,
`
`among others:
`
`the level of ordinary skill in the art at the time the application was filed;
`
`the scope and content of the prior art; and
`
`what differences, if any, existed between the claimed invention and the
`
`
`
`
`
`
`
`prior art.
`
`11
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`30.
`
`Petitioners’ counsel has informed me that a single prior art reference
`
`can render a patent claim obvious if any differences between that reference and the
`
`claims would have been obvious to a person of ordinary skill in the art. Alternatively,
`
`the teachings of two or more references may be combined in the same way as
`
`disclosed in the claims, if such a combination would have been obvious to one
`
`having ordinary skill in the art. In determining whether a combination based on
`
`either a single reference or multiple references would have been obvious, it is
`
`appropriate to consider, among other factors:
`
`
`
`whether the teachings of the prior art references disclose known
`
`concepts combined in familiar ways, and when combined, would yield predictable
`
`results;
`
`
`
`whether a person of ordinary skill in the art could implement a
`
`predictable variation, and would see the benefit of doing so;
`
`
`
`whether the claimed elements represent one of a limited number of
`
`known design choices, and would have a reasonable expectation of success by those
`
`skilled in the art;
`
`
`
`whether a person of ordinary skill would have recognized a reason to
`
`combine known elements in the manner described in the claim;
`
`
`
`whether there is some teaching or suggestion in the prior art to make
`
`the modification or combination of elements claimed in the patent; and
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`
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`whether the innovation applies a known technique that had been used
`
`to improve a similar device or method in a similar way.
`
`31.
`
`Petitioners’ counsel has informed me that one of ordinary skill in the
`
`art has ordinary creativity and is not an automaton. Petitioners’ counsel has also
`
`informed me that in considering obviousness, it is important not to determine
`
`obviousness using the benefit of hindsight derived from the patent being considered.
`
`VI.
`
`SUMMARY OF OPINIONS
`
`32.
`
`For the reasons I discuss below, it is my opinion that claims 1-9 of
`
`the ’072 patent are disclosed in the prior art, and are anticipated and/or rendered
`
`obvious by the prior art.
`
`VII. BRIEF DESCRIPTION OF TECHNOLOGY
`
`33.
`
`Sound is produced from sources that create displacement of the air
`
`particles around them. Displacement of these air particles causes them to oscillate,
`
`forming alternating regions of high pressure (many particles are in close vicinity of
`
`each other thus raising the air pressure) and regions of low pressure (very few
`
`particles are in that region thus lowering the air pressure). These patterns of high and
`
`low pressure propagate from the source and are called acoustic signals. They
`
`propagate through free space to a receiver (e.g., a microphone) where they are
`
`converted from pressure signals to electrical signals that can be processed by circuits
`
`attached to the microphones.
`
`13
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`34. As sound (i.e., acoustic signals) emanates from a sound source, it
`
`exhibits an approximately spherical wave front near the source. As it travels farther
`
`away, the sphere becomes larger and larger, at which point, the spherical wavefront
`
`is said to be a plane wave (i.e., a spherical wavefront with negligible curvature).
`
`Plane waves are a convenient analysis tool for many types of systems including
`
`microphone arrays. Plane waves can simply be described by a wave vector that has
`
`a magnitude (indicating the size of the wave) and a direction of propagation.
`
`35.
`
`In voice communication applications, it is often necessary to focus a
`
`microphone system to pick up sound from the direction of someone speaking while
`
`reducing the sound that the microphone system picks up from other sources (e.g.,
`
`from the direction of a noise source). In the professional recording industry, this
`
`focusing is achieved by using physical microphones with directional pickup patterns
`
`that can be pointed by rotating
`
`the microphone. However,
`
`in portable
`
`communication devices physical directional microphones are sometimes too large,
`
`prohibiting integration with the device. Instead, miniature microphones that can be
`
`easily integrated in circuit boards are used. These miniature microphones are non-
`
`directional, having an omnidirectional pickup pattern that captures sound equally
`
`from all directions.
`
`36.
`
`It was well-known to a person of skill in the art, that by combining and
`
`processing the signals from two or more closely-spaced miniature microphones it is
`14
`
`Samsung Exhibit 1002
`Page 018 of 151
`
`

`

`IPR2022-00213
`U.S. Patent No. 8,280,072
`
`possible to create electronic microphones that have a specified directionality pattern.
`
`These electronic microphones are often called differential microphones because one
`
`aspect of the signal combination involves subtracting the signal of one microphone
`
`from other microphones. Another term that has been used is “virtual” microphone
`
`because the sound pattern is created by processing the signals produced by physical
`
`microphones .
`
`37.
`
`In a simplified example below, a two-microphone array consists of two
`
`Figure 1, below, I have schematically represented a situation in which a plane wave
`
`approaches an array of two omnidirectional physical microphones and in which the
`
`omnidirectional physical microphones that produce signals () and (). In
`signal produced by the second microphone () is subtracted from the signal
`produced by the first microphone ().
`
`d
`

`
`+
`
`–
`
`Kyriakakis Fig. 1.
`
`15
`
`Samsung Exhibit 1002
`Page 019 of 151
`
`

`

`38. A plane wave originating from a sound source can be mathematically
`
`IPR2022-00213
`U.S. Patent No. 8,280,072
`
`described as a signal: ()= in which t is time, is the source amplitude
`and ω is the source frequency. The plane wave has a wave vector, ⃗, that describes
`wavenumber and is defined as = (where is the frequency and c is the speed
`
`the direction of the plane wave. The magnitude of the wave vector is called the
`
`of sound). The wavenumber is used to describe the delay between two wavefronts
`
`that are separated by a given distance.
`
`39.
`
`In the example above, using the mid-point between the microphones as
`
`a reference, we can see that the plane wave arrives at the first microphone before it
`
`reaches the mid-point because the plane wave travels a shorter distance from the
`
`first microphone is:
`
`source. If the plane wave arriving at the mid-point is , then the signal at the
`()=
` since it travels a shorter distance of cos compared to the midpoint.
`plane wave arriving at the mid-point is , then the signal at the second
`()=
`
`40.
`
`The plane wave arrives at the second microphone after it has already
`
`reached the mid-point because it travels a longer distance from the source. If the
`
`microphone is
`
`16
`
`Samsung Exhibit 1002
`Page 020 of 151
`
`

`

`IPR2022-00213
`U.S. Patent No. 8,280,072
`
`41. A well-known method for combining the two microphone signals to
`
`produce a virtual directional microphone is to subtract one from the other. For
`
`which can be represented as:
`
` because it travels a longer distance of cos compared to the midpoint.
`example, in Figure 1, the second signal () is subtracted from the first signal (),
`()−()=−=
`−=−2sincos.
`
`42.
`
`If we subtract the first signal from the second, we get the same
`
`expression, but with the opposite sign. In Figure 2, below, I have schematically
`
`represented a situation in which a plane wave approaches the same array of two
`
`omnidirectional physical microphones but this time the signal produced by the first
`
`microphone () is subtracted from the signal produced by the second microphone
`().
`
`17
`
`Samsung Exhibit 1002
`Page 021 of 151
`
`

`

`IPR2022-00213
`U.S. Patent No. 8,280,072
`
`–
`
`+
`
`d
`

`
`Kyriakakis Fig. 2.
`
`43.
`
`The output can be represented as:
`
`()−()=−=
`−=2.
`
`44.
`
`The polar pattern, which tells us the angular pattern of the virtual
`
`directional microphone created by the subtraction of the two omnidirectional
`
`microphones, is calculated by taking the magnitude of the signal differences. The
`
`magnitude of the polar pattern is the same for either subtraction:
`
`()=|()−()|=|()−()|=2.
` of the incoming plane wave varies from 0 to 360°, the microphone exhibits the
`
`45.
`
`Plotting the result of the above equation shows that as the incident angle
`
`following directionality pattern:
`
`18
`
`Samsung Exhibit 1002
`Page 022 of 151
`
`

`

`IPR2022-00213
`U.S. Patent No. 8,280,072
`
`Kyriakakis Fig. 3.
`
`46. As can be seen in the graph above, the front (0°) and back (180°)
`
`directions pick up the most sound while the sides (at 90° and 270°) pick up the least
`
`sound. The pickup from other directions gradually decreases between these two
`
`extremes as shown in the graph. This is often called a bidirectional (or figure-8)
`
`microphone. In this case, it is a virtual microphone that is created by combining two
`
`omnidirectional microphones and subtracting one from the other.
`
`19
`
`Samsung Exhibit 1002
`Page 023 of 151
`
`

`

`IPR2022-00213
`U.S. Patent No. 8,280,072
`
`47.
`
`The orientation of the figure-8 shown above in Figure 3 can be changed
`
`by introducing delay. For example, a 90° phase shift block can be inserted for one
`
`of the microphone signals (say o2(t)), thereby shifting the signal by 90°. In Figure 4,

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