Declaration of Dr. Mark Mahon
`EX1002
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`IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`SAMSUNG ELECTRONICS CO., LTD.,
`SAMSUNG ELECTRONICS AMERICA, INC.
`Petitioners,
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`v.
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`MASSIVELY BROADBAND LLC.
`
`Patent Owner.
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`––––––––––
`Case No. IPR2025-01605
`U.S. Patent No. 10,797,783
`––––––––––
`DECLARATION OF DR. MAHON IN SUPPORT OF PETITION FOR
`INTER PARTES REVIEW OF U.S. PATENT NO. 10,797,783
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`TABLE OF CONTENTS
`Page
`I. INTRODUCTION ...............................................................................................................1
`II. QUALIFICATIONS ............................................................................................................1
`III. LEGAL STANDARDS .....................................................................................................10
`A. Person of Ordinary Skill in the Art ........................................................................10
`B. Claim Construction ................................................................................................11
`C. Presumption of Validity .........................................................................................12
`D. Obviousness ...........................................................................................................12
`IV. BACKGROUND ...............................................................................................................15
`A. ’783 Patent .............................................................................................................15
`1. Earliest Priority Date ..................................................................................15
`2. Specification ..............................................................................................15
`3. Prosecution History ....................................................................................18
`B. Asserted Prior Art ..................................................................................................21
`1. Ganz (EX1005) ..........................................................................................21
`2. Larrick (EX1007) .......................................................................................22
`3. Engels (EX1008) ........................................................................................24
`4. Bareis (EX1009) ........................................................................................25
`5. Soomro (EX1010) ......................................................................................25
`6. Gardner (EX1013) .....................................................................................26
`V. PERSON OF ORDINARY SKILL ....................................................................................26
`VI. CLAIM CONSTRUCTION ...............................................................................................27
`VII. GROUND 1: GANZ AND LARRICK IN COMBINATION WITH SOOMRO
`RENDERS CLAIMS 1 AND 13-15 OBVIOUS ...............................................................28
`A. Overview and Motivation to Combine ..................................................................28
`1. Motivation to Combine Ganz and Larrick .................................................28
`2. Motivation to Combine Ganz/Larrick and Soomro ...................................34
`B. Limitation-By-Limitation Analysis .......................................................................36
`1. Claim 1 .......................................................................................................36
`2. Claim 13 .....................................................................................................50
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`3. Claim 14 .....................................................................................................52
`4. Claim 15 .....................................................................................................54
`VIII. GROUND 2: GANZ/LARRICK/SOOMRO IN COMBINATION WITH BAREIS
`RENDERS CLAIMS 2-5 OBVIOUS ................................................................................55
`A. Overview and Motivation to Combine ..................................................................55
`B. Limitation-By-Limitation Analysis .......................................................................56
`1. Claim 2 .......................................................................................................56
`2. Claim 3 .......................................................................................................57
`3. Claim 4 .......................................................................................................57
`4. Claim 5 .......................................................................................................57
`IX. GROUND 3: GANZ AND LARRICK IN COMBINATION WITH ENGELS
`RENDERS CLAIM 6 OBVIOUS ......................................................................................58
`A. Overview and Motivation to Combine ..................................................................58
`B. Limitation-By-Limitation Analysis .......................................................................59
`1. Claim 6 .......................................................................................................59
`X. GROUND 4: GANZ IN COMBINATION WITH LARRICK RENDERS
`CLAIMS 7-10 AND 16-17 OBVIOUS .............................................................................60
`A. Overview and Motivation to Combine ..................................................................60
`B. Limitation-By-Limitation Analysis .......................................................................60
`1. Claim 7 .......................................................................................................60
`2. Claim 8 .......................................................................................................64
`3. Claim 9 .......................................................................................................65
`4. Claim 10 .....................................................................................................65
`5. Claim 16 .....................................................................................................65
`6. Claim 17 .....................................................................................................69
`XI. GROUND 5: GANZ AND LARRICK, IN COMBINATION WITH BAREIS
`RENDERS CLAIMS 11-12 OBVIOUS ............................................................................69
`A. Overview and Motivation to Combine ..................................................................69
`B. Limitation-By-Limitation Analysis .......................................................................70
`1. Claim 11 .....................................................................................................70
`2. Claim 12 .....................................................................................................71
`XII. GROUND 6: GANZ AND LARRICK IN COMBINATION WITH GARDNER
`RENDERS CLAIMS 14-15 OBVIOUS ............................................................................73
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`A. Overview and Motivation to Combine ..................................................................73
`B. Limitation-By-Limitation Analysis .......................................................................75
`1. Claim 14: ....................................................................................................75
`2. Claim 15: ....................................................................................................76
`XIII. CONCLUSION ..................................................................................................................76
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`EXHIBIT LIST
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`Exhibit Description
`EX1001 U.S. Patent 10,797, 783 (“’783 Patent”)
`EX1002 Intentionally Omitted
`EX1003 Certificate of Correction for U.S. Patent 10,797,783
`EX1004 File History of U.S. Patent 10,797,783
`EX1005 U.S. Patent 6, 584,080 (“Ganz”)
`EX1006 Intentionally Omitted
`EX1007 U.S. Patent 7,209,523 (“Larrick”)
`EX1008 Patent Cooperation Treaty Pate nt Application WO 03/058850
`(“Engels”)
`EX1009 U.S. Patent Application P ub. No. 2004/0136373 (“Bareis”)
`EX1010 U.S. Patent Application P ub. No. 2003/0002456 (“Soomro”)
`EX1011 U.S. Provisional Application No. 60/498,324
`EX1012 U.S. Provisional Application No. 60/496,913
`EX1013 U.S. Patent Application P ub. No. 2005/0233709 (“Gardner”)
`EX1014 Patent Owner Preliminary In fringement Contentions, Ex. 8
`(September 16, 2025)
`EX1015 Curriculum Vitae of Mark Mahon Ph.D.
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`LIST OF CHALLENGED CLAIMS
`Claim
`1[pre] A wireless network device, comprising:
`[1a] a wireless transmitter that transmits wireless data through
`electromagnetic signals that have a bandwidth greater than or
`equal to 100 MHz and less than or equal to 500 MHz;
`[1b] a wireless receiver that receives wireless data through
`electromagnetic signals that have a bandwidth greater than or
`equal to 100 MHz and less than or equal to 500 MHz;
`[1c] wherein the wireless transmit ter is configured for transmitting
`wireless data that contains inform ation present in or determined
`from wireless data that has been received by the wireless receiver;
`[1d] wherein the wireless network devi ce is configured for processing
`wireless data received by the wireless receiver, and
`[1e] wherein the wireless network is configured for determining
`whether any, a portion, or all information in the processed wireless
`data should be transmitted by the wireless transmitter,
`[1f] wherein the wireless network devi ce is configured for transmitting
`beacon frames with the wireless transmitter.
`2 The wireless network device of claim 1 wherein the wireless
`transmitter is configured for tr ansmitting wireless data at more
`than one data rate.
`3 The wireless network device of claim 1 wherein the wireless
`receiver is configured for receiving wireless data at more than one
`data rate.
`4 The wireless network device of claim 1 wherein the wireless
`network device is configured to be powered through a connection
`to a DC power source.
`5 The wireless network device of claim 1 wherein the wireless
`network device is configured to be powered through a connection
`to an AC power source.
`6 The wireless network device of claim 1 wherein the wireless
`network device is configured to operate in a cellular network.
`7[pre] A wireless network device, comprisin g:
`[7a] a wireless transmitter that transmits wireless data through
`electromagnetic signals that have a bandwidth greater than or
`equal to 100 MHz and less than or equal to 500 MHz;
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`Claim
`[7b] a wireless receiver that receives wireless data through
`electromagnetic signals that have a bandwidth greater than or
`equal to 100 MHz and less than or equal to 500 MHz;
`[7c] wherein the wireless transmit ter is configured for transmitting
`wireless data that contains inform ation present in or determined
`from wireless data that has been received by the wireless receiver;
`[7d] wherein the wireless network devi ce is configured for processing
`wireless data received by the wireless receiver, and
`[7e] wherein the wireless network devi ce is configured for determining
`whether any, a portion, or all information in the processed wireless
`data should be transmitted by the wireless transmitter;
`[7f] a wired connection port which permits a wired internet connection
`wherein the wireless network device is configured for transmitting
`and receiving wired data through the wired connection port;
`[7g] wherein the wireless transmit ter is configured for transmitting
`wireless data that contains inform ation present in or determined
`from received wired data; and
`[7h] wherein the wireless network devi ce is configured for transmitting
`via the wired connection port wired data that contains information
`present in or determined from wireless data that has been received
`by the wireless receiver.
`8 The wireless network device of claim 7 wherein the wireless
`network device is configured for processing received wired data
`and determining whether any, a portion, or all information in the
`processed wired data should be transmitted as wireless data to one
`or more other devices b
`y the wireless transmitter.
`9 The wireless network device of claim 7 wherein the wireless
`network device is configured for providing an internet connection
`to one or more other devices.
`10 The wireless network device of cl aim 7 wherein the wired internet
`connection is an Ethernet connection.
`11 The wireless network device of cl aim 7 wherein the wired internet
`connection is a coaxial connection.
`12 The wireless network device of cl aim 7 wherein the wired internet
`connection is a wired optical cable connection.
`13[pre] A wireless network device, comprisin g:
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`Claim
`[13a] a wireless transmitter that transmits wireless data through
`electromagnetic signals that have a bandwidth greater than or
`equal to 100 MHz and less than or equal to 500 MHz;
`[13b] a wireless receiver that receives wireless data through
`electromagnetic signals that have a bandwidth greater than or
`equal to 100 MHz and less than or equal to 500 MHz;
`[13c] wherein the wireless transmit ter is configured for transmitting
`wireless data that contains inform ation present in or determined
`from wireless data that has been received by the wireless receiver;
`[13d] wherein the wireless network devi ce is configured for processing
`wireless data received by the wireless receiver,
`[13e] wherein the wireless network devi ce is configured for determining
`whether any, a portion, or all information in the processed wireless
`data should be transmitted by the wireless transmitter;
`[13f] wherein the wireless transmit ter is configured for transmitting
`wireless data through OFDM electr omagnetic signals that have a
`bandwidth greater than or equal to 100 MHz and less than or equal
`to 500 MHz; and
`[13g] wherein the wireless receiver is configured for receiving wireless
`data through OFDM electroma gnetic signals that have a
`bandwidth greater than or equal to 100 MHz and less than or equal
`to 500 MHz.
`14 The wireless network device of claim 13 wherein the wireless
`transmitter is configured for tr ansmitting wireless data through
`electromagnetic signals that have a bandwidth of 100 MHz.
`15 The wireless network device of claim 13 wherein the wireless
`transmitter is configured for tr ansmitting wireless data through
`electromagnetic signals that have a bandwidth of 160 MHz.
`16[pre] A wireless network device, comprisin g:
`[16a] a wireless transmitter that transmits wireless data through
`electromagnetic signals that have a bandwidth greater than or
`equal to 100 MHz and less than or equal to 500 MHz;
`[16b] a wireless receiver that receives wireless data through
`electromagnetic signals that have a bnadwidth greater than or
`equal to 100 MHz and less than or equal to 500 MHz;
`[16c] wherein the wireless transmit ter is configured for transmitting
`wireless data that contains inform ation present in or determined
`from wireless data that has been received by the wireless receiver;
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`Claim
`[16d] wherein the wireless network devi ce is configured for processing
`wireless data received by the wireless receiver,
`[16e] wherein the wireless network devi ce is configured for determining
`whether any, a portion, or all information in the processed wireless
`data should be transmitted by the wireless transmitter;
`[16f] wherein the wireless transmit ter is configured for transmitting
`wireless data through electroma gnetic signals that have a
`bandwidth greater than or equal to 100 MHz and less than or equal
`to 500 MHz at a data rate greate r than or equal to 100 megabits
`per second and less than or equal to 480 megabits per second; and
`[16g] wherein the wireless receiver is configured for receiving wireless
`data through electromagnetic si gnals that have a bandwidth
`greater than or equal to 100 MHz and less than or equal to 500
`MHz at a data rate greater than or equal to 100 megabits per
`second and less than or equal to 480 megabits per second.
`17 The wireless network device of claim 16 wherein the wireless
`transmitter and the wireless receiver are both part of a transceiver.
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`Petition for Inter Partes Review
`Patent 10,797,783
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`I. INTRODUCTION
`I, MARK MAHON, Ph.D. hereby declare as follows:
`1. My name is Mark Mahon. I have been retained to testify as an expert in
`this Inter Partes Petition on behalf of Samsung Electronics Co., Ltd. (“SEC”) and
`Samsung Electronics America, Inc. (“ SEA”) (collectively, “Samsung” or
`“Petitioner”).
`2. I have prepared this declaration in connection with Samsung’s related
`petition for inter partes review (“IPR”) of U.S. Patent No. 10,797,783 (the “’783
`patent,” EX1001), which I am informed is being filed concurrently with this
`declaration. I have been asked to provide certain opinions relating to the patentability
`of the ’783 patent. Specifically, I have been asked to provide my opinion regarding
`whether claims 1-17 of the ’783 patent (“ the Challenged Claims ”) are invalid as
`obvious in view of the prior art.
`II. QUALIFICATIONS
`3. I am over the age of 18 and am competent to write this declaration. I
`have personal knowledge, or have developed knowledge of these technologies based
`upon education, training, or experience, of the matters set forth herein.
`4. My qualifications are summarized here and explained in more detail in
`my curriculum vitae, which is attached as Appendix A to this report. Appendix A
`also includes a list of my publications a nd the cases in which I have testified at
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`deposition, hearing, or trial within the past four years.
`5. I am a Teaching Professor in the Sc hool of Electrical Engineering and
`Computer Science at Pennsylvania State Un iversity, University Park, PA (“Penn
`State” or “PSU”). I have worked on te lecommunications and wireless networks,
`including Z-Wave, Bluetooth, Zigbee, Wi-Fi, NFC, AMPS, IS-95, CDMA2000,
`GSM, EDGE, UMTS/WCDMA, LTE, and 5G cellular systems since 1988.
`6. I received my B.S. in Electronics Engineering from the University of
`Scranton in 1987. I received my M.S. in Electrical Engineering and Ph.D. in
`Acoustics from Penn State in 1991 and 2001, respectively.
`7. In 1988, after I received my bachel or’s degree, I joined the Central
`Intelligence Agency (CIA) while pursuing my M.S. degree at Penn State part-time.
`My first job at the CIA involved designi ng and testing systems to automatically
`capture and characterize telecommunicati on signals and emissions from various
`wireless and computer networking devices.
`8. I returned to Penn State in early 1990 to pursue graduate research full-
`time and complete my M.S. degree. My graduate research work focused on
`wideband beamforming and adaptive signal processing. After completing my M.S.
`degree in EE in 1991, I accepted a full-time faculty research position at the Applied
`Research Lab at PSU, primarily working on classified programs, and began working
`on diverse radio frequency and acoustic sensor systems including wireless
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`communications and small wireless netw orks for acoustic tracking, source
`localization, and feature extraction.
`9. I began pursuing my Ph.D. part-time in 1993 while continuing my
`faculty research position. In 1997, as part of my faculty research position, I began
`working on classified programs focused on mathematical analytical modeling of
`cellular communication networks and the de velopment of hardware and software
`systems to test against cellular networks. My role was to develop the algorithms and
`write the code running on a specially developed embedded system. For this work, I
`received a letter of recognition as the “genius behind the VELA software algorithms”
`from the Director of National Reconnaissa nce Office (NRO) Systems Engineering
`and Technology Office. As part of this same work, I was exte nsively involved in
`protocol and signaling analysis as well as researching model-specific performance
`and unique functional characteristics associated with individual mobile devices. The
`work involved testing dozens of handsets from many manufacturers in controlled
`and real-world environments against network simulators and live operational
`networks for each research project.
`10. In 2000, my research extended into utilizing non-orthogonal wavelets
`for improving detection a nd localization of cellular handsets from high altitude
`sensor systems. In 2001, I completed my Ph.D. and my research focused on the
`utilization of advanced communication si gnals for wideband characterization and
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`remote sensing of propagation channels.
`11. Beginning in 1997, my cellular communications research work focused
`on CDMA, GSM, EDGE, UMTS , LTE, and 5G cellular systems primarily under
`grants sponsored principally by the Department of Defense. This classified research
`work required 3GPP protocol analysis and development of real-time embedded
`hardware and software syst ems capable of interacting with cellular networks and
`cellular handsets. A large portion of my work was directed at architectures,
`protocols, software, and signaling.
`12. I have been working on classified projects since 1988. Before 1998,
`because the work was not deemed highly classified, I was able to publish eight
`journal and conference papers prior to 2000. Between 1999 and 2015, however, I
`was allowed to publish only one article in an unclassified symposium and published
`and presented about a dozen articles in classified settings. This is because during this
`period, the vast majority of my research was highly classified. As a result, nearly all
`of my research results were summarized in classified reports and not available to the
`general public. Further, because the U.S. government owns any intellectual property
`resulting from the sponsored research work , I did not pursue or file patent
`applications.
`13. Beginning in 2003, I was co-principal investigator and technical lead
`on a 3 year multi-million-dollar resear ch effort for developing the Global
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`Information Grid (GIG). This project wa s sponsored by the Secretary of Defense’s
`Office with a goal of developing a real- time, multi-intelligence (multi-Int) network
`for collecting, processing, storing, di sseminating, and managing information on
`demand for decision makers including the warfighter, combatant command centers,
`policy makers, and support pe rsonnel and was the larges t network-centric warfare
`project in development at the time. My research team (Ubiquitous Automated
`Information Manager) focused on building and deploying a scalable application to
`perform real-time, multi-int data fusion to support every user in the system. This
`software application was deployed in Combat Operation Centers, Joint Interagency
`Task Force locations, and on various platforms (mobile and small computing
`environments) used by various warfighters. The fused data sources included various
`content management systems, supply chain logistic reports, GPS-based reports, new
`feeds, backend databases, sensor system reports, and various other broad data
`sources.
`14. Beginning in 1994, I worked on various projects that involved the
`implementation and design of user interfaces to support the use of the research,
`design, analysis tools and signal processing systems for the end user. The user
`platforms included a broad array of foot prints including, small handheld devices
`with screens or visual displays and those limited to audio-only inputs, medium sized
`laptops and small desktop syst ems, and also large, heavy devices, such as servers
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`and clusters in operational environments (including combat operations centers and
`3D immersive environments).
`15. Specifically, for the GIG research e ffort, I led a team of software
`engineers to deploy our infe rencing tool for a disparate range of end users, from
`dismounted combat soldiers with only a mi crophone as an interface to soldiers in
`mules with smart devices (tablets and laptops with multiple visual display interaction
`capabilities) to field command centers (medium sized clients with significant video
`displays and processing power with touch and stylus interfaces to the ) to combat
`operation centers with high-powered processing and complex user-interface
`capabilities/modalities.
`16. In 2015, I transferred to the School of Electrical Engineering and
`Computer Science at Penn State as a teachi ng faculty member. In that role, I have
`continued teaching graduate and undergraduate courses, guiding Ph.D. and M.S.
`students in communication and mobile netw orking (including LTE and 5G cellular
`networks), and pursuing research in this and related areas. Since 2015, I have been
`an author on nine refereed papers as listed in my curriculum vitae (CV).
`17. Because of my decades of research and my continuing work at Penn
`State, I have intimate knowledge of te lecommunication networks, including the
`technology involved in the patents in this case. I have been highly recognized as an
`expert in such systems within the res earch community. I was recognized twice by
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`the National Reconnaissance Office with commendation letters for work dealing
`with detecting cellular signals in low si gnal to noise ratio environments. The U.S.
`government awarded me over $12M in gr ants between 2003 and 2015 for projects
`focused on mobile communication devices and networks, in which I served as a
`Principal Investigator (PI), Co- PI, and/or technical lead.
`18. Additionally, during my research caree r, I interacted extensively with
`computer scientists and e ngineers responsible for the design, development, and
`testing of telephony and data networking systems and testbeds. As a research faculty
`member, I oversaw engineers and computer scientists that executed many joint
`projects with development organizations. Th ese interactions exposed me to a wide
`range of computer scientists and engineers working on telecommunication network
`technologies. Since 2011, I have been teac hing undergraduate and graduate classes
`in communication and mobile networking a nd am familiar with the curricula being
`taught to electrical engineers and computer scientists. The interactions with a wide
`range of computer scientists and engineers working on telecommunication network
`technologies and the familiarity with the cl asses taught to electrical engineers and
`computer scientists have allowed me to have a good unde rstanding of the level of
`skills possessed by a person of ordinary skill in the field of cellular technology.
`19. I have extensive experience with m obile networks in general and LTE
`and 5G specifically. While most of my research efforts between 1998 and 2015 were
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`highly classified, I can state that they included detailed inves tigation of network
`architectures, signaling, and functional beha vior. A typical research effort would
`involve studying 3GPP, 3GPP2, IEEE, and other protocol standards to fully
`comprehend all aspects of L1, L2, and L3 requirements including timing, bit-level
`construction of the control and user plane messages, and timing characteristics for a
`given standard as well as functional be havior of network components and user
`equipment.
`20. From 2006 through 2015, my research focused specifically on LTE. My
`research continues to this day, although I am no longer operating in a classified
`environment. During this time, I inves tigated the performance and functional
`differences of many varied network and handset devices to see how differing
`signaling and hardware configurations (including MIMO) and environmental factors
`influenced the behavior of user equipmen t in a given network environment. This
`included how diversity techniques (transm it and receive), synchronization, timing,
`and signal to interference pl us noise ratio (SINR) for a given device would affect
`specific functional aspects including elements of the receiver structure, decoding and
`demodulation performance, calculation of parameters used by the device for making
`decisions and deriving parameters reported to the network.
`21. As part of my research work, I built several custom CDMA, GSM,
`UMTS, and LTE platforms that implemen ted specific network-side and user
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`equipment-side functionality including cu stom signal generation and processing
`structures, particularly the signal processing chains on both the transmit and receive
`sides. This equipment was developed us ing network simulation hardware in a
`laboratory environment and was later tested with corresponding networks in both
`controlled and fully opera tional environments. Implementing the transmit and
`receive chains for custom built protocol-e nabled equipment required me to gain an
`intimate understanding of the relevant 3GPP protocol specifications and the
`underlying structures. Since 2015, I have been primarily focused on guiding
`graduate students pursuing research incl uding using code domain non-orthogonal
`multiple access (NOMA) combined with MIMO sparse coding multiple access to
`minimize latency and maximize user density in grant free Internet of Things (IoT)
`environments. Additionally, I am guiding my graduate students in pursuing research
`in optimized distributed processing algorithms, implementation of block chain
`coding techniques to improve handover s ecurity, and edge computing resource
`allocation in 4G (LTE)/5G (NR) networks.
`22. Much of the classified research wo rk I performed also led to similar
`approaches for other wireless protocol s including IEEE 802.11 and 802.15 (e.g.,
`Zigbee, Bluetooth, and UWB), HART, and other short-range standards as well as
`HF radio and Wi-MAX.
`23. My curriculum vitae, included as an appendix to this declaration,
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`includes a list of publications on which I am a named author. It contains further
`details regarding my experience, education, publications, and other qualifications to
`render an expert opinion in connection with this proceeding.
`24. In writing this Declaration, I have considered the following: my own
`knowledge and experience, including my work experience in the fields of wireless
`communication networks, research and development of wireless signaling,
`protocols, transmission, and detection techniques, design a nd construction of
`wireless test equipment, pr ototypes, engineering models , and related areas; my
`experience in teaching those subjects; an d my experience in working with others
`involved in those fields, the materials c ited and/or referen ced throughout this
`Petition.
`III. LEGAL STANDARDS
`25. Counsel for Samsung has informed me of the following legal standards.
`I am not an attorney, and I am relying only on instructions from Samsung’s attorneys
`for these legal standards.
`A. Person of Ordinary Skill in the Art
`26. I understand that issues of clai m construction and invalidity are
`analyzed from the perspective of a person of ordinary skill in the art (“POSITA”).
`27. I understand that a POSITA is a hypot hetical person who is used to
`analyzing the prior art without the benefit of hindsight. A POSITA is presumed to
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`be one who thinks along the lines of conventional wisdom in the art.
`28. I understand that the hypothetical POSITA is presumed to have
`knowledge of all references that are suffic iently related to on e another and to the
`per