WI-LAN Inc. v. Alcatel-Lucent USA Inc. et al

Filing 167

OPENING CLAIM CONSTRUCTION BRIEF filed by WI-LAN Inc.. (Attachments: # 1 Affidavit DECLARATION OF JEFFREY T. HAN IN SUPPORT OF WI-LANS OPENING CLAIM CONSTRUCTION BRIEF, # 2 Exhibit A-U.S. Patent No. 6,088,326, # 3 Exhibit B-U.S. Patent No. 6,195,327, # 4 Exhibit C-U.S. Patent No. 6,222,819, # 5 Exhibit D-U.S. Patent No. 6,381,211, # 6 Exhibit E-copy of The IEEE Standard Dictionary of Electrical and Electronics Terms (6th ed. 1996), # 7 Exhibit F-copy of Alan Freedman, The ComputerGlossary (7th ed. 1995), # 8 Exhibit G-copy of Harry Newton, Newtons Telecom Dictionary (11th ed. 1996), # 9 Exhibit H-copy of Ramjee Prasad, CDMA for Wireless Personal Communications (1996), # 10 Exhibit I-copy of Theodore S. Rappaport,Wireless Communications (1996), # 11 Exhibit J-copy of Shing-Fong Su, The UMTS Air-Interface in RF Engineering (2007), # 12 Exhibit K-copy of 3GPP TS 25.211,v.6.10.0 (Release 6), # 13 Exhibit L-copy of Jean Conan & Rolando Oliver, Hardware and Software Implementation of the Viterbi Decoding Algorithm for Convolutional Codes, in MIMI 76: Proceedings of the International Symposium on Mini and Micro Computers (M.H. Hamza ed., 1977), # 14 Exhibit M-Definition of Overlay, OxfordDictionaries Online, http://oxforddictionaries.com/definition/overlay?q=overlay, # 15 Exhibit N-copy of the Manual of Patent Examining Procedure (6th ed. rev. 3, July 1997))(Weaver, David)

IN THE UNITED STATES DISTRICT COURT
FOR THE EASTERN DISTRICT OF TEXAS
TYLER DIVISION
WI-LAN INC.,
Plaintiff,
v.
ALCATEL-LUCENT USA INC.;
TELEFONAKTIEBOLAGET LM
ERICSSON; ERICSSON INC.; SONY
ERICSSON MOBILE COMMUNICATIONS
AB; SONY ERICSSON MOBILE
COMMUNICATIONS (USA) INC.; HTC
CORPORATION; HTC AMERICA, INC.;
EXEDEA INC.; LG ELECTRONICS, INC.;
LG ELECTRONICS MOBILECOMM U.S.A.,
INC.; LG ELECTRONICS U.S.A., INC.
Defendants.

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Civil Action No. 6:10-cv-521-LED
JURY TRIAL DEMANDED

DECLARATION OF JEFFREY T. HAN IN SUPPORT OF
WI-LAN’S OPENING CLAIM CONSTRUCTION BRIEF

I, Jeffrey T. Han, do hereby declare as follows:
1.

I am an attorney with Vinson & Elkins, LLP, and one of the attorneys representing WiLAN Inc. (“Wi-LAN”) in the above-captioned action.

2.

Attached hereto as Exhibit A is a true and correct copy of U.S. Patent No. 6,088,326.

3.

Attached hereto as Exhibit B is a true and correct copy of U.S. Patent No. 6,195,327.

4.

Attached hereto as Exhibit C is a true and correct copy of U.S. Patent No. 6,222,819.

5.

Attached hereto as Exhibit D is a true and correct copy of U.S. Patent No. 6,381,211.

6.

Attached hereto as Exhibit E is a true and correct copy of The IEEE Standard Dictionary of
Electrical and Electronics Terms (6th ed. 1996), as abridged and produced by Defendants
and Bates numbered DEFS0011211 – DEFS0011216.

7.

Attached hereto as Exhibit F is a true and correct copy of Alan Freedman, The Computer
Glossary (7th ed. 1995), as abridged and produced by Defendants and Bates numbered
DEFS0011157 – DEFS0011161.

8.

Attached hereto as Exhibit G is a true and correct copy of Harry Newton, Newton’s
Telecom Dictionary (11th ed. 1996), as abridged and produced by Defendants and Bates
numbered DEFS0011198 – DEFS0011202.

9.

Attached hereto as Exhibit H is a true and correct copy of Ramjee Prasad, CDMA for
Wireless Personal Communications (1996), as abridged and produced by Defendants and
Bates numbered DEFS0011193 – DEFS0011197.

10.

Attached hereto as Exhibit I is a true and correct copy of Theodore S. Rappaport,
Wireless Communications (1996), as abridged and produced by Defendants and Bates
numbered DEFS0011162 – DEFS0011169.

11.

Attached hereto as Exhibit J is a true and correct abridged copy of Shing-Fong Su, The
UMTS Air-Interface in RF Engineering (2007), previously produced by Wi-LAN and Bates
numbered WIL-0192767 – WIL-0192770.

12.

Attached hereto as Exhibit K is a true and correct abridged copy of 3GPP TS 25.211,
v.6.10.0 (Release 6), previously produced by Wi-LAN and Bates numbered WIL0001837 – WIL-0001845.

13.

Attached hereto as Exhibit L is a true and correct copy of Jean Conan & Rolando Oliver,
Hardware and Software Implementation of the Viterbi Decoding Algorithm for

2

Convolutional Codes, in MIMI 76: Proceedings of the International Symposium on Mini
and Micro Computers (M.H. Hamza ed., 1977), Bates numbered WIL-0192844 – WIL0192852.
14.

Attached hereto as Exhibit M is a true and correct copy of Definition of Overlay, Oxford
Dictionaries Online, http://oxforddictionaries.com/definition/overlay?q=overlay, as produced
by Defendants and Bates numbered DEFS0011210.

15.

Attached hereto as Exhibit N is a true and correct abridged copy of the Manual of Patent
Examining Procedure (6th ed. rev. 3, July 1997), obtained from the website of the U.S.
Patent and Trademark Office and Bates numbered WIL-0192853 – WIL-0192858.

16.

I declare under penalty of perjury under the laws of the United States that every statement
contained in this declaration is within my personal knowledge and is true and correct.

Executed on this 16th day of March, 2012.

/s/ Jeffrey T. Han
Jeffrey T. Han

US 1315658v.1

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