Apple, Inc. v. Motorola, Inc. et al
Filing
109
Declaration of Carlos A. Rodriguez filed by Defendants Motorola Mobility, Inc., Motorola, Inc. re: 95 Motion Requesting Claims Construction by Defendants. (Attachments: # 1 Exhibit 1 - Excerpts from Patent No. 6,275,983 Prosecution History, # 2 Exhibit 2 - Excerpts from Patent No. 6,212,575 Prosecution History, # 3 Exhibit 4 - July 4, 1011 Correspondence from Erwine to Haskett, # 4 Exhibit 5 - Excerpts from Patent No. 6,175,559 Prosecution History, # 5 Exhibit 6 - Excerpts from July 13, 2011 Deposition of Leonard Cimini, Ph.D., # 6 Exhibit 7 - Excerpts from American Heritage College Dictionary) (Hansen, Scott) Modified on 7/18/2011 (llj).
EXHIBIT 6
071311cimini (3).txt
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(In Re:
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(Testimony of:
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(Taken on:
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Apple, Inc. vs. Motorola, Inc)
Leonard Cimini, Ph.D.)
July 13, 2011)
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Unedited, uncertified rough draft
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THE VIDEOGRAPHER:
This is the
2
videotaped deposition of Dr. Leonard Cimini,
3
taken by the defendant in the matter of Apple,
4
Inc., and NeXT Software, Inc., a/k/a NeXT
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071311cimini (3).txt
Computer, Inc., plaintiffs and counterclaim
6
defendants, versus Motorola Inc. and
7
MotorolaMobility, Inc., defendants and
8
counterclaim plaintiffs, in and for the United
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States District Court for the Western District of
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Wisconsin, case number 10-CV-662.
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This deposition is being held at
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Morris Nichols Arsht & Tunnell, Wilmington,
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Delaware.
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2011, at approximately 11 a.m.
We're going on the record on July 13,
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The court reporter is Juli LaBadia
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from the firm of Wilcox & Fetzer, Wilmington,
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Delaware.
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videotape specialist of Discovery Video Services,
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in association with Wilcox & Fetzer.
My name is Lindsay DuPhily, I'm the
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Counsel will now introduce
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themselves and then the court reporter will swear
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in the witness.
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MR. WEINSTEIN:
I'm Marc Weinstein
of Quinn Emmanuel, representing Motorola.
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MR. HASLAM:
Bob Haslam, Covington &
Burling, representing Apple Inc. and NeXT.
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LEONARD CIMINI, Ph.D.
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The witness herein, having first been
5
duly sworn on oath, was examined and
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testified as follows:
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8
9
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DIRECT EXAMINATION
BY MR. WEINSTEIN:
Q.
Okay.
Thank you for coming this morning.
Could you just give me your full name and the
Page 2
071311cimini (3).txt
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spelling.
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A.
Leonard Cimini.
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Q.
And just confirm that you understand
14
Last name C-i-m-i-n-i.
you're under oath?
15
A.
Yes.
16
Q.
That this is no different than testifying
17
in front of the judge in a court?
18
A.
Yes.
19
Q.
And just to confirm, also, there's no
20
reason that you are impaired in any way this
21
morning in giving your testimony?
22
medication or anything that --
23
A.
No.
24
Q.
Okay.
There's no
Have you been deposed before?
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Unedited, uncertified rough draft
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things that you have researched, and worked on.
2
First, can you just tell me a little bit about
3
your Ph.D.?
4
A.
What was the focus of that?
My Ph.D. was on -- in the broad sense,
5
detection and estimation theory.
And it was
6
specifically on robust detection and estimation.
7
So, the gist of that is that you try to -- when
8
you design a system, you don't actually know what
9
the environment is like.
You make a guess.
And
10
if you design your system based on your guess,
11
you're often quite wrong.
12
degrades rapidly.
13
14
And the system
So, you design it based on sort of a
class of guesses.
15
Q.
Okay.
16
A.
And that's what my -- it was mainly on the
Page 3
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071311cimini (3).txt
title, it doesn't sound like that. It's sum
18
results and quantization in filtering and
19
detection.
20
21
Q.
And your first job after getting your
Ph.D. was with AT&T?
22
A.
Yes.
23
Q.
And please tell me the things you, in your
24
initial role there, what are the things you
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Unedited, uncertified rough draft
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2
worked on?
A.
My -- I worked in a group that did
3
cellular systems engineering.
4
This is before
there were cellular systems.
5
Q.
And the timing of that was?
6
A.
April, 1982.
7
Q.
Okay.
8
9
And what did you do for cellular
systems engineering?
A.
My -- my job, I worked in a
10
forward-looking radio group.
11
wireless.
We didn't call it
It was radio then.
12
Q.
Uh-huh.
13
A.
And my job was next generation cellular.
14
So we didn't have a first, but mine was the next,
15
which would be digital cellular.
16
to determine what modulation techniques should be
17
used.
18
and proposed that for the next generation.
And my job was
So I worked on a technology called OFDM,
19
Q.
Can you explain OFDM.
20
A.
So, OFDM is what's used in Wi-fi in 802.11
21
22
today.
Q.
Uh-huh.
Page 4
23
A.
071311cimini (3).txt
And in many systems.
24
Q.
What other systems is it used in?
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Unedited, uncertified rough draft
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A.
WiMax.
WiMax is sort of a smaller
2
distance cellular type system that's popular
3
especially in Korea.
4
for broadband.
It's called WiBro there,
5
Q.
Uh-huh.
6
A.
And the main problem with transmitting at
7
higher bit rates is the fact that the signal gets
8
to the destination by multiple paths.
9
arrives, it has spread your pulse, because they
10
So when it
arrive at different times, these different paths.
11
Q.
Uh-huh.
12
A.
And so, what happens is your pulse spreads
13
into the next pulse.
14
interference.
15
transmitting at higher bit rates.
16
This is called inner symbol
And that's the main limitation in
So, what OFDM does, is it's
17
essentially the same as saying if I have a wire
18
that allows me to transmit one megabit per
19
second.
20
Q.
Uh-huh.
21
A.
If I want to transmit 10 megabits per
22
second, I take 10 wires and I put them together.
23
And that's what OFDM is.
24
not wires.
Except the wires are
They're frequencies.
They're
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frequency bands.
So OFDM stands for orthogonal
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frequency division and multiplexing.
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it couldn't be built, even at very low rates.
Page 5
And in 1982
071311cimini (3).txt
4
And so, we -- we gave up on that
5
technology.
Until the late '80s and early '90s,
6
when DSP technology progressed enough that we
7
could build it.
8
Q.
And that's digital signal processing?
9
A.
Yes.
10
11
1982 digital signal processors were
very, very new.
Q.
Okay.
And so, this was done in
12
development throughout the early, mid, and late
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'80s?
14
A.
That was from 1982 to 1985.
15
Q.
Okay.
16
A.
And then in 1985, I moved to the research
17
area at Bell Labs, and worked on fiberoptic
18
communications for five years.
19
And then in 1990, I went back to
20
working on radio wireless systems.
Both
21
cellular -- at that point, it would be 3G
22
systems.
23
Q.
Uh-huh.
24
A.
Although they weren't called that then,
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Unedited, uncertified rough draft
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either.
And in building systems, you know,
2
wi-fi, 802.11 type systems.
3
2002 when AT&T downsized, and I came to the
4
University of Delaware.
And I did that until
5
Q.
And in the U.S., what systems use OFDM?
6
A.
80 -- the initial one was 802.11A.
But
7
802.11, the current version, 802.11G, 802.11N,
8
and the newer systems, which will come out later,
9
802.11AC.
They all use OFDM and WiMax, which is
Page 6
071311cimini (3).txt
10
802.16.
802.16.
I don't know how many WiMax
11
systems are deployed in the United States.
12
Q.
And is OFDM used for any other?
13
A.
OFDM is part of the third --
14
Q.
That's what --
15
A.
-- generation cellular systems.
16
for the down link.
17
the mobile units.
18
19
Q.
Okay.
But only
So, from the base station to
And only in some forms of it.
And then you've now been at
Delaware since '92 as a professor?
20
A.
2002.
21
Q.
2002.
22
A.
Yes.
23
Q.
Is and what other topics that you teach?
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A.
Mostly communications.
So I teach a
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Unedited, uncertified rough draft
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graduate course in digital communications.
I
2
teach an undergraduate course, senior level, in
3
communication systems.
4
level course that's called signals and systems.
5
It's the basic -- what are called linear time and
6
variance systems.
And I teach a sophomore
7
Q.
I'm familiar with that course.
8
A.
Okay.
9
Q.
Yes.
10
A.
It's a required course.
11
Q.
Yes.
12
Everyone has to take that course.
Okay.
Is there any cellular system
around the world that uses OFDM?
13
A.
Not at the present time.
14
Q.
Okay.
15
I'd like to introduce as Cimini
Exhibit Number 2, this is -- sorry.
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071311cimini (3).txt
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17
(Cimini Exhibit 2 marked for
identification)
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19
MR. HASLAM:
thanks.
20
21
22
I've got a copy,
MR. WEINSTEIN:
Okay.
You bet.
BY MR. WEINSTEIN:
Q.
This is Dr. Cimini's declaration that was
23
submitted as part of Apple's opening claim
24
construction brief.
Okay.
If you would turn to
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Unedited, uncertified rough draft
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page 2.
2
A.
Yup.
3
Q.
In paragraph 9, you said in preparing this
4
declaration, I have extensively reviewed various
5
materials, including the '559 patent and its file
6
history.
7
that you referred to?
8
9
A.
Can you tell me what other materials
For this dec -- for making this
declaration?
10
Q.
Yes.
11
A.
Just the '559 patent and its file history.
12
Q.
So if the -- any statement that you've
13
made in the declaration, if it was not from the
14
'559 patent or the file history, was it just
15
based on your general knowledge?
16
A.
Yes.
17
Q.
So there were no other technical papers or
18
books or documents that you?
19
A.
Not in writing this declaration.
20
Q.
Were there any discussions you had with
21
other professors or engineers in helping to
Page 8
071311cimini (3).txt
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prepare the dec?
23
A.
No.
24
Q.
Did you, in fact, write the declaration
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2
3
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yourself?
A.
The Covington attorneys and I wrote the
patent -- wrote the declaration together.
Q.
Okay.
In paragraph 10, you say the '559
5
patent is directed to the field of wireless
6
telecommunication systems, and that addresses the
7
problem of multiple cellular telephones trying to
8
communicate with the same base station in the
9
cellular network at the same time.
10
11
12
13
On what basis do you make that
statement?
A.
From the description and specification of
the patent.
14
Q.
And could you point -- oh.
15
A.
I don't have --
16
Q.
Before we do that.
17
A.
Yeah.
18
Q.
Let me introduce as Cimini Exhibit Number
Yes.
19
3, this is U.S. patent number 6,175,559.
20
Tyler Brown.
21
To
(Cimini Exhibit 3 marked for
22
identification)
23
BY MR. WEINSTEIN:
24
A.
Yeah.
Thank you.
Were you waiting for my
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Unedited, uncertified rough draft
1
answer?
Page 9
071311cimini (3).txt
2
Q.
Yes.
3
A.
Okay.
4
Sorry.
So, in -- in column 1,
around line 15 --
5
Q.
Uh-huh?
6
A.
Because multiple mobile stations may be
7
8
9
10
trying to access the channel simultaneously.
Q.
Okay.
And just to step back a bit.
In
preparing for today, did you review the 559
patent again?
11
A.
Yes.
12
Q.
And when did you do that?
13
A.
Yesterday, and Sunday.
14
Q.
And were there any other materials that
15
16
17
you used in preparing?
A.
Yes.
I looked at -- I looked at several
of the other patents that I had.
18
Q.
Several other patents?
19
A.
I can't remember all the numbers.
20
Q.
Several other patents related to this
21
patent?
22
A.
Related to this one.
23
Q.
Anything else?
24
Any other technical
documents?
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Unedited, uncertified rough draft
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A.
No.
2
Q.
Did you refer to any --
3
A.
Oh, wait.
4
5
6
7
Yes.
The 3GPP.
Some of the
3GPP documents.
Q.
Did that include the -- I'm sorry.
TS25.213 standard?
A.
Yes.
Page 10
A 3GPP
8
9
Q.
Okay.
071311cimini (3).txt
So, and the next line in paragraph
10, it says, "When a new cellular telephone
10
enters a cell, it must notify the base station of
11
its presence so that it can begin to send and
12
receive data on the network.
13
telephone transmits a choice signal called a
14
preamble to allow the base station to detect its
15
presence."
16
The new cellular
So from the time that a cell phone
17
enters a cell to the time that it actually
18
transmits the preamble sequence, can you explain
19
what steps take place?
20
21
A.
Not exactly.
So I can tell you in general
terms.
22
Q.
Okay.
23
A.
So when you're -- when you have your cell
24
phone and you're in a -- in an area, you're in
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Unedited, uncertified rough draft
1
Wilmington.
2
Q.
Uh-huh.
3
A.
You turn your phone on.
Your phone
4
immediately makes contact with the cellular
5
system, trying to find the nearest base station.
6
So that's all part of the initial process.
7
knowing where you are, first of all.
8
Q.
Okay.
9
A.
Just
But the process where now you have
10
something to send is slightly different than --
11
this is more about the mobile station initiating,
12
you know, communications with the base station.
13
Q.
Such as making a phone call?
Page 11
14
15
A.
071311cimini (3).txt
Such as making a phone call, a text,
anything.
16
Q.
Right.
17
A.
And so, what you need is you need some
18
information that needs to be exchanged with the
19
base station, that one, allows the base station
20
to know you're there, and to do synchronization.
21
And that's what this short preamble is for.
22
So this would happen almost
23
immediately when you have something to send.
24
general terms.
In
I can't tell you exactly how -17
Unedited, uncertified rough draft
1
Q.
Okay.
2
A.
-- 3G operates or even a 2G system.
3
Q.
Okay.
So before the preamble is actually
4
sent, are there steps, are there any other
5
communications that occur between the mobile
6
station and the base station?
7
A.
I don't know how each system operates, but
8
in the older cellular systems, so if we go back
9
to the 2G, what happened is as soon as you
10
were -- your phone is turned on, with nothing to
11
transmit, there's essentially something that
12
would be -- you can call a beacon, that allows
13
the station to -- to know where you are, within
14
which cell you are.
15
16
17
Q.
So the beacon is from -- from which to
which?
A.
From the mobile station to -It would be from the base station to the
18
mobile.
Setting up sort of a handshaking, to say
19
yes, I know you're there.
Page 12
071311cimini (3).txt
But in the newer systems, that might
20
21
22
23
24
not be necessary.
Q.
I'm not sure.
So in the newer system -- I'm sorry.
So
for 3G it might not -A.
It might not be necessary.
But I can't
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2
say.
Q.
Okay.
Then the last line is that the base
3
station then transmits to the new cellular
4
telephone a unique identifying value that the new
5
cellular telephone uses in future transmissions.
6
Can you explain, what is the unique identifying
7
value?
8
9
A.
So, the unique identifying value depends
on the system, all right.
10
it's a CDMA system.
11
So let's assume that
So either -- either 2G or
the newer 3G.
12
Q.
Uh-huh.
13
A.
So what the base station would have to
14
tell the cell -- the cell phone is how that --
15
how to communicate so that the base station can
16
distinguish it from other users, and the mobile
17
station is transmitting to the correct base
18
station.
19
Q.
Okay.
20
A.
So this identifying value could be a code,
21
if it's a CDMA system.
22
would operate for CDMA.
23
24
Q.
Okay.
And that's how 2G and 3G
And the code, is the code actually
sent from the base station to the mobile station?
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Unedited, uncertified rough draft
Page 13
071311cimini (3).txt
1
A.
The code is actually sent from the --
2
okay.
3
actual code is sent.
4
station sends to the mobile station an index, so
5
the mobile station has a table where the code --
6
say index 7 means this code.
So I should back up.
7
I'm not sure if the
It could be that the base
Or it could be, actually send, if
8
it's being done by some circuitry that's
9
generating the code, it can tell it the -- the
10
weights on the -- on the shift register.
11
I don't
know how it's actually done.
12
Q.
Okay.
13
A.
In the newer systems.
14
Q.
Okay.
15
A.
Okay.
16
Q.
Because many new cellular telephones often
Let's move on to paragraph 11.
17
enter a cell at the same time, multiple new
18
cellular telephones may try to transmit preambles
19
to the base station at the same time.
20
was the basis for that statement?
21
A.
And what
So, let me see if I can find the line.
22
Right.
So, this comes from -- you can go the
23
same line we read before, because multiple mobile
24
stations may be trying to access the channel
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Unedited, uncertified rough draft
1
simultaneously.
2
to many users -- multiple new cellular telephones
3
might try to transmit the preamble to the base
4
station at the same time.
5
simultaneously.
6
Q.
Uh-huh.
All right.
So that corresponds
So that comes from
And then the following statement,
Page 14
071311cimini (3).txt
7
the base station must be able to distinguish the
8
different preambles.
9
A.
Right.
So this -- this comes from reading
10
the patent, but basically, also general
11
knowledge, right?
12
have multiple users all trying to access the
13
channel at the same time, you need a way to
14
separate them.
So if you need to -- if you
15
Q.
Okay.
16
A.
Otherwise they just look like one blob of
17
noise to the base station.
18
needs to be able to separate these.
19
20
Q.
Okay.
So the base station
And the '559 patent, you're saying,
is directed to CDMA?
21
A.
Yeah.
That's what it says.
22
Q.
Okay.
And is it -- is the '559 patent
23
also applicable to other forms of cellular
24
systems?
21
Unedited, uncertified rough draft
1
A.
No.
2
Q.
Okay.
In paragraph 12, you get into doing
3
some background on CDMA systems.
The second
4
sentence, CDMA allows multiple cellular
5
telephones to use the same physical communication
6
channel.
7
A.
Can you explain what that means?
So, the -- you need to separate users in
8
some way.
And so, you can separate them in time
9
or frequency.
So that means users use different
10
times, so you get a turn and I get a turn.
Or
11
use different frequencies, which is the way the
12
oldest systems operated. Or there's another way,
Page 15
071311cimini (3).txt
13
where you can use the same time and the same
14
frequency, but each user is assigned a different
15
code.
16
And ideally, these codes are
17
orthogonal.
So that at the destination, at the
18
base station, each user has a different code.
19
The base station correlates with each of these
20
codes, and separates the users.
21
allowed to use the same frequency channel at the
22
same time.
23
(Phone beeps)
24
MR. WEINSTEIN:
So they're
Excuse me.
22
Unedited, uncertified rough draft
1
Q.
In the last clause, it says "Without
2
significant interference by encoding transmitted
3
data, using a code that is unique to that
4
cellular telephone, and that can be distinguished
5
from the codes of all cellular -- all other
6
cellular telephones."
7
code you were talking about before?
8
9
10
11
12
13
A.
Yes.
Is that the same unique
I -- in the previous explanation, I
actually answered, you know, explained the next
sentence.
Q.
Okay.
So that's after the preamble has
been sent?
A.
Well, it's a combination, right?
So
14
there's two -- there's two features to a
15
communication system, right?
16
synchronization access, and then there's actual
17
transmission of data.
18
Q.
Okay.
Page 16
There's the
071311cimini (3).txt
19
20
A.
So the code would be used in -- a code
would be used in both cases.
21
Q.
Okay?
22
A.
But it's in a -- in the preamble part,
23
you're going to separate users to start access to
24
the channel.
In the -- once you have access,
23
Unedited, uncertified rough draft
1
then the actual data communication occurs,
2
potentially with a different code.
3
how the system is designed.
4
5
6
7
Q.
Okay.
It depends on
And in the CDMA, is that the same
code or different codes?
A.
CDMA -- stands for code division multiple
access.
8
Q.
Right.
9
A.
It simply means that each user has a
10
different code.
11
Q.
That would be --
12
A.
In order to access the channel.
13
14
In order
to transmit data.
Q.
Right.
The code used for the preamble,
15
and then the code used for later messaging, is
16
that the same code or different code in CDMA?
17
18
A.
It could be either.
In the simplest case,
it would be the same.
19
Q.
All right.
20
A.
But --
21
Q.
Can you explain to me, I know if you give
22
me some background on it, but what are the
23
primary differences between CDMA and OFDM/FDMA?
24
A.
Okay.
So -Page 17
071311cimini (3).txt
24
Unedited, uncertified rough draft
1
MR. HASLAM:
I'm going to let him
2
answer that, but I'm going to object on the
3
relevance of that.
4
discussed in his declaration, and that's what
5
we're here to talk about.
6
It's not a topic that's
MR. WEINSTEIN:
7
Q.
Please answer.
8
A.
Okay.
Well -- okay.
9
So, FDMA means I separate users by
different -- each user uses a different
10
frequency.
11
for example, which was analog, called amps, used
12
a separate frequency.
13
frequency, and you kept it forever.
14
frequency channel was yours.
15
your -- when you pick up a wired telephone.
16
get that wire, and that wire is yours and no one
17
else uses it.
18
So the very first cellular system is,
So you were given a
That
That's similar to
You
In -- in TDMA, we all use the same
19
wire, but we share it.
20
then you use it.
21
all use it at the same time, but we all use a
22
different code.
23
24
So I use it first, and
In CDMA, we all use the wire,
OFDM is not the same class.
not an access technology.
It's
OFDM is a modulation
25
Unedited, uncertified rough draft
1
technique that permits you to transmit at higher
2
bit rates.
3
And it could apply to all three systems.
4
TDMA or FDMA.
So it applies to one user at a time.
Page 18
CDMA,
5
Q.
Okay.
6
in CDMA?
7
A.
071311cimini (3).txt
So, I'm sorry. So OFDM can be used
Yeah, it can.
There remember plenty of
8
technologies that are called multi carrier CDMA,
9
that look very much like OFDM.
10
Q.
And those are used in the U.S.?
11
A.
I don't know.
The 3G technologies, some
12
of the original 3G proposals were multi carrier
13
CDMA, but I don't know how much of it is actually
14
being -- going to be deployed, or even considered
15
in the future.
16
Q.
Okay.
I'd like to enter as -- this is now
17
Cimini Exhibit Number 4.
18
of Dr. Cimini's publications.
19
And this is just a list
(Cimini Exhibit 4 marked for
20
identification)
21
BY MR. WEINSTEIN:
22
Q.
And this is a publication list that comes
23
from the University of Delaware's website that's
24
linked to your bio.
26
Unedited, uncertified rough draft
1
A.
Okay.
Yeah.
2
Q.
And this and lists your journal articles.
3
Also conference papers, your patents, and your
4
books.
Books is on -- I guess it's page 6.
5
A.
Page 6.
6
Q.
No, I'm sorry.
7
It's not there.
and on the very last page.
Page 8.
8
A.
Yes.
9
Q.
Okay.
10
A.
They're just book chapters.
Page 19
I'm sorry
11
Q.
071311cimini (3).txt
Those are just book chapters?
12
A.
Yes.
13
Q.
And do any of those book chapters relate
14
to CDMA?
15
A.
No.
16
Q.
And in this, there are 50 journal articles
17
listed.
18
OFDM.
19
A.
20
I guess the majority are relating to
Do any of them relate to CDMA?
I'm sorry, I'm trying -- I'm looking
through it --
21
Q.
Sure.
22
A.
-- to see if there are.
23
24
No.
I don't -- I
don't believe so.
Q.
Okay.
And is that also the case for
27
Unedited, uncertified rough draft
1
the -- the conference papers?
2
A.
I would think so.
3
Q.
There's quite a few more.
4
A.
Yes.
5
Q.
And just also to confirm, also, for your
6
patents?
7
A.
No.
8
Q.
So, in -- in providing the overview of
9
10
11
No CDMA.
CDMA, how -- on what basis do you -- are you able
to discuss it?
A.
CDMA is a well-known technology, and
12
it's -- it's well developed already in textbooks.
13
And I've worked in cellular, and wi-fi for almost
14
30 years, so I've developed a background where I
15
understand these.
16
short courses that covered CDMA.
And I've taught courses and
Page 20
17
Q.
Okay.
071311cimini (3).txt
And returning to your declaration,
18
in paragraph 13, you said the basic unit of
19
information transmitted over CDMA is called a
20
chip.
21
A.
Can you explain the meaning of a chip?
In the -- in the fundamental principle of
22
CDMA that allows it to -- to work, is that what
23
you do is you take a given user or information
24
symbols from the user, information from the user,
_____________________________________________________________________
88
Unedited, uncertified rough draft
1
code, what do you mean that it's used to perform
2
signal separation?
3
4
5
A.
That's to determine which base station --
you know, which base station you're talking to.
Q.
So this is -- when you mean signal
6
separation, you mean that the base station knows
7
it's supposed to receive it or it's --
8
9
A.
No.
This doesn't have anything to do with
whether it's supposed to receive it or not.
It
10
just has a code that's -- that identifies the --
11
that particular base station.
12
for -- you're a base station.
So it knows it's
13
Q.
Right.
14
A.
You know this is for you, as opposed to
15
16
17
for another base station.
Q.
Right.
That's what I intended to say, is
that --
18
A.
Oh, okay.
19
Q.
So the base station knows when it's
20
receiving a signal from a mobile station -- the?
21
A.
That's for itself.
22
Q.
It knows it's for the base station?
Page 21
071311cimini (3).txt
23
A.
Yes.
Yes.
24
Q.
To put it again, so to tell the base
89
Unedited, uncertified rough draft
1
station that is signal is indeed intended for it?
2
A.
Okay.
3
Q.
Okay.
4
5
identify.
A.
And the inner code to uniquely
What's the -- can you explain that?
Each mobile station then would have its
6
own -- the each mobile station within that base
7
station's cell area would have its own
8
identifying code.
9
Q.
And in choosing that code, is that based
10
on information it receives from the base station?
11
The inner code.
12
A.
The inner code is chosen based on -- this
13
again gets back to that other question we talked
14
about.
15
codes assigned in some way to mobile stations, or
16
are they given to the mobile stations when they
17
make this handshaking.
18
19
Q.
Is the -- the other issue.
Right.
Are these
And that's just something you're
not sure about?
20
A.
Something I'm not sure about.
21
Q.
Okay.
So, I know you're unsure, but
22
it's -- we were saying it's possible, then, that
23
the base station sends information to tell a
24
mobile station use this particular outer code, or
90
Unedited, uncertified rough draft
1
one of these particular outer codes, and then
2
also use one of these particular inner codes?
Page 22
3
A.
So wait.
071311cimini (3).txt
That's different from the
4
question you just asked me a minute ago.
5
minute ago you asked about the inner code.
6
Q.
Yes.
7
A.
Right.
A
8
So the inner code is specific for
each mobile.
9
Q.
Right.
10
A.
So in that case, somehow the mobile must
11
know what its code is.
12
in the mobile unit itself, or it's sent by the
13
base station.
14
So, it either is embedded
The outer code is something
15
different.
The outer code is something which is
16
common to everybody in the cell.
17
station, you know, is -- is broadcasting this all
18
the time, for example.
So the base
19
Q.
Uh-huh.
20
A.
And everybody's just listening to what it
21
is, and then it feeds it back if it hears it.
22
Right?
It's -- it's like an identifier.
23
Q.
Right.
24
A.
-- of that base station.
91
Unedited, uncertified rough draft
_____________________________________________________________________
100
Unedited, uncertified rough draft
1
and the codes didn't match, you wouldn't be able
2
to decode it.
3
I'm -- if I had the correct one, I would decode
4
my -- I would be able to detect my -- if I had
5
the one that's for me, and I know it's for me,
6
then all of the others, I don't decode those, but
Page 23
So what that means is that I -- if
071311cimini (3).txt
7
they become zero -- you know, like zero
8
background noise to me.
9
intended to mean.
That's what this is
10
Q.
Okay.
11
A.
Flipped it the other way, it means I only
12
can detect the one that's using the correct outer
13
code.
14
Q.
Okay.
15
A.
That makes a better -- maybe a better way
16
17
18
That makes sense.
to say this.
Q.
Right.
It -- the I think that sentence
just kind of takes the next step leap, without --
19
A.
It's okay.
20
Q.
-- making it's clear that it's --
21
A.
I understand.
22
Q.
It states it's not correlating it, because
23
it's not correlating it, it can't decode it
24
correctly.
101
Unedited, uncertified rough draft
1
A.
Right.
2
Q.
The next line the '559 patent suggests to
3
use gold and Kasami codes to form the outer code.
4
How does the -- well, start with the example of
5
using a common one, where each -- where there's
6
only one outer code for the base station.
7
A.
Uh-huh.
8
Q.
How does -- or let me -- what is in the
9
mobile station that enables it to generate the
10
same code as all the other mobile stations in
11
the -- in that cell?
12
A.
I can't tell you exactly how it's
Page 24
071311cimini (3).txt
13
happening in 3GPP.
14
Gold code, for example, or a Kasami, because
15
these come from actual shift -- actual length
16
shift register sequences.
17
register to generate it.
18
information you really need to transmit is how
19
long the code is or how many shift register --
20
shift registers you need.
21
usually sort of a generator that tells them how
22
to make the connections.
23
the Gold code in one transmission.
24
Q.
But what I would do with a
So you use the shift
You tell the -- only
And there's also
And that would generate
What do you mean by a generator to make
102
Unedited, uncertified rough draft
1
the connections?
2
A.
It -- a shift register.
3
Q.
Uh-huh.
4
A.
Okay?
5
So a shift register has a bunch of
boxes which are essentially delays.
6
Q.
Right.
7
A.
And then there are connections, there are
8
feedback connections, and feed forward
9
connections.
10
Q.
Uh-huh.
11
A.
And it tells them how to make these
12
connections.
Which ones are connected.
13
there's four boxes, do you add the output of 1
14
and 2 or do you add the output of 1 and 3 or do
15
you add the output of 1, 2, and 3.
16
connections are part of what's called the
17
generator equation for this.
18
generates the code.
Page 25
So if
Those
And that's what
071311cimini (3).txt
19
This is true for all pseudo random
20
sequences.
There's a standard diagram, and these
21
connections are specified.
22
specify the connections, and how many of these
23
shift registers there are, you can generate any
24
pseudo random sequence.
So if you simply
Any M sequence.
133
Unedited, uncertified rough draft
1
A.
Under the way you just defined it, no.
2
Q.
So --
3
A.
Let me -- can I repeat it because I'm not
4
sure I understood.
5
Q.
Yes.
6
A.
So, a symbol is defined as 8 chips.
7
Q.
Yes.
8
A.
And you want the outer code to be 9 chips
9
long.
10
Q.
Repeating at 9 chips, rather than 8 chips.
11
A.
Right.
So then you asked -- okay.
The
12
relationship between -- so it's not an integer
13
number of symbols.
14
Q.
Okay.
Yes.
In that situation, would an outer code of
15
9 chips fall within the scope of claim 1, but not
16
within the scope of claim 2?
17
A.
Yes.
If claim 1 is meant to be anything,
18
it doesn't have to have that particular period.
19
Yes.
20
Q.
Okay.
21
A.
They would be different.
22
23
24
MR. HASLAM:
I have no further
questions.
THE VIDEOGRAPHER:
Page 26
This deposition
071311cimini (3).txt
134
Unedited, uncertified rough draft
1
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sending at approximately 1:47 p.m.
(Deposition concluded at 1:47 p.m.)
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