EXHIBIT 15 

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IN THE UNITED STATES DISTRICT COURT

FOR THE EASTERN DISTRICT OF TEXAS 

MARSHALL DIVISION

XR COMMUNICATIONS, LLC, dba 

VIVATO TECHNOLOGIES, 

 Plaintiff, 

vs. 

AT&T SERVICES INC., ET AL., 

 Defendants. 

ERICSSON, INC. ET AL., 

 Intervenors. 

 Case No. 2:23-cv-00202-JRG-RSP 

 (LEAD CASE)

 JURY TRIAL DEMANDED 

DECLARATION OF JAMES A. PROCTOR

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I, James A. Proctor, Jr., declare as follows: 

1. I have been asked to provide an opinion concerning certain language that appears 

in U.S. Patent Nos. 7,177,369 (the “’369 Patent”) and 8,289,939 (the “’939 Patent”). I understand 

that Plaintiff has also asserted U.S. Patent Nos. 8,737,511 (the “’511 Patent”) and 10,715,235 (the 

“’235 Patent”) against Defendants, though I have not been asked to provide opinions regarding the 

’511 and ’235 Patents, though I may be asked to rebut, if necessary, any statements or opinions by 

Plaintiff’s expert with which I disagree. Collectively, I refer to the ’369, ’939, ’235, and ’511 

Patents as the “Asserted Patents.” I have reviewed the Asserted Patents, as well as their respective 

prosecution histories. I have also reviewed extrinsic evidence regarding the patents, including any 

extrinsic evidence that Plaintiff has alleged is relevant to the construction of certain claim terms. 

If called upon, I would be willing to testify as set forth in this declaration. 

I. QUALIFICATIONS

2. I am qualified by education and experience to testify as an expert in the field of 

telecommunications. Attached as Exhibit 1 to this declaration is a copy of my curriculum vitae 

detailing my education and experience. Additionally, the following overview of my background 

pertains to my qualifications for providing expert testimony in this matter.

3. I have worked as an engineer and entrepreneur in the field of wireless 

communications for over 25 years, and I have been involved with various aspects of wireless 

communications for the duration of my career. 

4. I am currently a named inventor or co-inventor on more than 315 issued U.S. 

patents, and more than 700 international patent publications in total. A number of these patents 

and patent applications are related to the subject matter of the ’235 patent. As an initial example 

of my relevant qualifications, a selection of my issued patents pertaining to aspects of cellular 

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networks, antennas, and antenna arrays are listed in the following table. The listed patents are 

either prior art or are contemporaneous to the claimed priority date of the ’235 and ’939 Patents. 

U.S. Pat. Num. Title Priority Date

5,687,196 Range and bearing tracking system with multipath rejection 9/30/94

6,362,790 Antenna array structure stacked over printed wiring board 

with beamforming components 9/18/98 

6,100,843 Adaptive antenna for use in same frequency networks 9/21/98

6,404,386 Adaptive antenna for use in same frequency networks 9/21/98

6,400,317 Method and apparatus for antenna control in a 

communications network 9/21/98 

6,792,290 Method and apparatus for performing directional re-scan of 

an adaptive antenna 9/21/98 

6,473,036 Method and apparatus for adapting antenna array to reduce 

adaptation time while increasing array performance 9/21/98 

6,239,756 Antenna array with housing 11/19/99

6,545,990 Method and apparatus for a spectrally compliant cellular 

communication system 12/20/99 

7,002,902 Method and system for economical beam forming in a radio 

communication system 2/24/00 

6,396,456 Stacked dipole antenna for use in wireless communications 

systems 1/31/01 

7,999,559 Method and apparatus for adapting antenna array using 

received predetermined signal 2/2/2001 

7,425,928 Method and apparatus for frequency selective beam forming 6/12/2001 

7,253,783 Low cost multiple pattern antenna for use with multiple 

receiver systems 9/17/2002 

5. The following images depict a wireless product developed by myself and my team 

at WiDeFi, Inc., which included 3 antennas (2 microstrip patch antennas and a printed dipole). 

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6. For these reasons, and because of my technical experience and training as outlined 

below, I am qualified to offer technical opinions regarding the Asserted Patents.

7. A substantial portion of my work has been focused on wireless communication 

systems and products. For example, my educational background includes a BSEE from the 

University of Florida (1991) and MSEE from the Georgia Institute of Technology (1992) focusing 

on digital signal processing.

8. From 1986 to 1991, while at the University of Florida, I interned with Harris 

Corporation in various roles including mechanical design, software development, and digital 

design. From 1991 to 1992, while at Georgia Institute of Technology, I worked at the Georgia 

Tech Research Institute (GTRI) as a graduate research assistant, performing software development 

on classified government programs.

9. From 1993 to 1995, while working for Harris Corporation, I designed various 

cellular communications systems for voice, data, and tracking/location. Many of the systems I 

designed utilized advanced communications technologies, such as those utilized in the thendeveloping and future telecommunication standards (such as IS-95, W-CDMA, and aspects of 

LTE).

10. From 1995 to 1998, I worked at Spectrian in advanced development and technical 

marketing. At Spectrian, I interfaced with Nortel’s and Qualcomm’s product management and 

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performed advanced technology development and systems analysis. In this role, I designed IS-95 

CDMA and GSM base station power amplifiers and control electronics, and received several 

patents associated with advanced linearization techniques for the reduction of transmitted 

distortion.

11. From 1998 to 2002, I served as the Director of Strategic and Technical Marketing 

at Tantivy Communications, a venture capital-funded 3G cellular data and chip set company. At 

Tantivy, I helped to architect and standardize the I-CDMA Spread Spectrum Systems Air Interface 

Standard (T1P1.4). I also developed both subscriber units and base stations that complied with 

the standard. The base stations utilized various IP protocols and interfaced with the wire line 

network utilizing IP over Ethernet. Additionally, I participated in and provided technical 

contributions to 3GPP/3GPP2 standardization efforts related to the development of CDMA2000 

and 1xEV-DO. This work resulted in my being named as a co-inventor on more than 150 pending 

or issued U.S. patents or applications.

12. From 2002 to 2007, as co-founder of WiDeFi, Inc., I served in various roles 

including President, CEO, CTO, and board member. As the CEO, my responsibilities included 

advanced development of platform technologies. I was co-inventor of wireless technology 

components, including a frequency translating TDD repeater, a same frequency repeater 

architecture for TDD/FDD-based systems, and physical layer multi-stream MIMO repeater 

technology. WiDeFi invented and provided wireless home networking products based on WiFi 

and cellular technologies. While at WiDeFi, I was a named inventor on over 25 issued U.S. patents 

or patent applications.

13. From 2007 to 2009, I consulted as a principal engineer for Qualcomm Inc. as part 

of the acquisition of WiDeFi’s technology. While at Qualcomm, I worked with its corporate R&D 

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division and developed consumer 3G and 4G cellular coverage enhancement systems utilizing 

WiDeFi’s baseband interference cancellation technologies. My responsibilities included working 

with international cellular operators on product requirements, detailed W-CDMA simulations, 

Long Term Evolution (“LTE”) systems analysis, and participation in prototype product realization. 

I am currently a named inventor on roughly 45 issued U.S. patents or patent applications assigned 

to Qualcomm.

14. From 2010 to the present, I have served as managing director and co-founder of 

Proxicom Wireless, LLC, which has developed and continues to develop cloud-based, mobile 

social networking and mobile payments technology based upon the proximity and location of 

mobile devices. Proxicom currently holds twelve issued U.S. patents and multiple pending patent 

applications, of which I am a co-inventor. Significant aspects of Proxicom’s technology involve 

a mobile device’s use of short range wireless technologies (802.11, near field communications, 

Bluetooth) in combination with cellular data links (3G/WCDMA or 4G/LTE, for example) to 

facilitate frictionless interactions via a wireless networked central cloud server.

15. Since 2007, I also have been the principal of Proctor Consulting, LLC. In this role, 

I have been a consultant relating to wired, wireless, and cellular communication and technologies, 

start-up companies and intellectual property. I also have been involved with numerous patent 

infringement, patent validity, and patent analysis assignments for public and private companies in 

the wired, wireless, and cellular networking industries.

16. Additionally, I have worked and consulted for both cellular infrastructure and 

device focused companies (Spectrian, Qualcomm, Fastback Networks), and defense contractors 

(Harris Corporation), where I developed covert-tracking and location technologies involving 

CDMA and smart-antenna technologies.

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17. In various of the above-detailed roles, I have been responsible for the development 

of business plans, product development plans, product development budgets, and product bill of 

materials estimations. I have been responsible for numerous product development teams, 

including schedule and costs of the development process at various stages of my career. For 

example, at Tantivy Communications, I ran a joint development of I-CDMA cellular base stations 

in Seoul, Korea that were used in a field trial in that country. Additionally, as founder and CEO 

of WiDeFi, Inc., I was responsible for similar such activities, as required to raise venture capital 

funding and reporting to the board of directors. 

18. I am being compensated for my expert work at the rate of USD $550 per hour. My 

compensation does not depend on the outcome of this case. Nor is it dependent on any of the 

opinions that I have provided in this Report or would provide in this case. 

II. LEGAL STANDARD

19. I am not a patent lawyer, but counsel have informed me about the legal principles 

that apply in construing patent claims. As a general matter, I understand that the words of a claim 

are generally construed to have the plain and ordinary meaning as those words would have been 

understood by a person of ordinary skill in the art (a “POSITA”) at the time of the invention based 

upon that person reading the claim terms themselves, the terms in the context of the claim in which 

they appear, the entire patent specification, including the figures, and the context of the file history 

of the patent and related patents. I also understand that terms must be construed based upon a 

complete understanding of what the inventor actually invented and intended to be covered (as 

evidenced in the patent and file history) by the claim in which the terms appear.

20. I also understand that an inventor can use terms in a manner other than in their plain 

and ordinary meaning by clearly, deliberately, and precisely defining those terms in the patent 

specification or in the file history.

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21. I also understand that the “intrinsic evidence,” which includes the claims, the 

specification, and the file history, including post-grant proceedings before the United States Patent 

and Trademark Office (“PTO”), are the most important tools to determine the meaning of a claim 

term and that “extrinsic evidence,” such as dictionaries, textbooks, and other publications, may 

also provide guidance about the meaning of a claim term.

22. I also understand that if a claim term, read in-light of the specification and the 

prosecution history, fails to inform a POSITA with reasonable certainty about the scope of the 

invention, then the claim term is indefinite.

23. I understand that claim elements may be expressed as a means for performing a 

recited function. I further understand that for such a means-plus- function element, the element is 

to be construed to cover the corresponding structure, material, or acts described in the patent 

specification for performing that function and equivalents thereof. Thus, I understand that in the 

case of a means-plus-function element, the scope of the claim element is limited to only structure 

that is both actually disclosed in the patent specification and clearly linked to the claimed 

function(s). 

24. I understand that even if a claim element does not use the word “means,” such a 

claim element should still be treated as a means-plus-function element if a POSITA would 

understand that the claim element recites a function and that the words of the claim do not recite 

sufficiently definite structure for performing the claimed function(s). 

25. I understand that if a claim element is found to be a means-plus-function claim 

element, there is a two-part analysis that involves: (1) identifying the function(s) and (2) 

identifying the corresponding structure from the specification that performs the function.

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26. I understand that for a means-plus-function element directed to implementation via 

known computing elements, the patent specification must disclose at least an algorithm for 

performing the claimed function(s) in order to disclose sufficiently definite structure. I understand 

that such an algorithm may be expressed as a mathematical formula, in prose, or as a flow chart, 

or in any other manner that describes with reasonable certainty the way that such algorithm 

specifically performs the claimed function(s).

27. However, I also understand that the knowledge of a POSITA cannot be used to 

create a disclosure of structure for a means-plus-function element when the patent specification 

does not otherwise provide a sufficiently definite disclosure of corresponding structure that is 

clearly linked to performing the claimed function(s). 

28. I further understand that when there are multiple claimed functions, the 

corresponding structure must be clearly linked to and be sufficiently definite for performing all 

such claimed functions. 

29. I understand that when a patent fails to disclose sufficiently definite structure for 

performing the claimed function(s) of a means-plus-function element, the claims (and their 

dependents) in which such means-plus-function element appears are invalid. 

III. MATERIALS CONSIDERED

30. In forming my opinions, I have reviewed the specifications of the Asserted Patents 

and their prosecution histories, as well as Plaintiff’s Infringement Contentions. I note that the ’939 

Patent was previously asserted in District Court litigation in the Central District of California 

against NETGEAR and Aruba Networks, and in the Western District of Texas against Cisco. I 

have reviewed the parties’ claim construction submissions in both cases as well as the claim 

construction orders that issued in both cases. 

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IV. LEVEL OF ORDINARY SKILL IN THE ART

31. I understand that the content of a patent (including its claims) and prior art should 

be interpreted the way a POSITA would have interpreted the material at the alleged time of 

invention unless otherwise construed by the Court as a matter of law. 

32. I understand that the Plaintiff has alleged a time of invention of April 27, 2001 for 

the ’369 Patent. 

33. I understand that the Plaintiff has alleged a time of invention of February 1, 2002 

for the ’235 Patent. 

34. I understand that the Plaintiff has alleged a time of invention of November 4, 2002 

for the ’939 Patent. 

35. I understand that the Plaintiff has alleged a time of invention of April 13, 2012 for 

the ’511 Patent. 

36. In my opinion, a POSITA in the field of art related to the ’369 and ’939 Patents 

would have been a person familiar with wireless communications networks and equipment and 

would have had a combination of work experience and/or education. I believe that such a POSITA 

would have had at least a Bachelor’s degree in an academic area emphasizing electrical 

engineering or a similar discipline, and at least two years of experience in the field working with, 

teaching, or researching wireless communication networks. Superior education could compensate 

for a deficiency in work experience, and vice versa. 

37. Additionally, I believe that such a POSITA would have had at least a working 

knowledge of the protocols and architecture of common wireless communications networks, as 

well as an understanding of the components and subsystems within available wireless 

communication equipment. Further, a POSITA would have had an awareness of the specifications 

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and regulations governing electromagnetic transmission patterns in frequency bands applicable to 

common wireless communication networks. 

38. I am a POSITA under this definition, and I would have been a POSITA under this 

definition as of the April 27, 2001 alleged invention date of the ’369 Patent and the November 4, 

2002 alleged invention date of the ’939 Patent. 

V. OVERVIEW OF THE ’369 PATENT

39. The ’369 Patent is titled “Multipath communication methods and apparatuses.” It 

relates to “to data communications, and more particularly to wireless communication systems, 

apparatuses and related methods that support wireless communication in a multipath signal 

propagation environment.” ’369 Patent at 1:14-17. The ’369 Patent explains that subscribers will 

move in a wireless communication network and that “there will not always be a clear or otherwise 

unobstructed communication path between a transmitting network and the receiving device.” ’369 

Patent at 1:34-46. The ’369 Patent further explains that “[m]ultipath propagation is primarily the 

reflections and diffraction from objects in the coverage area of the transmitting and receiving 

antennas,” and multipath propagation can cause interference. ’369 Patent at 3:12-17. 

40. The ’369 Patent’s solution is to “identify[] at least one multipath transmission delay 

within a reverse path data signal, determin[e] at least one forward path pre-equalization parameter 

based on the transmission delay, and modify[] a forward data path signal based on the forward 

path pre-equalization parameter.” ’369 Patent at 2:1-8. 

VI. OPINIONS REGARDING THE ’369 PATENT 

41. I understand that Plaintiff has asserted claims 1-7, 9-10, 12-14, 15, 19, 21, 28, 32-

33, 35-37, and 41 of the ’369 Patent. 

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A. “substantially reciprocal to” 

Claim Term Defendants’/ Intervenors’ 

Construction

Plaintiff’s Construction

“substantially reciprocal to”

Claim 12

Indefinite No construction necessary

42. Claim 12 depends from claim 3, which depends from claim 2, which in turn 

depends from claim 1. 

43. Claim 1 recites: 

A method comprising: 

identifying at least one multipath transmission delay within a reverse path data 

signal received from a receiving device; 

determining at least one forward path pre-equalization parameter based on said at 

least one transmission delay; and

modifying a forward path data signal that is to be transmitted to the receiving device 

based on said at least one forward path pre-equalization parameter, where said 

modifying includes selectively setting different transmission power levels for at 

least two Orthogonal Frequency Division Multiplexing (OFDM) tones in said 

forward path data signal. 

44. Claim 2 recites: 

The method as recited in claim 1, further comprising: 

receiving said reverse path data signal over at least one reverse transmission path. 

45. Claim 3 recites: 

The method as recited in claim 2, further comprising: 

transmitting said modified forward path data signal over at least one forward 

transmission path. 

46. Claim 12 recites: 

The method as recited in claim 3, wherein said at least one reverse transmission 

path is substantially reciprocal to said at least one forward transmission path. 

47. The term “reciprocal” is used in the following context in the ’369 Patent: 

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As is well known, many materials are electromagnetically isotropic, which is a 

property resulting from symmetry in their associated permittivity and permeability 

tensors. The Lorentz Reciprocity Theorem applies to such materials. Refraction and 

dielectric reflection from materials therefore often show reciprocity, or equivalence 

of forward and reverse channel characteristics. Diffraction and reflection are 

inherently reciprocal due to the minimal media affecting the electromagnetic wave. 

Thus, reciprocity can be used to determine channel characteristics that are used 

while pre-equalizing a transmitted path. The use of a reciprocal channel is very 

useful, for example, when Time Division Duplex (TDD) channels are implemented.

’369 Patent, 7:22-34. 

48. The term “substantially reciprocal” is thus used in the context of describing how 

reciprocal (i.e., how equivalent) the reverse transmission path (channel characteristics) are to the 

forward transmission path (channel characteristics). 

49. In my opinion, the term “substantially reciprocal” is indefinite. The ’369 Patent 

provides no guidance on how reciprocal the reverse transmission path channel characteristics must 

be to the forward transmission path channel characteristics to be “substantially reciprocal.” The 

degree of reciprocity is highly relevant to the design of wireless communication systems, and needs 

to be measurable using a definitive and analytical definition. Simply referring to “substantially 

reciprocal” does not inform a POSITA what degree of reciprocity is enough to meet this claim. 

50. The term “reciprocal” is also disclosed in a specific example associated with a 

specific “fixed wireless system” using 802.11a:

If TDD is used, then the channel can be assumed to be reciprocal for durations 

(coherence time) of approximately 10 ms. The 10 ms duration can be 

determined in a fixed wireless system by passing vehicles, moving people, 

blowing trees, and/or other interruptions nearby or within the communication 

path/region. 

’369 Patent, 10:67-11:5. 

51. For a given system configuration and “coherence time,” the above example is 

assumed to be reciprocal. If this were a mobile system rather than the fixed system from the above 

example, and the receiver were moving, the changes in the environment would increase and the 

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coherence time (meaning the time duration over which the channel characteristics would not vary) 

would decrease making the system less “substantially” reciprocal. Similarly as system’s 

configuration changes (such as data rate increasing), the reciprocity of the channel is valid for a 

shorter period of time because the higher data rate would require more accurate estimates of the 

channel characteristics between the forward and reverse channels. Thus, because the nature of 

whether a channel is sufficiently reciprocal depends on the characteristics, environment, and 

configuration of the system in question, a POSITA would not be able determine where the 

boundary lies between when the forward and reverse paths are substantially reciprocal when they 

are less than substantially reciprocal. 

B. “a plurality of first device receive antennas”

Claim Term Defendants’/ Intervenors’ 

Construction

Plaintiff’s Construction

“a plurality of first device 

receive antennas”

Claim 19

Indefinite No construction necessary

52. Claim 19 depends from claim 16, which depends from claim 13, which depends 

from claim 1. I reproduce claim 1 in paragraph 43 above. 

53. Claim 13 recites: 

The method as recited in claim 1, wherein identifying said at least one multipath 

transmission delay, determining said at least one forward path pre-equalization 

parameter, and modifying said forward path data signal are performed by a 

transmitting device.

54. Claim 15 recites: 

The method as recited in claim 13, further comprising: 

using at least one transmitting device receive antenna operatively coupled to said 

transmitting device to receive said reverse path data signal over at least one reverse 

transmission path from the receiving device. 

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55. Claim 19 recites: 

The method as recited in claim 15, wherein said transmitting device is operatively 

coupled to a plurality of first device receive antennas.

56. In my opinion, the term “a plurality of first device receive antennas,” when read in 

light of the specification and file history, does not inform a POSITA, with reasonable certainty, of 

the scope of the invention. In other words, a POSITA would find this term to be indefinite. The 

term is indefinite because of a lack of clarity as to which device is the “first device” to which the 

“plurality of . . . receive antennas” belong. It is not clear whether the “plurality of . . . receive 

antennas” belong to the “transmitting device” (which is introduced in claim 13), the “receiving 

device,” or a newly introduced device referred to as a “first device.” A POSITA would find it 

impossible to determine which device is the claimed “first device.”

57. Additionally, other claims do use the terms “transmitting device [] antennas” and 

“receiving device [] antennas.” See, e.g., cls. 23 (“receiving device transmit antennas”), 35-36 

(“transmitting device transmit antennas”), 39 (“receiving device receive antennas”). Thus, it is 

not clear from the language of other claims what the claimed “first device” is. 

58. Further, neither the specification nor the prosecution history provides any guidance 

to a POSITA that would help determine what device has the “plurality of . . . receive antennas.” 

While the specification uses the terms “receive antennas,” “receiver antennas,” and “receiving 

antennas,” none of these uses informs a POSITA about the “device” these antennas belong to. See, 

e.g., ’369 Patent at 3:15 (“receiving antennas”), 4:64-65 (“receiving antennas”), 5:7-8 (“receiving 

antennas”), 5:52 (“receiver antennas”), 6:43-45 (“separate receive antennas”), 7:42 (“multiple 

receive antennas”). 

59. The presence of multiple possible interpretations, where the “first device” may be 

the “transmitting device,” the “receiving device,” or a third unclaimed device, creates significant 

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uncertainty about the scope of this claim. A POSITA would not understand which device is 

claimed “first device,” and so the limitation “a plurality of first device receive antennas” lacks any 

certainty as to its meaning or scope, let alone reasonable certainty. Thus, in my opinion, this term 

is indefinite. 

VII. OVERVIEW OF THE ’939 PATENT

60. The ’939 Patent is titled “Signal Communication Coordination,” and its disclosure 

relates to “coordination of signals being communicated across one or more media and in particular, 

by way of example but not limitation, to preventing the thrashing of signals (e.g., packets) by 

coordinating the release of downlink packets with the reception of uplink packets using a media 

access control (MAC)-type mechanism.” ’939 Patent at 1:27-33. 

61. The ’939 Patent discloses an “exemplary access station implementation” including 

“wireless input/output (I/O) unit that is configured to establish multiple access points; and signal 

transmission/reception coordination logic that is capable of ascertaining that an access point of the 

multiple access points is receiving a signal and that is adapted to restrain at least one other access 

point of the multiple access points from transmitting another signal responsive to the ascertaining 

that the access point is receiving the signal.” ’939 Patent at 2:13-21. 

62. Figure 1 (below) shows “an exemplary wireless communications environment 100” 

with an access station 102 that communicates wirelessly with multiple remote clients 104(1), 

104(2) . . . (104(N). ’939 Patent at 3:25-46. 

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63. The specification explains: 

In wireless communication, signals may be sent from a transmitter to a receiver 

using electromagnetic waves that emanate from one or more antennas as focused 

in one or more desired directions, which contrasts with omni-directional 

transmission. When the electromagnetic waves are focused in a desired direction, 

the pattern formed by the electromagnetic wave is termed a “beam” or “beam 

pattern.” The production and/or application of such electromagnetic beams is 

typically referred to as “beamforming.”

’939 Patent at 4:28-36.

64. The specification further describes this access station 102 in Figure 4 (below), 

which shows a wireless I/O unit 206 and signal transmission/reception coordination logic 404. 

Wireless I/O unit 206 is introduced in Figure 2, and in the Figure 4 embodiment establishes two 

or more access points 402. ’939 Patent at 5:38-40.

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65. The specification explains that a problem with access points utilizing beamforming 

is that “bleedover between access points 402 can occur,” including, for example, downlink 

transmissions from one access point destroying uplink signal reception from another access point. 

’939 Patent at 5:48-56. 

66. The ’939 Patent’s solution to this problem is using “signal transmission/reception 

coordination logic 404,” which monitors multiple access points to “ascertain when a signal is being 

received.” ’939 Patent at 5:65-67. The signal transmission/reception coordination logic 404 

“coordinates uplink signal receptions and downlink signal transmissions across different access 

points 402 so as to avoid or at least reduce the frequency at which downlink signals are transmitted 

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at a first access point[] while uplink signals are being received at a second access point.” ’939 

Patent at 5:59-64. 

67. Upon ascertaining that an access point is receiving a signal, “is capable of 

restraining (e.g., limiting preventing, delaying, etc.) the transmission of signals on other access 

points.” ’939 Patent at 6:1-15. 

A. Prosecution History for the ’939 Patent

68. U.S. Patent Application No. 10/700,342 (the “’342 Application”) was filed on 

November 3, 2003, and lists Bobby Jose, Eduardo Casas, James Brennan, and Praveeen Mehrotra 

as inventors. 

69. The ’342 Application claims priority to two provisional applications, Provisional 

Application Nos. 60/423,702 and 60/423,696. Both provisional applications were filed November 

4, 2002.

70. The original ’342 Application contained 115 claims. Independent claim 107, which 

issued as claim 15, is reproduced below: 

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71. The Applicant cancelled originally filed claims 108, 27-36, and 45-102. ’939 File 

History, Oct. 30, 2009 Claims. I understand that the Examiner rejected the remaining claims as 

obvious over U.S. Patent Publication No. 2003/0064752 (“Adachi ’752”) in view of U.S. Patent 

Pub. No. 2002/0031104 (“Griffith ’104”), and U.S. Patent No. 6,983,167 (“Adachi ’167”). ’939 

File History, Nov. 9, 2010 Non-Final Rejection. 

72. In response, the Applicant argued that the claims required that “one access point is 

restrained in response to a different access point receiving a signal. In Adachi ‘752, specifically 

paragraph [0102], the access point which receives the signal is the same access point which is 

restrained.” ’939 File History, May 9, 2011 Office Action Response, at 13-14. 

73. The Examiner rejected the claims over U.S. Patent Publication No. 2003/0214961 

(“Nevo ’961”) in view of Griffith ’104 and Adachi ’167. ’939 File History, November 8, 2011 

Non-Final Rejection.

74. The Applicant responded by amending the claims and added new claim 116. In 

include the Applicant’s marked up amendment to claim 107 below. 

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’939 File History, Jan. 30, 2012 Office Action Response at 5. 

75. The Applicant’s accompanying remarks distinguished Nevo ’961 as “coordinating 

a frequency hopping transceiver (Bluetooth) and a potentially interfering 802.11 transceiver by 

determining the hopping pattern, selecting either the Bluetooth or the 802.11 transceiver as 

dominant, predicting the occurrence of interference, and preemptively notifying the dominated 

device to suspend transmission to avoid interference.” ’939 File History, January 30, 2012 Office 

Action Response at 8-10. The Applicant explained that the claims differed from Nevo because 

“the coordination logic of claim 9 ascertains, by monitoring the plurality of access points, that one 

access point is receiving a signal and in response restrains a second access point from transmitting 

an interfering signal. Rather than a Nevo’s selecting a dominant transceiver, determining a hopping 

pattern, predicting when interference will occur, and preemptively preventing interference by 

notifying the dominated transceiver to stop transmission, claim 9 is directed to ascertaining by 

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monitoring a plurality of access points that any first access point is receiving and restraining at

least a second access point from transmitting.” ’939 File History, January 30, 2012 Office Action 

Response at 8-10. The Applicant further argued that claim 107 (which issued as claim 15) was 

allowable for the same reasons as claim 9. 

76. The Examiner then rejected some of the claims as obvious over Nevo ’961 in view 

of Adachi ’167 and U.S. Patent No. 7,779,071 (“Lor ’071”), but allowed claims 107, 108, and 116, 

which issued as claims 15, 16, and 17. 

77. The Applicant then amended the claims, and also added claim 117, which issued as 

claim 30. I reproduce claim 117 below: 

78. The Examiner subsequently entered an amendment as a condition of allowance, but 

pending claims 107 and 117 were not affected by the Examiner’s amendment. 

VIII. OPINIONS REGARDING THE ’939 PATENT

79. I understand that Plaintiff has asserted claims 15, 17, 20-22, 30, and 33-35 of the 

’939 Patent. 

A. “wireless input/output (I/O) unit”

Claim Term Defendants’/ Intervenors’ 

Construction

Plaintiff’s Construction

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“wireless input/output (I/O) 

unit”

Claims 15, 30

Governed by 35 U.S.C. § 

112, ¶6, and indefinite

Function: “establish a 

plurality of access points”

Structure: None disclosed

Plain and Ordinary Meaning

Alternative proposed 

construction, should the term 

be treated as a means-plusfunction limitation:

Function: 

“establish a plurality of 

access points”

Structure: 

Wireless input/output unit 206 

and equivalents thereof 

80. Claims 15 and 30 recite a “wireless input/output (I/O) unit” that performs the 

following function: 

• “establish a plurality of access points”

81. I understand that Plaintiff contends that the claim limitation “wireless input/output 

(I/O) unit” does not need to be construed and is not a means-plus-function limitation. I disagree. 

The term “wireless input/output (I/O) unit that is configured to establish a plurality of access 

points” does not have a customary, or plain and ordinary, meaning to a POSITA and Plaintiff cites 

to no extrinsic evidence or support for any plain and ordinary construction. 

82. I understand that Defendants and Intervenors contend that this term should be 

construed under 35 U.S.C. § 112, ¶ 6, which I further understand to govern means-plus-function 

terms (which I describe my understanding of in § II). 

83. Having considered the parties’ positions, and based on my review of the claim 

language in the context of the specification and the prosecution history, it is my opinion that this 

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limitation is functional in nature and that the specification discloses no corresponding structure for 

performing the claimed function. 

1. The term “wireless input/output (I/O) unit” is a means-plus-function 

term

84. I reproduce Claim 30 of the ’939 Patent, which contains the “wireless input/output 

(I/O) unit” term, below:

30. An apparatus comprising:

a wireless input/output (I/O) unit that is configured to establish a plurality of 

access points; and

signal transmission/reception coordination logic that is capable of ascertaining, by 

monitoring the plurality of access points for received signals, that a first access 

point of the plurality of access points is receiving a first signal on a first channel 

and that is adapted to restrain at least a second access point of the plurality of access 

points from transmitting a second signal on a second channel different from the first 

channel responsive to the ascertaining that the first access point is receiving the first 

signal.

85. The claimed “wireless input/output (I/O) unit” performs at least one claimed 

function, namely, “establish a plurality of access points.” Further a POSITA would not understand 

that the term “wireless input/output (I/O) unit” or the words of claims 15 and 30 describe or recite 

sufficiently definite structure for performing the claimed function recited for this claim limitation. 

86. I understand that Plaintiff has not identified any extrinsic evidence in its P.R. 4-2 

disclosures that define the term “wireless input/output (I/O) unit” at the time of the alleged 

invention, either alone or with the claimed function “establish a plurality of access points.” 

87. By my own experience, the term “wireless input/output (I/O) unit” is not a standard 

term used by others in the art, and I have not encountered the term outside the context of Plaintiff’s 

patents. Further, the term “wireless input/output (I/O) unit” is not a term of art associated with 

performing the function “establish a plurality of access points.” 

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88. In my opinion, the term “unit” is a generic placeholder for anything that operates 

as a means for performing the claimed function. In the context of the claim, the term “unit” does 

not provide any indication of structure for providing the claimed “establish[ing]” function and sets 

forth a black box recitation of structure analogous to if the term “means” had been used. The term 

“wireless input/output (I/O)” does not impart any structure into the term “unit.” I have reviewed 

the specification and file history and nothing in the specification or file history convey additional 

structure for performing the claimed function “establish a plurality of access points.” At best, the 

words “wireless input/output (I/O)” only convey transmitting and receiving wireless signals to a 

POSITA. However, the ’939 patent specification recites that a “wireless input/output unit 206” 

performs two functions: (1) establishing multiple access points, and (2) transmitting and/or 

receiving wireless signals. ’939 Patent at 2:14-16, 4:20-25, 5:38-40. Thus, the ’939 Patent makes 

clear that transmitting and receiving wireless signals is a separate function from establishing 

multiple access points. 

89. I note that the ’939 Patent never explains what it means to “establish a plurality of 

access points” or “establish[] multiple access points.” While the ’939 Patent states that the wireless 

(I/O) unit 206 establishes multiple access points, it never explains what that claimed function 

means. In my opinion the terms “establish a plurality of access points” and “establish multiple 

access points” are not terms of art, and a POSITA would not understand them without reading the 

patent specification. I performed a Google advanced search of these two terms individually, with 

a date range of Jan. 1, 1990 to November 4, 2002, and also with no date constraints. I did not find 

use of these terms in any literature which confirmed my understanding that these terms were not 

commonly used in that time period, or presently. Instead, the ’939 Patent merely states that wireless 

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I/O unit 206 “establishes” multiple access points. See, e.g., ’939 Patent at Abstract, 2:14-16, 5:38-

40, and 5:57-58. 

90. In my opinion, a POSITA at the time of the alleged invention would not know what 

it meant to “establish” either “multiple access points” or “a plurality of access points.” 

91. For example a POSITA would understand that an access point is an individual 

device. The specification confirms this understanding, stating: “ Each access point of the multiple 

access points 402 may correspond to, for example, an individual access point in accordance with 

an IEEE 802.11-based standard.” 5:40-43. A POSITA would not understand what it means to 

establish an physical access point. I note that, in prior litigation, Plaintiff also took the position 

that this limitation is not a means-plus-function limitation and identified intrinsic evidence to 

support its position. I have reviewed this evidence that Plaintiff relies on, and I disagree with 

Plaintiff. 

92. For example, in the Central District of California, Plaintiff identified “3:25-7:36” 

of the ’939 Patent specification as intrinsic evidence to support its construction of “wireless 

input/output (I/O) unit.” I have reviewed this passage of the specification and it does not support 

the position that “wireless input/output (I/O) unit” is not a means-plus-function limitation. Instead, 

it reinforces my opinion that the term is a means-plus-function limitation. The specification states, 

in the context of Figure 2: “FIG. 2 is an exemplary wireless LAN/WAN communications 

environment 200 that includes an access station 102, a wireless input/output (I/O) unit 206, an 

antenna array 208, and multiple communication beams 202.” ’939 Patent at 4:4-7. Further, the 

specification explains: 

Access station 102 includes wireless I/O unit 206. Wireless I/O unit 206 includes 

an antenna array 208 that is implemented as two or more antennas, and optionally 

as a phased array of antennas. Wireless I/O unit 206 is capable of transmitting 

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and/or receiving (i.e., transceiving) signals (e.g., wireless communication(s) 106 

(of FIG. 1)) via antenna array 208

4:17-23.

93. The specification’s description of wireless I/O unit 206 in the context of Figure 2 

only shows structure to transmit and receive signals, and does not show any structure for 

establishing multiple access points. 

94. In the context of Figure 4, the specification explains: 

FIG. 4 illustrates an exemplary access station 102 that establishes multiple access 

points 402 and includes signal transmission/reception coordination logic 404. As 

illustrated, access station 102 includes a wireless I/O unit 206. Wireless I/O unit 

206 includes or is associated with signal transmission/reception coordination logic 

404. Such logic may be implemented as hardware, software, firmware, some 

combination thereof, and so forth.

5:30-37.

95. The only structure that the Figure 4 embodiment contains is “signal 

transmission/reception coordination logic,” which the specification states “may be implemented 

as hardware, software, firmware, some combination thereof.” Further, the specification never 

describes the signal transmission/reception coordination logic as establishing multiple access 

points. 

96. Thus, in my opinion a POSITA would not understand that the term “wireless 

input/output (I/O) unit” discloses sufficient structure for performing the claimed function 

“establish a plurality of access points” and would understand that the term is a “means-plusfunction” limitation. 

2. The claimed function of the “wireless input/output (I/O) unit”

97. A POSITA would understand that the term “wireless input/output (I/O) unit,” as 

recited in claims 15 and 30 would have the function “establish a plurality of access points.”

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3. The specification discloses no corresponding structure for performing 

the claimed function

98. As I discuss above, claims 15 and 30 of the ’939 Patent do not recite sufficiently 

definite structure for performing the claimed function, and so a POSITA would look to the 

specification for corresponding structure that performs the claimed function for the recited 

“wireless input/output (I/O) unit.” In my opinion, the specification of the ’939 Patent does not 

disclose any structure for performing the claimed function “establish a plurality of access points.”

99. In the event that this limitation is found to be a means-plus-function limitation, I 

understand that Plaintiff has identified “wireless input/output unit 206 and equivalents thereof” as 

corresponding structure. 

100. As I explain above, the ’939 Patent never explains what it means to “establish” one 

or more access points, which as I discuss above is a device. Instead, the ’939 Patent simply states 

that multiple access points are established and states that there is “a wireless input/output (I/O) 

unit that is configured to establish multiple access points.” ’939 Patent at 2:13-16. 

101. The Figure 4 embodiment, shown below, shows a number of access points 402, and 

the ’939 Patent states “Fig. 4 illustrates an exemplary access station 102 that establishes multiple 

access points 402.” ’939 Patent at 5:30-31. Further, the ’939 Patent explains that “In a described 

implementation, wireless I/O unit 206 establishes two or more access points 402, such as multiple 

access points 402(1), 402(2) . . . 402(N).” ’939 Patent at 5:38-40. 

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102. However, the ’939 Patent never explains what it means to “establish” multiple 

access points: the specification simply restates the claimed function. 

103. Additionally, I note that the ’939 Patent refers to “wireless input/output (I/O) unit 

206” in the Figure 2, 4, and 6 embodiments. However, these embodiments do not recite 

sufficiently definite structure for a “wireless input/output (I/O) unit 206” that performs the claimed 

function. 

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104. First, the Figure 2 embodiment does not disclose any corresponding structure for 

performing the claimed function. Indeed, the Figure 2 embodiment (which is shown below) makes 

no mention of establishing multiple access points at all. Instead, the specification states that “FIG. 

2 is an exemplary wireless LAN/WAN communications environment that includes an access 

station, a wireless input/output (I/O) unit, an antenna array, and multiple communication beams.” 

’939 Patent at 2:53-56. Figure 2 shows an access station 102 including a wireless input/output 

unit 206. ’939 Patent at 4:4-6, 4:17-27. The specification explains that wireless I/O unit 206 

“includes an antenna array 208” and “is capable of transmitting and/or receiving (i.e., transceiving) 

signals (e.g., wireless communication(s) 106 (of Fig. 1)) via antenna array 208.” 4:17-23.

105. The Figure 2 embodiment thus never discloses the claimed function: “establish a 

plurality of access points.” The Figure 2 embodiment only ever discloses transmitting multiple 

communication beams, but communication beams are not the claimed access points. 

106. Further, Figure 2 only discloses that wireless input/output unit 206 has an antenna 

array 208, which may be a phased array, and does not describe wireless input/output unit 206 as 

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having any other structure apart from implementing a beamformer. However, antenna array 208 

(with or without a beamformer) is not structure that is capable of performing the function “establish 

a plurality of access points” and the ’939 Patent specification never links antenna array 208 to the 

claimed function. I note that the disclosed antenna array, including those with beamformers, only 

addresses the wireless coverage areas of an access point, but cannot establish an access point itself 

(which is a device). This understanding is consistent with the example of “an individual access 

point in accordance with an IEEE 802.11-based standard” being a device and not a coverage area. 

The ’939 Patent confirms this distinction between an access point and a coverage area, stating that 

“Additionally, a wireless coverage area or region for each respective access point 402 of the 

multiple access points 402 may correspond to, for example, a respective communication beam 202 

of multiple communication beams 202.” 5:43-47.

107. The Figure 4 embodiment also does not disclose any corresponding structure that 

performs the recited function. The specification states that “FIG. 4 illustrates an exemplary access 

station that establishes multiple access points and includes signal transmission/reception 

coordination logic.” ’939 Patent at 2:59-61. Figure 4 explains that access station 102 includes a 

wireless I/O unit 206, and this wireless I/O unit 206 “includes or is associated with signal 

transmission/reception coordination logic 404.” ’939 Patent at 5:30-35. The ’939 Patent explains 

“such logic may be implemented as hardware, software, firmware, some combination thereof, and 

so forth.” ’939 Patent at 5:35-37.

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108. While Figure 4 explains that “wireless I/O unit 206 establishes two or more access 

points 402,” it never explains how an access point is established. ’939 Patent at 5:38-40. Indeed, 

as I explain above, Figure 4 does not disclose any structure at all: the only disclosed components 

are wireless input/output unit 206 and signal transmission/reception coordination logic 404. The 

’939 Patent makes clear that this logic does not have any definite structure, instead stating that 

“such logic may be implemented as hardware, software, firmware, some combination thereof, and 

so forth.” ’939 Patent at 5:35-37. And the ’939 Patent does not disclose any algorithm or procedure 

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that this “hardware, software, firmware, [or] some combination thereof” would use to “establish a 

plurality of access points.” 

109. Similarly, the Figure 6 embodiment also does not disclose any corresponding 

structure that performs the claimed function. The specification explains that “FIG. 6 illustrates an 

exemplary access station that includes multiple components such as medium access controllers 

(MACs), baseband (BB) units, and MAC coordinator logic.” ’939 Patent at 2:65-67. Figure 6 

(below) “illustrates an exemplary access station 102 that includes multiple components such as 

medium access controllers (MACs) 604, baseband (BB) units 608, and MAC coordinator logic 

606.” ’939 Patent at 6:54-57. “[A]ccess station 102 also includes an Ethernet switch and/or router 

602, radio frequency (RF) parts 610, a beamformer 612, and antenna array 208.” ’939 Patent at 

6:57-60. I note that this description of Figure 6 makes no mention of establish[ing] a plurality of 

access points. 

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110. The ’939 Patent does suggest that wireless input/output unit 206 may “correspond 

to MACs 604, MAC coordinator logic 606, BB units 608, and RF parts 610” and may further 

include “one or more of Ethernet switch/router 602, beamformer 612, and antenna array 208.” 

6:60-64. However, the Figure 6 embodiment does not disclose the function “establish a plurality 

of access points,” and does not link any structure to performing that function. 

111. Indeed, the structure recited in the Figure 6 embodiment, including “baseband (BB) 

units 608,” “Ethernet switch and/or router 602, radio frequency (RF) parts 610, a beamformer 612, 

and antenna array 208” is not structure that that a POSITA would associate with the function 

“establish a plurality of access points.”

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112. Indeed, the specification confirms this lack of disclosure, explaining that the 

embodiments in the patent, i.e., “[t]he diagrams of FIGS.1-13” “are illustrated as blocks 

representing features, devices, logic, functions, actions, some combination thereof and so forth.”

’939 Patent at 18:56-58. The specification makes this even more clear and states 

“By way of example only, the blocks of FIGS. 1-13 (e.g., the components of FIGS. 

2, 4, 6, 8, and 10-13 and/or the actions of FIGS. 5, 7, and 9) may be implemented 

fully or partially as one or more processors and/or as one or more media. Such 

processors may be general purpose microprocessors, special-purpose digital signal 

processors, some combination thereof, and so forth. Such media may be 

transmission or storage media, volatile or non-volatile memory, programmable or 

hard-wired coding, some combination thereof, and so forth.” 

’939 Patent at 18:66-19:7. 

113. Thus, it is my opinion that the ’939 Patent does not disclose any structure for 

performing the claimed function “establish a plurality of access points” and does not link any 

structure to performing this function. 

B. “signal transmission/reception coordination logic” 

Claim Term Defendants’/ Intervenors’ 

Construction

Plaintiff’s Construction

“signal 

transmission/reception 

coordination logic” 

Claims 15, 30 

Governed by 35 U.S.C. § 

112, ¶6, and indefinite 

Function: 

Claim 15: “ascertaining, by 

monitoring the plurality of 

access points for received 

signals, that:” (i) “a first access 

point of the plurality of access 

points is receiving a first signal 

on a first channel,” (ii) “a 

second access point of the 

plurality of access points is 

receiving a second signal that 

is ongoing on a second 

channel,” (iii) “restrain[ing] at 

least a third access point of the 

Plain and Ordinary Meaning; 

no construction necessary 

Alternative proposed 

construction, should the term 

be treated as a means-plusfunction limitation:

Function: 

Claim 15: ascertaining, by 

monitoring the plurality of 

access points for received 

signals, that: a first access 

point of the plurality of 

access points is receiving a 

first signal on a first channel, 

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plurality of access points from 

transmitting a third signal on a 

third channel responsive to the 

ascertaining that the first 

access point is receiving the 

first signal and that the second 

access point is receiving the 

second signal that is ongoingon the second channel, wherein 

the restraining at least the third 

access point prevents 

degradation to the first and 

second signals” 

Structure: None disclosed 

Claim 30: (i) “ascertaining, by 

monitoring the plurality of 

access points for received 

signals, that a first access point 

of the plurality of access points 

is receiving a first signal on a 

first channel” and (ii) 

“restrain[ing] at least a second 

access point of the plurality of 

access points from transmitting 

a second signal on asecond 

channel different from the first 

channel responsive to the 

ascertaining that the first 

access point is receiving the 

first signal.” 

Structure: None disclosed

a second access point of the 

plurality of access points is 

receiving a second signal that 

is ongoing on a second 

channel, restrain[ing] at least 

a third access point of the 

plurality of access points 

from transmitting a third 

signal on a third channel 

responsive to the ascertaining 

that the first access point is 

receiving the first signal and 

that the second access point is 

receiving the second signal 

that is ongoing-on the second 

channel, wherein the 

restraining at least the third 

access point prevents 

degradation to the first and 

second signals.

Claim 30: ascertaining, by 

monitoring the plurality of 

access points for received 

signals, that a first access 

point of the plurality of 

access points is receiving a 

first signal on a first channel, 

restrain[ing] at least a second 

access point of the plurality 

of access points from 

transmitting a second signal 

on a second channel different 

from the first channel 

responsive to the ascertaining 

that the first access point is 

receiving the first signal.

Structure:

Signal transmission/reception 

logic 404 and/or MAC 

coordinator logic 606 and/or 

6:1-51 and/or 6:65-7:20 

and/or 9:11-59 and/or 11:19-

12:21 and/or 14:28-15:22 

and/or 15:23-65 and/or 16:53-

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67 and/or 18:12-55 and 

equivalents thereof.

The corresponding structure 

of “signal 

transmission/reception logic 

404” includes the 

characteristics and 

configuration set forth for the 

signal transmission/reception 

coordination logic 404 (and 

the MAC coordinator logic 

606, which is subsumed 

within the corresponding 

structure of the signal 

transmission/reception 

coordination logic 404) in the 

’939 Patent, including at 6:1-

51 and/or 6:65-7:20 and/or 

9:11-59 and/or 11:19-12:21 

and/or 14:28-15:22 and/or 

15:23-65 and/or 16:53-67 

and/or 18:12-55, and 

equivalents thereof.

114. Claim 15 and 30 recite “signal transmission/reception coordination logic” which 

performs the following functions: 

• “ascertaining, by monitoring the plurality of access points for received signals, 

that:” (i) “a first access point of the plurality of access points is receiving a first 

signal on a first channel,” (ii) “a second access point of the plurality of access 

points is receiving a second signal that is ongoing on a second channel,” (iii) 

“restrain[ing] at least a third access point of the plurality of access points from 

transmitting a third signal on a third channel responsive to the ascertaining that 

the first access point is receiving the first signal and that the second access point 

is receiving the second signal that is ongoing-on the second channel, wherein the 

restraining at least the third access point prevents degradation to the first and 

second signals” (claim 15)

• “ascertaining, by monitoring the plurality of access points for received signals, 

that a first access point of the plurality of access points is receiving a first signal 

on a first channel” (claim 30)

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• “restrain[ing] at least a second access point of the plurality of access points from 

transmitting a second signal on a second channel different from the first channel 

responsive to the ascertaining that the first access point is receiving the first 

signal.” (claim 30)

115. I understand that Plaintiff contends that the claim limitation “signal 

transmission/reception coordination logic” does not need to be construed and is not a means-plusfunction limitation. I disagree. The term “signal transmission/reception coordination logic” does 

not have a customary, or plain and ordinary, meaning to a POSITA and Plaintiff cites to no 

extrinsic evidence or support for any plain and ordinary construction. 

116. I understand that Plaintiff also contends that, if this term is found to be a meansplus-function limitation, this limitation has the function and corresponding structure that I 

reproduce in the table above. 

117. I understand that Defendants and Intervenors contend that this term should be 

construed under 35 U.S.C. § 112, ¶ 6, which I further understand to govern means-plus-function 

terms (which I describe my understanding of in § II). 

118. Having considered the parties’ positions, and based on my review of the claim 

language in the context of the specification and the prosecution history, it is my opinion that this 

limitation is functional in nature and that the specification discloses no corresponding structure for 

performing the claimed functions. 

1. The term “signal transmission/reception coordination logic” is a 

means-plus-function term

119. I reproduce Claim 15 of the ’939 Patent, which contains the “signal 

transmission/reception coordination logic” term, below: 

An apparatus comprising: 

a wireless input/output (I/O) unit that is configured to establish a plurality of access 

points; and 

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signal transmission/reception coordination logic that is capable of ascertaining, by 

monitoring the plurality of access points for received signals, that:

a first access point of the plurality of access points is receiving a first signal 

on a first channel,

a second access point of the plurality of access points is receiving a second 

signal that is ongoing on a second channel, the signal transmission/reception 

coordination logic adapted to restrain at least a third access point of the 

plurality of access points from transmitting a third signal on a third channel 

responsive to the ascertaining that the first access point is receiving the first 

signal and that the second access point is receiving the second signal that is 

ongoing-on the second channel,

wherein the restraining at least the third access point prevents degradation 

to the first and second signals.

120. I reproduce Claim 30 of the ’939 Patent, which contains the “signal 

transmission/reception coordination logic” term with a different function, below:

30. An apparatus comprising:

a wireless input/output (I/O) unit that is configured to establish a plurality of access 

points; and

signal transmission/reception coordination logic that is capable of ascertaining, by 

monitoring the plurality of access points for received signals, that a first access 

point of the plurality of access points is receiving a first signal on a first channel 

and that is adapted to restrain at least a second access point of the plurality of access 

points from transmitting a second signal on a second channel different from the first 

channel responsive to the ascertaining that the first access point is receiving the first 

signal.

121. The claimed “signal transmission/reception coordination logic” performs several 

functions, which I identify above in paragraph 114. However, the term “signal 

transmission/reception coordination logic” does not recite sufficiently definite structure for 

performing the claimed functions. The term “signal transmission/reception coordination logic” is 

not a standard term used by others in the art. I know of no dictionary or textbook that defines or 

even mentions the term “signal transmission/reception coordination logic.” In fact, I have never 

encountered the term other than in the ’939 Patent. 

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122. Further, I note that the word “logic,” in the context of this limitation and in view of 

the ’939 Patent specification, is a “nonce” word. The term “logic” does not convey any structural 

information to a POSITA, much like other “nonce” terms like “module,” “unit,” “component,” or 

“device.” The specification of the ’939 Patent confirms the “nonce” nature of the term “logic,” 

because when describing “signal transmission/reception coordination logic 404,” the specification 

states that “Such logic may be implemented as hardware, software, firmware, some combination 

thereof, and so forth.” ’939 Patent at 5:30-37. 

123. Indeed, the ’939 Patent explains that almost its entire disclosure is functional in 

nature, stating: “The diagrams of FIGS. 1-13 are illustrated as blocks representing features, 

devices, logic, functions, actions, some combination thereof, and so forth. However, the order 

and/or layout in which the diagrams are described and/or shown is not intended to be construed as 

a limitation, and any number of the blocks can be combined, augmented, omitted, and/or rearranged in any order to implement one or more methods, systems, apparatuses, access stations, 

arrangements, schemes, approaches, etc. for signal communication coordination.” ’939 Patent at 

18:56-65. 

124. The ’939 Patent further explains that the preferred embodiments “the features, 

logic, devices, and functions” of the preferred embodiments in Figures 2-4, 6, 8, and 10-13 “can 

be implemented in any suitable hardware, software, firmware, or combination thereof and using 

any suitable coding/logical mechanism(s), wireless protocol paradigm(s), radio frequency 

technology, and so forth.” ’939 Patent at 19:11-19. 

125. I understand that Plaintiff appears to take the position that “signal 

transmission/reception coordination logic” can be MAC coordinator logic, such as MAC 

coordinator logic 606. However, the specification states that MAC coordinator logic can be 

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anything, stating that “MAC coordinator logic 606 may be implemented as hardware, software, 

firm ware, some combination thereof, and so forth.” ’939 Patent at 7:18-20. In other words, much 

like signal transmission/reception coordination logic 404, MAC coordinator logic 606 does not 

convey any structural information to a POSITA. 

126. Additionally, the specification states that “signal transmission/reception 

coordination logic” can be implemented in either the baseband level or at a “MAC level.” ’939 

Patent at 18:12-44. A POSITA would understand that “logic” operating at the baseband level 

would be very different from “logic” operating at the MAC level. 

2. The claimed functions of the “signal transmission/reception 

coordination logic”

127. A POSITA would understand that the claimed “signal transmission/reception 

coordination logic” to have the following functions: 

• Claim 15: “ascertaining, by monitoring the plurality of access points for received 

signals, that:” (i) “a first access point of the plurality of access points is receiving 

a first signal on a first channel,” (ii) “a second access point of the plurality of 

access points is receiving a second signal that is ongoing on a second channel,” 

(iii) “restrain[ing] at least a third access point of the plurality of access points 

from transmitting a third signal on a third channel responsive to the ascertaining 

that the first access point is receiving the first signal and that the second access 

point is receiving the second signal that is ongoing-on the second channel, 

wherein the restraining at least the third access point prevents degradation to the 

first and second signals” 

• Claim 30: (i) “ascertaining, by monitoring the plurality of access points for received 

signals, that a first access point of the plurality of access points is receiving a first 

signal on a first channel” and (ii) “restrain[ing] at least a second access point of the 

plurality of access points from transmitting a second signal on asecond channel 

different from the first channel responsive to the ascertaining that the first access 

point is receiving the first signal.”

3. The specification discloses no corresponding structure for performing 

the claimed functions

128. As I discuss above, the claims of the ’939 Patent do not recite sufficiently definite 

structure for “signal transmission/reception coordination logic” that performs the recited functions. 

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A POSITA would look to the specification for corresponding structure that performs the claimed 

function. In my opinion, the specification discloses no structure that performs the claimed 

functions that I identify above in paragraph 127.

129. The ’939 Patent describes “signal transmission/reception coordination logic that is 

capable of ascertaining that an access point of the multiple access points is receiving a signal and 

that is adapted to restrain at least one other access point of the multiple access points from 

transmitting another signal responsive to the ascertaining that the access point is receiving the 

signal.” ’939 Patent at 2:16-21.

130. However, the ’939 Patent never explains how the “signal transmission/reception 

coordination logic” performs the function of “ascertaining” that an “access point” is receiving a 

signal on a first channel, which claims 15 and 30 both require. 

131. Further claims 15 and 30 both include the requirement that the “signal 

transmission/reception coordination logic” “restrain” a different access point from transmitting on 

a different channel in response to the ascertaining that an access point is receiving on a first 

channel. For example, claim 30 requires the step: 

• “signal transmission/reception coordination logic . . . that is adapted to restrain at 

least a second access point of the plurality of access points from transmitting a 

second signal on a second channel different from the first channel responsive to 

the ascertaining that the first access point is receiving the first signal [on a first 

channel]”

132. Similarly, claim 15 requires the step: 

• “the signal transmission/reception coordination logic adapted to restrain at least a 

third access point of the plurality of access points from transmitting a third signal 

on a third channel responsive to the ascertaining that the first access point is 

receiving the first signal [on a first channel] and that the second access point is 

receiving the second signal that is ongoing-on the second channel”

133. I note that the Figure 4 embodiment (below) describes a “signal 

transmission/reception coordination logic 404.” However, this is not corresponding structure for 

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performing the recited functions. I note that the specification (including in the discussion of the 

Figure 4 embodiment) only ever describes the “signal transmission/reception coordination logic” 

in functional terms, and expressly states that “such logic may be implemented as hardware, 

software, firmware, some combination thereof, and so forth.” This broad description of logic, i.e.

some combination of hardware, software, and firmware, does not inform a POSITA about the 

structure that performs the recited functions. 

134. Further, the discussion of the Figure 4 embodiment only repeats the stated functions 

without ever explaining how those functions are performed. The specification only states that 

“Specifically, signal transmission/reception coordination logic 404 is adapted to monitor the 

multiple access points 402(1 . . . N) to ascertain when a signal is being received. When an access 

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point 402(w) is ascertained to be receiving a signal, signal transmission/reception coordination 

logic 404 is capable of restraining (e.g., limiting, preventing, delaying, etc.) the transmission of 

signals on the other access points 402(1 . . . w−1, w+1 . . . N).” 5:65-6:5. This disclosure simply 

repeats parts of the function of the “signal transmission/reception coordination logic,” i.e.

“ascertaining” whether an access point is receiving a signal and “restraining” a different access 

point from transmitting, but without any explanation of what structure performs the functions of 

“ascertaining” and “restraining.” Further, this disclosure only repeats part of the claimed 

functions.

135. For example, the disclosure accompanying the Figure 4 embodiment also states that 

“one access point 402 . . . may operate on a different channel from that of another access point 402 

. . . If the different channels are adjacent and/or not sufficiently-well defined, it may be beneficial 

to restrain transmission on a first channel with a first access point 402 even when receiving a 

wireless communication on a second different channel with a second access point 402.” ’939 

Patent at 6:39-46. Further, “for different channel situations, signal transmission/reception 

coordination logic 404 may restrain transmission on one channel on the basis of reception on 

another channel with an ongoing transmission on a third channel to prevent (e.g., inter-modulation) 

distortion to the signals being communicated in the wireless system.” ’939 Patent at 6:47-53. 

However, these disclosures merely restate functions, such as the functions I discuss above in 

paragraphs 131 and 132. The discussion of the Figure 4 embodiment includes no structure that 

performs the claimed function. 

136. Further, while the ’939 Patent discloses a “flow diagram 500” in Figure 5 that 

“illustrates an exemplary method for using an access station having signal transmission/reception 

coordination logic for multiple access points,” 6:16-18, this flow diagram does not disclose any 

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structure for performing the recited functions. The discussion of Figure 5 only states that “at block 

502, multiple access points are monitored,” and that “at block 504, it is ascertained that an access 

point of the multiple monitored access points is receiving a signal,” and “at block 506, the other 

access points of the multiple monitored access points are restrained from transmitting a signal.” 

’939 Patent at 6:16-38. This disclosure in Figure 5 merely states that a function is performed, and 

it does not inform a POSITA as to what structure performs those functions. In addition, the 

discussion of Figure 5 does not disclose any of the restraining on a different channel functions that 

I discuss above in paragraphs 131 and 132. 

137. Additionally, the Figure 10 embodiment (below), also “illustrates an exemplary 

implementation 1000 for signal transmission/reception coordination logic 404.” ’939 Patent at 

15:23-25. However, the discussion of this embodiment also does not disclose corresponding 

structure for performing the claimed functions. 

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138. In describing Figure 10, the specification only states that “signal 

transmission/reception coordination logic 404 accepts as inputs receive information (1, 2, . . . N) 

and produces as outputs combined receive information (1, 2, . . . K). The number of ‘N’ receive 

information inputs may not equal the number ‘K’ of combined receive information outputs.” 

15:25-30. The discussion of Figure 10 only discloses two functional components, as shown in 

Figure 10: receive information combiner 1002 and receive information selector 1004. 15:31-33. 

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However, as was the case in Figure 4, the Figure 10 embodiment only describes these components 

in functional terms. 

139. For example, the specification states that “receive information combiner 1002 

applies a signal coordination function to the receive information (1, 2 . . . N) to produce the 

combined receive information (1, 2 . . . K)” and that “receive information selector 1004 enables a 

selectivity to be applied to the combining of the receive information (1, 2 . . . N). Factors 

controlling this receive information selectivity are generally represented by general selectivity 

1006. Receive information selector 1004 instructs receive information combiner 1002 as to what 

receive information (1, 2 . . . N) is to be combined or excluded and into which groups or segments.” 

’939 Patent at 15:34-47. The specification never explains what structure “receive information 

combiner 1002” and “receive information selector 1004” have, and a POSITA would not know 

what structure performs these functions. 

140. I note that the specification does state that “[i]n a more-specific implementation 

with reference to FIGS. 6 and 8, signal transmission/reception coordination logic 404 may be 

realized as MAC coordinator logic 606.” 15:49-51. However, MAC coordinator logic 606 is also 

not sufficient structure for performing the claimed function. 

141. MAC coordinator logic is first discussed in the context of Figure 6, where “FIG. 6 

illustrates an exemplary access station 102 that includes multiple components such as medium 

access controllers (MACs) 604, baseband (BB) units 608, and MAC coordinator logic 606.” 6:54-

57. The specification makes clear that, like signal transmission/reception coordination logic 404, 

MAC coordinator logic 606 can be anything, stating “MAC coordinator logic 606 may be 

implemented as hardware, software, firmware, some combination thereof, and so forth.” 7:18-20. 

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142. Further, MAC coordinator logic 606 is not described as performing the claimed 

function. For example, the discussion of Figure 6 simply states that “MAC coordinator logic 606 

is configured to coordinate the activities of the multiple MACs 604 (e.g., as a multi-MAC 

controller (MMC)) with regard to at least one non-associated respective BB unit 608. For example, 

MAC coordinator logic 606 may forward an instruction to MAC 604(1) responsive, at least partly, 

to an indicator provided from BB unit 608(2).” 7:11-18. A POSITA would not understand this 

disclosure accompanying Figure 6 to describe performing any of the recited functions, including 

the functions I discuss above in paragraphs 131 and 132. More specifically, a POSITA would not 

understand this disclosure as describing, for example, ascertaining reception by a first access point 

on a first channel and restraining transmission by a second access point on a second channel.

143. The specification further describes the operation of MAC coordinator logic and 

states: “MAC coordinator logic 606 is coupled to both of multiple BB units 608(1, 2 . . . N) and 

multiple MACs 604(1, 2 . . . N). In a described implementation, MAC coordinator logic 606 is 

configured to prevent MACs 604(1, 2 . . . N) from causing a transmission if at least one and 

optionally if any of BB units 608(1, 2 . . . N) are receiving. For example, if BB unit 608(2) indicates 

that it is receiving a packet, MAC coordinator logic 606 instructs MACs 604(1, 2 . . . N) so as to 

restrain them from causing a packet transmission during the packet reception.” 9:11-20. The 

specification further explains that: “MAC coordinator logic 606 is thus able to monitor BB units 

608(1, 2 . . . N). MAC coordinator logic 606 analyzes the receive indicators to produce a 

constructive receive indicator (“C-Rcv. Indicator” in FIG. 6).” 9:28-31. However, a POSITA 

would not understand these disclosures accompanying Figure 6 to disclose performing any of the 

recited functions, such as ascertaining reception by a first access point on a first channel and 

restraining transmission by a second access point on a second channel. Additionally, a POSITA 

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would not understand these disclosures as describing any specific structure for MAC coordinator 

logic 606, which the specification explicitly states “may be implemented as hardware, software, 

firmware, some combination thereof, and so forth.” 7:18-20. 

144. The specification then discusses the operation of MAC coordinator logic 606 with 

respect to Figure 8, which “illustrates another exemplary access station 102A” which includes 

“thirteen MACs 604” and thirteen “BB units 608”. 10:61-65. However, the Figure 8 embodiment 

does not impart any structure to the MAC coordinator logic 606. Instead, it simply states that 

“MAC coordinator logic 606 (and signal transmission/reception coordination logic 404 (of FIG. 

4)) may be modified, tweaked, expanded, etc. based on any one or more of many factors.” 11:54-

57. These factors include “channel assignment information 802, receive indicator enable 

information 804, timer logic 816, and scanning logic 812.” 11:58-60. These additional factors, 

however, do not impart any structure to MAC coordinator logic 606. 

145. Further, the Figure 8 embodiment discloses the opposite of the claimed functions. 

Where the claims require ascertaining reception by a first access point on a first channel and 

restraining transmission by a second access point on a second channel, the Figure 8 embodiment 

discloses: 

Channel assignment information 802 enables receive indicators (1, 2 . . . 13) to be 

combined by receive indicators combiner 810 on a per-channel basis. As a result, 

constructive receive indicators (1, 2 . . . 13) restrain signal transmissions from MAC 

604/BB unit 608 pairs when a signal reception is occurring on the same channel, 

even if by a different MAC 604/BB unit 608 pair. A downlinked packet that is 

transmitted on one channel while an uplinked packet is being received on another 

channel does not usually cause the uplinked packet to be thrashed (as long as the 

two channels are sufficiently well-defined or otherwise separated). On the other 

hand, a downlinked packet that is transmitted on a channel while an uplinked packet 

is being received on the same channel does usually cause the uplinked packet to be 

thrashed, even if the transmission and reception occur using different 

communication beams 202 (of FIGS. 2 and 3).

11:65-12:13. 

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146. Finally, I have reviewed the structure proposed by Plaintiff, which is: 

Signal transmission/reception logic 404 and/or MAC coordinator logic 606 and/or 

6:1-51 and/or 6:65-7:20 and/or 9:11-59 and/or 11:19-12:21 and/or 14:28-15:22 

and/or 15:23-65 and/or 16:53- 67 and/or 18:12-55 and equivalents thereof.

The corresponding structure of “signal transmission/reception logic 404” includes 

the characteristics and configuration set forth for the signal transmission/reception 

coordination logic 404 (and the MAC coordinator logic 606, which is subsumed 

within the corresponding structure of the signal transmission/reception 

coordination logic 404) in the ’939 Patent, including at 6:1-51 and/or 6:65-7:20 

and/or 9:11-59 and/or 11:19-12:21 and/or 14:28-15:22 and/or 15:23-65 and/or 

16:53-67 and/or 18:12-55, and equivalents thereof. 

147. In my opinion, Plaintiff’s proposed structure is not sufficient to perform the claimed 

functions, including the functions requiring restraining an access point on a different channel as I 

describe above in paragraphs 131 and 132. 

148. I note that Plaintiff’s proposed structure includes signal transmission/reception 

coordination logic 404, which is neither corresponding structure nor sufficient structure for the 

reasons I discuss above in paragraphs 133 to 139. 

149. Plaintiff’s proposed structure also states that the “corresponding structure of ‘signal 

transmission/reception coordination logic 404’ includes the characteristics and configuration set 

forth for the signal transmission/reception coordination logic 404.” In addition to my opinion that 

signal transmission/reception coordination logic 404 is neither corresponding structure nor 

sufficient structure for the reasons I discuss above, I note that Plaintiff’s position appears to be that 

its alleged corresponding structure performs the functions recited in the specification regardless of 

whether they appear in the claim language. Further, I note that “characteristics and configuration” 

is a description of the functions that signal transmission/reception coordination logic 404 performs, 

and does not describe the structure that performs those functions. 

150. I also note that Plaintiff’s proposed structure includes MAC coordinator logic 606, 

which is neither corresponding structure nor sufficient structure for the reasons I discuss above in 

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paragraphs 140 to 145. Further, I note that Plaintiff appears to take the position that MAC 

coordinator logic 606 “is subsumed within the corresponding structure of the signal 

transmission/reception coordination logic 404.” In addition to my opinions above regarding the 

lack of structure for both signal transmission/reception coordination logic 404 and MAC 

coordinator logic 606, I cannot find any support in the ’939 Patent specification for the proposition 

that MAC coordinator logic 606 is “subsumed within the corresponding structure of the signal 

transmission/reception coordination logic 404.”

151. Plaintiff’s proposed structure also includes the discussion of Figure 9 (14:28-

15:22), portions of the discussion of Figure 10 (15:23-65), portions of the discussion of Figure 11 

(16:53-67) and the discussion of Figure 13 (18:12-55). I discuss Figure 10 in paragraphs 137 to 

139 above, and discuss Figures 9, 11, and 13 below. 

152. Figure 9 (below) merely describes “a flow diagram 900 that illustrates another 

exemplary method for using MAC coordinator logic with multiple MACs and associated BB 

units.” 14:28-30. 

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153. However, the flowchart in Figure 9 merely states functions performed without any 

explanation as to what structure performs these functions. Also, this functional disclosure does 

not disclose any of the restrain on a different channel functions that I discuss above in paragraphs 

131 and 132. 

154. The disclosure in Figures 11 and 13 relate to a “multiple access station 

environment.” 16:39-40, 18:12-13. However, while the disclosure of these embodiments mentions 

“signal transmission/reception coordination logic 404” and “MAC coordinator logic 606,” they do 

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not impart any structure to either and describe both in functional terms. Further the descriptions 

accompanying these figures does not suggest that “signal transmission/reception coordination 

logic 404” and “MAC coordinator logic 606” perform functions that are different from those 

disclosed in Figures 4, 6, 8, and 10. As I explain above, “signal transmission/reception 

coordination logic 404” and “MAC coordinator logic 606” in Figures 4, 6, 8, and 10 do not perform 

the functions recited in claims 15 and 30. 

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Executed this 11th day of June, 2024.

Respectfully Submitted,

_____________________________

James A. Proctor, Jr.

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Exhibit 1

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Proctor CV

James A. Proctor Jr.

1680 North Riverside Drive, Indialantic, FL 32903 - (321) 271-8411 - jproctor@ieee.org

EDUCATION

Georgia Institute of Technology, Atlanta, Georgia M.S. Electrical Engineering

Graduated: September 1992

Interests: Digital Signal Processing, Communications, Optics

The University of Florida, Gainesville, Florida B.S. Electrical Engineering

Graduated: May 1991

Minor Studies: Business

Honors & Activities: PI ETA SIGMA Honor Society

ALPHA LAMBDA DELTA Freshman Honor Society

ETA KAPPA NU National Electrical Engineering Fraternity

Skills & Achievements

- Successfully led Qualcomm / WiDeFi integration efforts resulting in a new product effort within

Qualcomm related to the 3G/4G Market

- Co-founded WiDeFi and successfully raised >$14M of venture funding

- Generated intellectual property and product strategy leading to the acquisition of two companies 

(WiDeFi, and Tantivy Communications), contributing to > $100M of revenue

- Performed extensive customer and industry business development to provide support for innovative 

product definition, requirement definition, and customer support for business plan and forecasts

(Qualcomm, WiDeFi, and Tantivy Communications)

- Led and coached many R&D teams to refine and de-risk innovative wireless concepts

- Led cross functional product teams to deliver high volume ready prototypes 

- Ability to balance market, programmatic, and technical concerns and refine clear strategy and 

actionable plans 

- Generated >320 issued US Patents Currently and >700 international patent publications

- Have spoken at numerous public events: industry, venture, and technical

- Strong communication and technical skills

Work Experience

Proctor Consulting, LLC December 2008 - Present

- Early stage market and technology strategy

o Interim CTO/Team Member, business development/validation 

o Roadmap / IP development

o Advisory Board Member

- Technical / Market Consultant

o Fastback Networks, Audigence, Peregrine Semiconductor

- Intellectual property portfolio analysis within the communications market space

o Market / Product Applicability, Claims Chart Development and Analysis, Valuation 

o Expert Witness Consulting in Wireless Communications (WiFi, 2G-GSM, 3G-C2K/WCDMA, 

4G/LTE and associated networks)

Proxicom Wireless. Co-Founder, Managing Director November 2011 – Present

- Proximity based mobile technology utilizing a centralized trusted third party

- Development of foundational Intellectual Property (12+ US Patents)

- Enabling technology applicable to a variety of proximity based applications including highly secure: 

Mobile Payments, Electronic Coupons and Loyalty, Rating and Reviews, Social Commerce 

 

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Proctor CV

Qualcomm Inc., Principal Engineer (Consulting) October 2007 - October 2009

- Technical and Business development leadership of a consumer level 3G wireless repeater product 

concept based upon WiDeFi’s technology during the integration

- Provided technical leadership in architecture development

o Defined initial architecture approach for the wireless repeater concept based upon WiDeFi’s 

technology

o Worked with technical team to refine approach and achieve “key proof points” 

- Performed Business Development with International Wireless Operators

o Worked closely with business development from ESG and QCT divisions 

o Developed bottoms up forecast with the top international wireless operators for consumer 

repeater products.

o Refined product features to meet carrier’s requirements 

- Market Analysis to estimate Market Size and Competitive Landscape

- Named inventor on 44+ Issued or pending patents for Qualcomm on wireless repeater concepts

WiDeFi, Inc., EVP/CTO, and Co-Founder, Director August 2005 - October 2007 

- Focused on aligning WiDeFi’s technology and product roadmaps to customer and market drivers 

o Strategic and Technical Marketing, Product Definition

o Market Analysis to estimate Market Size and Competitive Landscape

o Collaborated with customers and internal team to define and pursue product/customer 

opportunities (Retail Wi-Fi, Mesh Repeater, VoiP over Wi-Fi Repeater, Cellular Repeaters, WiMax Repeaters, In-Building Distribution Systems)

o Customer Development from initial contact, joint testing, first purchase order, to new product 

introduction

o Contributed to and managed WiDeFi’s IP portfolio

o Pursued fund raising from corporate and venture capital communities

WiDeFi, Inc., President, CEO, and Co-Founder, Director July 2002 - August 2005

- Led WiDeFi from inception to the recruitment of an expansion-stage CEO. 

- Principal duties:

o Direct Fundraising of initial seed and Series A Venture Capital

o General Management (Finance, Business Administration, Legal/Contracts and Organizational 

Development/Recruiting)

o Coordination of Board of Directors and Investors

o Sales (WiDeFi was Cash Flow positive prior to venture investment)

Tantivy Communications April 1998 - June 2002

Director of Strategic and Technical Marketing

- Business Development/Technical Due Diligence

- Represented Tantivy in a wide range of Wireless Broad Band Industry Conferences

- Intellectual Property Management and Strategy

o Represented Tantivy’s Patents and their value to External Companies

o Performed Validity, Infringement, and Value Analysis of Tantivy Patents for non-Tantivy products

- Industry Standards Representation for 3G Technologies

o TIA/3GPP2, Over 15 Technical Contributions/Papers

o T1P1 (3GPP Member)

- Project Management of an International Technology Transfer Team (S Korea)

- Performed System Architecture and Analysis 

Spectrian, Advanced Development and Technical Marketing 1995 - April 1998

- Interfaced with NORTEL/Qualcomm’s Product Management

- Performed Advanced Technology Development/Systems Analysis

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Proctor CV

Harris Corp. GCSD, September 1992 - 1995

Senior Engineer Signal Processing Section, Modems Group

Georgia Tech Research Institute, CSITL June 1991 - August 1992

Harris Corp.. ISD, Electro-optics, Co-op May 1990 - August 1990

- Acousto-optic signal processing

Standards Development

- Participated in architecting “Internet CDMA” (I-CDMA)

- Jointly led establishment of the Committee T1, working group T1P1.4 “WWINA” standardization 

effort, which stands for “Wireless Wideband Internet Access” 

o T1 Approved this system as the T1.723-2002 standard

- ATIS approved as ATIS0700723-2002 I-CDMA Spread Spectrum Systems Air Interface Standard

- Participated in 3GPP2 Standards Developments (including 15+ technical contributions)

Intellectual Property

- More than 320 Issued U.S. Patents

- More than 700 Issued or Pending International Patent Applications (WIPO)

- Patents Cited at the USPTO more than 6000 times

- 55+ Patents Assigned to Intel

- 45+ Patents Assigned to Qualcomm

- 16+ Patents designated as “Standards Essential” for UMTS (WCDMA)

- 6+ Patents designated as “Standards Essential” for LTE

Testifying Expert Experience

SPH Am., LLC v. Acer, Inc., 09CV02535-CAB MDD, 2012 WL 1344515 (S.D. Cal. Apr. 18, 2012).

Testifying Expert offering opinions on validity for the defense. The technology related to WCDMA 

modulation techniques. Resulted in settlement prior to trial.

WI-LAN USA, INC. and WI-LAN INC. v. ELEFONAKTIEBOLAGET LM ERICSSON and ERICSSON INC., 

Case No. l:12-23569-Civ (S.D. FL)

Testifying expert offering opinions on infringement for the defense. The technology involved LTE 

“contention free” handover (CFRA), and Media Access Control (MAC) layer messaging for Quality of 

Service (QOS). Resulted in a summary judgement finding of non-infringement for the defense, and 

settlement after appeal.

U.S. ETHERNET INNOVATIONS, LLC. V. STMICROELECTRONICS, INC., 

Civil Action No. 6:12-cv-4181-MHS-JDL

Testifying expert offering opinions on both validity and infringement for the defense. The 

technology related to Ethernet devices. Resulted in settlement prior to trial.

UNWIRED PLANET. V. SQUARE, INC., 

Case No. 3:13-CV-00579-RCJ-WGC, DISTRICT OF NEVADA,

Case CBM2014-00156, Case IPR2014-01164, Case IPR2014-01165, UNITED STATES PATENT TRIAL 

AND APPEAL BOARD, 

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Proctor CV

Provided testimony related to claim construction, and validity for the defense. The technology 

was related to location based services (LBS). The case resulted in a finding by the Patent Trial and 

Appeal Board of unpatentability of all asserted claims. 

PRISM TECHNOLOGIES LLC. V. T-MOBILE USA, INC., Case No. 12-CV-124

Testifying expert at trial, and deposition offering opinions on both validity and infringement for the 

defense. The technology was related to SIM/USIM/ISIM based authentication in UMTS, LTE, and IMS 

networks. The case resulted in a jury verdict of non-infringement.

FASTVDO LLC. V. AT&T Mobility LLC, AT&T Services, Inc., and Apple Inc., 

Case No. 3:16-cv-00385-H-WVG 

Engaged by Apple as the testifying expert offering opinions on infringement for the defense. The 

technology was related to Forward Error Correction (FEC) and voice codecs in GSM and WCDMA 

standards, including detailed FEC performance simulations. The case was concluded based upon an

IPR outcome finding unpatentable subject matter by the PTAB.

BLACKBERRY LIMITED V. BLU PRODUCTS, INC.,

Case No.: 16-23535-CIV-MORENO

Engaged by Blackberry as the testifying expert offering opinions on infringement for the plaintiff. 

The technology involved WCDMA and battery saving techniques in Radio Resource Control (RRC) 

states. The case was settled between the parties prior to trial.

CELLULAR COMMUNICATIONS EQUIPMENT LLC V. AT&T Inc., and Apple Inc.

Case No.: 2:15-cv-00576-RWS-RSP 

Engaged engaged by Apple as the testifying expert offering opinions on validity and benefits of 

the alleged inventions for the defense. The technology involved Media Access Control (MAC) messaging 

for LTE (Power Headroom Reporting) and LTE Advanced (CSI reporting for Carrier Aggregation). The 

case resulted in summary judgement for the defense.

GENERAL ACCESS SOLUTIONS, LTD. v. Sprint Corporation et al.

Civil Action No. 2:16-cv- 00465 (E.D. Tex.) and PTAB Proceedings (IPR2017-01885 (Patent 7,173,916 

B2) IPR2017-01887 (Patent 6,891,810 B2) IPR2017-01889 (Patent 7,230,931 B2),

Engaged by Sprint to provide expert testimony relating to claim construction, and validity for the 

defense before the Patent Trial and Appeal Board (PTAB) relating to an Inter Partes Review petition, 

providing multiple expert declarations, and deposition testimony. The technology related to Adaptive 

Modulation and Coding (AMC) in a wireless system; Adaptive Beamforming, Sectorization, and MultiInput Multi-Output (MIMO). All trials were instituted by the PTAB Board, with a finding of all petitioned 

claims unpatentable for two of the three patents.

TC TECHNOLOGY LLC. V., Sprint Corporation and Sprint Spectrum, L.P

Case 1:16-cv-00153-RGA 

Engaged by Sprint to provide expert testimony relating to validity and infringement by the 

defense, in the district of Delaware. The technology related to OFDMA and SC-FDMA use in the LTE 

uplink, for multiplexing transmissions from different UEs utilizing mutually exclusive OFDM subcarriers. 

The matter was resolved.

Mobility Workx, LLC v T-Mobile US, Inc.

Civil Action No. 4:17-cv-00567-ALM 

Retained by the defendant, and provided declarations and deposition for claim construction, engaged for 

both invalidity and non-infringement analysis and testimony. This matter relates to LTE handover, and 

Mobile IP. The case was settled between the parties prior to trial.

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Mobility Workx, LLC v Cellco Partnership d/b/a Verizon Wireless

Case No. 4:17-cv-872-ALM 

Retained by the defendant, engaged for both invalidity and non-infringement analysis and testimony. 

This matter relates to LTE handover, and Mobile IP. The case further related to 3GPP compliance testing 

techniques. This matter was resolved during trial preparation. 

Uniloc USA, Inc., et al. v. Apple Inc. 

No. 18-cv-158 and 18-cv-161, engaged by Apple as a technical and testifying expert. This matter relates 

to Quality of Service aspect of 3G UMTS (WCDMA), and the request and allocation of uplink resources in 

LTE. The matter was stayed, pending result of PTAB IPR Trial.

Wi-LAN v. LG, 

Case No. Case No.: 3:18-cv-01577-H-BGS 

Engaged by LG as a technical and testifying expert. The technology involved LTE “contention free” 

handover (CFRA), Media Access Control (MAC) layer messaging for bandwidth management and Quality 

of Service (QOS). This matter was resolved.

Fractus, S.A. v. Sprint Communications Company, L.P. et al., 

Civil Action No. 2:18-cv-00135 (E.D. Tex.), Engaged by Sprint and Verizon Wireless as a technical and 

testifying expert for invalidity. The technology involved design aspects of antenna element placement in 

multiband antenna arrays for use at cellular base stations. This matter was resolved.

Wilson Electronics, LLC v.Cellphone-Mate,Inc. dba SureCall,

Case No. 2:17-cv- 00305-DB (District of Utah)

Retained by the Wilson Electronics, and engaged for both invalidity and non-infringement analysis and 

testimony in both district court and in ITU proceedings. This matter relates to cellular multi-band wireless 

signal boosters / repeaters. This matter was resolved.

Sol IP, LLC v Joint Defense Group (AT&T, Ericsson, Nokia, Sprint, Verizon)

Civil Action No. 2:18-cv-00526 (E.D. Tex.)

Retained by each of the defendants, and engaged to provide testimony relating to infringement of the 

asserted claims for 8 of the asserted patents. The subject matter related to random access, paging, 

resource allocation, and carrier aggregation in LTE. The matter was resolved.

Polaris PowerLED Technologies, LLC v. TCL Corporation, et al., C.D. California Civil Action No.: 8:20-cv00127-JVS-DFMBGL Ref. No.: 16725-7 and 16725-8 

Engaged by TCL and Hisense to provide expert testimony in district court and to provide a declaration as 

an expert in an Inter Party Review (IPR) proceeding before the U.S Patent Trial and Appeals Board. The 

subject matter related to power supply circuitry for use in backlight displays and U.S. Pat. No 11,011,752. 

The IPR was instituted, and the proceedings were terminated following settlement.

SmartSky Networks v. Wireless Systems Solutions, LLC; DAG Wireless Solutions, et al., M.D. North 

Carolina (Case No. 1:20-cv-00834-NCT-LPA), and related arbitration proceedings

Engaged by SmartSky to provide expert testimony related to a trade secret dispute in district court, and 

an arbitration proceeding. The technology related to air to ground internet service for aircraft using a 

proprietary LTE derived system including airborne radios and ground stations allowing for increased 

range and velocity beyond that which can be provided by standards based LTE systems. The system 

includes advanced UE and eNodeB architectures, and modified LTE protocols. I provided expert reports 

and declarations in both district court and arbitration. I further provided live testimony before an 

arbitration panel. The arbitration panel found in favor of SmartSky, achieving a successful injunction 

against WSS/DAG. 

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Dali Wireless v. JMA Wireless, Civil Action 1:99-mc-09999 

Engaged by JMA Wireless to provide several declarations as an expert in an Inter Party Review (IPR) 

proceeding before the U.S Patent Trial and Appeals Board, and further testimony relating to the district 

course cases. The subject matter related to in-building wireless signal distribution systems utilizing digital 

network (CPRI / IP packetized) interfaces and as well as LTE eNodeB architectures. This matter was 

resolved pending expert discovery.

Dali Wireless v. Corning Optical Communications LLC, No. 3:20-cv-06469 (N.D. Cal.) and Dali Wireless, 

Inc. v. Corning Incorporated et al., No. 6:20-cv-00827 (W.D. Tex.)

Engaged by Corning to provide several declarations as an expert in an Inter Party Review (IPR) 

proceeding before the U.S Patent Trial and Appeals Board and further testimony relating to the district 

course cases. The subject matter related to distributed antenna systems for in-building wireless signal 

distribution as well as intercell frequency reuse and interference management techniques. This matter 

was resolved pending expert discovery.

Flexiworld Technologies, Inc. v. Amazon.com, Inc., et al., Case No. 6:20-cv-00553-ADA (W.D. Texas), 

and Case No. 2:21-cv-01055-DGE (W.D. Washington, Tacoma)

Engaged by Amazon to provide testimony for district court matter in the Western District of Texas. The 

matter related to approaches for mobile devices to utilize Bluetooth to interface with smart speakers and 

servers, allowing for the request of content to be played by an output device (speaker) based upon 

specific requests, including in some cases voice requests. This matter was transferred to Western District 

of Washington, Tacoma Division and remains pending.

WSOU Investments, LLC d/b/a Brazos Licensing and Development v. Huawei Technologies Co., Ltd. et 

al., 6:20-cv-00544 (W.D. Tex.)

Engaged by Huawei to provide expert testimony in district court. The matter related to LTE protocols and 

signaling, Hybrid ARQ, and scheduling of retransmissions relative to new transmissions from a UE to an 

eNodeB. I provided a claim construction declaration, prior to the matter being resolved. 

Ericsson, Inc. IPR petition of 7,532,865, (TOT Power Control, S.L, Patent Owner)

Engaged by Ericsson, Inc. to provide a declaration as an expert in an Inter Party Review (IPR) 

proceeding before the U.S Patent Trial and Appeals Board, relating to US. Pat. No. 7,532,865. The matter 

involved “outer loop” power control techniques in WCDMA systems or other mobile devices. 

Sierra Wireless et al, IPR petition of 7,215,653 (Sisvel, Patent Owner).

Engaged by Sierra Wireless to provide a declaration as an expert in an Inter Party Review (IPR) 

proceeding before the U.S. Patent Trial and Appeals Board, relating to US. Pat. No. 7,215,653. This 

matter involved the control of uplink data rates and power control in a CDMA system called 1xEV-DO 

developed within the 3GPP2 standards, in which I personally participated. The IPR was instituted by the 

PTAB, and all claims were found unpatentable.

KAIFI LLC v. T-Mobile US, Inc. et al., Case No. 2:20-cv-281-JRG (E.D. Tex.)

Engaged by T-Mobile to provide expert testimony for both (in)validity and (non)infringement for a district 

court matter in the Eastern District of Texas. The matter involved a mobile device’s roaming between an 

outdoor cellular / LTE networks and an indoor Wi-Fi network. It further included approaches for the LTE 

core network to perform the selection of transmission paths of VoLTE and VoWiFi signals involving the 

LTE core (EPC), including the ePDG, and IMS networks. This matter settled.

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KAIFI LLC v. Verizon Wireless. et al., Civil Action No. 2:20-cv-00280-JRG (E.D. Tex.)

Engaged by Verizon to provide expert testimony relating to (in)validity for a district court matter in the 

Eastern District of Texas. The matter involved a mobile device’s roaming between an outdoor cellular / 

LTE networks and an indoor Wi-Fi network. It further included approaches for the LTE core network to 

perform the selection of transmission paths of VoLTE and VoWiFi signals involving the LTE core (EPC), 

including the ePDG, and IMS networks. This matter settled.

NEO Wireless, LLC v. DELL Technologies Inc. and DELL Inc., Case No. 6:21-cv-024-ADA (W.D. Tex.)

Engaged by Dell to provide expert testimony relating to claim construction, (in)validity and 

(non)infringement in the Western District of Texas, Waco Division. The matter involved LTE and 5G 

devices and standards aspects including signaling aspect associated with: OFDM/OFDMA, resource 

scheduling and frame structures, random access and ranging, transmit diversity and beamforming 

signaling. This matter was settled by the parties.

American Patents v. Xerox., Case No. 6:21- cv-636-ADA, (W.D. Tex.)

Engaged by Xerox to provide expert testimony relating to claim construction, (in)validity and 

(non)infringement in the Western District of Texas, Waco Division. The matter involved IEEE802.11

(WiFi) based systems relating to a number of patents, including Time and frequency synchronization in 

multi-input, multi-output (MIMO) systems, the assessment and management of interference in 802.11 

systems. This matter was resolved.

TurboCode, v. Dell Technologies Inc. and Dell Inc., Case No. Civil Action No. 6:21-cv-359 (W.D. of Tex.)

Engaged by Dell to provide expert testimony relating to claim construction, (in)validity and 

(non)infringement in the Western District of Texas, Waco Division. The matter involved 3G / WCDMA use 

and implementations of Turbo Coding in wireless transmission and reception. This matter was settled by 

the parties.

XR Communications d/b/a Vivato Technologies v. Microsoft Corporation, Case No: 6:21-cv-695 (WDTX) 

Engaged by Microsoft to provide expert testimony relating to claim construction, (in)validity and 

(non)infringement in the Western District of Texas. The matter involved the use of transmit beamforming, 

channel estimation and diversity techniques in IEEE802.11n, 802.11AC, and 802.11AX systems (WiFi). 

This matter was settled by the parties.

Finesse Wireless, LLC v. AT&T Mobility LLC; Cellco Partnership d/b/a Verizon Wireless; Nokia of 

America Corporation; Ericsson Inc., Case No. 2:21-CV-00063-JRG (E.D. TX).

Engaged by Nokia to provide expert testimony relating to claim construction, (in)validity and 

(non)infringement in the Eastern District of Texas. The matter involved aspects of LTE and 5G 

infrastructure relating to the cancelation of radio frequency intermodulation distortion produced in a 

transmitter from the receiver of the same base station, and involving both passive intermodulation (PIM) 

and active intermodulation from Power amplifiers (PA). This matter remains pending.

GODO KAISHA IP BRIDGE v Ericsson and Nokia Case No. 2:21-CV-213-JRG, Case No. 2:21-CV-215-

JRG (E.D. TX).

Engaged by Nokia and Ericsson to provide expert testimony relating to claim construction, (in)validity and 

(non)infringement in the Eastern District of Texas. The matter involved aspects of LTE and 5G 

infrastructure relating to the channel state information (CSI/CQI) configuration and triggering for periodic 

and aperiodic, wideband and sub-band reports from LTE/NR UEs. This matter was settled prior to trail.

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Microsoft Corporation, IPR petition of ‘414, ‘763, ‘988, ‘890 (Lemco Corporation, Patent Owner).

Engaged by Microsoft Corporation to provide several declarations as an expert in Inter Party Review 

(IPR) proceedings before the U.S. Patent Trial and Appeals Board, relating to US. Pat. Nos. 7,653,414, 

7,548,763, 7,855,988, and 9,191,980. These matters involved distributed cellular network infrastructure 

architectures. The patents relate to software implementations of cellular network infrastructure, including 

a distributed mobile architecture server and a distributed mobile architecture gateway. This matter 

remains pending.

Ozmo v. Dell, Case No: 6:22-cv-00642-ADA (WDTX)

Engaged by Dell to testimony related to claim construction, (in)validity and (non)infringement relating to 

U.S Pat. Nos. 8,599,814; 9,264,991; 10,873,906; 11,012,934; 11,122,504; and 11,252,659 and share 

common provisional applications. The subject matter of the patents relate to seamlessly integrating 

short-range wireless personal area networks (“WPANs”) into longer-range wireless local area networks. 

(“WLANs”). 

XR Communications d/b/a Vivato Technologies v. ASUSTek Computer Inc., Computer Inc.

Case No: 6:21-cv-00622-ADA (WDTX) 

Engaged by ASUSTek to provide expert testimony relating to claim construction, (in)validity and 

(non)infringement in the Western District of Texas. The matter involved the use of transmit beamforming, 

channel estimation and diversity techniques in IEEE802.11n, 802.11ac, and 802.11ax systems (WiFi). 

This matter was settled.

Cobblestone Wireless, LLC v AT&T, T-Mobile, and Verizon.

Case No: 2:2-cv-00474, 2:23-cv-00477, 2:23-cv-00478 (E.D. Tex.)

Engaged by Joint Defense Group (including Nokia and Ericsson) to provide several declarations as an 

expert in Inter Party Review (IPR) proceedings before the U.S. Patent Trial and Appeals Board. Provided 

declarations for US Pat. Nos. 10,368,361, 9,094,888, 8,554,196, 10,368,361, 8,891,347. I was further 

engaged to provide expert testimony relating to Interparty claim construction, (in)validity and 

(non)infringement in the Eastern District of Texas. The matter involved various aspects of 3GPP LTE and 

5G transmit beamforming, including: handoff, beam and frequency resource management, beam 

management and selection, adaptation based upon Channel State information (CSI), This matter 

remains pending.

Samsung v. Cobblestone Wireless, LLC.

Engaged by Samsung to provide several declarations as an expert in Inter Party Review (IPR) 

proceedings before the U.S. Patent Trial and Appeals Board. Provided declarations for US Pat. Nos. 

10,368,361, 9,094,888, 8,554,196, 10,368,361, 8,891,347. The matter involved various aspects of 3GPP 

LTE and 5G transmit beamforming, including: handoff, beam and frequency resource management, beam 

management and selection, adaptation based upon Channel State information (CSI), This matter 

remains pending.

Lenovo (United States) Inc. v. ASUSTeK Computer Inc.; ASUS Computer International.

Case No.: 23-CV- 5892 (N.D. Cal.), ITC matter Inv. No. 337-TA-1382

Engaged by AsusTek to provide opinions regarding claim construction, validity and infringement of US. 

Pat. Nos. 7,792,066 and 10,952,203. The technology included Wake on Wireless Lan utilizing magic 

packets and the PS mode of 802.11 devices, and personal computer architecture and power states 

(APM,ACPI). The technology further included the use of triggered based uplink OFDMA resource 

allocation in WiFi 6 (802.11AX). This matter remains pending.

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List of Issued U.S. Patents

United States Pat. No. Title

5,550,549 Transponder system and method

5,687,196 Range and bearing tracking system with multipath rejection

5,898,338 Adaptive digital predistortion linearization and feed-forward correction of RF power amplifier

5,929,704 Control of RF error extraction using auto-calibrating RF correlator

5,949,283 Adaptive digital predistortion linearization and feed-forward correction of RF power amplifier

5,960,047 System and method for transmitting information signals

6,078,216 Aliased wide band performance monitor for adjusting predistortion and vector modulator control parameters of RF amplifier

6,100,843 Adaptive antenna for use in same frequency networks

6,212,220 Method and apparatus for creating non-interfering signals using non-orthogonal techniques

6,222,832 Fast Acquisition of traffic channels for a highly variable data rate reverse link of a CDMA wireless communication system

6,239,756 Antenna array with housing

6,301,291 Pilot symbol assisted modulation and demodulation in wireless communication systems

6,304,215 Method of use for an adaptive antenna in same frequency networks

6,362,790 Antenna array structure stacked over printed wiring board with beamforming components

6,388,999 Dynamic bandwidth allocation for multiple access communications using buffer urgency factor

6,396,456 Stacked dipole antenna for use in wireless communications systems

6,400,317 Method and apparatus for antenna control in a communications network

6,404,386 Adaptive antenna for use in same frequency networks

6,421,336 Variable rate orthogonally coded reverse link structure

6,448,938 Method and apparatus for frequency selective beam forming

6,452,913 Fast acquisition of traffic channels for a highly variable data rate reverse link of a CDMA wireless communication system

6,456,835 Arbitration method for high power transmissions in a code division multiple access system

6,473,036 Method and apparatus for adapting antenna array to reduce adaptation time while increasing array performance

6,515,635 Adaptive antenna for use in wireless communication systems

6,518,920 Adaptive antenna for use in same frequency networks

6,542,481 Dynamic bandwidth allocation for multiple access communication using session queues

6,545,990 Method and apparatus for a spectrally compliant cellular communication system

6,545,994 Access probe acknowledgment including collision detection to avoid oversetting initial power level

6,563,809 Subscriber-controlled registration technique in a CDMA system

6,600,456 Adaptive antenna for use in wireless communication systems

6,614,776 Forward error correction scheme for high rate data exchange in a wireless system

6,678,260 System and method for maintaining wireless channels over a reverse link of a CDMA wireless communication system

6,707,804 Fast acquisition of traffic channels for a highly variable data rate reverse link of a CDMA wireless communication system

6,785,323 Variable rate coding for forward link

6,788,268 Method and apparatus for frequency selective beam forming

6,792,290 Method and apparatus for performing directional re-scan of an adaptive antenna

6,801,564 Reverse link correlation filter in wireless communication systems

6,804,223 Reverse link pilot integrated with block codes

6,873,293 Adaptive receive and omnidirectional transmit antenna array

6,888,504 Aperiodic array antenna

6,888,807 Applying session services based on packet flows

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6,894,653 Low cost multiple pattern antenna for use with multiple receiver systems

6,904,079 Access channel structure for wireless communication system

6,911,879 Electronic phase shifter with enhanced phase shift performance

6,917,581 Use of orthogonal or near orthogonal codes in reverse link

6,917,642 Method for using a non-orthogonal pilot signal with data channel interference cancellation

6,925,070 Time-slotted data packets with a preamble

6,928,064 Fast acquisition of traffic channels for a highly variable data rate reverse link of a CDMA wireless communication system

6,933,887 Method and apparatus for adapting antenna array using received predetermined signal

6,937,562 Application specific traffic optimization in a wireless link

6,940,842 System and method for maintaining wireless channels over a reverse link of a CDMA wireless communication system

6,941,152 Wireless subscriber network registration system for configurable services

6,954,448 Alternate channel for carrying selected message types

6,956,840 Power control protocol for highly variable data rate reverse link of a wireless communication system

6,973,140 Maximizing data rate by adjusting codes and code rates in CDMA system

6,989,797 Adaptive antenna for use in wireless communication systems

6,992,546 Electronic phase shifter with enhanced phase shift performance

7,002,902 Method and system for economical beam forming in a radio communication system

7,006,428 Method for allowing multi-user orthogonal and non-orthogonal interoperability of code channels

7,006,483 Qualifying available reverse link coding rates from access channel power setting

7,009,559 Method and apparatus for adapting antenna array using received predetermined signal

7,015,773 Electronic phase shifter with enhanced phase shift performance

7,034,759 Adaptive receive and omnidirectional transmit antenna array

7,072,316 Subscriber-controlled registration technique in a CDMA system

7,079,523 Maintenance link using active/standby request channels

7,092,430 Method for using a non-orthogonal pilot signal with data channel interference cancellation

7,113,786 Antenna adaptation to manage the active set to manipulate soft hand-off regions

7,145,964 Maximizing data rate by adjusting codes and code rates in CDMA system

7,176,844 Aperiodic array antenna

7,184,417 Power control protocol for highly variable data rate reverse link of a wireless communication system

7,187,904 Frequency translating repeater with low cost high performance local oscillator architecture

7,200,134

Wireless area network using frequency translation and retransmission based on modified protocol messages for enhancing 

network coverage

7,215,297 Adaptive antenna for use in wireless communication systems

7,218,623 Coded reverse link messages for closed-loop power control of forward link control messages

7,221,664 Transmittal of heartbeat signal at a lower level than heartbeat request

7,224,685 Method of detection of signals using an adaptive antenna in a peer-to-peer network

7,227,907 Antenna adaptation comparison method for high mobility

7,230,935 Physical layer repeater with selective use of higher layer functions based on network operating conditions

7,233,627 Method for searching pilot signals to synchronize a CDMA receiver with an associated transmitter

7,233,771 Non-frequency translating repeater with downlink detection for uplink and downlink synchronization

7,253,783 Low cost multiple pattern antenna for use with multiple receiver systems

7,272,169 Reverse link correlation filter in wireless communication systems

7,289,827 Method and apparatus for performing directional re-scan of an adaptive antenna

7,308,285 Antenna adaptation in a time division duplexing system

7,366,154 Forward error correction scheme for high rate data exchange in a wireless system

7,394,791 Multi-detection of heartbeat to reduce error probability

7,425,928 Method and apparatus for frequency selective beam forming

7,426,241 Variable rate coding for forward link

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7,428,263 Method for using a non-orthogonal pilot signal with data channel interference cancellation

7,433,340 Staggering forward and reverse wireless channel allocation timing

7,447,187 Reverse link pilot integrated with block codes

7,463,200 Directional antenna configuration for TDD repeater

7,463,201 Aperiodic array antenna

7,480,280 Fast acquisition of traffic channels for a highly variable data rate reverse link of a CDMA wireless communication system

7,483,473 Access channel structure for wireless communication system

7,496,072 System and method for controlling signal strength over a reverse link of a CDMA wireless communication system

7,502,351 Alternate channel for carrying selected message types

7,502,424 Maximizing data rate by adjusting codes and code rates

7,528,789 Adaptive antenna for use in wireless communication systems

7,529,264 Use of orthogonal or near orthogonal codes in reverse link

7,551,663 Use of correlation combination to achieve channel detection

7,580,674 Intelligent interface for controlling an adaptive antenna array

7,586,880 Method of detection of signals using an adaptive antenna in a peer-to-peer network

7,592,969 Multiple-antenna device having an isolation element

7,593,380 Variable rate forward error correction for enabling high performance communication

7,602,749 Fast acquisition of traffic channels for a highly variable data rate reverse link of a CDMA wireless communication system

7,613,227 Reverse link correlation filter in wireless communication systems

7,701,903 Power control protocol for highly variable data rate reverse link of a wireless communication system

7,733,285 Integrated, closely spaced, high isolation, printed dipoles

7,746,830 System and method for maintaining wireless channels over a reverse link of a CDMA wireless communication system

7,773,566

System and method for maintaining timing of synchronization messages over a reverse link of a CDMA wireless 

communication system

7,787,408 Wireless repeater with master/slave configuration

7,826,437 Variable rate coding for enabling high performance communication

7,889,702 Time-slotted data packets with a preamble

7,893,889 Multiple-antenna device having an isolation element

7,907,513 Superimposed composite channel filter

7,907,891

Physical layer repeater utilizing real time measurement metrics and adaptive antenna array to promote signal integrity and 

amplification

7,911,985 Automatic gain control and filtering techniques for use in on-channel repeater

7,911,993 Method and apparatus for allowing soft handoff of a CDMA reverse link utilizing an orthogonal channel structure

7,916,772 Method for searching pilot signals to synchronize a CDMA receiver with an associated transmitter

7,936,728

System and method for maintaining timing of synchronization messages over a reverse link of a CDMA wireless 

communication system

7,936,736 Enforcing policies in wireless communication using exchanged identities

7,944,845 Application specific traffic optimization in a wireless link

7,990,904 Wireless network repeater

8,023,885 Non-frequency translating repeater with downlink detection for uplink and downlink synchronization

8,027,642 Transmission canceller for wireless local area network

8,045,536 Forward error correction scheme for high rate data exchange in a wireless system

8,059,727 Physical layer repeater configuration for increasing MIMO performance

8,060,009 Wireless local area network repeater with automatic gain control for extending network coverage

8,068,474 Variable rate coding for enabling high performance communication

8,072,944 Staggering forward and reverse wireless channel allocation timing

8,072,958 Reverse link pilot integrated with block codes

8,078,100 Physical layer repeater with discrete time filter for all-digital detection and delay generation

8,089,913 Physical layer repeater with selective use of higher layer functions based on network operating conditions

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8,090,359

Exchanging identifiers between wireless communication to determine further information to be exchanged or further services 

to be provided

8,090,616 Visual identification information used as confirmation in a wireless communication

8,095,067 Frequency translating repeater with low cost high performance local oscillator architecture

8,111,645 Wireless local area network repeater with detection

8,116,239 Use of a filterbank in an adaptive on-channel repeater utilizing adaptive antenna arrays

8,116,749 Protocol for anonymous wireless communication

8,121,535 Configuration of a repeater

8,122,134 Reducing loop effects in a wireless local area network repeater

8,134,980 Transmittal of heartbeat signal at a lower level than heartbeat request

8,139,546 System and method for maintaining wireless channels over a reverse link of a CDMA wireless communication system

8,155,096 Antenna control system and method

8,175,120 Minimal maintenance link to support synchronization

8,194,783 Variable rate coding for a forward and reverse link

8,204,140 Subscriber unit and method for variable forward error correction (FEC) decoding

8,238,912 Non-intrusive detection of enhanced capabilities at existing cellsites in a wireless data communication system

8,259,687 Dynamic bandwidth allocation for multiple access communications using buffer urgency factor

8,259,744 Use of orthogonal or near orthogonal codes in reverse link

8,265,630 Antenna adaptation to manage the active set to manipulate soft hand-off regions

8,274,954 Alternate channel for carrying selected message types

8,285,201 Wideband echo cancellation in a repeater

8,315,294 Method for searching pilot signals to synchronize a CDMA receiver with an associated transmitter

8,321,542 Wireless channel allocation in a base station processor

8,358,969 Feedback delay control in an echo cancellation repeater

8,363,590 Physical layer repeater with roaming support based on multiple identifiers

8,369,277 Signaling for wireless communications

8,369,842

Exchanging identifiers between wireless communication to determine further information to be exchanged or further services 

to be provided

8,370,955 Enforcing policies in wireless communication using exchanged identities

8,374,592

Exchanging identifiers between wireless communication to determine further information to be exchanged or further services 

to be provided

8,385,305 Hybrid band intelligent backhaul radio

8,385,818 Delay control to improve frequency domain channel estimation in an echo cancellation repeater

8,385,896

Exchanging identifiers between wireless communication to determine further information to be exchanged or further services 

to be provided

8,385,913 Using a first wireless link to exchange identification information used to communicate over a second wireless link

8,422,540 Intelligent backhaul radio with zero division duplexing

8,437,329 Variable rate coding for enabling high performance communication

8,437,330 Antenna control system and method

8,463,255 Method and apparatus for a spectrally compliant cellular communication system

8,467,353 Time-slotted data packets with a preamble

8,467,363 Intelligent backhaul radio and antenna system

8,477,665 Method in a wireless repeater employing an antenna array for interference reduction

8,498,234 Wireless local area network repeater

8,502,733 Transmit co-channel spectrum sharing

8,503,926 IQ imbalance compensation in interference cancellation repeater using a zero-IF radio architecture

8,509,268 Minimal maintenance link to support sychronization

8,509,835 Reverse link initial power setting using effective radiated power message to compute path loss

8,521,862 Wireless channel allocation in a base station processor

8,526,401 Power control protocol for highly variable data rate reverse link of wireless communication system

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Proctor CV

8,537,656 Method for compensating for multi-path of a CDMA reverse link utilizing an orthogonal channel structure

8,542,623 Use of RF reference in a digital baseband interference cancellation repeater

8,553,610 Interference cancellation repeater incorporating a non-linear element

8,559,379 Method and apparatus for mitigating oscillation between repeaters

8,576,805 Subscriber-controlled registration technique in a CDMA system

8,582,552 Maintaining a maintenance channel in a reverse link of a wireless communications system

8,599,906 Closed form calculation of temporal equalizer weights used in a repeater transmitter leakage cancellation system

8,605,702 Maintaining a maintenance channel in a reverse link of a wireless communications system

8,619,837 Use of adaptive antenna array in conjunction with an on-channel repeater to improve signal quality

8,630,211 Hybrid radio architecture for repeaters using RF cancellation reference

8,638,839 Intelligent backhaul radio with co-band zero division duplexing

8,638,877 Methods, apparatuses and systems for selective transmission of traffic data using orthogonal sequences

8,649,418 Enhancement of the channel propagation matrix order and rank for a wireless channel

8,676,131 Method and apparatus for allowing soft handoff of a CDMA reverse link utilizing an orthogonal channel structure

8,687,606 Alternate channel for carrying selected message types

8,709,092 Periprosthetic fracture management enhancements

8,737,343 Coded reverse link messages for closed-loop power control of forward link control messages

8,755,360 Method and apparatus for a spectrally compliant cellular communication system

8,755,473 Method and apparatus for detecting rapid changes in signaling path environment

8,774,079 Repeater techniques for multiple input multiple output utilizing beam formers

8,787,248 Method in a wireless repeater employing an antenna array including vertical and horizontal feeds for interference reduction

8,790,321 Apparatus, system, and method for harvesting improved bone graft material with reamer-irrigator-aspirator (RIA) device

8,792,458 System and method for maintaining wireless channels over a reverse link of a CDMA wireless communication system

8,811,367 Qualifying available reverse link coding rates from access channel power setting

8,824,442 Intelligent backhaul radio with adaptive channel bandwidth control

8,830,977 Reverse link pilot integrated with block codes

8,842,642 Transmitting acknowledgement messages using a staggered uplink time slot

8,849,186 Repeater communication using inserted low power sequences

8,849,698

Exchanging identifiers between wireless communication to determine further information to be exchanged or further services 

to be provided

8,861,429 Selective carrier amplification in a wireless repeater

8,885,688 Control message management in physical layer repeater

8,897,340 Enhancement of the channel propagation matrix order and rank for a wireless channel

8,908,654 Dynamic bandwidth allocation for multiple access communications using buffer urgency factor

8,937,874 Adjusting repeater gains based upon received downlink power level

8,942,216 Hybrid band intelligent backhaul radio

8,948,235 Intelligent backhaul radio with co-band zero division duplexing utilizing transmitter to receiver antenna isolation adaptation

8,958,457 Channel structure for a wireless communication system

8,964,909 Maximizing data rate by adjusting codes and code rates

8,989,762 Advanced backhaul services

9,014,118 Signaling for wireless communications

9,019,930 Coded reverse link messages for closed-loop power control of forward link control messages

9,020,009 Inserted pilot construction for an echo cancellation repeater

9,020,621 Network based media enhancement function based on an identifier

9,038,129 Enforcing policies in wireless communication using exchanged identities

9,042,400 Multi-detection of heartbeat to reduce error probability

9,135,612 Proximity detection, virtual detection, or location based triggering of the exchange of value and information

9,161,164

Exchanging identifiers between wireless communication to determine further information to be exchanged or further services 

to be provided

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Proctor CV

9,179,240 Transmit co-channel spectrum sharing

9,185,604 Qualifying available reverse link coding rates from access channel power setting

9,210,616 Application specific traffic optimization in a wireless link

9,225,395 Antenna control system and method

9,226,295 Hybrid band radio with data direction determined by a link performance metric

9,237,209 Time-slotted data packets with a preamble

9,247,510 Use of correlation combination to achieve channel detection

9,252,857 Embedded control signaling for wireless systems

9,294,222 Variable rate coding for forward and reverse link

9,301,274 Minimal maintenance link to support synchronization

9,306,658 Method and apparatus for a spectrally compliant cellular communication system

9,306,703 Variable rate coding for enabling high performance communication

9,307,532 Signaling for wireless communications

9,325,398 Method for installing a backhaul radio with an antenna array

9,325,477 Alternate channel for carrying selected message types

9,345,523 Periprosthetic fracture management enhancements

9,363,759 Power control protocol for highly variable data rate reverse link of a wireless communication system

9,369,235 Maximizing data rate by adjusting codes and code rates

9,374,822 Method for installing a hybrid band radio

9,397,808 Reverse link pilot integrated with block codes

9,398,120 Time-slotted data packets with a preamble

9,456,376 Subscriber-controlled registration technique in a CDMA system

9,456,428 Method and apparatus for allowing soft handoff of a CDMA reverse link utilizing an orthogonal channel structure

9,460,433 Proximity detection, virtual detection, or location based triggering of the exchange of value and information

9,490,918 Zero division duplexing MIMO backhaul radio with adaptable RF and/or baseband cancellation

9,496,915 Use of orthogonal or near orthogonal codes in reverse link

9,497,761 Qualifying available reverse link coding rates from access channel power setting

9,522,066 Periprosthetic fracture management enhancements

9,525,923 Multi-detection of heartbeat to reduce error probability

9,554,061 Smart hub

9,555,169 Apparatus for harvesting improved bone graft material utilizing an implantable biodegradable filter

9,572,163 Hybrid band radio with adaptive antenna arrays

9,577,733 Method for installing a backhaul link with multiple antenna patterns

9,655,062 System and method for coordination of wireless maintenance channel power control

9,661,583 Reverse link initial power setting using effective radiated power message to compute path loss

9,686,713 Application specific traffic optimization in a wireless link

9,686,790 Signaling for wireless communications

9,713,019 Self organizing backhaul radio

9,713,157 Method for installing a backhaul link with alignment signals

9,775,115 Antenna control system and method

9,780,930 Communicating reference and data information in a wireless network

9,781,626 Wireless channel allocation in a base station processor

9,807,714 Minimal maintenance link to support synchronization

9,832,664 Receiving and transmitting reverse link signals from subscriber units

9,867,101 Method and apparatus for allowing soft handoff of a CDMA reverse link utilizing an orthogonal channel structure

9,872,196 Subscriber-controlled registration technique in a CDMA system

9,876,530 Advanced backhaul services

9,913,271 Qualifying available reverse link coding rates from access channel power setting

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Proctor CV

9,913,722 Periprosthetic fracture management enhancements

9,924,468 Antenna control system and method

9,936,500 Transmitting acknowledgement messages using a staggered uplink time slot

9,954,635 Variable rate coding for enabling high performance communication

9,974,116 Handoff to base station having enhanced capabilities

10,057,700 Smart hub

10,063,363 Zero division duplexing MIMO radio with adaptable RF and/or baseband cancellation

10,064,144 Use of correlation combination to achieve channel detection

10,129,888 Method for installing a fixed wireless access link with alignment signals

10,153,885 Alternate channel for carrying selected message types

10,204,357 Proximity detection, virtual detection, or location based triggering of the exchange of value and information

10,211,940 Use of orthogonal or near orthogonal codes in reverse link

10,237,760 Self organizing backhaul radio

10,284,253 Advanced backhaul services

10,286,123 Removable biocompatible substrate filter for a reaming and collection device

10,299,218 System and method for coordination of wireless maintenance channel power control

10,306,635 Hybrid band radio with multiple antenna arrays

10,356,782 Embedded control signaling for self-organizing wireless backhaul radio and systems

10,357,370 Periprosthetic fracture management enhancements

10,390,311 Maintaining a maintenance channel in a reverse link of a wireless communications system

10,638,468 Qualifying available reverse link coding rates from access channel power setting

10,687,161 Smart hub

10,687,950 Periprosthetic shoulder fracture repair

10,700,733 Advanced backhaul services

10,708,918 Electronic alignment using signature emissions for backhaul radios

10,735,979 Self organizing backhaul radio

10,736,110 Method for installing a fixed wireless access link with alignment signals

10,762,532 Proximity detection, virtual detection, or location based triggering of the exchange of value and information

10,805,887 Maintaining a maintenance channel in a reverse link of a wireless communications system

10,821,030 Apparatus and method for a temperature released adhesive structure for use with bandages

10,874,520 Combination intra-medullary and extra-medullary fracture stabilization with aligning arm

10,932,267 Hybrid band radio with multiple antenna arrays

10,966,201 Embedded control signaling for self-organizing wireless backhaul radio and systems

11,000,380 Combination intra-medullary and extra medullary fracture stabilization with aligning arm

11,013,605 Combination intra-medullary and extra medullary fracture stabilization with aligning arm

11,074,615 Efficient and secure communication using wireless service identifiers

11,219,527 Combination intra-medullary and extra-medullary fracture stabilization with aligning arm

11,238,499 Proximity detection, virtual detection, or location based triggering of the exchange of value and information

11,260,164 Negative pressure wound therapy dressing and related apparatus

11,303,322 Advanced backhaul services

11,310,614 Smart Hub

11,334,918

Exchanging identifiers between wireless communication to determine further information to be exchanged or further services 

to be provided

11,343,060 Zero division duplexing MIMO radio with adaptable RF and/or baseband cancellation

11,343,684 Self organizing backhaul radio

11,437,740 Removable biocompatible substrate filter for a reaming and collection device

11,443,344 Efficient and secure communication using wireless service identifiers

11,6333,217 Reduction and fixation apparatus for calcaneal fracture

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Proctor CV

11,684,518 Apparatus and method for a temperature released adhesive structure for use with bandages

11,687,971 Efficient and secure communication using wireless service identifiers

11,723,776 Periprosthetic shoulder fracture repair

11,995,685 Efficient and secure communication using wireless service identifiers

D532780 Wireless repeater housing

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