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IN THE UNITED STATES PATENT AND TRADEMARK OFFICE

In re Patent of: Sorour Falahati, et al.


U.S. Patent No.: 10,470,203 Attorney Docket No.: 50095-0062IP1
Issue Date: November 5, 2019
Appl. Serial No.: 16/398,655
Filing Date: April 30, 2019
Title: SCHEDULING REQUEST RESOURCE CONFIGURATION

Mail Stop Patent Board


Patent Trial and Appeal Board
U.S. Patent and Trademark Office
P.O. Box 1450
Alexandria, VA 22313-1450

PETITION FOR INTER PARTES REVIEW OF UNITED STATES PATENT


NO. 10,470,203 PURSUANT TO 35 U.S.C. §§ 311–319, 37 C.F.R. § 42
Attorney Docket No 50095-0062IP1
IPR of U.S. Patent No. 10,470,203

TABLE OF CONTENTS

I. PETITIONER HAS STANDING....................................................................1


II. SUMMARY OF THE ’203 PATENT .............................................................1
A. Background of Related Technology .........................................................1
B. Brief Description.......................................................................................2
C. Summary of the Prosecution History of the ’203 Patent ..........................7
D. Effective Priority Date of the Claims of the ’203 Patent..........................9
E. Level of Ordinary Skill ...........................................................................10
III. CLAIM CONSTRUCTION ..........................................................................10
IV. APPLICATION OF PRIOR ART TO THE CHALLENGED CLAIMS ......10
A. Grounds ...................................................................................................11
B. Grounds 1, 2, and 3 .................................................................................13
1. Overview of TS 38.331 (EX1004) ................................................13
2. Overview of TS 38.213 (EX1005) ................................................16
3. Overview of R1-1720097 (EX1008) .............................................17
4. Overview of R1-1719932 (EX1006) .............................................18
5. Combinations of TS 38.331, TS 38.213, R1-1720097, and R1-
1719932 .........................................................................................19
6. TS 38.331 in combination with TS 38.213 (Ground 1), TS 38.331
in combination with TS 38.213 and R1-1720097 (Ground 2), and
TS 38.331 in combination with TS 38.213 and R1-1719932
(Ground 3) render obvious Claims 1-8 .........................................27
C. Ground 4 .................................................................................................44
1. Overview of Zhang (EX1007).......................................................44
2. Combination of TS 38.331, TS 38.213, R1-1719932, and Zhang.
.......................................................................................................48
3. TS 38.331 in combination with TS 38.213 and R1-1719932 and
further in combination with Zhang renders obvious Claims 4-8 ..53
V. PAYMENT OF FEES – 37 C.F.R. § 42.103 .................................................61
VI. CONCLUSION..............................................................................................61
VII. MANDATORY NOTICES UNDER 37 C.F.R § 42.8(a)(1).........................61
Real Party-In-Interest Under 37 C.F.R. § 42.8(b)(1) ....................................61
Related Matters Under 37 C.F.R. § 42.8(b)(2) ..............................................62
Lead And Back-Up Counsel Under 37 C.F.R. § 42.8(b)(3)..........................62
Service Information .......................................................................................62 

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EXHIBITS

EX1001 U.S. Patent No. 10,470,203

EX1002 File History for U.S. Patent No. 10,470,203

EX1003 Expert Declaration of Jonathan Wells, Ph.D.

EX1004 3rd Generation Partnership Project; Technical Specification


Group Radio Access Network NR Radio Resource Control
(RRC) protocol specification (Release 15), 3GPP TS 38.331
V15.0.0 (December 2017) (“TS 38.331”)

EX1005 3rd Generation Partnership Project; Technical Specification


Group Radio Access Network NR Physical layer procedures for
control (Release 15), 3GPP TS 38.213 V15.0.0 (December
2017) (“TS 38.213”)

EX1006 “Remaining issues on UL data transmission procedure,” 3GPP


TSG RAN WG1 Meeting 91, R1-1719932, November 27-
December 1, 2017 (“R1-1719932”)

EX1007 International Publication No. WO 2017/014802 A1 to Zhang et


al. (“Zhang”)

EX1008 “Remaining details of UL data trans-mission procedures in


NR,” 3GPP TSG RAN WG1 Meeting 91, R1-1720097,
November 27-December 1, 2017 (“R1-1720097”)

EX1009 Declaration of Friedhelm Rodermund

EX1010 “UL data transmission procedures in NR,” 3GPP TSG RAN


WG1 Meeting 90bis, R1-1717396, October 9-13, 2017

EX1011 “On UL Data Transmission Procedure,” 3GPP TSG RAN WG1


#90bis, R1-1718647, October 9-13, 2017

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EX1012 3rd Generation Partnership Project; Technical Specification


Group Radio Access Network; Evolved Universal Terrestrial
Radio Access (E-UTRA); Medium Access Control (MAC)
protocol specification (Release 8), 3GPP TS 36.321 V8.10.0
(September 2011)

EX1013 3rd Generation Partnership Project; Technical Specification


Group Radio Access Network; Evolved Universal Terrestrial
Radio Access (E-UTRA); Radio Resource Control (RRC);
Protocol specification (Release 8), 3GPP TS 36.331 V8.16.0
(December 2011)

EX1014 3rd Generation Partnership Project; Technical Specification


Group Radio Access Network; Evolved Universal Terrestrial
Radio Access (E-UTRA); Physical Channels and Modulation
(Release 8), 3GPP TS 36.211 V8.9.0 (December 2009)

EX1015 3rd Generation Partnership Project; Technical Specification


Group Radio Access Network; Evolved Universal Terrestrial
Radio Access (E-UTRA); Physical layer procedures (Release
8), 3GPP TS36.213 V8.8.0 (September 2009)

EX1016 Dalman, Parkvall and Sköld, “4G LTE/LTE-Advanced for


Mobile Broadband,” Elsevier, 2011, pp. 229-231, 277-279.

EX1017 3rd Generation Partnership Project; Technical Specification


Group Radio Access Network; NR; Radio Resource Control
(RRC) protocol specification (Release 15), 3GPP TS38.331
V15.3.0 (September 2018)

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Apple Inc. (“Petitioner” or “Apple”) petitions for Inter Partes Review (“IPR”)

of claims 1-8 (“the Challenged Claims”) of U.S. Patent 10,470,203 (“’203 Patent”).

As explained in this Petition, there exists a reasonable likelihood that Petitioner will

prevail.

I. PETITIONER HAS STANDING

Petitioner certifies that the ’203 Patent is available for IPR. As of the time of

filing, this patent has not been involved in patent litigation. Petitioner is not barred

or estopped from requesting this review based on the grounds identified in Section

IV.A.

II. SUMMARY OF THE ’203 PATENT

A. Background of Related Technology

The ’203 Patent is generally directed to transmitting scheduling requests (SRs)

on a Physical Uplink Control Channel at a particular symbol with a particular

periodicity, with transmissions configured using a Radio Resource Control (RRC)

message. EX1001, 1:46-60, 4:5-20, 7:18-52; EX1003 ¶39. While the ’203 Patent

is directed to 5G NR (5th Generation New Radio) systems (EX1001, 1:34-45), the

basic functionality and mechanisms disclosed were developed and used in the earlier

generation 4G/LTE (4th Generation Long Term Evolution) systems. EX1003 ¶39.

LTE was developed as part of 3GPP (Third Generation Partnership Project) Release

8 around 2008, and is defined through a series of 3GPP Technical Specifications

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(TS). Id. As explained in more detail in Dr. Wells’ expert declaration, scheduling

requests were specified in these LTE technical specifications for use in LTE systems

approximately 10 years before the filing of the ’203 Patent, and many of the

concepts disclosed in the ’203 Patent were well known and used in LTE. Id. ¶¶39-

53. In particular, using the standard LTE nomenclature of numbering the 14 symbols

in a subframe from 0 to 13, in LTE, an SR sent using PUCCH format 1 is transmitted

on the PUCCH using symbols number 0, 1, 5, 6, 7, 8, 12 and 13 of the 14 symbol

LTE subframe. Id. ¶53.

B. Brief Description

The ’203 Patent describes “a method of operating a user equipment in a radio

access network,” where the “user equipment is configured with a reference time

resource . . . for transmission of a scheduling request” for use in 5th Generation (5G)

telecommunication networks or 5G radio access technology (RAT) or networks

(RAN), including a RAN according to New Radio (NR). EX1001, Abstract, 1:34-

45. The ’203 Patent explains that 5G radio telecommunication technology is being

developed that “aims at providing systems with a high level of flexibility, which can

lead to undesirable levels of (control) signaling overhead.” Id., 1:19-23. An

example of control signaling relates to “scheduling request, e.g., if a user equipment

(UE) requests resources for transmission,” where a UE sends a transmission “to a

network (e.g., a network node) indicating that the UE desires resources for uplink

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transmission.” Id., 1:23-26, 1:34-38. In these scenarios, the scheduling request must

be sent on resources that need to be configured or reserved. Id., 1:26-27.

Generally, the ’203 Patent describes a UE (e.g., first radio node) in a radio

access network that is configured with a reference time resource that is available in

one or more slots for transmitting a scheduling request by the UE. Id., 1:46-51. The

reference time resource may be included in a message, such as a Radio Resource

Control (RRC) message. Id., 4:27-33, 22:47-49. The UE transmits a scheduling

request message based on a number of factors and variables discussed below. A

scheduling request indicates that a UE or first radio node is requesting resources for

transmission (e.g., if it has data in a buffer waiting to be transmitted). Id., 4:37-39.

The scheduling request can be carried by a scheduling request message. Id., 4:43-

44.

Referencing Figure 1 (reproduced below), the ’203 Patent discusses

configuration of scheduling requests. Id., 7:18. Figure 1 shows several consecutive

slots, each of which has a slot duration based on the number of symbols in a slot

(e.g., 12 or 14). Id., 7:18-21. In the case of NR technology, this number is 14. Id.,

7:21. For each slot, a reference time resource for a scheduling request is configured,

for example, with radio resource control (RRC) signaling. Id., 7:21-25. The

reference time resource for a scheduling request (SR) may be referred to as a

configured PUCCH (physical uplink control channel) resource for SR, as shown in

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FIG. 1. Id., 7:21-24. In Figure 1 below, each slot is shown as including two PUCCH

resources. Id.; EX1003 ¶56. The remaining 12 symbols per slot are not depicted.

Id.

Id., FIG. 1.1

1
Annotations to the figures throughout this petition are shown in green and yellow.

Red text shown in figures have not been added by Petitioner.

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The reference time resource includes the reference symbol R, where each of

the slots has a slot duration that is based on a number, N, of symbols in the slot. Id.,

1:65-2:1, 7:25-28. N may be 14, such as in the case of NR technology, where each

of the symbols in the slot may be numbered with consecutive integers (e.g., 0 to N-

1). Id., 3:31-34. The PUCCH resource for SR has a starting symbol within a slot,

which may be the reference symbol R. Id., 7:35-37. In particular, the reference

symbol R may be configured for a starting slot based on a slot offset, where the

starting slot may be the first slot for which the reference symbol R is available. Id.,

4:27-29. In some instances, the reference symbol R may be the first symbol

available for transmission of a scheduling request. Id., 4:33-36.

An SR periodicity, P, is configured for scheduling requests, which indicates a

periodicity with a time period shorter than the slot duration (e.g., a smaller number

of symbols than symbols/slot). Id., 2:1-4, 7:29-32. For example, for a slot duration

N of 14, the SR periodicity P may be 2 or 7 symbols. Id., 3:35-39, 7:37-39. In

general, the periodicity indicates a period of available resources for transmission of

scheduling requests, while the reference symbol R may be understood as “an

anchoring symbol for a pattern defined by the periodicity.” Id., 3:39-43.

Other available symbols in a slot may be determined either automatically or

by the UE or network node for reception or scheduling. Id., 7:32-35.

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When a UE transmits a scheduling request message, for example, to a network

node, the UE is configured based on the reference symbol R and scheduling request

periodicity P. Id., 1:55-60, 2:4-8, 4:21-24. The scheduling request message can be

transmitted over one or more symbols, and may be, for example, a PUCCH format

0 message that is transmitted over 1 symbol. Id., 5:1-9. Transmitting or receiving a

scheduling request message includes determining a set of symbols that are available

for transmitting the request, based on the reference symbol R and the periodicity P.

Id., 4:21-24. In particular, UE is configured for transmitting a scheduling request

message at a request transmission symbol T, which is based on reference symbol R

and periodicity P. Id., 2:4-8. In some instances, the request transmission symbol T

may be the reference symbol R. Id., 3:49-51. In general, the request transmission

symbol T is determined from the symbols of a slot that can be addressed based on

the reference symbol R and the periodicity P. Id., 3:51-55.

With respect to schematic teachings, Figures 2 and 3 (reproduced below)

purport to show “a radio node, in particular a terminal or wireless device 10, which

may in particular be implemented as a UE (User Equipment)” and “a radio node 100,

which may in particular be implemented as a network node 100, for example an eNB

or gNB for NR,” respectively. Id., 7:62-64, 8:18-20. The radio nodes 10, 100 of

Figures 2 and 3 each include processing circuitry 20, 120, radio circuitry 22, 122,

and antenna circuitry 24, 124, respectively. Id., 7:62-8:37.

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Radio node
Radio node

Processing
Processing circuitry
circuitry
Radio
Radio circuitry
circuitry
Antenna
Antenna circuitry
circuitry

Id., FIGS. 2-3 (annotated).

C. Summary of the Prosecution History of the ’203 Patent

The ’203 Patent issued on November 5, 2019, from U.S. Patent Application

No. 16/398,655 (“the ‘655 application”), which was filed on April 30, 2019 with 20

claims. See EX1002, 109-112, 163-170. The ’655 application is a continuation of

PCT Application Serial No. PCT/SE2018/050027 filed January 12, 2018. Id., 163-

170.

The prosecution history for the ’203 Patent is short. The ’655 application was

filed with a Track One request, and after an Examiner-initiated interview, the

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Examiner issued a notice of allowance that added the features of then-pending claims

2, 3, and 4 to the independent claims. Id., 48-63, 109. This is illustrated below with

the Examiner’s Amendment to claim 1 followed by original claims 2-4:

1. [Amended by Examiner’s Amendment in the Notice of


Allowance] A method of operating a user equipment in a New Radio (NR)
radio access network, the method comprising:
receiving a Radio Resource Control (RRC) message configuring the
user equipment with a reference time resource, the reference time resource
being available, in at least one slot, for transmission of a scheduling request
by the user equipment, the reference time resource comprising a reference
symbol R, the reference symbol R being configured for a starting slot based
on a slot offset, the slot offset being predefined, each of the at least one slot
having a slot duration of 14 symbols, the received RRC message further
configuring the user equipment with a requesting periodicity P indicating a
periodicity with a time period shorter than the slot duration, the requesting
periodicity P corresponding to one of 2 and 7 symbols; and
transmitting a scheduling request message on a Physical Uplink Control
Channel (PUCCH) at a request transmission symbol T which is based on the
reference symbol R and the requesting periodicity P, the scheduling request
message being a PUCCH format 0 message transmitted over 1 symbol.
2. [Original, as filed] The method according to Claim 1, wherein
the requesting periodicity P corresponds to one of 2 and 7 symbols.
3. [Original, as filed] The method according to Claim 1, wherein
the reference symbol R is configured for a starting slot based on a slot offset,
wherein the slot offset is predefined.

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4. [Original, as filed] The method according to Claim 1, wherein


the scheduling request message is a PUCCH format 0 message transmitted
over 1 symbol.
EX1002, 53-54, 109.

During prosecution, the parties discussed only three prior art references. Id.,

62. Notably, while the applicant cited two 3GPP meeting documents as prior art

references, it omitted and failed to cite “Remaining issues on UL data transmission

procedure,” 3GPP TSG RAN WG1 Meeting 91, R1-1719932, November 27-

December 1, 2017 (“R1-1719932,” EX1006), which is related to the two cited 3GPP

documents shown on the front page of the ’203 Patent but not cumulative of those

references. See EX1001, 2; EX1003 ¶63. The other 3GPP-related documents relied

upon in this Petition are also not cumulative of the two cited 3GPP documents.

EX1003 ¶63. Additionally, the applicant omitted and failed to cite any other

technical specifications from the 3GPP related to the technology claimed in the ’203

Patent (e.g., EX1004, EX1005, EX1008). See id., 1-2.

D. Effective Priority Date of the Claims of the ’203 Patent

The ’203 Patent issued from U.S. Application No. 16/398,655 filed April 30,

2019. EX1001, 1. Claims 1, 4, and 7 of the ’203 Patent are independent claims.

Claims 2-3, 5-6, and 8 depend from one of claim 1, 4, or 7. Accordingly, claims 2-

3, 5-6, and 8 cannot enjoy an effective filing date earlier than that of claims 1, 4, and

7 from which they depend (i.e., no earlier than January 12, 2018).

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E. Level of Ordinary Skill

For purposes of this IPR, Petitioner submits that a person of ordinary skill in

the art at the time of the alleged invention (a “POSITA”) would have had Bachelor’s

degree in electrical engineering, computer engineering, computer science, or a

related field, and 2-3 years of experience related to the design or development of

network communication systems, or the equivalent. EX1003 ¶17. Additional

graduate education could substitute for professional experience, or significant

experience in the field could substitute for formal education. Id.

III. CLAIM CONSTRUCTION

Petitioner submits that all claim terms should be construed according to the

Phillips standard. Phillips v. AWH Corp., 415 F.3d 1303 (Fed. Cir. 2005); 37 C.F.R.

§ 42.100. Petitioner submits that no formal claim constructions are necessary. 2

Petitioner reserves the right to respond to any constructions offered/adopted by

Patent Owner/Board.

IV. APPLICATION OF PRIOR ART TO THE CHALLENGED CLAIMS

2
Petitioner is not conceding that each challenged claim satisfies all statutory

requirements, such as 35 U.S.C. § 112. As this is an IPR petition, Petitioner is

pursuing prior art-based grounds. Petitioner is not waiving any arguments

concerning other grounds that can only be raised in district court.

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A. Grounds

The Challenged Claims are unpatentable over the 35 U.S.C § 103

(obviousness) grounds in the table below. Accompanying explanations and support

are provided in Dr. Wells’ Declaration (EX1003).

Ground Claim(s) 103 Basis


1 1-8 TS 38.331 in view of TS 38.213
2 1-8 TS 38.331 in view of TS 38.213 and R1-
1720097
3 1-8 TS 38.331 in view of TS 38.213 and R1-
1719932
4 4-8 TS 38.331 in view of Zhang, TS 38.213,
and R1-1719932

As shown below, each reference pre-dates January 12, 2018 (“Critical Date”),

which is the earliest date to which the ’203 Patent claims priority. Petitioner does

not concede that the ’203 Patent is entitled to the claimed priority.

Reference Date Section

3rd Generation Partnership Project; January 4, 20183 102(a)(1)


Technical Specification Group Radio (published)
Access Network NR Radio Resource

3
For each of the 3GPP technical documents, as here, although the face of the

document shows a first date, historic 3GPP ftp server information for the document

provides a slightly different second date for publication. EX1009 ¶¶52-53.

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Reference Date Section

Control (RRC) protocol specification


(Release 15), 3GPP TS 38.331 V15.0.0
(December 2017) (“TS 38.331”)

3rd Generation Partnership Project; January 3, 20184 102(a)(1)


Technical Specification Group Radio (published)
Access Network NR Physical layer
procedures for control (Release 15),
3GPP TS 38.213 V15.0.0 (December
2017) (“TS 38.213”)

“Remaining details of UL data November 18, 20175 102(a)(1)


transmission procedures in NR,” 3GPP (published)
TSG RAN WG1 Meeting 91, R1-
1720097, November 27-December 1,
2017 (“R1-1720097”)

“Remaining issues on UL data November 18, 20176 102(a)(1)


transmission procedure,” 3GPP TSG (published)
RAN WG1 Meeting 91, R1-1719932,
November 27-December 1, 2017 (“R1-
1719932”)

4
Id. ¶¶50-51; see supra note 3.
5
Id. ¶¶45-49; see supra note 3.
6
Id. ¶¶40-44; see supra note 3.

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Reference Date Section

“Zhang” International Pub. No. January 26, 2017 102(a)(1)


WO 2017/014802 102(a)(2)

B. Grounds 1, 2, and 3

1. Overview of TS 38.331 (EX1004)7

TS 38.331 is a technical specification relating to Radio Access Network

technology from the 3rd Generation Partnership Project (3GPP). EX1004, 1, 8. It

specifies the Radio Resource Control (RRC) protocol “for the radio interface

between UE and NG-RAN,” where UE stands for user equipment and NG-RAN

stands for Next-Generation Radio Access Network. Id., 1. TS 38.331’s disclosure

includes specific references to other 3GPP documents, including TS 38.213

(EX1005). Id., 9, 109-112, 130.

With reference to Figure 4.2.1-1 (reproduced below), TS 38.331 discloses an

“overview of UE RRC state machine and state transitions in NR,” or new radio. Id.,

13.

7
General descriptions provided for this and other references and combinations

thereof are incorporated into each subsection and mapping of the claims that

includes citations to these references.

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Id., 13.

TS 38.331 discusses RRC reconfiguration, the purpose of which is to modify

an RRC connection, for example, as shown in Figure 5.3.5.1-1 (reproduced below).

Id., 22. In particular, a UE receives a RRC reconfiguration message that includes

information element (IE) PUCCH-Config. Id., 65, 109-112

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Id., 22.

Where a PUCCH resource is used, PUCCH-Config IE is used to configure

user equipment-specific PUCCH parameters. Id., 109. For instance, for a PUCCH

format 0 resource, a sequence of values is defined, including startingSymbolIndex,

which can have an integer value from 0 to 13. Id., 111. TS 38.331 discloses that a

slot duration of 14 symbols is used, with the symbols having indexed integer values

from 0 to 13. EX1004, 146 (defining variable maxSymbolIndex, “Maximum index

identifying a symbol within a slot (14 symbols, indexed from 0..13),” as 13).

With respect to PUCCH format 0 resource configuration, TS 38.331 further

references TS 38.213 (section 9.2) and to L1 parameter “PUCCH-F0-resource

config” in that document, discussed further infra Section IV.B.2. Id., 111.

Moreover, in the case of PUCCH format 0 resource configuration, the scheduling

request message is transmitted as a PUCCH format 0 resource. Id.; EX1003 ¶68.

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TS 38.331 further explains that the “IE SchedulingRequestResource-Config

determines physical layer resources on PUCCH where the UE may send the

dedicated scheduling request (D-SR),” again referencing TS 38.213, section 9.2.2.

TS 38.331, 130. The SchedulingRequestResource-Config IE defines a periodicity,

or scheduling periodicity, value that corresponds to “L1 parameter ‘SR-periodicity’”

in TS 38.213, section 9.2.2. Id., 130. The technical specification supports

periodicities of 2 symbols or 7 symbols. Id., 138.

2. Overview of TS 38.213 (EX1005)


Like TS 38.331, TS 38.213 is a technical specification from the 3GPP that

relates to Radio Access Network technology. EX1005, 1, 5. It “specifies and

establishes the characteristics of the physicals[sic] layer procedures for control

operations in 5G-NR.” Id., 6. As discussed supra Section IV.B.1, TS 38.213 is

referenced by TS 38.331. Notably, TS 38.213 also references TS 38.331. E.g.,

EX1005, 6.

TS 38.213 discusses configuring user equipment (UE) using higher layer

parameter SR-configurations, a set of configurations for scheduling request

transmission. Id., 31. In particular, the UE is configured by higher layers to transmit

a scheduling request in a PUCCH transmission that uses, for example, PUCCH

format 0 with SR-configurations, a PUCCH resource by higher layer parameter SR-

resource that provides a PUCCH format 0 resource through higher layer parameter

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PUCCH-resource-config-PF0, a periodicity SRPERIODICITY in symbols by higher

layer parameter SR-periodicity, and an offset SROFFSET in symbols by higher layer

parameter SR-offset for a PUCCH transmission that transmits the scheduling request.

Id., 31-32. SRPERIODICITY values of 2 symbols or 7 symbols are supported. Id., 32.

TS 38.213 explains that a “UE is provided by higher layers” with, for example,

“PUCCH-resource-config-PF0 providing resources for PUCCH transmission with

PUCCH format 0” where a PUCCH format 0 resource includes an index of the first

symbol for PUCCH format 0 indicated by higher layer parameter PUCCH-F0-F2-

starting symbol. Id., 28.

TS 38.213 specifically explains that scheduling request information is

conveyed, or transmitted, in a PUCCH transmission using a PUCCH format 0, and

that for a PUCCH format 0 resource, the number of symbols is indicated by higher

layer parameter PUCCH-F0-F2-number of symbols. Id., 28, 31-32. TS 38.213

further teaches that if a UE is not transmitting PUCCH and the UE is transmitting

uplink control information (UCI), the UE transmits the UCI on PUCCH format 0 if

the transmission is over 1 symbol or 2 symbols and/or the number of UCI bits is 1

or 2. Id., 29-30. UCI includes data such as a scheduling request. EX1003 ¶71.

3. Overview of R1-1720097 (EX1008)

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R1-1720097 provides meeting notes from the 3GPP (authored by Intel)

relating to the “SR aspects for grant-based transmission” per a meeting of the 3GPP

that occurred between November 27 and December 1, 2017. EX1008, 1.

With regard to scheduling request (SR) resource configuration, R1-1720097

discloses that an RRC indicates a “periodicity and offset which identify the

slots/symbols to be used for SR. Id., 5. R1-1720097 further describes the

relationship between “SR periodicity and offset configuration,” as shown below:

Id., 6.

4. Overview of R1-1719932 (EX1006)

R1-1719932 provides meeting notes from the 3GPP (authored by LG

Electronics) relating to the “design of UL data transmission with and without grant”

per a meeting of the 3GPP that occurred between November 27 and December 1,

2017. EX1006, 1. With regard to scheduling request (SR) resource configuration,

R1-1719932 discloses that an RRC indicates a “periodicity and offset which identify

the slots/symbols to be used for SR,” including the possibility of the periodicity

being shorter than a slot. Id.

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In particular, R1-1719932 explains that for a SR configuration of a periodicity

shorter than a slot, “a scheduling request can be configured with symbol-level

periodicity.” Id., 3. However, it is not desirable for an SR PUCCH to be mapped

across a slot boundary. Id. In order to maintain the boundary between slots with

symbol-level periodicity, one method that can be employed is using an SR occasion

pattern for a slot that has a symbol-level periodicity in the slot. Id. In this way, by

repeating the SR occasion pattern, symbol-level periodicity can be achieved without

violating slot boundaries. Id.

5. Combinations of TS 38.331, TS 38.213, R1-1720097,


and R1-1719932

a. TS 38.331 and TS 38.213 (Ground 1)

As discussed supra Section IV.B.1, TS 38.331 relates to Radio Access

Network technology from the 3GPP and specifies the Radio Resource Control

(RRC) protocol “for the radio interface between UE and NG-RAN.” EX1004, 1, 8.

TS 38.331 teaches that a UE receives a RRC reconfiguration message that includes

information element (IE) PUCCH-Config, which is used to configure user

equipment-specific PUCCH parameters. Id., 65, 109-112

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Id., 22.

With respect to PUCCH format 0 resource configuration, TS 38.331

specifically references TS 38.213 (section 9.2) and parameter “PUCCH-F0-resource

config” in that document when suggesting how the PUCCH format 0 resource

disclosed in TS 38.331 is configured:

Id., 111 (highlighted).

TS 38.213 similarly discloses configuring a user equipment for transmission

of a scheduling request. EX1005, 31-32. TS 38.213 explains that the user equipment

is “configured by higher layers to convey a SR in a PUCCH transmission using …

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PUCCH format 0” using “higher layer parameter SR-configurations, a PUCCH

resource by higher layer parameter SR-resource providing a PUCCH format 0

resource through higher layer parameter PUCCH-resource-config-PF0 . . . , a

periodicity SRPERIODICITY in symbols by higher layer parameter SR-periodicity, and

an offset SROFFSET in symbols by higher layer parameter SR-offset for a PUCCH

transmission conveying SR.” Id.; see also id., 6 (referencing TS 38.311 and

indicating that the technical specification documents should be read together);

EX1004, 111, 130 (referencing specific sections of TS 38.213 for more detailed

information).

TS 38.331 and TS 38.213 are related technical specifications from the same

group (3GPP) from the same release version (15.0.0) and published on the same date

that both relate to Radio Access Network and New Radio technology. EX1004, 1;

EX1005, 1. Moreover, each of the technical specifications specifically references

the other. E.g., EX1004, 111 (referencing “section 9.2” of EX1005 as it relates to

“PUCCH Format 0 resource configuration”); EX1005, 6. Indeed, TS 38.213

specifically lists TS 38.331 as a document that contains “provisions which, though

reference in this text, constitute provisions of the present document,” essentially

incorporating TS 38.331 by reference. EX1005, 6; see also EX1004, 9. As such, a

POSITA would have generally been motivated to combine the teachings of TS

38.331 with the teachings of TS 38.213. EX1003 ¶¶97-100. TS 38.213 expands the

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framework with additional details, at least, pertaining to configuration of user

equipment for transmission of a scheduling request, as specifically called out by TS

38.331. EX1004, 111; EX1003 ¶¶97-100. Indeed, a POSITA would have

understood that TS 38.331 and TS 38.321 are part of a collection of documents that

are considered as portions, or chapters, of a larger document that would have been

considered collectively as a single teaching. EX1003 ¶¶97, 100. Thus, to the extent

that TS 38.331 does not explain specific implementation details relating to

configuring the user equipment, including additional information regarding how the

user equipment transmits scheduling requests in a PUCCH transmission, TS 38.213

discloses this information. EX1005, 31-32; EX1003 ¶¶92-101. A POSITA would

have been motivated to look to TS 38.213 for these implementation details regarding

the “UE procedure for reporting SR” as TS 38.213 explains. EX1003 ¶¶96-100.

b. TS 38.331, TS 38.213, and R1-1720097 (Ground


2)

Like TS 38.331 and TS 38.213, R1-1720097 is a technical document from the

3GPP. As discussed supra Section IV.B.3, R1-1720097 provides meeting notes

relating to “UL data transmission procedures including enhancement on grant-based

UL transmission and uplink grant-free transmission.” EX1008, 1. With respect to

grant-based UL transmission, R1-1720097 explains that “[f]or each ‘SR

configuration,’” a “periodicity and offset which identify the slots/symbols to be used

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for SR” are “indicated via RRC.” EX1008, 5. R1-1720097 explains that a slot

duration of 14 symbols is used with periodicity values of 2 or 7 symbols. Id. The

“[r]elation of SR periodicity and offset configuration” in Table 3 of R1-1720097

indicates that, for “[s]lot based SR periodicity,” “SR offset relative to SFN [system

frame number] = 0 to determine a slot is configured by the same set of values as the

SR periodicity.” Id., 6. R1-1720097 further states that “SR offset within a slot

follows the associated PUCCH resource configuration.” Id. A POSITA would have

understood that the “SR offset relative to SFN = 0” of R1-1720097 provides

reference symbol R, which is configured for a starting slot based on a slot offset that

is predefined. EX1003 ¶¶152-153. In particular, the “SR offset relative to SFN =

0” in conjunction with the known slot duration of 14, provides the reference symbol

R,8 where R is equal to the remainder when “SR offset relative to SFN = 0” is divided

by the slot duration of 14 (i.e., R = “SR offset relative to SFN = 0” mod 14). Id.

Moreover, R is configured for a starting slot based on a slot offset as based on the

“SR offset relative to SFN=0.” Id.

R1-1720097, like TS 38.331 and TS 38.213, provides further explanation and

detail for the SR configuration for a user device. EX1003 ¶¶152-153. A POSITA

would have been motivated to combine the teachings of TS 38.331 and TS 38.213

8
EX1001, 4:26-36; see also id., 1:46-61.

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with the teachings of R1-1720097 to realize the benefit provided by adopting these

implementation details, e.g., SR configuration including reference symbol R

configured for a starting slot based on a predefined slot offset. Id. ¶154. The

combination of TS 38.331, TS 38.213, and R1-1720097 would have been

predictable, foreseeable, and beneficial because 1) TS 38.331, TS 38.213, and R1-

1720097 disclose configuring a scheduling request for a specific user equipment

(EX1004, 22, 109; EX1005, 31-32; EX1008, 5-6), and 2) the combination merely

involves incorporating known features that are explicitly disclosed by R1-1720097

and would have been understood by a POSITA as likely present (and desirable), but

not explicitly disclosed by TS 38.331 and TS 38.213. See EX1003 ¶154. Moreover,

a POSITA would have been motivated to combine TS 38.331 and TS 38.213 to

provide enhancements of SR-related aspects of grant-based UL transmissions.

EX1008, 1 (Introduction); EX1003 ¶154. The combination is predictable, at least in

part, because elements of the combined system would each perform similar functions

that they had been known to perform prior to the combination. Id. For example, the

user equipment in TS 38.331 and TS 38.213 would still perform the same or similar

functions, including receiving an RRC message for SR configuration, as it did prior

to the combination with R1-1720097. Id. ¶139. Thus, combining the teachings of

TS 38.331 and TS 38.213 with R1-1720097 would have merely involved combining

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prior art elements according to known methods to yield predictable results. EX1003

¶154.

Moreover, a POSITA reviewing the 3GPP technical specifications (TS 38.331

and TS 38.213) would have been motivated to look to other 3GPP technical

documents, such as meeting notes of the 3GPP group, for technical and

implementation details and otherwise. EX1003 ¶¶154-157. Examples of these

meeting notes include the 3GPP/Intel notes of R1-1720097 and the 3GPP/LG

Electronics notes of R1-1719932. Id. A POSITA would have understood that these

meeting notes would provide information about proposals relating to the standard

that are being considered by the 3GPP and by wireless companies, prior to adoption

by the 3GPP. Id., 157. Notably, regardless of whether information disclosed in

meeting notes are eventually adopted, a POSITA would have been prompted to look

to meeting notes, generally, in order to learn of and understand alternatives or other

options being considered. Id. (Appendix B). Indeed, the very format of standards-

based deliberation compels participants to consider different documents, not in

isolation, but as collections of teachings. It should be noted, however, that each of

the portions of R1-1720097 discussed herein, were eventually adopted in the

standard. Id.

c. TS 38.331, TS 38.213, and R1-1719932 (Ground


3)

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Like TS 38.331 and TS 38.213, R1-191332 is a technical document from the

3GPP. As discussed supra Section IV.B.4, R1-1719932 provides meeting notes

relating to the “design of UL data transmission with and without grant.” EX1006,

1. With regard to scheduling request (SR) resource configuration, R1-1719932

discloses that an RRC indicates a “periodicity and offset which identify the

slots/symbols to be used for SR,” including the possibility of the periodicity being

shorter than a slot. Id. In such a situation, in order to maintain the boundary between

slots with symbol-level periodicity, an SR occasion pattern for a slot that has a

symbol-level periodicity in the slot is used. Id. In this way, by repeating the SR

occasion pattern, symbol-level periodicity can be achieved without violating slot

boundaries. Id.

Combining the teachings of TS 38.331 and TS 38.213 with R1-1719932

would have merely involved combining prior art elements according to known

methods to yield predictable results. EX1003 ¶¶155-156. R1-1719932, like TS

38.331 and TS 38.213, discloses scheduling request configuration of a user device.

Id., ¶155. A POSITA would have been motivated to combine the teachings of TS

38.331 and TS 38.213 with the teachings of R1-1719932 to realize the

implementation details, e.g., configuration of R based on a predefined offset of 0, of

a scheduling configuration where the periodicity is shorter than the slot. EX1003

¶156. The combination of TS 38.331, TS 38.213, and R1-1719932 would have been

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predictable and foreseeable because 1) TS 38.331, TS 38.213, and R1-1719932

disclose configuring a scheduling request for a specific user equipment (EX1004,

22, 109; EX1005, 31-32; EX1006, 3), and 2) the combination merely involves

incorporating known features that are explicitly disclosed by R1-1719932 and would

have been understood by a POSITA as likely present, but not explicitly disclosed by

TS 38.331 and TS 38.213. EX1003 ¶156. The combination is predictable, at least

in part, because elements of the combined system would each perform similar

functions they had been known to perform prior to the combination. Id. For

example, the user equipment in TS 38.331 and TS 38.213 would still perform the

same or similar functions, including receiving an RRC message for SR

configuration, as it did prior to the combination with R1-1719932. Id.

Additionally, as discussed above with respect to R1-1720097, a POSITA

reviewing the 3GPP technical specifications (TS 38.331 and TS 38.213) would have

been motivated to look to other 3GPP technical documents, such as meeting notes

of the 3GPP group, including R1-1719932. EX1003 ¶157; supra Section IV.B.5.b.

6. TS 38.331 in combination with TS 38.213 (Ground 1),


TS 38.331 in combination with TS 38.213 and R1-
1720097 (Ground 2), and TS 38.331 in combination
with TS 38.213 and R1-1719932 (Ground 3) render
obvious Claims 1-8

[1pre] A method of operating a user equipment in a New Radio (NR) radio access
network, the method comprising:

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To the extent the preamble is limiting, TS 38.331 discloses a method of

operating a user equipment in a New Radio (NR) radio access network. EX1004, 1,

13, 17; EX1003 ¶¶89-91. In particular, TS 38.331 discloses an overview of user

equipment (UE) radio resource control (RRC) state machine and state transitions in

an NR radio access network (RAN). EX1004, 13 (e.g., Figure 4.2.1-1), 22. Figure

5.3.5.1-1 (reproduced below) shows a successful RRC reconfiguration process

between a UE and RAN.

Id., 22.

[1a] receiving a Radio Resource Control (RRC) message configuring the user
equipment with a reference time resource, the reference time resource being
available, in at least one slot, for transmission of a scheduling request by the user
equipment, the reference time resource comprising a reference symbol R, the
reference symbol R being configured for a starting slot based on a slot offset, the
slot offset being predefined,

TS 38.331 discloses receiving a Radio Resource Control (RRC) message that

configures the user equipment (UE) with a reference time resource that is available,

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in at least one slot, for transmission of a scheduling request by the user equipment,

the reference time resource comprising a reference symbol R. EX1004, 22, 59, 61-

62, 65, 109-112, 129-130; EX1003 ¶¶92-101.

In particular, TS 38.331 discloses the process of RRC reconfiguration, which

is used to modify an RRC connection, as shown in Figure 5.3.5.1-1 (reproduced

above with respect to [1pre]). EX1004, 22. In this process, a user equipment

receives a RRC reconfiguration message (see RRCReconfiguration) that includes

information element (IE) PUCCH-Config. Id., 22, 65, 109. The PUCCH-Config IE

of the RRC message “is used to configure the UE specific PUCCH parameters.” Id.,

109. Among the UE-specific PUCCH parameters is a “PUCCH format 0 resource,”

where TS 38.331 refers to TS 38.213 for more information relating to the

configuration. Id., 111. The PUCCH format 0 resource, PUCCH-format0, includes

a sequence of values, including startingSymbolIndex, which has an integer value

between 0 and 13. Id.

The PUCCH-Config IE corresponds to the received RRC message that is used

for configuring the user equipment. EX1003 ¶¶94-95. The PUCCH-Config IE uses

PUCCH format 0 resource PUCCH-format0, which is a reference time resource, for

performing the configuration. Id. ¶95 A POSITA would have recognized that the

PUCCH format 0 resource PUCCH-format0 is available, in at least one slot, for

transmission of a scheduling request by the user equipment because a scheduling

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request constitutes an example of uplink control information and would be

transmitted on the PUCCH. Id. ¶95; EX1004, 111. The reference time resource,

PUCCH format 0 resource PUCCH-format0 of TS 38.331, includes a reference

symbol R in the form of startingSymbolIndex. EX1003 ¶95. Moreover, as TS

38.331 explains, the PUCCH Format 0 resource is configured according to TS

38.213. EX1004, 111. The reference time resource, PUCCH format 0 resource

PUCCH-resource-config-PF0 of TS 38.213, includes a reference symbol R in the

form of an index of the first symbol for PUCCH format 0 by higher layer parameter

PUCCH-F0-F2-starting symbol. EX1005, 28. TS 38.213 discloses that the “UE is

configured by higher layers to convey a SR in a PUCCH transmission using …

PUCCH format 0” by various values, including “an offset SROFFSET in symbols by

higher layer parameter SR-offset for a PUCCH transmission conveying SR.” Id., 31-

32. A POSITA would have understood that startingSymbolIndex (reference symbol

R) is configured for a starting slot based on “an offset SROFFSET in symbols by higher

layer parameter SR-offset,” as TS 38.213 explains. EX1003 ¶96. Moreover, a

POSITA would have understood that the “higher layer parameter SR-offset” is a

predefined offset that is provided by the network. Id.

Nevertheless, if this combination of TS 38.331 and TS 38.213 is deemed to

not disclose the reference symbol R being configured for a starting slot based on a

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slot offset, the slot offset being predefined, R1-1720097 (Ground 2) or R1-1719932

teaches these features (Ground 3). EX1003 ¶¶150-157.

With respect to Ground 2, R1-1720097 first discloses that “[f]or each ‘SR

configuration,’” a “periodicity and offset which identify the slots/symbols to be used

for SR” are “indicated via RRC.” EX1008, 5. Periodicity values of 2 or 7 symbols

are disclosed, with a slot duration of 14 symbols. Id. R1-1720097 additionally

explains the “[r]elation of SR periodicity and offset configuration” in Table 3,

indicating that, for “[s]lot based SR periodicity,” “SR offset relative to SFN = 0 to

determine a slot is configured by the same set of values as the SR periodicity.” Id.,

6. R1-1720097 further states that “SR offset within a slot follows the associated

PUCCH resource configuration.” Id. A POSITA would have understood that the

“SR offset relative to SFN = 0” of R1-1720097 provides reference symbol R, which

is configured for a starting slot based on a slot offset that is predefined. EX1003

¶153. In particular, the “SR offset relative to SFN = 0” in conjunction with the

known slot duration of 14, provides the reference symbol R where R is equal to the

remainder when “SR offset relative to SFN = 0” is divided by the slot duration of 14

(i.e., R = “SR offset relative to SFN = 0” mod 14). Id. The predefined offset is

indicated by SFN=0, where SFN is predefined to be 0 in the 3GPP R1-1720097

document. Id. Moreover, R is configured for a starting slot based on a predefined

slot offset as based on the predefined “SR offset relative to SFN=0.” Id.

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With respect to Ground 3, R1-1719932 discusses scheduling configuration

where the periodicity is shorter than the slot. EX1006 at 3. R1-1719932 observes

that it is not desirable for an SR PUCCH to be mapped across a slot boundary, so it

discloses the use of an SR occasion pattern for a slot that has a symbol-level

periodicity in the slot in order to maintain the boundary between slots with symbol-

level periodicity. Id. In this way, symbol-level periodicity can be achieved without

violating slot boundaries. Id. A POSITA would have understood that R1-1719932’s

disclosure of “symbol-level periodicity without violation slot boundary” teaches the

use of a slot offset of 0, which would be used to configure R for the starting slot.

EX1003 ¶¶155-156. Because the slot offset value is defined by the 3GPP R1-

1719932 document to be 0, the slot offset is predefined. Id.

[1b] each of the at least one slot having a slot duration of 14 symbols,

TS 38.331 discloses each of the at least one slot having a slot duration of 14

symbols. EX1004, 146-147; EX1003 ¶¶102-103. In particular, TS 38.331 teaches

that maxSymbolIndex, which is the maximum index for identifying a symbol within

a slot, is an integer value between 0 and 13, with a total of 14 symbols in a slot.

EX1004, 146-147. Thus, TS 38.331 discloses a slot with a slot duration of 14

symbols. Id.

[1c] the received RRC message further configuring the user equipment with a
requesting periodicity P indicating a periodicity with a time period shorter than

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the slot duration, the requesting periodicity P corresponding to one of 2 and 7


symbols; and

TS 38.331 discloses the received RRC message further configuring the user

equipment with a requesting periodicity P indicating a periodicity with a time period

shorter than the slot duration, the requesting periodicity P corresponding to one of 2

and 7 symbols. EX1004, 65, 130, 137-138; EX1003 ¶¶104-107. In particular, TS

38.331 teaches value periodicity, which corresponds to “SR periodicity” or “SR-

periodicity” in TS 38.213. EX1004, 130; EX1003 ¶105.

TS 38.213 teaches the received RRC message configuring the user equipment

with a requesting periodicity P indicating a periodicity with a time period shorter

than the slot duration. EX1003 ¶106. In particular, TS 38.213 states that the UE is

configured “for SR transmission” by a number of parameters, including “a

periodicity SRPERIODICITY in symbols by higher layer parameter SR-periodicity.”

EX1005, 31-32. Notably, the “SR-periodicity” parameter discussed in TS 38.213 is

specifically called out by TS 38.331 as corresponding to TS 38.331’s “periodicity”

value. EX1004, 130.9 With respect to the periodicity, TS 38.213 lists 2 symbols

and 7 symbols as being acceptable values, both of which are shorter than the slot

9
TS 38.331 references Section 9.2.2 of TS 38.213, although it actually appears in

Section 9.2.4. EX1004, 130. This is a drafting error and inconsequential. EX1003

¶106 n.3.

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duration of 14 symbols, discussed above with respect to element [1b]. EX1005, 31-

32.

[1d] transmitting a scheduling request message on a Physical Uplink Control


Channel (PUCCH) at a request transmission symbol T which is based on the
reference symbol R and the requesting periodicity P, the scheduling request
message being a PUCCH format 0 message transmitted over 1 symbol.
TS 38.331 discloses transmitting a scheduling request (SR) message on a

Physical Uplink Control Channel (PUCCH), the scheduling request message being

a PUCCH format 0 message. EX1004, 65, 109-112; EX1003 ¶¶108-111. In

particular, TS 38.331 discloses “PUCCH Format 0 resource configuration” for the

PUCCH-format0 resource, with reference to a further discussion in section 9.2 of

TS 38.213. EX1004, 111.

TS 38.213 also discloses transmitting a scheduling request (SR) message on

a Physical Uplink Control Channel (PUCCH), with the SR message being

transmitted at a request transmission symbol T which is based on the reference

symbol R and the requesting periodicity P, and with the SR message being a

PUCCH format 0 message transmitted over 1 symbol. EX1003 ¶110. Section 9.2

of TS 38.213 explains that various uplink control information (UCI), including

schedule requests (i.e., schedule request messages), are transmitted, or reported, on

a PUCCH. EX1005, 28. TS 38.213 further states that a “UE is configured by

higher layers to convey a SR in a PUCCH transmission using … PUCCH format

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0” with SR-configurations, a PUCCH resource by higher layer parameter SR-

resource that provides a PUCCH format 0 resource through higher layer parameter

PUCCH-resource-config-PF0, a periodicity SRPERIODICITY in symbols by higher

layer parameter SR-periodicity, and an offset SROFFSET in symbols by higher layer

parameter SR-offset for a PUCCH transmission that transmits the scheduling

request. Id., 31-32. For the transmission of UCI, including an SR message, TS

38.213 discloses that the UCI (e.g., SR message) is transmitted on PUCCH format

0 if the transmission occurs over 1 symbol. Id., 29.

A POSITA would have understood that TS 38.213 discloses request

transmission symbol T which is based on the reference symbol R and the requesting

periodicity P in its “SR in a PUCCH transmission [request transmission symbol T]

using … a PUCCH resource by higher layer parameter SR-resource providing a

PUCCH format 0 resource through higher layer parameter PUCCH-resource-

config-PF0,” including “an index of the first symbol . . . for PUCCH format 0

[reference symbol R],” “a periodicity SRPERIODICITY in symbols by higher layer

parameter SR-periodicity [requesting periodicity P], and an offset SROFFSET in

symbols by higher layer parameter SR-offset for a PUCCH transmission conveying

SR.” EX1005, 28, 31-32; EX1003 ¶110. Of note, a POSITA would have understood

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that the “index of the first symbol” and the “offset SROFFSET in symbols” within a slot

both comprise reference symbol R. Id.

Nevertheless, if the combination of TS 38.331 and TS 38.213 is deemed to

not disclose the request transmission symbol T which is based on the reference

symbol R and the requesting periodicity P, R1-1720097 (Ground 2) teaches these

features. EX1003 ¶¶161-163.

With respect to Ground 2, R1-1720097 first discloses that “[f]or each ‘SR

configuration,’” a “periodicity and offset which identify the slots/symbols to be used

for SR” are “indicated via RRC.” EX1008, 5. Periodicity values of 2 or 7 symbols

are disclosed, with a slot duration of 14 symbols. Id. R1-1720097 additionally

explains the “[r]elation of SR periodicity and offset configuration” in Table 3,

indicating that, for “[s]lot based SR periodicity,” “SR offset relative to SFN = 0 to

determine a slot is configured by the same set of values as the SR periodicity.” Id.,

6. R1-1720097 further states that “SR offset within a slot follows the associated

PUCCH resource configuration.” Id. A POSITA would have understood that the

“SR offset relative to SFN = 0” of R1-1720097 provides reference symbol R, which

is configured for a starting slot based on a slot offset that is predefined. EX1003

¶163. In particular, the “SR offset relative to SFN = 0” in conjunction with the

known slot duration of 14, provides the reference symbol R where R is equal to the

remainder when “SR offset relative to SFN = 0” is divided by the slot duration of 14

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(i.e., R = “SR offset relative to SFN = 0” mod 14). Id. Moreover, R is configured

for a starting slot based on a slot offset as based on the “SR offset relative to SFN=0.”

Id.

A POSITA would have understood that TS 38.213 and R1-1720097 disclose

request transmission symbol T which is based on the reference symbol R and the

requesting periodicity P in its “SR in a PUCCH transmission [request transmission

symbol T] using … PUCCH format 0 resource … a periodicity SRPERIODICITY in

symbols by higher layer parameter SR-periodicity [requesting periodicity P], and an

offset SROFFSET [reference symbol R] in symbols by higher layer parameter SR-offset

for a PUCCH transmission conveying SR.” Id.

[2] The method according to claim 1, wherein the RRC message explicitly
indicates at least one of P and R.

TS 38.331 discloses that the RRC message explicitly indicates at least one of

P and R. EX1004, 109-112; EX1003 ¶¶113-114. In particular, the PUCCH-Config

IE (RRC message) of TS 38.331 explicitly includes startingSymbolIndex in PUCCH

format 0 resource, which corresponds to R. EX1004, 109-112; supra Section

IV.B.6.[1a].

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EX1004, 111 (highlighted). In particular, the PUCCH-Config IE (RRC message)

of TS 38.331 explicitly includes periodicity in the SchedulingRequestResource-

Config IE, which corresponds to P.

Id., 132.

[3] The method according to claim 1, wherein the reference time resource is
configured as one of 1 symbol, more than 1 symbol, and between 4 and 14 symbols.

TS 38.331 discloses wherein the reference time resource is configured as one

of 1 symbol, more than 1 symbol, and between 4 and 14 symbols. EX1004, 109-

112; EX1003 ¶¶116-118; supra Section IV.B.6.[1a].

Notably, the limitation of claim [3] is met as long as a particular reference

teaches a reference time resource that is at least 1 symbol, which it would need to be

in order to exist. EX1003 ¶117. As such, TS 38.331’s disclosure of a reference time

resource in the form of PUCCH format 0 resource is configured as one of 1 symbol,

more than 1 symbol, and between 4 and 14 symbol. Id.

[4pre] A user equipment for a New Radio (NR) radio access network, the user
equipment comprising:

To the extent the preamble is limiting, TS 38.331 discloses a user equipment

for a New Radio (NR) radio access network. EX1004, 1, 13, 17; EX1003 ¶¶121-

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123. In particular, TS 38.331 discloses an overview of user equipment (UE) radio

resource control (RRC) state machine and state transitions in a New Radio (NR)

radio access network. EX1004, 13 (e.g., Figure 4.2.1-1), 22. Figure 5.3.5.1-1

(reproduced below) shows a successful RRC reconfiguration process between a UE

and radio access network (RAN):

Id., 22.

[4a] processing circuitry and radio circuitry, and being configured to utilize the
processing circuitry and radio circuitry to:

TS 38.331 discloses a UE that performs a reconfiguration process with a radio

access network (RAN), sending and receiving various data. EX1004, 22; EX1003

¶¶124-126. To the extent that TS 38.331 does not explicitly describe the circuitry

included in the UE (processing and radio circuitry), such circuitry would be inherent

in view of the operation of the UE. EX1003 ¶¶124-125.

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In particular, TS 38.331 discloses a UE that “process[es] [] received

messages,” “receive[s] an RRC message,” and performs various other processes,

including the transmission and reception of data messages. E.g., EX1004, 12-13,

16, 24-25, 53, 155-157. That TS 38.331 does not explicitly state the circuitry

included in the UE does not preclude TS 38.331 from inherently teaching processing

and radio circuitry. A POSITA would have readily understood that, in light of the

UE’s ability to communicate with the radio access network, sending and receiving

information and processing that information, such circuitry would necessarily be

present. EX1003 ¶¶124-125; EX1004, 12-13, 16, 24-25, 53, 155-157.

Moreover, a POSITA would have understood that the UE includes both

processing and radio circuitry for such communications and processing with the

radio access network. EX1003 ¶125.

[4b] receive a Radio Resource Control (RRC) message configuring the user
equipment with a reference time resource, the reference time resource being
available, in at least one slot, for transmission of a scheduling request by the user
equipment, the reference time resource comprising a reference symbol R, the
reference symbol R being configured for a starting slot based on a slot offset, the
slot offset being predefined,

See discussion of element [1a]. See Section IV.B.6.[1a].

[4c] each of the at least one slot having a slot duration of 14 symbols,

See discussion of element [1b]. See Section IV.B.6.[1b].

[4d] the received RRC message further configuring the user equipment with a
requesting periodicity P indicating a periodicity with a time period shorter than

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the slot duration, the requesting periodicity P corresponding to one of 2 and 7


symbols; and

See discussion of element [1c]. See Section IV.B.6.[1c].

[4e] transmit a scheduling request message on a Physical Uplink Control Channel


(PUCCH) at a request transmission symbol T which is based on the reference
symbol R and the requesting periodicity P, the scheduling request message being
a PUCCH format 0 message transmitted over 1 symbol.

See discussion of element [1d]. See Section IV.B.6.[1d]. In particular, in TS

38.331, a UE performs the transmitting of a scheduling request message. EX1004,

9, FIG. 4.2.1-1, FIG. 4.2.1-2, FIG. 5.2.2.1-1; EX1003 ¶130.

[5] The user equipment according to claim 4, wherein the RRC message explicitly
indicates at least one of P and R.

See discussion of claim [2]. Supra Section IV.B.6.[2].

[6] The user equipment according to claim 4, wherein the reference time resource
is configured as one of 1 symbol, 2 symbols, and one of between 4 and 14 symbols.
See discussion of claim [3]. Supra Section IV.B.6.[3].

[7pre] A network node for a New Radio (NR) radio access network, the network
node comprising:
To the extent the preamble is limiting, TS 38.331 discloses a network node

for a New Radio (NR) radio access network. EX1004, 1, 13, 17, 158; EX1003

¶¶137-139. In particular, TS 38.331 discloses an overview of user equipment (UE)

radio resource control (RRC) state machine and state transitions in a New Radio

(NR) radio access network. EX1004, 13 (e.g., Figure 4.2.1-1), 22. Figure 5.3.5.1-1

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(reproduced below) shows a successful RRC reconfiguration process between a UE

and radio access network (RAN).

Id., 22. A POSITA would have understood that the radio access network (RAN)

may be a network node. EX1003 ¶138; EX1001, 1:36-37 (“transmission from a user

equipment (UE) to a network (e.g., a network node)”).

Moreover, TS 38.331 discloses “RRC messages that are transferred between

network nodes,” including “RRC messages [that] may be transferred to or from the

UE.” EX1004, 158.

[7a] processing circuitry and radio circuitry, and being configured to utilize the
processing circuitry and radio circuitry to:

As discussed with respect to [7pre], TS 38.331 discloses an RRC

reconfiguration process between a UE and a RAN, and a POSITA would have

understood that the RAN could be a network node. Supra Section IV.B.6.[7pre].

Moreover, 38.331 discloses “RRC messages that are transferred between network

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nodes” and “to or from the UE.” EX1004, 158. To the extent that TS 38.331 does

not explicitly describe the circuitry included in the network nodes (processing and

radio circuitry), such circuitry would be inherent in view of the operation of the

network nodes. EX1003 ¶¶140-141.

In particular, TS 38.331 discloses that network nodes can transmit and receive

RRC messages used to configure a UE, and performs various other processes,

including the transmission and reception of data messages. E.g., EX1004, 158-159.

That TS 38.331 does not explicitly describe the circuitry included in the network

node does not preclude TS 38.331 from inherently teaching processing and radio

circuitry. A POSITA would have readily understood that, in light of the network’s

ability to communicate with the UE and other network nodes, sending and receiving

information and processing that information, such circuitry would necessarily be

present. EX1003 ¶140; EX1004, 12-13, 16, 24-25, 53, 155-159.

Moreover, a POSITA would have understood that the network node includes

both processing and radio circuitry for such communications and processing with

the radio access network. EX1003 ¶141; supra Section IV.B.6.[4a].

[7b] configure a user equipment by transmitting, to the user equipment, a Radio


Resource Control (RRC) message configuring the user equipment with a
reference time resource, the reference time resource being available, in at least
one slot, for transmission of a scheduling request by the user equipment, the
reference time resource comprising a reference symbol R, the reference symbol R
being configured for a starting slot based on a slot offset, the slot offset being
predefined,

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See discussion of elements [1a] and [4b]. Supra Section

IV.B.6.[1a],[4b],[7pre].

[7c] each of the at least one slot having a slot duration of 14 symbols,
See discussion of elements [1b] and [4c]. Supra Section IV.B.6.[1b],[4c].

[7d] the transmitted RRC message further configuring the user equipment with a
requesting periodicity P indicating a periodicity with a time period shorter than
the slot duration, the requesting periodicity P corresponding to one of 2 and 7
symbols; and
See discussion of elements [1c] and [4d]. Supra Section IV.B.6.[1c],[4d].

[7e] receive a scheduling request message on a Physical Uplink Control Channel


(PUCCH) at a request transmission symbol RC which is based on the reference
symbol R and the requesting periodicity P, the scheduling request message being
a PUCCH format 0 message transmitted over 1 symbol.
See discussion of elements [1d] and [4e]. Supra Section IV.B.6.[1d],[4e]. The

request transmission symbol T discussed with respect to elements [1d] and [4e]

correspond to request transmission symbol RC in element [7e]. EX1003 ¶145.

[8] The network node according to claim 7, wherein the RRC message explicitly
indicates at least one of P and R.
See discussion of claim [2]. Supra Section IV.B.6.[2].

C. Ground 4

1. Overview of Zhang (EX1007)

Zhang is a PCT patent application directed to a “network device (e.g., an

evolved Node B (eNB), user equipment (UE), or the like) [that] can operate to reduce

an interruption time during a fallback operation resulting from a communication link

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blockage condition” that further “enables communication between other network

devices or different radio access technologies (RATs) in a heterogeneous network.”

EX1007, Abstract.

With reference to Figure 1 (reproduced below), Zhang discloses a 3GPP

“radio access network (RAN) anchored wireless [] local area network (WLAN)

wireless communications network environment for a UE or eNB.” Id. ¶¶[0006],

[0028]. “The network architecture 100 can comprise an end-to-end network for

cellular communications, including a UE 110, an eNB 120, and the following two

gateway entities of an evolved packet core (EPC), or other network core, which are

examples of network entities and can be extended to other network entities such as

for 5G and beyond.” Id. ¶[0029].

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Id., FIG. 1.

Zhang shows “example components of a User Equipment (UE) device 1300,”

which includes “application circuitry 1302, baseband circuitry 1304, Radio

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Frequency (RF) circuitry 1306, front-end module (FEM) circuitry 1308 and one or

more antennas.” Id. ¶[0094], FIG. 13. The application circuitry 1302 may include

“circuitry such as . . . one or more single-core or multi-core processors.” Id. ¶[0096].

Similarly, the baseband circuitry 1304 “may include circuitry such as . . . one or

more single-core or multi-core processors” to “process baseband signals received

from a receive signal path of the RF circuitry 1306 and to generate baseband signals

for a transmit signal path of the RF circuitry 1306.” Id. ¶[0097]. Additionally, “the

baseband circuitry 1304 may include elements of a protocol stack such as . . . radio

resource control (RRC) elements.” Id. ¶[0098]. “A central processing unit (CPU)

1304e of the baseband circuitry 1304 may be configured to run elements of the

protocol stack for signaling of the PHY, MAC, RLC, PDCP and/or RRC layers.” Id.

Zhang also discloses an “[a]ccess equipment (e.g., eNB, network entity, or the

like).” Id. ¶¶[0114]-[0115], FIG. 14. The access equipment includes a

“communication platform 1408,” which can include electronic components and

associated circuitry that provide for processing and manipulation of received

signal(s) and other signal(s) to be transmitted.” Id. ¶[0115]. The communication

platform 1408 includes a receiver/transmitter 1410, a multiplexer/demultiplexer

1412, and a modulator/demodulator 1414. Id. ¶¶[0116]-[0017]. “Access equipment

and/or software related to access of a network also includes a processor 1416

configured to confer . . . functionality to substantially any electronic component in

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access equipment and/or software,” and the “processor 1416 can facilitate

configuration of access equipment and/or software through, for example, monitor

component 1404, antenna component 1406, and one or more components therein.”

Id. ¶[0118].

2. Combination of TS 38.331, TS 38.213, R1-1719932, and


Zhang.

TS 38.331 discloses both user equipment and network nodes that perform

various functions, including receiving/transmitting a RRC message and

transmitting/receiving a scheduling request. Supra Section IV.B.6.[1a],[1d].

To the extent that the user equipment and network nodes of TS 38.331 are not

understood to include specific circuitry, including processing circuitry and radio

circuitry, a POSITA would have included this circuitry in each of those devices to

perform the processing and radio communications, including receiving/transmitting

a RRC message and transmitting/receiving a scheduling request message, as Zhang

disclosed. EX1003 ¶195; supra Section IV.B.6.[1a],[1d].

Like TS 38.331, TS 38.213, and R1-1719932, Zhang is directed to enabling

communications between devices, including user equipment and access equipment

(e.g., eNB), using radio access technologies. EX1007, Abstract; EX1003 ¶181. As

discussed supra Section IV.C.1, Zhang discloses a 3GPP “radio access network

(RAN) anchored wireless [] local area network (WLAN) wireless communications

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network environment for a UE or eNB.” EX1007 ¶¶[0006], [0028]. The user

equipment and eNB (network node) of Zhang perform various functions, including

receiving and transmitting signals, including data messages, and processing those

signals. Id. ¶[0015], [0097], [0096]-[0113]. To perform these functions, Zhang

discloses the various components included in the user equipment and eNB (network

node). Id.

Zhang’s user equipment, shown in Figure 13 (reproduced below), includes

“application circuitry 1302, baseband circuitry 1304, Radio Frequency (RF)

circuitry 1306, front-end module (FEM) circuitry 1308 and one or more antennas.”

Id. ¶[0094]. The application circuitry 1302 includes “circuitry such as . . . one or

more single-core or multi-core processors.” Id. ¶[0096]. The baseband circuitry

1304 includes “circuitry such as . . . one or more single-core or multi-core

processors” to “process baseband signals received from a receive signal path of the

RF circuitry 1306 and to generate baseband signals for a transmit signal path of the

RF circuitry 1306.” Id. ¶[0097]. The “baseband circuitry 1304 may include

elements of a protocol stack such as . . . radio resource control (RRC) elements.” Id.

¶[0098]. The baseband circuitry also includes a CPU 1304e “configured to run

elements of the protocol stack for signaling of the PHY, MAC, RLC, PDCP and/or

RRC layers.” Id.

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Id., FIG. 13 (annotated).

Zhang’s “[a]ccess equipment (e.g., eNB …)” (network node) includes a

“communication platform 1408,” which can include electronic components and

associated circuitry that provide for processing and manipulation of received

signal(s) and other signal(s) to be transmitted.” Id. ¶¶[0114]-[0115]. The

communication platform 1408 includes a receiver/transmitter 1410, a

multiplexer/demultiplexer 1412, and a modulator/demodulator 1414. Id. ¶¶[0116]-

[0017]. “Access equipment and/or software related to access of a network also

includes a processor 1416 configured to confer . . . functionality to substantially any

electronic component in access equipment and/or software,” and the “processor

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1416” facilitates “configuration of access equipment and/or software through, for

example, monitor component 1404, antenna component 1406, and one or more

components therein.” Id. ¶[0118].

Id., FIG. 14 (annotated).

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Combining the teachings of TS 38.331, TS 38.213, and R1-1719932 with

Zhang would have merely involved combining prior art elements according to

known methods to yield predictable results. EX1003 ¶195. Zhang, like TS 38.331,

TS 38.213, and R1-1719932 discloses communication devices, such as user

equipment and access nodes (e.g., eNB, gNB), communicating in an NR radio access

network. Id. A POSITA would have been motivated to combine the teachings of

TS 38.331, TS 38.213, and R1-1719932 with the teachings of Zhang to realize the

implementation details, e.g., processing circuitry and radio circuitry for processing,

receiving, and transmitting data. Id. The combination of TS 38.331, TS 38.213, R1-

1719932, and Zhang would have been predictable and foreseeable because 1) TS

38.331, TS 38.213, R1-1719932, and Zhang disclose communications between user

equipment (EX1004, 9, 17; EX1005, 31-32; EX1006, 2-4; EX1007 ¶¶[0005],

[0024], [0026], [0028]-[0044], [0095]-[0113]) and network nodes (EX1004, 9, 17,

158; EX1005, 10; EX1006, 2, 4, 6, 9; EX1007 ¶¶[0005], [0024], [0026], [0028]-

[0044], [0114]-[0122]) and 2) the combination merely involves incorporating known

features that are explicitly disclosed by Zhang and would have been understood by

a POSITA as likely present, but not explicitly disclosed by TS 38.331, TS 38.213,

and R1-1719932. EX1003 ¶195. The combination is predictable, at least in part,

because elements of the combined system would each perform similar functions they

had been known to perform prior to the combination. Id. For example, the user

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equipment in TS 38.331, TS 38.213, and R1-1719932 would still perform the same

or similar functions, including receiving an RRC message for SR configuration, as

it did prior to the combination with Zhang. Id.

3. TS 38.331 in combination with TS 38.213 and R1-


1719932 and further in combination with Zhang
renders obvious Claims 4-8

[4pre] A user equipment for a New Radio (NR) radio access network, the user
equipment comprising:

To the extent the preamble is limiting, TS 38.331 discloses a user equipment

for a New Radio (NR) radio access network. EX1004, 1, 13, 17; EX1003 ¶¶193-

196; supra Section IV.B.6.[4pre]. Additionally, Zhang disclose a 3GPP “radio

access network (RAN) anchored wireless [] local area network (WLAN) wireless

communications network environment for a UE or eNB.” EX1007 ¶¶[0006], [0028],

FIG. 1.

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Id., FIG. 1 (annotated).

[4a] processing circuitry and radio circuitry, and being configured to utilize the
processing circuitry and radio circuitry to:

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Zhang discloses processing circuitry and radio circuitry, and being configured

to utilize the processing circuitry and radio circuitry. EX1003 ¶¶197-200. In

particular, as shown in Figure 13 (reproduced below), Zhang teaches a UE 1300 that

includes processing circuitry (highlighted blue) in the form of “central processing

unit (CPU) 1304e of the baseband circuitry 1304 [that] may be configured to run

elements of the protocol stack for signaling of the PHY, MAC, RLC, PDCP and/or

RRC layers.” EX1007 ¶[0098]. Additionally, “[t]he baseband circuitry 1304 (e.g.,

one or more of baseband processors 1304a-d) may handle various radio control

functions that enable communication with one or more radio networks via the RF

circuitry 1306,” which “enables communication with wireless networks.” Id.

¶¶[0097], [0100]. The radio circuitry of Zhang (highlighted yellow) includes the RF

circuitry 1306 and the front-end module (FEM) circuitry 1308. EX1003 ¶199.

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EX1007, FIG. 13 (highlighted).

[4b] receive a Radio Resource Control (RRC) message configuring the user
equipment with a reference time resource, the reference time resource being
available, in at least one slot, for transmission of a scheduling request by the user
equipment, the reference time resource comprising a reference symbol R, the
reference symbol R being configured for a starting slot based on a slot offset, the
slot offset being predefined,

See discussion of element [1a] in Grounds 1-3. See Section IV.B.6.[1a].

[4c] each of the at least one slot having a slot duration of 14 symbols,
See discussion of element [1b] in Grounds 1-3. See Section IV.B.6.[1b].

[4d] the received RRC message further configuring the user equipment with a
requesting periodicity P indicating a periodicity with a time period shorter than
the slot duration, the requesting periodicity P corresponding to one of 2 and 7
symbols; and

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See discussion of element [1c] in Grounds 1-3. See Section IV.B.6.[1c].

[4e] transmit a scheduling request message on a Physical Uplink Control Channel


(PUCCH) at a request transmission symbol T which is based on the reference
symbol R and the requesting periodicity P, the scheduling request message being
a PUCCH format 0 message transmitted over 1 symbol.
See discussion of element [1d] in Grounds 1-32. See Section IV.B.6.[1d].

[5] The user equipment according to claim 4, wherein the RRC message explicitly
indicates at least one of P and R.

See discussion of claim [2] in Grounds 1-3. See Section IV.B.6.[2].

[6] The user equipment according to claim 4, wherein the reference time resource
is configured as one of 1 symbol, 2 symbols, and one of between 4 and 14 symbols.
See discussion of claim [3] in Grounds 1-3. See Section IV.B.6.[3].

[7pre] A network node for a New Radio (NR) radio access network, the network
node comprising:
To the extent the preamble is limiting, TS 38.331 discloses a network node

for a New Radio (NR) radio access network. EX1004, 1, 13, 17, 158; EX1003

¶¶211-216; supra Section IV.B.6.[7pre].

Additionally, Zhang discloses a 3GPP “radio access network (RAN) anchored

wireless [] local area network (WLAN) wireless communications network

environment for a UE or eNB.” EX1007 ¶¶[0006], [0028], FIG. 1; supra Section

IV.C.3.[4pre]. The ’203 Patent explains that “a radio node” may be “implemented

as a network node 100, for example an eNB or gNB or similar for NR.” EX1001,

8:18-20. As such, Zhang’s eNB discloses a “network node.” EX1003 ¶214.

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[7a] processing circuitry and radio circuitry, and being configured to utilize the
processing circuitry and radio circuitry to:

Zhang discloses processing circuitry and radio circuitry, and being configured

to utilize the processing circuitry and radio circuitry. EX1003 ¶¶217-220. In

particular, as shown in Figure 14 (reproduced below), Zhang teaches a block

diagram of “[a]ccess equipment (e.g., eNB, network entity, or the like)” that includes

processing circuitry (highlighted blue below) and radio circuitry (highlighted yellow

below). EX1007 ¶¶[0114]-[0115]; EX1003 ¶219.

The access equipment includes a “communication platform 1408,” which can

include electronic components and associated circuitry that provide for processing

and manipulation of received signal(s) and other signal(s) to be transmitted,” where

the platform includes receiver/transmitter 1410, a multiplexer/demultiplexer 1412,

and a modulator/demodulator 1414. EX1007 ¶¶[0115]-[0117]. The access

equipment also “includes a processor 1416 configured to confer . . . functionality to

substantially any electronic component in access equipment and/or software” and

“facilitate configuration of access equipment and/or software through, for example,

monitor component 1404, antenna component 1406, and one or more components

therein.” Id. ¶[0118].

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Id., FIG. 14. (annotated)

[7b] configure a user equipment by transmitting, to the user equipment, a Radio


Resource Control (RRC) message configuring the user equipment with a
reference time resource, the reference time resource being available, in at least
one slot, for transmission of a scheduling request by the user equipment, the
reference time resource comprising a reference symbol R, the reference symbol R
being configured for a starting slot based on a slot offset, the slot offset being
predefined,
See discussion of elements [1a] and [4b] in Grounds 1-3. Supra Section

IV.B.6.[1a],[4b].

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[7c] each of the at least one slot having a slot duration of 14 symbols,

See discussion of elements [1b] and [4c] in Grounds 1-3. Supra Section

IV.B.6.[1b],[4c].

[7d] the transmitted RRC message further configuring the user equipment with a
requesting periodicity P indicating a periodicity with a time period shorter than
the slot duration, the requesting periodicity P corresponding to one of 2 and 7
symbols; and
See discussion of elements [1c] and [4d] in Grounds 1-3. Supra Section

IV.B.6.[1c],[4d].

[7e] receive a scheduling request message on a Physical Uplink Control Channel


(PUCCH) at a request transmission symbol RC which is based on the reference
symbol R and the requesting periodicity P, the scheduling request message being
a PUCCH format 0 message transmitted over 1 symbol.

See discussion of elements [1d] and [4e] in Grounds 1-3. Supra Section

IV.B.6.[1d],[4e]. The request transmission symbol T discussed with respect to

elements [1d] and [4e] correspond to request transmission symbol RC in element

[7e]. EX1003 ¶¶131, 210.

[8] The network node according to claim 7, wherein the RRC message explicitly
indicates at least one of P and R.
See discussion of claim [2] in Grounds 1-3. See Section IV.B.6.[2].

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V. PAYMENT OF FEES – 37 C.F.R. § 42.103

Apple authorizes the Patent and Trademark Office to charge Deposit

Account No. 06-1050 for the fee set in 37 C.F.R. § 42.15(a) for this Petition and

further authorizes payment for any additional fees to be charged to this Deposit

Account.

VI. CONCLUSION

The cited prior art references identified in this Petition contain pertinent

technological teachings (both cited and uncited), either explicitly or inherently

disclosed, which were not previously considered in the manner presented herein, or

relied upon on the record during original examination of the ’203 Patent. In sum,

these references provide new, non-cumulative technological teachings which

indicate a reasonable likelihood of success as to Petitioner’s assertion that the

Challenged Claims of the ’203 Patent are not patentable pursuant to the grounds

presented in this Petition. Accordingly, Petitioner respectfully requests institution

of an IPR for those claims of the ’203 Patent for each of the grounds presented

herein.

VII. MANDATORY NOTICES UNDER 37 C.F.R § 42.8(a)(1)

Real Party-In-Interest Under 37 C.F.R. § 42.8(b)(1)

Apple Inc. is the real party-in-interest.

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Related Matters Under 37 C.F.R. § 42.8(b)(2)

The ’203 patent was the subject of an IPR petition filed by Samsung

Electronics Co., LTD. (“Samsung”) in IPR2021-00588. Samsung’s petition was

dismissed prior to institution before a preliminary response was filed. Apple was

not a real party-in-interest to IPR2021-00588. Samsung is not a real party-in-

interest in this proceeding, and is not in privity with Apple.

Lead And Back-Up Counsel Under 37 C.F.R. § 42.8(b)(3)


Apple provides the following designation of counsel.

Lead Counsel Backup counsel


W. Karl Renner, Reg. No. 41,265 Jeremy J. Monaldo, Reg. No. 58,680
Fish & Richardson P.C. Thomas A. Rozylowicz, Reg. No. 50,620
3200 RBC Plaza Jennifer J. Huang, Reg. No. 64,297
60 South Sixth Street Fish & Richardson P.C.
Minneapolis, MN 55402 3200 RBC Plaza
Tel: 202-783-5070 60 South Sixth Street
Fax: 877-769-7945 Minneapolis, MN 55402
Email: IPR50095-0062IP1@fr.com Tel: 202-783-5070
Fax: 877-769-7945
PTABInbound@fr.com

Service Information

Please address correspondence/service to the above-listed address. Sam-

sung consents to email service at IPR50095-0062IP1@fr.com (referencing No.

50095-0062IP1 and cc’ing PTABInbound@fr.com).

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Respectfully submitted,

Dated January 21, 2022 /W. Karl Renner/


W. Karl Renner, Reg. No. 41,265
Jeremy J. Monaldo, Reg. No. 58,680
Thomas A. Rozylowicz, Reg. No. 50,620
Jennifer J. Huang, Reg. No. 64,297
Fish & Richardson P.C.
3200 RBC Plaza, 60 South Sixth Street
Minneapolis, MN 55402
T: 202-783-5070
F: 877-769-7945

(Control No. IPR2022-00340) Attorneys for Petitioner

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CERTIFICATION UNDER 37 CFR § 42.24

Under the provisions of 37 CFR § 42.24(d), the undersigned hereby certifies

that the word count for the foregoing Petition for Inter partes Review totals 11,363

words, which is less than the 14,000 allowed under 37 CFR § 42.24.

Dated January 21, 2022 /W. Karl Renner/


W. Karl Renner, Reg. No. 41,265
Jeremy J. Monaldo, Reg. No. 58,680
Thomas A. Rozylowicz, Reg. No. 50,620
Jennifer J. Huang, Reg. No. 64,297
Fish & Richardson P.C.
3200 RBC Plaza, 60 South Sixth Street
Minneapolis, MN 55402
T: 202-783-5070
F: 877-769-7945

Attorneys for Petitioner

64
Attorney Docket No 50095-0062IP1
IPR of U.S. Patent No. 10,470,203

CERTIFICATE OF SERVICE

Pursuant to 37 CFR §§ 42.6(e)(4)(i) et seq. and 42.105(b), the undersigned

certifies that on January 21, 2022, a complete and entire copy of this Petition for

Inter partes Review and all supporting exhibits were provided via Federal Express,

to the Patent Owner, by serving the correspondence address of record as follows:

CHRISTOPHER & WEISBERG, P.A.


1232 N. University Drive
Plantation, FL 33322

/Crena Pacheco/
Crena Pacheco
Fish & Richardson P.C.
60 South Sixth Street, Suite 3200
Minneapolis, MN 55402
(617) 956-5938

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