UNITED STATES PATENT AND TRADEMARK … and ZTE (USA) Inc. as an expert witness in the...

UNITED STATES PATENT AND TRADEMARK OFFICE

BEFORE THE PATENT TRIAL AND APPEAL BOARD

HTC Corporation and ZTE (USA) Inc. Petitioner

v.

CELLULAR COMMUNICATIONS EQUIPMENT LLC Patent Owner

INTER PARTES REVIEW OF U.S. PATENT NO. 9,037,129 Case IPR No.: To Be Assigned

DECLARATION OF DR. ROBERT AKL, D.Sc.

HTC/ZTE EXHIBIT 1002

i

Table of Contents

I. INTRODUCTION ........................................................................................... 1

II. QUALIFICATIONS ........................................................................................ 2

III. SCOPE OF OPINION ..................................................................................... 6

IV. MATERIALS REVIEWED AND CONSIDERED ........................................ 7

V. LEVEL OF ORDINARY SKILL IN THE ART ............................................. 8

VI. LEGAL PRINCIPLES ..................................................................................... 9

VII. CELL-BROADCAST SERVICE OVERVIEW ........................................... 10

VIII. MOBILE SUBSCRIBER IDENTITY (TMSI and IMSI) OVERVIEW ....... 12

IX. U.S. PATENT NO. 9,037,129 (“‘129 patent”).............................................. 15 A. Overview of the ‘129 Patent ................................................................ 15 B. Prosecution History of the ‘129 Patent ............................................... 19

X. OVERVIEW OF THE PRIOR ART REFERENCES ................................... 20 A. “Sennett-286,” U.S. Patent No. 8,368,530 (Ex. 1003) ........................ 20 B. “Sennett-280,” U.S. Patent No. 8,682,280 (Ex. 1005) ........................ 25 C. “Collins,” U.S. Patent No. 6,157,815 (Ex. 1007) ................................ 27 D. “Karl,” U.S. Patent No. 7,616,942 (Ex. 1008) .................................... 29

XI. CLAIM CONSTRUCTION .......................................................................... 32

XII. SPECIFIC GROUNDS OF CHALLENGE ................................................... 35 A. Ground A: Sennett-286 (Ex. 1003) in view of Sennett-280 (Ex. 1005)

and AAPA Renders Obvious, Under 35 U.S.C. § 103, Claims 1-20 .. 35 B. Ground B: Collins (Ex. 1007) in view of Karl (Ex. 1008) and AAPA

Renders Obvious, Under 35 U.S.C. § 103, Claims 1-20 ..................... 56

HTC/ZTE EXHIBIT 1002-2

Declaration of Dr. Robert Akl, D.Sc. U.S. Patent No. 9,037,129

1

I. INTRODUCTION

My name is Robert Akl, and I have been retained by counsel for HTC 1.

Corporation and ZTE (USA) Inc. as an expert witness in the above-captioned

proceeding.

My opinions are based on my years of education, research and 2.

experience, as well as my investigation and study of relevant materials. The

materials that I studied for this declaration include all exhibits of the petition.

I may rely upon these materials, my knowledge and experience, and/or 3.

additional materials to rebut arguments raised by the patent owner. Further, I may

also consider additional documents and information in forming any necessary

opinions, including documents that may not yet have been provided to me.

My analysis of the materials produced in this investigation is ongoing 4.

and I will continue to review any new material as it is provided. This declaration

represents only those opinions I have formed to date. I reserve the right to revise,

supplement, and/or amend my opinions stated herein based on new information

and on my continuing analysis of the materials already provided.

I am being compensated on a per hour basis for my time spent working 5.

on issues in this case. My compensation does not depend on the outcome of this

matter or the opinions I express.



2

II. QUALIFICATIONS

I am an expert in the field of wireless communications. I have studied, 6.

taught, practiced, and researched in the field of wireless communications for over

twenty years. I have summarized in this section my educational background, work

experience, and other relevant qualifications. A true and accurate copy of my

curriculum vitae is attached as Appendix A to my declaration.

I earned my Bachelor of Science degrees in Electrical Engineering and 7.

Computer Science summa cum laude with a grade point average of 4.0/4.0 and a

ranking of first in my undergraduate class from Washington University in Saint

Louis in 1994. In 1996, I earned my Master of Science degree in Electrical

Engineering from Washington University in Saint Louis with a grade point average

of 4.0/4.0. I earned my Doctorate of Science in Electrical Engineering from

Washington University in Saint Louis in 2000, again with a grade point average of

4.0/4.0, with my dissertation on “Cell Design to Maximize Capacity in Cellular

Code Division Multiple Access (CDMA) Networks.”

While a graduate student, from 1996 through 2000, I worked at 8.

MinMax Corporation in St. Louis, where I designed software packages that

provided tools to flexibly allocate capacity in a CDMA communications network

and maximize the number of subscribers. As part of this work, I validated the

hardware architecture for an Asynchronous Transfer Mode (ATM) switch capable



3

of channel group switching, as well as performed logical and timing simulations,

and developed the hardware architecture for the ATM switch. I also worked with

Teleware Corporation in Seoul, South Korea, where I designed and developed

algorithms that were commercially deployed in a software package suite for

analyzing the capacity in a CDMA network implementing the IS-95 standard to

maximize the number of subscribers.

After obtaining my Doctorate of Science degree, I worked as a Senior 9.

Systems Engineer at Comspace Corporation from October of 2000 to December of

2001. In this position, I designed and developed advanced data coding and

modulation methods for improving the reliability and increasing the available data

rates for cellular communications. I coded and simulated different encoding

schemes (including Turbo coding, Viterbi decoding, trellis coded modulation, and

Reed-Muller codes) and modulation techniques using amplitude and phase

characteristics and multi-level star constellations. This work further entailed the

optimization of soft decision parameters and interleavers for additive white

Gaussian and Rayleigh faded channels. In addition, I also extended the control and

trunking of Logic Trunked Radio (LTR) to include one-to-one and one-to-many

voice and data messaging.

In January of 2002, I joined the faculty of the University of New 10.

Orleans in Louisiana as an Assistant Professor in the Department of Electrical



4

Engineering. While on this faculty, I designed and taught two new courses called

“Computer Systems Design I and II.” I also developed a Computer Engineering

Curriculum with strong hardware-design emphasis, formed a wireless research

group, and advised graduate and undergraduate students.

In September of 2002, I received an appointment as an Assistant 11.

Professor in the Department of Computer Science and Engineering at the

University of North Texas (UNT), in Denton, Texas. In May of 2008, I became a

tenured Associate Professor in the Department of Computer Science and

Engineering. As a faculty member, I taught courses and directed research in

wireless communications, including 2G, 3G, 4G, CDMA/WCDMA, GSM, UMTS,

LTE, wireless sensors, Bluetooth, VoIP, multi-cell network optimization, call

admission control, channel coding, ad-hoc networks, and computer architecture. I

was the director of the Wireless Sensor Lab (“WiSL”). Several of my research

projects were funded by industry. In January of 2015, I was appointed Associate

Chair of Graduate Studies.

In addition to advising and mentoring students at UNT, I was asked to 12.

join the faculty of the University of Arkansas in Little Rock as an Adjunct

Assistant Professor from 2004 to 2008 in order to supervise the research of two

Ph.D. graduate students who were doing research in wireless communications. At

UNT, I have advised and supervised more than 250 undergraduate and graduate



5

students, many of whom received a master’s or doctorate degree under my

guidance.

In addition to my academic work, I have remained active in the 13.

communication industry through my consulting work. In 2002, I consulted for

Input/Output Inc. and designed and implemented algorithms for optimizing the

frequency selection process used by sonar for scanning the bottom of the ocean. In

2004, I worked with Allegiant Integrated Solutions in Ft. Worth, Texas to design

and develop an integrated set of tools for fast deployment of wireless networks.

Among other features, these tools optimize the placement of Access Points and

determine their respective channel allocations to minimize interference and

maximize capacity. I also assisted the Collin County Sheriff’s Office (Texas) in a

double homicide investigation, analyzing cellular record data to determine user

location.

I have authored and co-authored approximately 75 journal 14.

publications, conference proceedings, technical papers, book chapters, and

technical presentations, in a broad array of communications-related technology,

including networking and wireless communication. I have also developed and

taught over 100 courses related to communications and computer system designs,

including a number of courses on LTE, VoIP, wireless communication,

communications systems, sensor networks, computer systems design, and



6

computer architecture. These courses have included introductory courses on

communication networks and signals and systems, as well as more advanced

courses on wireless communications. A complete list of my publications and the

courses I have developed and/or taught is also contained in my curriculum vitae.

My professional affiliations include services in various professional 15.

organizations and serving as a reviewer for a number of technical publications,

journals, and conferences. I have also received a number of awards and

recognitions, including the IEEE Professionalism Award (2008), UNT College of

Engineering Outstanding Teacher Award (2008), and Tech Titan of the Future

(2010) among others, which are listed in my curriculum vitae.

A complete list of cases in which I have testified at trial, hearing, or by 16.

deposition within the preceding four years is provided in my curriculum vitae,

which is attached as Appendix A. In the listed cases, I have been retained by both

patent owners as well as petitioners.

III. SCOPE OF OPINION

I have been asked to provide my opinions regarding whether claims 1-17.

20 of the U.S. Patent No. 9,037,129 (“the ‘129 patent”) would have been obvious

to one of ordinary skill in art at the time of the alleged invention in view of U.S.

Patent No. 7,844,286 (“Sennett-286”) (Ex. 1003), U.S. Patent No. 8,682,280

(“Sennett-280”) (Ex. 1005), U.S. Patent No. 6,157,815 (“Collins”) (Ex. 1007), U.S.



7

Patent No. 7,616,942 (“Karl”) (Ex. 1008), and Applicant Admitted Prior Art

(“AAPA”) (Ex. 1001).

This declaration, including the exhibits hereto, sets forth my opinion 18.

on this topic.

IV. MATERIALS REVIEWED AND CONSIDERED

In connection with my work on this matter, I have reviewed and 19.

considered the following documents:

Exhibit No. Exhibit

1001 U.S. Patent No. 9,037,129 (“‘129 patent”)

1003 U.S. Patent No. 7,844,286 (“Sennett-286”)

1004 U.S. Provisional Patent Application No. 60/788,508 File History (“Sennett-286 provisional”)

1005 U.S. Patent No. 8,682,280 (“Sennett-280”)

1006 U.S. Provisional Patent Application No. 60/829,798 File History (“Sennett-280 provisional”)

1007 U.S. Patent No. 6,157,815 (“Collins”)

1008 U.S. Patent No. 7,616,942 (“Karl”)

1009 U.S. Provisional Patent Application No. 60/603,697 File History (“Karl provisional”)

1010 U.S. Patent No. 9,037,129 File History (“‘129 file history”)

1011 Fed. Commnc’s Comm’n, “Report and Order and Further Notice of Proposed Rule Making” (Dec. 9, 1994) (“FCC 94-288”)

1012 ETSI TS 100 902 V7.3.0 (2000-04) (“GSM 03.41”)

1013 3GPP TS 23.003 V.7.1.0 (2006-09) (“TS 23.003”)

1014 3GPP GSM 03.41, Jun. 23, 2003 http://web.archive.org/web/20030623174701/http://www.3gpp.org/ftp/specs/html-info/0341.htm

1015 3GPP TS 23.003, December 6, 2006, http://web.archive.org/web/20061206062007/http://www.3gpp.org/ftp/Specs/html-info/23003.htm



8

1016 U.S. Patent No. 8,868,060 File History (“‘060 file history”)

I also have relied on my academic and professional experience in 20.

reaching the opinions expressed in this declaration.

V. LEVEL OF ORDINARY SKILL IN THE ART

In rendering the opinions set forth in this declaration, I was asked to 21.

consider the patent claims and the prior art through the eyes of a person of ordinary

skill in the art (“POSITA”). I considered factors such as the educational level and

years of experience of those working in the pertinent art; the types of problems

encountered in the art; the teachings of the prior art; patents and publications of

other persons or companies; and the sophistication of the technology. I understand

that a POSITA is not a specific real individual, but rather a hypothetical individual

having the qualities reflected by the factors discussed above.

Taking these factors into consideration, it is my opinion that a 22.

POSITA as of the time of the ‘129 patent would have had a B.S. degree in

computer science, computer engineering, electrical engineering, or a related field,

and around 2 years of experience in the design or development of wireless

communication systems, or the equivalent. Such a person would have been aware

of slotted paging mechanism (including discontinuous reception “DRX” paging)

and cell broadcasting in cellular networks, and would understand the prior art

references described in this declaration.



9

VI. LEGAL PRINCIPLES

It is my understanding that there are two ways in which prior art may 23.

render a patent claim unpatentable. First, the prior art can be shown to “anticipate”

the claim. Second, the prior art can be shown to have made the claim “obvious” to

a POSITA.

It is my understanding that a patent claim is unpatentable as being 24.

obvious in view of prior art if the differences between the subject matter sought to

be patented and the prior art are such that the subject matter as a whole would have

been obvious at the time the alleged invention was made to a POSITA to which

said subject matter pertains. I further understand that an obviousness analysis takes

into consideration factual inquiries such as the level of ordinary skill in the art, the

scope and content of the prior art, and the differences between the prior art and the

patent claim.

I understand that the U.S. Supreme Court has recognized several 25.

rationales for combining references and for modifying a reference as part of an

obviousness analysis. These rationales include combining prior art elements

according to known methods to yield predictable results, simple substitution of a

known element for another to obtain predictable results, a predictable use of prior

art elements in accordance with their established functions, applying a known

technique to improve a known device (or process) and yield predictable results,



10

and choosing from a finite number of known predictable solutions with a

reasonable expectation of success. It is further my understanding that an

obviousness analysis takes into consideration whether the prior art provides a

teaching, suggestion, or motivation to combine teachings of multiple prior art

references to arrive at the patent claim.

I also understand that the earliest possible priority date for the ‘129 26.

patent is April 2, 2007. I have therefore analyzed obviousness as of that date or

somewhat before that date.

VII. CELL-BROADCAST SERVICE OVERVIEW

The 3rd Generation Partnership Project (3GPP) is an organization that 27.

unites various telecommunications standard development organizations in order to

determine standards for cellular telecommunications network technologies.

Accordingly, one of skill in the art would look to the 3GPP website for information

relating to cellular telecommunications network technologies. As an example, one

of skill in the art interested in learning about cellular broadcast services would look

to the relevant specifications found on the 3GPP website.

The 3GPP working group publishes working specifications on its 28.

website, www.3gpp.org. These specifications are freely provided to the public

without access controls such as login/passwords. (See, e.g., 3GPP Specifications

Home, http://www.3gpp.org/specifications/specifications (accessed 2017-03-14);



11

see also, GSM 03.41). For example, all of the specifications for GSM 03.41 (since

renamed TS 100 902) can be found at the following web address:

http://www.3gpp.org/dynareport/0341.htm.

In my experience, these 3GPP specifications can also be found through 29.

popular search engines such as www.google.com. For example, V7.3.0 of ETSI TS

100 902 (formerly “GSM 03.41”) specification (Ex. 1012) was available to the

public no later than June 23, 2003, which is before the earlies priority date of the

‘129 patent. (Ex. 1014.)

GSM 03.41 specification describes a “Cell Broadcast short message 30.

service (CBS).” (GSM 03.4, § 1, p. 6.) The CBS service “permits a number of

unacknowledged general messages to be broadcast to all receivers within a

particular region.” (GSM 03.41, § 2, p. 7.) For example, a public land mobile

network (PLMN) may be used to transmit messages. (Id.) Since the messages can

be broadcast to receivers unacknowledged, a CBS service is useful because system

bandwidth is not required for receiving acknowledgements from various receivers,

and important messages can be broadcast to several receivers quickly.

One example of a receiver, a mobile station/subscriber (MS) can read 31.

“different cell broadcast channels” in order to “receiv[e] a CBS message,” which

can then be displayed by the MS. (GSM 03.41, § 2, p. 7.; see also § 9.3, p. 23-27

for discussion of the messages sent to the MS.)



12

Accordingly, GSM 03.41 specification defines a standard for Cell 32.

Broadcast short message service (CBS) that can be used to transmit messages to

several mobile stations (MS) without receiving any acknowledgements from an

MS.

This CBS service is relevant to the ‘129 patent, as the ‘129 patent itself 33.

discloses that the GSM 03.41 defines an “existing broadcast service” that can send

“short messages to all mobile terminals attached or registered to a base station or

cell.” (‘129 patent, 1:46-55.) The ‘129 patent further discloses that this “GSM Cell-

Broadcast Service” can be used in “at least one or more of the embodiments”

described in the ‘129 patent to send messages to mobile terminals. (Id.)

Accordingly, the ‘129 patent may utilize a Cell-Broadcast short message service

(CBS) like the one disclosed in GSM 03.41 for transmitting unacknowledged

messages to various mobile subscribers (MS).

VIII. MOBILE SUBSCRIBER IDENTITY (TMSI and IMSI) OVERVIEW

As noted above, 3GPP working group publishes working 34.

specifications on its website, www.3gpp.org. These specifications are freely

provided to the public without access controls such as login/passwords. (See, e.g.,

Ex. 1013). For example, all of the specifications for TS 23.003 can be found at the

following web address: http://www.3gpp.org/dynareport/23003.htm.



13

As noted above, one of skill in the art wishing to learn about how 35.

temporary mobile subscriber identities (TMSI) are used by a network to

communicate with mobile terminals (e.g., a cellular telephone) in a particular

geographic location would look to the relevant specifications found on the 3GPP

website.

V7.1.0 of 3GPP TS 23.003 (“TS 23.003”) specification (Ex. 1013) was 36.

available to the public no later than December 6, 2006, which is before the earliest

priority date of the ‘129 patent. (Ex. 1015.)

TS 23.003 specifies that in a global system for mobile communications 37.

(GSM) “A unique International Mobile Subscriber Identity (IMSI) shall be

allocated to each mobile subscriber in the GSM/UMTS system.” (TS 23.003, § 2.1,

p. 10.) The IMSI is a unique mobile subscriber identifier assigned to a mobile

subscriber (MS). However, if an IMSI is used to identify numerous routine cellular

communications for an MS, the IMSI of an MS may be compromised due to

numerous exchanges of the IMSI between an MS and other components of a GSM,

such as a base station or mobile switching center (MSC). Accordingly, in order to

“support [] subscriber identity confidentiality,” a visitor location register (VLR) or

serving GPRS (general packet radio service) support node (SGSN), which manages

authentication of mobile users, may allocate each MS supported by the VLR or



14

SGSN a Temporary Mobile Subscriber Identity (TMSI) to visiting mobile

subscribers. (TS 23.003, § 2.1, p. 10.)

The VLR and SGSNs can “correlat[e] an allocated TMSI with the 38.

IMSI of the MS to which it is allocated.” (TS 23.003, § 2.1, p. 10.) Accordingly, as

long as an MS is in a particular geographic area, the TMSI can be used to identify

an MS for communications with components of a GSM such as a base station or

MSC. If a user relocates to a different area, a new TMSI can be allocated to the MS

and associated with the IMSI. In other words, the “TMSI has only local

significance.” (TS 23.003, § 2.4, p. 11.)

Below is an excerpt from TS 23.003 showing the Structure of TMSI. 39.

TS 23.003 specification states that the TMSI consists of 4 octets and it can be

coded using a full hexadecimal representation. (TS 23.003, § 2.4, p. 11,

highlighting is mine.)

Further, multiple TMSIs can be allocated to a single MS, where 40.

different TMSIs are associated with different services or types of services being

provided to the MS. (TS 23.003, § 2.1, p. 10.) An MS with one or more allocated



15

TMSI can then “use an allocated TMSI according to the specifications” of the

TMSI that indicate a particular service. (TS 23.003, § 2.4, p. 11.)

The use of TMSIs as discussed in TS 23.003 is relevant to the ‘129 41.

patent, as the ‘129 patent itself discloses that the TMSIs of “3GPP TS 23.003

V7.1.0 (2006 September), chapter 2” may be used as “subscriber identities” for

processing a regular incoming phone call. (‘129 patent, 4:25-45.) The ‘129 patent

further discloses that when an MS or mobile terminal detects a “TMSI allocated

from the network to the terminal,” the terminal “establishes a physical and/or

logical channel in the customary manner.” (‘129 patent, 3:41-46.) Accordingly, the

‘129 patent may utilize TMSIs as described in TS 23.003 in order to confidentially

communicate with mobile subscribers (MSs) based on a location of an MS.

IX. U.S. PATENT NO. 9,037,129 (“‘129 patent”)

A. Overview of the ‘129 Patent

The ‘129 patent describes “conveying information such as emergency 42.

information to a large number of people in an efficient way.” (‘129 patent, 1:33-

35.) Specifically, the ‘129 patent addresses using an “existing broadcast service

such as the GSM Cell-Broadcast Service” to allow “messages to be broadcast to all

mobile users in a specified geographical area” that avoids “frequent reading of a

notification channel,” which “has harsh consequences on the battery drain and the

stand-by time of a [mobile] terminal.” (‘129 patent, 1:46, 53-55, and 58-61.)



16

In the ‘129 patent, the “broadcast service” is “actively invoked by the 43.

terminal in case of need only, using a paging mechanism.” (‘129 patent, 1:64-2:3.)

In other words, the ‘129 patent describes a procedure for invoking a broadcast

service, such as the one discussed above with respect to existing GSM 03.41

specification (GSM 03.41; see, e.g., §§ 1, 2, 9.3; pp. 6, 7, 23-27), with a paging

service.

Since the existing GSM Cell-Broadcast Service “normally requires a 44.

very frequent reading of a notification channel,” it is difficult for a mobile terminal

to utilize “a power saving sleep mode” (also referred to as “stand-by time”). (‘129

patent, 1:57-61.) The ‘129 patent uses the Cell-Broadcast Service for emergency

support while avoiding the drawbacks of minimal stand-by time and increased

battery drain by actively invoking a broadcast service using this “paging

mechanism.” (‘129 patent, 1:60-2:3.)

Thus, in the ‘129 patent, the network notifies the phone of an 45.

emergency broadcast via a discontinuous reception (“DRX”) paging message.

(‘129 patent, 3:35-41.) The paging message includes not the phone’s temporary

mobile subscriber identity (“TMSI”) that the network normally allocates to the

phone, but an identifier of the emergency (“E-TMSI”).

The ‘129 patent describes that when a “mobile receives a valid E-46.

TMSI ... it switches to Cell-Broadcast mode and starts to monitor the Cell-



17

Broadcast Notification channels for emergency information contents.” (‘129

patent, 5:20-24.) An E-TMSI (or emergency TMSI) of the ‘129 patent is a type of

“specific identifier” as defined by the ‘129 patent. (‘129 patent, 4:65-5:3.) An E-

TMSI can be defined according to the TS 23.003 standard (TS 23.003; see, e.g., §§

2.1 and 2.4, pp. 10 and 11) described above. (‘129 patent, 4:25-45.) A page sent to

a mobile terminal can include a specific identifier, such as the E-TMSI, which the

mobile terminal can receive and recognize the specific identifier “as an indication

to switch to . . . the cell broadcast service.” (‘129 patent, 4:30-34.)

‘129 patent, FIG. 1

In the ‘129 patent’s solution, if the phone identifies its TMSI in a 47.

paging message, it processes the message as a regular incoming phone call. (‘129

patent, 3:41-46.) But if the paging message includes an E-TMSI, the phone



18

switches to the broadcasting channel to receive the emergency broadcast. (‘129

patent, 3:46-52.)

‘129 patent, FIG. 5

In summary, the ‘129 patent does not invent cellular communications 48.

or cellular broadcast services; instead, it admits that the GSM 03.41 specification

defines a cell broadcast service before the ‘129 patent. (‘129 patent, 1:46-55.) Nor

does the ‘129 patent invent emergency broadcast services; as examples, FCC 94-

288 (Ex. 1011) and Karl (Ex. 1008) discuss emergency cellular broadcast services

before the ‘129 patent, as explained below. Further, the ‘129 patent does not invent

discontinuous reception (“DRX”) techniques or paging messages. These were

incorporated into cellular communication systems well before the ‘129 patent. For

example, the ‘129 patent admits that “3GPP TS 23.003 V7.12.0 (2006 September)

specification, chapter 2” defines the normal TMSI. (‘129 patent, 4:25-27.) Further,



19

the ‘129 patent admits that it was “customary” for a base station to send a terminal

a TMSI in a paging message, and when the terminal detected the TMSI in the

paging message, the terminal would establish a physical and/or logical channel.

(‘129 patent, 3:33-46.) Further, the ‘129 patent admits that DRX techniques were

already implemented in GSM. (‘129 patent, 4:16-24.)

Thus, the alleged innovation of the ‘129 patent is limited only to 49.

switching a user equipment to a broadcast channel when it receives a paging

message with a specific identifier indicative of an emergency.

Further, the prior references discussed in this declaration teach all of 50.

the limitations of the claims of the ‘129 patent, including specific identifiers used

to activate a broadcast mode and TMSIs used to establish a point-to-point

communication channel for normal telephone services.

B. Prosecution History of the ‘129 Patent

During prosecution, the Applicant amended claims of co-pending 51.

Application No. 14/517,769 to overcome a statutory double patenting rejection and

filed a terminal disclaimer to overcome an obviousness-type double patenting

rejection over its parent, U.S. Patent No. 8,868,060. (‘129 file history, pp. 102-

104.)

During prosecution of ‘129 patent’s parent application, the Applicant 52.

amended the claims four times before securing allowance. (‘060 file history, pp.



20

70-74, 111-15, 310-12, 339-41.) Despite numerous amendments and arguments,

the Applicant did not receive allowance until after amending the claims to recite:

(1) both the behavior of the mobile terminal if it received a paging message with a

specific identifier and the behavior of the terminal if it received a normal TMSI;

(2) that there are at least two different specific identifiers to indicate different types

of emergencies; and (3) that the cellular wireless network is bi-directional between

a base station and a plurality of terminals. (‘060 file history, pp. 70-74, 76-78.)

X. OVERVIEW OF THE PRIOR ART REFERENCES

A. “Sennett-286,” U.S. Patent No. 8,368,530 (Ex. 1003)

Sennett-286 is titled, “emergency notification system for a portable 53.

device,” and issued Nov. 30, 2010, from U.S. Patent Application No.11/472,078

(“Sennett-286 application”), filed June 21, 2006, which claims priority to U.S.

Provisional Application No. 60/788,508, filed Mar. 31, 2006 (“Sennett-286

provisional”). Thus, Sennett-286 constitutes prior art to the ‘129 patent under pre-

AIA 35 U.S.C. § 102(e) based on the filing date of either the Sennett-286

application or the Sennett-286 provisional.

The Sennett-286 application is fully supported by the Sennett-286 54.

provisional. For example, the Sennett-286 provisional includes all the figures and

associated descriptions of the Sennett-286 application.



21

In Sennett-286, “[s]ystems and methods for providing alerts to end 55.

users of networked enabled portable devices are provided so that the end users are

made aware when broadcast emergency alerts are issued.” (Sennett-286, Abstract.)

Sennett-286 is directed to “notification and reporting of emergency alerts, such as

those issued by the Emergency Alert System (“EAS”), to networked portable

devices.” (Id., 1:22-23.) Sennett-286 uses “[e]xisting broadcast technologies, such

as Cell Broadcast, . . . to support emergency alert notification(s) to wireless

subscribers” that avoids “continuous monitoring by the wireless subscriber’s

handset” which “will likely have a major impact on the handset battery life.” (Id.,

1:29-49.)

Thus, Sennett-286 seeks to solve the same problem as the ‘129 patent. 56.

(‘129 patent, 1:56-63.) For instance, Sennett-286 discloses “means for a portable

device to receive information about an emergency alert of which the user should be

aware, e.g., from the EAS, and to notify the user of the portable device of the

emergency alert without requiring action by the user.” (Id., 2:33-39.)



22

Sennett-286, FIG. 6

Sennett-286 discloses that the user portable device or mobile station 57.

has a Subscriber Identity Module (SIM) for storing an International Mobile

Subscriber Identity (IMSI) that uniquely identifies the mobile subscriber. (Sennett-

286, 8:14-19.) As shown in FIG. 6, the network of Sennett-286 includes a Mobile

Switching Center (MSC) that, in conjunction with other components such as the

Home Location Register (HLR) and Visitor Location Register (VLR), performs

registration, switching, authentication, location updating, handover, roaming, and

call routing functions for the network. (Sennett-286, 8:27-54.) To gain access to

the GSM services and receive incoming calls, the user mobile station first registers



23

with the network by performing a location update and IMSI attach procedure with

the MSC/VLR. (Sennett-286, 9:1-12.)

FIG. 6 and disclosures of telephone radio networks in Sennett-286 are 58.

similar to the disclosure of TMSI in the TS 23.003 specification discussed above.

(Supra ¶¶ 37-39.)

Sennett-286 also discloses “means for determining, in accordance with 59.

the received information, whether the emergency broadcast is relevant; means for

retrieving at least a subset of the stored emergency broadcast information if it is

determined that the emergency broadcast is relevant; a broadcast processor that

automatically tunes to the emergency broadcast upon determining that the

emergency broadcast is relevant,” (Sennett-286, Claim 8.) For example, “When the

user device detects the setting of the emergency alert indicator bit on the control

channel(s) that it is monitoring, the user device is able to immediately lead the user

to the emergency information, or instruct the user with pre-provisioned information

about the emergency alert, and any associated broadcast channels that contain the

emergency alert.” (Id., 2:54-62.) The emergency alert mechanism can also be an

emergency alert message “which modifies a storage location, e.g., a bit, on the user

device when the message is processed,” (id., 3:4-10,) or in the form of emergency

broadcast information that includes, e.g.,: “(A) information about available

broadcast technologies (e.g., Cell Broadcast, MBMS, DVB-H, MediaFLO, etc.),



24

(B) information concerning which broadcast technologies or network(s), such as

broadcast network 60, are specifically supported by the device 20 and (C)

information about emergency broadcast channels associated with each available

broadcast technology.” (Id., 3:54-62.)

Once an emergency alert is received, “special alert tones may be 60.

activated and special display graphics, symbols, text, etc. may be portrayed on a

display of the user device 20 that inform the user that an emergency broadcast is

being sent and to which channel or channels the user should tune for the

emergency broadcast.” (Id., 4:34-44.)

Thus, like the ‘129 patent, Sennett-286’s portable devices (or mobile 61.

stations) either receive a paging message comprising information related to

“International Mobile Subscriber Identity” (e.g. corresponding to the ‘129 patent’s

normal TMSI in exemplary embodiments, (‘129 patent, 3:23-46)), and in response

conduct a normal incoming call, (Sennett-286, 9:1-4,) or receive a paging message

comprising emergency broadcast information, emergency alert indicator bit, or

emergency alert message (e.g. corresponding to the ‘129 patent’s specific

identifiers indicating an emergency situation, (‘129 patent, 3:46-52)) and switch to

a broadcasting channel to receive an emergency broadcast, (Sennett-286, 2:54-62;

3:4-10; 3:50-52; 4:34-44; 8:14-19.)



25

B. “Sennett-280,” U.S. Patent No. 8,682,280 (Ex. 1005)

Sennett-280 is titled, “selectable processing of broadcast EAS 62.

messages” and issued Mar. 25, 2014, from U.S. Patent Application No.11/609,587

(“Sennett-280 application”), filed Dec. 12, 2006, which claims priority to U.S.

Provisional Application No. 60/829,798, filed Oct. 17, 2006 (“Sennett-280

provisional”). Thus, Sennett-280 constitutes prior art to the ‘129 patent under pre-

AIA 35 U.S.C. § 102(e) based on the filing date of either the Sennett-280

application or the Sennett-280 provisional.

Figures 1-7 of the Sennett-280 application are included in the Sennett-63.

280 provisional. The Sennett-280 provisional does not include figures related to

the example telephone radio networks, which are FIG. 8-10 of the Sennett-280

application.

Sennett-280 is directed to “broadcast of Emergency Alert System 64.

(EAS) notifications and messages” where “[b]roadcast emergency alert messages

are selectively processed in accordance with various aspects of the alerted event,

the alert message, and/or user preferences.” (Sennett-280, Abstract.) “A received

broadcast emergency alert message is analyzed to determine various characteristics

pertaining to the message, such as alert type, alert subtype, likelihood of alert

occurrence, alert severity, receipt time, geographic extent of the alert area,

originator of the alert message, a time when the alert message was originated.”



26

(Id.) Thus, “[a] user of the mobile device can tailor the type of EAS alerts to be

received, the time period, or periods, during which EAS alerts can be received, and

actions to be taken with respect to received alerts.” (Id.)

In Sennett-280, “an enhanced emergency alert message contains 65.

parameters indicative of the type of emergency alert. The parameters are used to

allow the subscriber to configure the reception of the alert tailored to the

subscriber's preferences.” (Sennett-280, 1:55-58.) For example, the type of EAS

alert (which are events disclosed in FCC 94-288) can include weather, AMBER,

general emergency and public safety, law enforcement, medical and public health,

chemical threat or attack, etc. (Id., 2:45-55.) “The parameters are utilized to allow

tailored manipulation of the received broadcast enhanced EAS message. In one

embodiment, the parameters are in a header of the enhanced EAS message. Upon

receipt, by a mobile device or the like, the header is analyzed to determine the type

of alert, and the message is handled in accordance with the type of alert and

instructions provided to the mobile device.” (Id., 2:55-61.)

Sennett-280 and Sennett-286 have the same inventors and both are 66.

directed to notification and broadcasting of EAS messages. (Sennett-286, 1:21-25;

Sennett-280, 1:16-17.) Further, Sennett-280 and Sennett-286 disclose identical

telephony radio networks and operating environments for notification and



27

broadcasting of EAS messages. (Sennett-286, 5:10-10:67; FIGs. 4-6; Sennett-280

11:39-17:26; FIGs. 8-10.)

C. “Collins,” U.S. Patent No. 6,157,815 (Ex. 1007)

Collins is titled, “method and apparatus for providing broadcasting 67.

messages in a communications network,” and issued December 5, 2000, from U.S.

Patent Application No. 08/912,049, filed August 15, 1997, which is a continuation

of U.S. Patent Application No. 08/316,157, filed September 30, 1994. Thus,

Collins constitutes prior art to the ‘129 patent under pre-AIA 35 U.S.C. § 102(b).

Collins discloses “a novel and improved method for providing 68.

broadcast short message services (SMS) in a communication network,” in a

manner “without depriving the receiver of the benefit of reduced power

consumption gained by slotted paging.” (Collins, 2:16-27.) Thus, Collins seeks to

solve the same problem as the ‘129 patent. (‘129 patent, 1:56-63.)

Collins discloses subscriber stations 12, 14, and 16, operating within a 69.

code division multiple access (“CDMA”) network. Collins’ central communication

center 10 is a base station operating within the CDMA network. (Collins, 4:11-16.)

Like the ‘129 patent, in Collins, the subscriber stations also receive paging

messages via a DRX mechanism, i.e., a slotted paging mechanism: “In a slotted

paging system, the subscriber station ‘wakes up’ or ‘powers up’ at predetermined



28

time intervals, referred to as slot cycles, to monitor its assigned paging channel for

traffic pages.” (Collins, 4:66-5:2.)

Ordinarily, the subscriber stations receive incoming calls using a 70.

temporary mobile subscriber identity: “When the central communications center

needs to set up a point to point communication with a subscriber station it

transmits a traffic page on the paging channel being monitored by the subscriber

station. The traffic page would typically comprise subscriber station identification

information and traffic channel identification information. In response to the

received traffic page, the identified subscriber station would prepare to conduct

point to point communications on the identified traffic channel.” (Collins, 1:26-

39.)

But subscriber stations can also receive broadcast pages. “[T]he 71.

broadcast page contains a broadcast handle that specifies the nature of the

corresponding broadcast message. This broadcast message may contain

information as to the source of the message, the function of the message, the

language in which the message is provided and a sequence number. The broadcast

handle provides sufficient information to allow the subscriber station to determine

whether or not to receive the related broadcast message.” (Collins, 3:40-48.) In

particular, the broadcast handle includes a “function code [that] indicates the

subject matter of the message.” (Collins, 12:11-12.)



29

“Decoder 56 decodes the broadcast page and provides the decoded 72.

broadcast page to page receive controller 62. Page receive controller 62 determines

in accordance with a predetermined set of user preferences if the forthcoming

broadcast message will be of interest to the subscriber station user.” (Collins, 7:40-

44.) “If page receive controller 62 determines that the forthcoming broadcast

message will be of interest to the subscriber station user, then it generates signals

to receive the broadcast message.” (Collins, 7:45-48.)

Thus, like the ‘129 patent, Collins’ subscriber stations either receive a 73.

traffic page comprising “subscriber station identification information” (e.g.

corresponding to the ‘129 patent’s normal TMSI in exemplary embodiments, (‘129

patent, 3:23-46)), and in response conduct a normal incoming call, (Collins, 1:26-

39,) or receive a broadcast page comprising a broadcast handle (e.g. corresponding

to the ‘129 patent’s specific identifiers indicating an emergency situation, (‘129

patent, 3:46-52)) and switch to a broadcasting channel to receive an emergency

broadcast. (Collins, 3:40-48; 7:40-48; 12:11-12.)

D. “Karl,” U.S. Patent No. 7,616,942 (Ex. 1008)

Karl is titled, “alert system and personal apparatus,” and issued 74.

November 10, 2009, from U.S. Patent Application No. 11/203,721 (“Karl

application”), filed August 15, 2005, which claims priority to U.S. Provisional

Patent Application No. 60/603,697 (“Karl provisional”; Exhibit 1009), filed



30

August 23, 2004. Thus, Karl constitutes prior art to the ‘129 patent under pre-AIA

35 U.S.C. § 102(e) based on the filing date of either the Karl application or the

Karl provisional.

Although the Karl provisional does not include any figures, the Karl 75.

application is fully supported by the Karl provisional at least because the Karl

provisional includes all the relevant substantive sections of the Karl application.

Karl is directed to “disseminat[ing] emergency information to the 76.

public utilizing a universal paging system through a personal alert device.” (Karl,

1:15-17.) For example, “[t]he emergency notification system 20 provides a quick

method for delivering emergency messages to a large number of mobile and static

devices of different types in a localized area.” (Karl, 4:12-15.) “The FCC has

adopted a mandatory protocol for the transmission of signals which includes state

and local identification and emergency codes. This universal approach greatly

enhances our ability to adopt a national approach in creating a personal portable

emergency alert system. The Federal Communication Commission released the

details, including location and emergency codes, of the proposed Emergency Alert

System in document FCC 94-288.” (Karl, 1:51-58; FCC-94-288.)

Karl discloses that its invention can operate within CDMA, GSM, and 77.

GPRS networks, among others. (Karl, 2:16-3:54; 6:53-67.) Karl discloses multiple

user devices for its networks, such as mobile phone 36 and E-FOB 38. (Karl, FIG.



31

1.) For example, “cellular network service providers 32 broadcast the message

through their network of cell towers 34. Mobile phones 36 in the identified area

receive the cell broadcast message from the network to alert the user of the nature

of the emergency. The majority of cellular phones and other wireless devices in

use today are capable of receiving broadcast messages through the GSM and

CDMA technologies.” (Karl, 5:39-46.)

Karl discloses the use of the Federal Communications Commission’s 78.

Emergency Alert System (“EAS”) with cellular networks. Specifically, Karl

discloses EAS event codes that are disclosed in FCC 94-288. For example, Karl

discloses: “‘EEE’ is the Event code which indicates the nature of the EAS

activation. The event codes are compatible with the codes used by the National

Weather Service (NWS) Weather Radio Specific Area Message Encoder

(WRSAME). There are over 30 Event codes such as EAN—Emergency Action

Notification (National only); TOR—Tornado Warning; HUW—Hurricane

Warning; and TSW—Tsunami Warning, for example.” (Karl, 4:45-52; FCC 94-

288, pp. 83-84.)

Because the event codes are standardized according to type of 79.

emergency, they are common to all of Karl’s user devices (e.g., mobile phone 36

or E-FOB 38). Karl also contemplates a power-saving mechanism; for example, by



32

using a wakeup code antenna 50 and RF receiver 52, which extend battery life by

only activating the user device when an EAS signal is received. (Karl, 6:15-52.)

In Karl, “[p]rocessor instructions may be stored in a flash memory 80.

device 66 which define how broadcast messages should be processed. The process

includes determination of the level of the emergency. For example, a high level

warning requiring the user to take shelter and/or terrorist alert may activate a red

LED.” (Karl, 7:3-8.) “A text display may be used to provide a text message to the

user. A vibrator 72 may be activated to provide a tactile alert of the warning signal

to the user. Additionally, a speaker or beeper 74 may be activated to provide an

audible alert of the warning signal to the user.” (Karl, 7:18-22.)

XI. CLAIM CONSTRUCTION

I understand that the terms of the ‘129 patent are to be given their 81.

broadest reasonable interpretation as understood by a POSITA at the time of the

invention in view of the specification. 37 C.F.R. § 42.100(b).

The “specific identifiers” recited in the claims of the ‘129 patent can 82.

be included in a “paging message” and are used for “indicating an emergency or

other situation.” (‘129 patent, 2:64-66.) (“Further, in step S23, the network starts

sending paging messages which include a specific identifier for indicating an

emergency or other situation.” (emphasis added).) “The sent paging messages may

indicate an emergency situation by help of the specific identifier such as an E-



33

TMSI.” (‘129 patent, 3:1-3, (emphasis added).) “Instead of E(mergency)-TMSI

any other name may be used for this specific identifier, provided that the format

and content is such that the terminals can recognize the specific identifier as an

indication to switch to the listening to the cell broadcast service.” (‘129 patent,

4:30-34, (emphasis added).)

The ‘129 patent discloses “Similar to a normal TMSI assigned to a 83.

terminal having local significance within a VLR and the area controlled by a VLR,

or within an SGSN and the area controlled by an SGSN, the specific identifier such

as E-TMSI may consist of 4 octets and can be coded using, e.g., a full hexadecimal

representation, with the structure and coding optionally chosen in order to meet

local needs.” (‘129 patent, 4:35-41; supra ¶¶ 37-39.) Accordingly, the specific

identifiers (e.g., E-TMSIs) of the ‘129 patent may be structured similar to the

TMSI’s discussed above and defined by TS 23.003 specification (TS 23.003; see,

e.g., §§ 2.1 and 2.4, pp. 10 and 11).

The “specific identifier” of the ‘129 patent is a “generic identifier for 84.

indicating an emergency situation.” (‘129 patent, 5:18-20.) This is in contrast to the

“normal TMSI” disclosed in the ‘129 patent that can be “assigned to a terminal”

and has “local significance.” (‘129 patent, 4:35-41.) These “normal TMSIs”

function according to the discussion above with respect to the TS 23.003 standard



34

(TS 23.003; see, e.g., §§ 2.1 and 2.4, pp. 10 and 11) and are distinct from the

“specific identifiers” recited in the claims of the ‘129 patent.

The ‘129 patent further discloses that “The discrimination between a 85.

normal TMSI temporarily assigned to the terminal and the specific identifier may

be done using some bits of the TMSI.” (‘129 patent, 4:46-48, (emphasis added).)

“The E-TMSI uses a number pattern unique to indicate emergency situations.”

(‘129 patent, 5:2-3, (emphasis added).) “The specific identifier such as E-TMSI

may be stored, similar to a normal TMSI, in the subscriber identity module,

SIM, or in another storage of the terminals so that some or all terminals store the

same specific identifier.” (‘129 patent, 4:52-54, (emphasis added).)

The “broadcast channel” recited in the claims of the ‘129 patent refers 86.

to a “cell-broadcast service” through which a terminal may receive broadcast

messages or broadcast content, such that the terminal “displays or announces or

otherwise notifies the user of the terminal [about] the broadcast content.” (‘129

patent, 2:49-55; 3:6-8 and 20-23.) Accordingly, when the mobile terminal switches

to a “broadcast channel,” the terminal is switching to a cell broadcast service such

as the one described above with respect to standard GSM 03.41 (GSM 03.41; see,

e.g., §§ 1, 2, 9.3; pp. 6, 7, 23-27). (‘129 patent, 1:46-55; 2:49-55; 3:3-8, 20-27, and

46-55; 5:20-24, 31-41, 56-67.)



35

The claims of the ‘129 patent recite “establishing/establish, … at least 87.

one of a physical channel and a logical channel when the received paging message

includes a mobile terminal identifier allocated to the mobile terminal.” This step

refers to a communication channel (e.g., a point-to-point communication channel)

established at a mobile terminal in response to a TMSI received by the terminal.

(‘129 patent, 3:41-46.) A POSITA would recognize that this functionality is similar

to that discussed above with respect to the existing TS 23.003 standard (TS 23.003;

see, e.g., §§ 2.1 and 2.4, pp. 10 and 11), where a TMSI is used to allow a network

to confidentially communicate with a mobile terminal located in a particular

region. Indeed, the ‘129 patent describes that the establishment of a “physical

and/or logical channel” occurs by the terminal “in the customary manner.” (‘129

patent, 3:41-46.)

Accordingly, the claims of the ‘129 patent recite “specific identifiers” 88.

that are used to switch a mobile terminal to a cell broadcast channel and a normal

or customary “mobile terminal identifier” (TMSI) that is used to establish a

physical or logical communication channel for the mobile terminal.

XII. SPECIFIC GROUNDS OF CHALLENGE

A. Ground A: Sennett-286 (Ex. 1003) in view of Sennett-280 (Ex. 1005) and AAPA Renders Obvious, Under 35 U.S.C. § 103, Claims 1-20

1. Sennett-286 in view of Sennett-280 and AAPA renders independent claims 1, 7, 13, and 17 obvious.



36

a. [1pre]: “A method of communicating in a bi-directional cellular wireless communication system between a base station and a plurality of mobile terminals supporting an emergency warning, the method comprising:”

[7pre]: “A mobile terminal configured for operating in a bi-directional cellular wireless communication system having a base station and a plurality of other mobile terminals supporting an emergency warning, the mobile terminal comprising:”

[13pre]: “A bi-directional cellular wireless communication system adapted to implement a cell broadcast service and a paging mode, the system comprising: a transmitter configured to broadcast content and transmit at least one paging message to a plurality of mobile terminals in a cell; and the plurality of mobile terminals, each of the plurality of mobile terminals comprising:”

[17pre]: “A method of communicating with a plurality of mobile terminals in a bi-directional cellular wireless communication system between a base station and the plurality of mobile terminals, the method comprising: broadcasting, at the base station, content to the plurality of mobile terminals in a cell; transmitting, at the base station, at least one paging message to the plurality of mobile terminals in the cell;”

Sennett-286 discloses “[s]ystems and methods for providing alerts to 89.

end users of networked enabled portable devices are provided so that the end users

are made aware when broadcast emergency alerts are issued.” (Sennett-286,

Abstract; see also FIG. 1; 3:21-62.) “Emergency information, as depicted in FIG.

3, can be delivered via any broadcast technology supported by the broadcast

processor 26 of the user device 20. In FIG. 3, at step 300, the broadcast network(s)

60 receives an emergency alert from the emergency alert network 50, such as the

EAS. At step 310, the broadcast network starts broadcasting the received



37

emergency alert. At step 320, whether activation occurs automatically or optionally

at the behest of a user that has been notified of the alert (e.g., via the process

depicted in FIG. 2), the associated emergency broadcast channel of the user device

20 is activated. The broadcast processor 26 receives the broadcasted emergency

alert data and displays the emergency alert via the user interface 28 of the user

device 20.” (Sennett-286, 4:45-62.)

Sennett-286, FIG. 1



38

As shown in FIG. 6 of Sennett-286, “Cell Broadcast Center (CBC) 633 90.

communicates cell broadcast messages that are typically delivered to multiple

users in a specified area. Cell Broadcast … enables messages to be communicated

to multiple mobile phone customers” (Id., 9:22-28) and “system information

messages dictate a MS [mobile station] where to listen for paging messages”

(claimed “paging message” and “paging mode”). (Id., 9:58-10:6.)

Sennett-286, FIG. 6

Thus, Sennett-286’s Base Station Subsystems (claimed “base station” 91.

or “transmitter”) is configured to transmit or broadcast content and messages to



39

portable devices or mobile stations (claimed “mobile terminals”) capable of

receiving paging or emergency messages in a bi-directional GSM, GPRS cellular

wireless communication network (claimed “bi-directional cellular wireless

communication system”). (Sennett-286, FIGs. 1, 4-6, 3:25-27; 5:10-34; 7:4-7.)

At least for the foregoing reasons, Sennett-286 discloses these 92.

limitations.

b. [1A]: “storing, at a mobile terminal of the plurality of mobile terminals, at least two specific identifiers common to the plurality of mobile terminals, the at least two specific identifiers being for different types of emergencies;”

[7A]: “a memory unit configured to store at least two specific identifiers common to the plurality of other mobile terminals, the at least two specific identifiers being for different types of emergencies;”

[13A]: “a memory unit configured to store at least two specific identifiers supporting an emergency warning, the at least two specific identifiers being for different types of emergencies;”

[17A]: “storing, at one of the plurality of mobile terminals, at least two specific identifiers common to the plurality of mobile terminals supporting an emergency warning, the at least two specific identifiers being for different types of emergencies;”

Sennett-286 provides an emergency notification system that “avoids 93.

continuous monitoring of broadcast technologies” and “provide[s] notification to

the user in real-time via an emergency alert mechanism which is implemented on

the user device, and supported by one or more telephony radio networks.”

(Sennett-286, 2:48-53, (emphasis added).) For example, Sennett-286 discloses



40

receiving and storing information indicative of “occurrence” and “relevance” of an

emergency broadcast. (Sennett-286, Claims 8-10, 12-13.) “When the user device

detects the setting of the emergency alert indicator bit on the control channel(s)

that it is monitoring, the user device is able to immediately lead the user to the

emergency information, or instruct the user with pre-provisioned information about

the emergency alert, and any associated broadcast channels that contain the

emergency alert.” (Sennett-286, 2:56-62, (emphasis added).) A POSITA would

understand that the setting of the emergency alert indicator bit is stored on the user

device before it can be detected.

“In another example embodiment, a Short Message Service (‘SMS’) 94.

message is delivered to the user device via a telephony radio network, which is

processed by the user device so that local knowledge is possessed on the portable

device that an emergency alert has been issued that is intended for the user of the

user device.” (Sennett-286, 2:65-3:3, (emphasis added).) Alternatively, “a message

is received, e.g., via an SMS message, control channel, or data channel, which

modifies a storage location, e.g., a bit, on the user device when the message is

processed. Thus, when modified, the storage location indicates that an emergency

alert has been issued that is intended for the user, and the user is notified.”

(Sennett-286, 3:4-10, (emphasis added).) A POSITA would understand that the



41

emergency alert message is stored on the user device before it can be further

processed.

As shown in FIG. 1 of Sennett-286, “storage device 22 is populated 95.

with emergency broadcast information from a network-based emergency

broadcast information database 10.” (Sennett-286, 3:49-52, (emphasis added).) The

emergency broadcast information can include, e.g.: “(A) information about

available broadcast technologies (e.g., Cell Broadcast, MBMS, DVB-H,

MediaFLO, etc.), (B) information concerning which broadcast technologies or

network(s), such as broadcast network 60, are specifically supported by the device

20, (C) information about emergency broadcast channels associated with each

available broadcast technology, or a combination thereof.” (Sennett-286, 3:54-62.)

Sennett-286’s emergency alert mechanism (e.g., emergency alert 96.

indicator bit, SMS message, or alert message) or emergency broadcast information

can be modified in view of Sennett-280 to constitute the claimed “specific

identifiers” common to the mobile terminals and for different types of

emergencies. A POSITA would understand that Sennett-286’s user devices would,

for comparison or other processing purposes, before receiving Sennett-286’s

emergency alert mechanism, store all possible values the emergency alert

mechanism could take, e.g., to identify a broadcast that is suitable for receiving and

displaying to the user.



42

As noted above, Sennett-280 and Sennett-286 have the same inventors 97.

and both are directed to the same purpose--notification and broadcasting of EAS

messages. (Sennett-286, 1:21-25; Sennett-280, 1:16-17.) Further, Sennett-280 and

Sennett-286 disclose identical telephony radio networks and operating

environments for notification and broadcasting of EAS messages. (Sennett-286,

5:10-10:67; FIGs. 4-6; Sennett-280, 11:39-17:26; FIGs. 8-10.) A POSITA would

look to Sennett-280 to implement the notification and broadcasting of EAS

emergency alerts of Sennett-286.

Sennett-280 discloses an enhanced EAS message that includes 98.

parameters, which indicate different types of EAS emergencies: “an EAS message,

referred to as an enhanced EAS message, comprises a parameter, or parameters,

indicative of the type of alert, such as for example, weather, AMBER, government

issued, geophysical e.g., landslide, meteorological, e.g., flood, general emergency

and public safety, ….” (Sennett-280, 2:43-55.) These different types of EAS

emergencies are standardized by the FCC, and they are common to all mobile

subscribers. (FCC 94-288, 83-84; Sennett-280, 1:23-46.) These different types of

EAS emergencies are common to mobile subscribers because they are used by

various devices for emergency broadcast in each of the networks identified by the

FCC, including cellular networks such as GSM and CDMA. (Id.)



43

A POSITA would recognize that Sennett-286’s emergency alert 99.

mechanism (e.g., emergency alert indicator bit, SMS message, or alert message) or

emergency broadcast information can be modified to include the parameters

indicating different types of EAS emergencies from Sennett-280. Sennett-280’s

parameters can constitute the claimed “specific identifiers” common to the mobile

terminals and for different types of emergencies, and stored on Sennett-286’s

storage 22 or Sennett-280’s EAS processor 34.

It would have been obvious to a POSITA to include the parameters for 100.

indicating different types of EAS emergencies, as taught by Sennett-280, in the

system of Sennett-286, which discloses that emergency alert mechanisms are

delivered, stored and checked at a mobile terminal to determine whether a paged

message requires switching to a broadcast mode for receiving emergency broadcast

content. As discussed above, Sennett-286 discloses a plurality of broadcast

technologies may be supported by the device, as well as a plurality of emergency

broadcast channels for each available broadcast technology. (Sennett-286, 4:23-

27.) It would have been obvious to use the parameters of Sennett-280 to identify

different types of emergencies so the portable device of Sennett-286 can uniquely

determine the type of emergency notification being received and then access the

appropriate broadcast channel to receive the emergency broadcast. Moreover, by

using the parameters of Sennett-280, “[a] user of the mobile device can tailor the



44

type of EAS alerts to be received, the time period, or periods, during which EAS

alerts can be received, and actions to be taken with respect to received alerts.”

(Sennett-280, Abstract.)

Accordingly, in view of Sennett-280, Sennett-286’s emergency 101.

broadcast information stored on storage 22 on the user device 20 can include

Sennett-280’s parameters for indicating different types of EAS emergencies, and,

further, Sennett-286’s emergency alert mechanism (e.g., emergency alert indicator

bit, SMS message, or alert message) can be modified to be include Sennett-280’s

parameters for indicating different types of EAS emergencies.

At least for the foregoing reasons, Sennett-286 in view of Sennett-280 102.

discloses these limitations.

c. [1B]: “checking, by the mobile terminal, whether a paging message received from the base station includes at least one specific identifier of the at least two specific identifiers;”

[7B]: “a control unit configured to: check whether a paging message received from the base station includes at least one specific identifier of the at least two specific identifiers;”

[13B]: “a control unit configured to: check whether the at least one paging message received from the transmitter includes at least one specific identifier of the at least two specific identifiers;”

[17B]: “checking, by the one of the plurality of mobile terminals, whether the at least one paging message received from the base station includes at least one specific identifier of the at least two specific identifiers;”



45






“means for determining, in accordance with the received information, whether

the emergency broadcast is relevant; means for retrieving at least a subset of the

stored emergency broadcast information if it is determined that the emergency

broadcast is relevant; a broadcast processor that automatically tunes to the

emergency broadcast upon determining that the emergency broadcast is relevant.”

(Sennett-286, Claim 8, (emphasis added).)

Sennett-286 discloses “At step 220, the telephony radio network 30 104.

informs the telephony processor 24 of portable device 20 that an emergency alert

message is being broadcast, e.g., using a pre-defined, standardized indicator bit on

at least one telephony network control channel, an SMS message, a data channel if

available, or the like.” (Sennett-286, 4:10-15.) “When the user device detects the

setting of the emergency alert indicator bit on the control channel(s) that it is

monitoring, the user device is able to immediately lead the user to the emergency

information, or instruct the user with pre-provisioned information about the

emergency alert, and any associated broadcast channels that contain the emergency



46

alert.” (Sennett-286, 2:54-62, (emphasis added).) The emergency alert mechanism

can also be an SMS message (id., 2:65-3:3) or an emergency alert message “which

modifies a storage location, e.g., a bit, on the user device when the message is

processed.” (Id., 3:4-10.)

As noted above, a POSITA would recognize that Sennett-286’s 105.

emergency alert mechanism (e.g., emergency alert indicator bit, SMS message, or

alert message) or emergency broadcast information can be modified to include the

parameters indicating different types of EAS emergencies from Sennett-280.

Sennett-280’s parameters can constitute the claimed “specific identifiers” common

to the mobile terminals and for different types of emergencies stored on Sennett-

286’s storage 22 or Sennett-280’s EAS processor 34.

Sennett-280 discloses: “[a]t step 42, upon receipt of the broadcast 106.

message (e.g., received by the broadcast processor 32 of the mobile device 38), the

received message is analyzed to determine if the message comprises a parameter

indicative of a characteristic of the emergency alert.” (Sennett-280, 5:57-63; FIG.

2.) A POSITA would understand Sennett-286’s “means for determining …

whether the emergency broadcast is relevant” (Sennett-286, Claim 8) could include

analyzing Sennett-280’s enhanced EAS message, which includes parameters

indicative of different types of EAS emergencies. For example, for Sennett-286 to

perform this procedure, Sennett-286’s portable device 20 would check whether the



47

emergency alert mechanism has a parameter corresponding to a type of broadcast

the portable device should receive. (Id.) Thus, a POSITA would understand that

Sennett-286’s portable device 20 would check if the emergency alert mechanism

includes Sennett’280’s parameters indicating different types of EAS emergencies

for which the broadcast message should be received. (Id.)



d. [1C]: “switching, by the mobile terminal, to a broadcast mode for receiving broadcast content on a broadcast channel when the received paging message includes the at least one specific identifier of the at least two specific identifiers;”

[7C]: “switch to a broadcast mode for receiving broadcast content on a broadcast channel when the paging message received from the base station includes the at least one specific identifier of the at least two specific identifiers;”

[13C]: “switch to a broadcast support mode for receiving the content transmitted by the transmitter on a broadcast channel when the at least one paging message transmitted by the transmitter includes the at least one specific identifier of the at least two specific identifiers;”

[17C]: “switching, by the one of the plurality of mobile terminals, to a broadcast mode for receiving broadcast content on a broadcast channel when the received paging message includes the at least one specific identifier of the at least two specific identifiers;”





48




“means for determining, in accordance with the received information, whether the

emergency broadcast is relevant; means for retrieving at least a subset of the stored

emergency broadcast information if it is determined that the emergency broadcast

is relevant; a broadcast processor that automatically tunes to the emergency

broadcast upon determining that the emergency broadcast is relevant.”

(Sennett-286, Claim 8, (emphasis added).)

Sennett-286 automatically tunes the portable device to the emergency 109.

broadcast channel if the emergency alert mechanism (e.g., emergency alert

indicator bit, emergency SMS message, or emergency alert message) indicates

relevant emergency information. (Sennett-286, Abstract; 4:34-44.) “When the user

device detects the setting of the emergency alert indicator bit on the control

channel(s) that it is monitoring, the user device is able to immediately lead the

user to the emergency information, or instruct the user with pre-provisioned

information about the emergency alert, and any associated broadcast channels that

contain the emergency alert.” (Sennett-286, 2:56-62, (emphasis added).)

Sennett-286 further discloses “In FIG. 3, at step 300, the broadcast 110.

network(s) 60 receives an emergency alert from the emergency alert network 50,



49

such as the EAS. At step 310, the broadcast network starts broadcasting the

received emergency alert. At step 320, whether activation occurs automatically or

optionally at the behest of a user that has been notified of the alert (e.g., via the

process depicted in FIG. 2), the associated emergency broadcast channel of the

user device 20 is activated.” (Sennett-286, 4:51-59, (emphasis added).)

A POSITA would recognize that Sennett-286’s emergency alert 111.

mechanism (e.g., emergency alert indicator bit, SMS message, or alert message) or

emergency broadcast information can be modified to include the parameters

indicating different types of EAS emergencies from Sennett-280. Sennett-280’s

parameters can constitute the claimed “specific identifiers” common to the mobile

terminals and for different types of emergencies stored on Sennett-286’s storage 22

or Sennett-280’s EAS processor 34.

Thus, a POSITA would understand that, for Sennett-286 to perform 112.

this procedure, Sennett-286’s portable device 20 would check whether the

emergency alert mechanism has a parameter corresponding to a type of broadcast

the portable device should receive. (Id.) Thus, a POSITA would understand that

Sennett-286’s portable device 20 would check if the emergency alert mechanism

includes Sennett’280’s parameters indicating different types of EAS emergencies

for which the broadcast message should be received, and if so, only then would

switch to a broadcast mode.



50



e. [1D]: “establishing, by the mobile terminal, at least one of a physical channel and a logical channel when the received paging message includes a mobile terminal identifier allocated to the mobile terminal.”

[7D]: “establish at least one of a physical channel and a logical channel when the received paging message includes a mobile terminal identifier allocated to the mobile terminal.”


[17D]: “establishing, by the one of the plurality of mobile terminals, at least one of a physical channel and a logical channel when the received paging message includes a mobile terminal identifier allocated to the one of the plurality of mobile terminals.”

As admitted by the ‘129 patent, this element recites nothing more than 114.

the standard operation of a cellular phone when receiving an incoming phone

call—establishing a point-to-point communication channel between the terminal

and the base station. (‘129 patent, 5:10-12; 5:20-24; 3:41-46 (admitting it is

“customary” for a base station to send a paging message including a TMSI

(claimed “mobile terminal identifier”) to a terminal, and when the terminal

detected the TMSI in the paging message, for the terminal to establish a physical

and/or logical channel).) The ‘129 patent also admits that “terminals receive a

TMSI derived from the international mobile subscriber identity, IMSI” (‘129



51

patent, 4:16-17); and that “3GPP TS 23.003 V7.1.0 (2006 September), chapter 2

defines actually valid subscriber identities such as IMSI, TMSI or P-TMSI.” (‘129

patent, 4:25-27.)

Sennett-286 and Sennett-280 both disclose that the user portable 115.

device or mobile station has a Subscriber Identity Module (SIM) for storing an

International Mobile Subscriber Identity (IMSI) that uniquely identifies the mobile

subscriber. (Sennett-286, 8:14-19; Sennett-280, 14:38-43.) Specifically, Sennett-

286 and Sennett-280 disclose “The MS 602 is physical equipment or Mobile

Equipment (ME), such as a mobile phone or a laptop computer (e.g., portable

device 20) that is used by mobile subscribers, with a Subscriber identity Module

(SIM). The SIM includes an International Mobile Subscriber Identity [IMSI],

which is a unique identifier of a subscriber.” (Sennett-286, 8:14-19; Sennett-280,

14:38-43.)

The telephony network of Sennett-286 and Sennett-280 includes a 116.

Mobile Switching Center (MSC) that, in conjunction with other components such

as the Home Location Register (HLR) and Visitor Location Register (VLR),

performs registration, switching, authentication, location updating, handover,

roaming, and call routing functions for the network. (Sennett-286, 8:27-54;

Sennett-280, 14:51-15:12.) To gain access to the GSM services and receive

incoming calls, the user mobile station first registers with the network by



52

performing a location update and IMSI attach procedure with the MSC/VLR.

(Sennett-286, 9:1-12; Sennett-280, 15:26-37.) Thus, Sennett-286 and Sennett-280

disclose that the user mobile station can receive incoming calls based on the

International Mobile Subscriber Identity (IMSI), which requires “establish[ing] at

least one of a physical channel and a logical channel,” as claimed.


and AAPA discloses these limitations.

2. Sennett-286 in view of Sennett-280 and AAPA renders claims 2, 8, 14, and 18 obvious.

a. [2]: “The method of claim 1, wherein the mobile terminal identifier is at least one of a temporary mobile subscriber identity, an international mobile subscriber identify, and a packet temporary mobile subscriber identity”

[8]: “The mobile terminal of claim 7, wherein the mobile terminal identifier is at least one of a temporary mobile subscriber identity, an international mobile subscriber identify, and a packet temporary mobile subscriber identity.”

[14]: “The system of claim 13, wherein the mobile terminal identifier is at least one of a temporary mobile subscriber identity, an international mobile subscriber identify, and a packet temporary mobile subscriber identity.”

[18] “The method of claim 17, wherein the mobile terminal identifier is at least one of a temporary mobile subscriber identity, an international mobile subscriber identify, and a packet temporary mobile subscriber identity.”

Sennett-286 and Sennett-280 disclose “The MS 602 is physical 118.

equipment or Mobile Equipment (ME), such as a mobile phone or a laptop



53

computer (e.g., portable device 20) that is used by mobile subscribers, with a

Subscriber identity Module (SIM). The SIM includes an International Mobile

Subscriber Identity [IMSI], which is a unique identifier of a subscriber.”

(Sennett-286, 8:14-19; Sennett-280, 14:38-43, (emphasis added).)

At least for the foregoing reasons, Sennett-286 and Sennett-280 both 119.

disclose these limitations.

3. Sennett-286 in view of Sennett-280 and AAPA renders claims 3 and 9 obvious.

a. [3]: “The method of claim 1, wherein the broadcast mode is a GSM cell-broadcast mode.”

[9]: “The mobile terminal of claim 7, wherein the broadcast mode is a GSM cell-broadcast mode.”

Sennett-286 and Sennett-280 disclose “To gain access to GSM 120.

services, such as speech, data, and short message service (SMS), the MS first

registers with the network to indicate its current location by performing a location

update and IMSI attach procedure.” (Sennett-286, 9:1-4; Sennett-280, 15:26-29.)

Sennett-286 and Sennett-280 also disclose “Cell Broadcast Center (CBC) 633

communicates cell broadcast messages that are typically delivered to multiple

users in a specified area. Cell Broadcast … enables messages to be communicated

to multiple mobile phone customers ….” (Sennett-286, 9:22-28; Sennett-280,

15:47-53.)



54

At least for the foregoing reasons, Sennett-286 and Sennett-280 both 121.

disclose these limitations.

4. Sennett-286 in view of Sennett-280 and AAPA renders claims 4 and 10 obvious.

a. [4]: “The method of claim 1, wherein the mobile terminal notifies and/or displays to a user of the mobile terminal the broadcast content.”

[10]: “The mobile terminal of claim 7, further comprising: an acoustical unit configured to announce the broadcast content; and a display unit configured to display the broadcast content.”

Sennett-286 discloses “the telephony processor 24 interacts with the 122.

user interface 28 of the user device 20 to inform the end user that an emergency

alert is being broadcast. The user interface 28 is not limited to display of

information, however. Any known output device for a user device 20 may be

utilized, whether visual, auditory and/or mechanical in operation. For example,

special alert tones may be activated and special display graphics, symbols, text,

etc. may be portrayed on a display of the user device 20 that inform the user that an

emergency broadcast is being sent and to which channel or channels the user

should tune for the emergency broadcast” (Sennett-286, 4:29-39.)


limitations.




55

a. [5]: “The method of claim 1, wherein a duration of the broadcast mode is dependent on the at least one specific identifier of the at least two specific identifiers.”

[11]: “The mobile terminal of claim 7, wherein a duration of the broadcast mode is dependent on the at least one specific identifier of the at least two specific identifiers.”

[15]: “The system of claim 13, wherein a duration of the broadcast mode is dependent on the at least one specific identifier of the at least two specific identifiers.”

[19] “The method of claim 17, wherein a duration of the broadcast mode is dependent on the al least one specific identifier of the al least two specific identifiers.”

Sennett-280 discloses “The message is processed in accordance with 124.

the preconfigured instructions and the characteristics pertaining to the message. A

user of the mobile device can tailor the type of EAS alerts to be received, the time

period, or periods, during which EAS alerts can be received, and actions to be

taken with respect to received alerts.” (Sennett-280, Abstract, (emphasis added);

see also 1:50-58.) Sennett-280 also discloses “processing the received broadcast

emergency alert message in accordance with predetermined instructions that define

how to process the received broadcast emergency alert message based on the at

least one parameter and a user-defined time frame in which the broadcast

emergency alert message is received.” (Sennett-280, Claim 1, (emphasis added).)


limitations.



56


a. [6]: “The method of claim 5 wherein the duration of the broadcast mode is for an indefinite length of time or for a limited duration of time based on the at least one specific identifier of the at least two specific identifiers.”

[12]: “The mobile terminal of claim 11, wherein the duration of the broadcast mode is for an indefinite length of time or for a limited duration of time based on the at least one specific identifier of the at least two specific identifiers.”

[16]: “The system of claim 15, wherein the duration of the broadcast mode is for an indefinite length of time or for a limited duration of time based on the at least one specific identifier of the at least two specific identifiers.”

[20] “The method of claim 19, wherein the duration of the broadcast mode is for an indefinite length of time or for a limited duration of time based on the at least one specific identifier of the at least two specific identifiers.”

A POSITA would understand the “duration” of broadcast mode recited 126.

in claims 5, 11, 15, and 19 is sufficiently broad to encompass “an indefinite length

of time” or “a limited duration of time” for the broadcast mode recited in claims 6,

12, 16, and 20. Thus, at least for the reasons provided above for claims 5, 11, 15,

and 19, Sennett-286 in view of Sennett-280 discloses these limitations.

B. Ground B: Collins (Ex. 1007) in view of Karl (Ex. 1008) and AAPA Renders Obvious, Under 35 U.S.C. § 103, Claims 1-20

1. Collins in view of Karl and AAPA renders independent claims 1, 7, 13, and 17 obvious.

a. [1pre]: “A method of communicating in a bi-directional cellular wireless communication system between a base station and a



57

plurality of mobile terminals supporting an emergency warning, the method comprising:”

[7pre]: “A mobile terminal configured for operating in a bi-directional cellular wireless communication system having a base station and a plurality of other mobile terminals supporting an emergency warning, the mobile terminal comprising:”

[13pre]: “A bi-directional cellular wireless communication system adapted to implement a cell broadcast service and a paging mode, the system comprising: a transmitter configured to broadcast content and transmit at least one paging message to a plurality of mobile terminals in a cell; and the plurality of mobile terminals, each of the plurality of mobile terminals comprising:”

[17pre]: “A method of communicating with a plurality of mobile terminals in a bi-directional cellular wireless communication system between a base station and the plurality of mobile terminals, the method comprising: broadcasting, at the base station, content to the plurality of mobile terminals in a cell; transmitting, at the base station, at least one paging message to the plurality of mobile terminals in the cell;”

Collins discloses “a novel and improved method for providing 127.

broadcast short message services (SMS) in a communication network,” in a

manner “without depriving the receiver of the benefit of reduced power

consumption gained by slotted paging.” (Collins, 2:16-27.) As shown in FIG. 1 of

Collins, “paging service providers 2, 4 and 6 provide messages to central

communications center 10” and “broadcast messages are then broadcast by central

communication center 10 to subscriber stations 12, 14 and 16” “in accordance with

a CDMA communication format.” (Collins, FIG. 1, 4:1-16.)



58

Collins, FIG. 1 Collins further discloses “a message to be broadcast comprising a 128.

message and a header indicating the nature of the message is provided to broadcast

page and message generator 20. Broadcast page and message generator 20

generates a broadcast message in accordance with a predetermined broadcast

format.” (Collins, 8:7-12.)

Thus, Collins’ central communication center 10 (claimed “base 129.

station” or “transmitter”) is configured to transmit or broadcast content and

messages to subscriber stations 12, 14, and 16 (claimed “mobile terminals”)

capable of receiving paging or emergency messages in a CDMA network (claimed

“bi-directional cellular wireless communication system”). (Id.; see also 2:43-46;

12:34-39.)



59

Karl is directed to “disseminat[ing] emergency information to the 130.

public utilizing a universal paging system through a personal alert device.” (Karl,

1:15-17.) For example, “[t]he emergency notification system 20 provides a quick

method for delivering emergency messages to a large number of mobile and static

devices of different types in a localized area.” (Karl, 4:12-15.) Karl discloses that

its invention can operate within CDMA, GSM, and GPRS networks, among others.

(Karl, 2:16-3:54; 6:53-67.) Karl discloses multiple user devices for its networks,

such as mobile phone 36 and E-FOB 38. (Karl, FIG. 1.) For example, “cellular

network service providers 32 broadcast the message through their network of cell

towers 34. Mobile phones 36 in the identified area receive the cell broadcast

message from the network to alert the user of the nature of the emergency. The

majority of cellular phones and other wireless devices in use today are capable of

receiving broadcast messages through the GSM and CDMA technologies.” (Karl,

5:39-46.)

At least for the foregoing reasons, Collins and Karl both disclose these 131.

limitations.

b. [1A]: “storing, at a mobile terminal of the plurality of mobile terminals, at least two specific identifiers common to the plurality of mobile terminals, the at least two specific identifiers being for different types of emergencies;”

[7A]: “a memory unit configured to store at least two specific identifiers common to the plurality of other mobile terminals, the



60

at least two specific identifiers being for different types of emergencies;”

[13A]: “a memory unit configured to store at least two specific identifiers supporting an emergency warning, the at least two specific identifiers being for different types of emergencies;”

[17A]: “storing, at one of the plurality of mobile terminals, at least two specific identifiers common to the plurality of mobile terminals supporting an emergency warning, the at least two specific identifiers being for different types of emergencies;”

Collins discloses a broadcast handle or a predetermined set of user 132.

preferences, which Collins’ subscriber stations (claimed “mobile terminals”) use to

determine whether to tune to a broadcast channel in the event of an emergency. For

example, Collins discloses: “the broadcast page contains a broadcast handle that

specifies the nature of the corresponding broadcast message. This broadcast

message may contain information as to the source of the message, the function of

the message, the language in which the message is provided and a sequence

number. The broadcast handle provides sufficient information to allow the

subscriber station to determine whether or not to receive the related broadcast

message.” (Collins, 3:40-48; see also 7:40-44; 8:54-59) (“Decoder 56 decodes the

broadcast page and provides the decoded broadcast page to page receive controller

62. Page receive controller 62 determines in accordance with a predetermined set

of user preferences if the forthcoming broadcast message will be of interest to the

subscriber station user.” (emphasis added)).



61

A POSITA would understand that Collins’ subscriber stations would, 133.

for comparison or other processing purposes, before receiving Collins’ broadcast

page, store all possible values the broadcast handle or the predetermined set of user

preferences could take, e.g., to identify a broadcast that is suitable for receiving

and displaying to the user. For example, Karl discloses: “Processor instructions

may be stored in a flash memory device 66 which define how broadcast messages

should be processed. The process includes determination of the level of the

emergency. For example, a high level warning requiring the user to take shelter

and/or terrorist alert may activate a red LED.” (Karl, 7:3-8.)

A POSITA would understand that to process broadcast handles and 134.

determine the level of the emergency associated with a broadcast handle, the

broadcast handle must be associated with the emergency level in some storage of

the device for comparison purposes before receiving Collins’ broadcast page. For

example, before receiving Collins’ broadcast page, a POSITA would understand

that the subscriber station would have to have stored some information that can be

compared with the broadcast handle provided in Collins’ broadcast page, to allow

the subscriber station to determine whether or not to receive the related broadcast

message.

Further, Karl discloses EAS event codes (which are the event codes 135.

disclosed in FCC 94-288 (Ex. 1011)). Collins’ broadcast handle values or



62

predetermined set of user preferences can be modified to take the values of the

EAS event codes disclosed in Karl. For example, Karl discloses: “‘EEE’ is the

Event code which indicates the nature of the EAS activation. The event codes are

compatible with the codes used by the National Weather Service (NWS) Weather

Radio Specific Area Message Encoder (WRSAME). There are over 30 Event

codes such as EAN—Emergency Action Notification (National only); TOR—

Tornado Warning; HUW—Hurricane Warning; and TSW—Tsunami Warning, for

example.” (Karl, 4:45-52; see also FCC 94-288, 83-84.) Because the event codes

are standardized according to type of emergency, they are common to all of Karl’s

user devices (e.g., mobile phone 36 or E-FOB 38).

A POSITA would be motivated to use Karl’s EAS event codes as the 136.

possible values of Collins’ broadcast handle or predetermined set of user

preferences. Collins’ broadcast handle is meant to “specif[y] the nature of the

corresponding broadcast message.” (Collins, 3:40-41; 6:25-28.) Collins’ broadcast

handle can include a “function code” which “indicates the subject matter of the

message.” (Collins, 12:8-12.) Karl’s event codes specify the nature of the

emergency that is the subject of the broadcast message. (Karl, 4:45-52.) Thus, A

POSITA would naturally and predictably understand that Karl’s event codes can be

used as the function codes, common to all of Collins’ subscriber stations, in

Collins’ broadcast handle to indicate the subject matter of the message, e.g., the



63

nature of the emergency subject to broadcast messaging. Further, Collins’

disclosure pertains to CDMA systems, e.g., Collins, FIG. 2, 4:3-16, and Karl

discloses that its techniques can be implemented in CDMA systems, e.g., Karl,

6:53-67; Karl provisional, 10. Moreover, A POSITA would recognize that by

including Karl’s event codes in Collins’ broadcast handle, Collins’ system would

comply with the EAS alert system established by the FCC, and Collins’ subscribers

would benefit by receiving FCC EAS-compliant emergency warning alerts. (See

Karl, 1:20-58; Karl provisional, 5-6.) Thus, Karl’s EAS event codes can be used as

the values of the function codes in Collins’ broadcast handle, constituting the

claimed “specific identifiers” common to the mobile terminals and for different

types of emergencies.

At least for the foregoing reasons, Collins in view of Karl discloses 137.

these limitations.

c. [1B]: “checking, by the mobile terminal, whether a paging message received from the base station includes at least one specific identifier of the at least two specific identifiers;”

[7B]: “a control unit configured to: check whether a paging message received from the base station includes at least one specific identifier of the at least two specific identifiers;”

[13B]: “a control unit configured to: check whether the at least one paging message received from the transmitter includes at least one specific identifier of the at least two specific identifiers;”

[17B]: “checking, by the one of the plurality of mobile terminals, whether the at least one paging message received from the base



64

station includes at least one specific identifier of the at least two specific identifiers;”

Collins discloses using the broadcast handle or the predetermined set 138.

of user preferences included in the broadcast page (claimed “paging message”) to

determine if the broadcast message will be of interest to the subscriber station user.

(Collins, 3:40-48; 7:40-44.)

For example, Collins discloses receiving a broadcast page via a slotted 139.

paging mechanism: “In a slotted paging system, the subscriber station ‘wakes up’

or ‘powers up’ at predetermined time intervals, referred to as slot cycles, to

monitor its assigned paging channel for traffic pages.” (Id., 4:66-5:2.)

“Furthermore, the broadcast page contains a broadcast handle that specifies the

nature of the corresponding broadcast message. This broadcast message may

contain information as to the source of the message, the function of the message,

the language in which the message is provided and a sequence number. The

broadcast handle provides sufficient information to allow the subscriber station to

determine whether or not to receive the related broadcast message.” (Id., 3:40-48.)

“Decoder 56 decodes the broadcast page and provides the decoded broadcast page

to page receive controller 62. Page receive controller 62 determines in accordance

with a predetermined set of user preferences if the forthcoming broadcast message

will be of interest to the subscriber station user.” (Id., 7:40-44.) Decoding the

broadcast page requires checking the contents it includes.



65

Based on Collins’ description of the slotted paging system, a POSITA 140.

would understand that Collins’ broadcast page is a message sent by a base station

to the subscriber station on a shared paging channel, and that the broadcast handle

or user preferences included in the broadcast page contains information

corresponding to unique identifiers of either the subscriber station or a type of

emergency. (Collins, 3:40-48, 7:40-48, 12:11-12.) Further, a POSITA would

understand that, for Collins to perform this procedure, Collins’ subscriber station

would check whether the broadcast handle or user preference has a value

corresponding to a type of broadcast the subscriber station would like to receive.

An ordinary artisan would understand that without checking for the value included

in the broadcast handle, Collins would not be able to perform the next steps of

determining whether to receive the broadcast message. (Id.)

Thus, a POSITA would understand that Collins’ subscriber station 141.

would check if the broadcast handle includes specific EAS event codes from Karl’s

group of EAS event codes for which the broadcast message should be received.


these limitations.

d. [1C]: “switching, by the mobile terminal, to a broadcast mode for receiving broadcast content on a broadcast channel when the received paging message includes the at least one specific identifier of the at least two specific identifiers;”



66

[7C]: “switch to a broadcast mode for receiving broadcast content on a broadcast channel when the paging message received from the base station includes the at least one specific identifier of the at least two specific identifiers;”

[13C]: “switch to a broadcast support mode for receiving the content transmitted by the transmitter on a broadcast channel when the at least one paging message transmitted by the transmitter includes the at least one specific identifier of the at least two specific identifiers;”

[17C]: “switching, by the one of the plurality of mobile terminals, to a broadcast mode for receiving broadcast content on a broadcast channel when the received paging message includes the at least one specific identifier of the at least two specific identifiers;”

In Collins, “If page receive controller 62 determines that the 143.

forthcoming broadcast message will be of interest to the subscriber station user,

then it generates signals to receive the broadcast message. Page receive controller

62 determines the slot in which the broadcast message will be provided. . . . Page

receive controller 62 provides a slot timing signal to receiver 52 that cause the

receiver to monitor the paging channel at the time appropriate for receiving the

broadcast message” (Collins, 7:40-56; 8:60-9:4.) Further, “the broadcast page

contains a broadcast handle that specifies the nature of the corresponding broadcast

message” and “provides sufficient information to allow the subscriber station to

determine whether or not to receive the related broadcast message.” (Collins, 3:40-

48; 11:66-12:7.) The broadcast handle includes a “function code [that] indicates

the subject matter of the message.” (Collins, 12:11-12.) As noted above, a POSITA



67

would understand that the function code can take the value of one of Karl’s

disclosed EAS event codes “such as EAN—Emergency Action Notification

(National only); TOR—Tornado Warning; HUW—Hurricane Warning; and

TSW—Tsunami Warning, for example.” (Karl, 4:45-52.)

Thus, a POSITA would understand that, for Collins to perform this 144.

procedure, Collins’ subscriber station would check whether the broadcast handle or

user preferences has a value corresponding to a type of broadcast the subscriber

station would like to receive. Thus, a POSITA would understand that Collins’

subscriber station would check if the broadcast handle or user preferences includes

specific identifiers from Karl’s group of EAS event codes for which the broadcast

message should be received, and if so, switch to a broadcast mode.


these limitations.

e. [1D]: “establishing, by the mobile terminal, at least one of a physical channel and a logical channel when the received paging message includes a mobile terminal identifier allocated to the mobile terminal.”





68

[17D]: “establishing, by the one of the plurality of mobile terminals, at least one of a physical channel and a logical channel when the received paging message includes a mobile terminal identifier allocated to the one of the plurality of mobile terminals.”

As admitted by the ‘129 patent, this element recites nothing more than 146.

the standard operation of a cellular phone when receiving an incoming phone

call—establishing a point-to-point communication channel between the terminal

and the base station. (‘129 patent, 5:10-12; 5:20-24; 3:41-46 (admitting it to be

“customary” for a base station to send a paging message including a TMSI to a

terminal, and when the terminal detected the TMSI in the paging message, for the

terminal to establish a physical and/or logical channel).)

The ‘129 patent distinguishes between point-to-point connection and 147.

broadcast mode: “the terminals are adapted to switch to the broadcast reception

mode when detecting the specific identifier in the paging message, instead of

establishing a point to point connection” (‘129 patent, 5:10-12) and “When a

mobile receives a valid E-TMSI, it does not establish a PtP [Point-to-Point]

connection. Instead it switches to Cell-Broadcast mode and starts to monitor the

Cell-Broadcast Notification channels for emergency information contents.” (‘129

patent, 5:20-24; (emphasis added).)

The ‘129 patent admits that the use of a TMSI (the claimed “mobile 148.

terminal identifier”) to receive incoming calls is “customary” in cellular networks



69

(such as Collins’ CDMA), i.e., it is admitted prior art. (‘129 patent, 3:41-46.)

Collins discloses “subscriber station identification” (the claimed “mobile terminal

identifier”) for establishing a point-to-point communication: “[t]ypically, when a

subscriber station registers with the central communications center, the central

communications center informs the subscriber station which paging channel of the

plurality of available paging channels to monitor. When the central

communications center needs to set up a point to point communication with a

subscriber station it transmits a traffic page on the paging channel being monitored

by the subscriber station. The traffic page would typically comprise subscriber

station identification information and traffic channel identification information.

In response to the received traffic page, the identified subscriber station would

prepare to conduct point to point communications on the identified traffic

channel.” (Collins, 1:26-39, (emphasis added).)

The ‘129 patent admits that “terminals receive a TMSI derived from 149.

the international mobile subscriber identity, IMSI” (‘129 patent, 4:16-17); and that

“3GPP TS 23.003 V7.1.0 (2006 September), chapter 2 defines actually valid

subscriber identities such as IMSI, TMSI or P-TMSI.” (‘129 patent, 4:25-27.)

Further, the ‘129 patent admits that IMSI allows for slotted paging: “The use of the

IMSI allows a staggering of the terminals to be paged into 10 groups, allowing for

large DRX cycles. In GSM ten paging groups exist so that only 10% (derived from



70

the IMSI) of all terminals in a cell sending the paging message listen to a paging

message.” (‘129 patent, 4:17-22.) And as noted above, Collins discloses slotted

paging. (Collins, 4:66-5:2.)

At least for the foregoing reasons, Collins in view of Karl and AAPA 150.


2. Collins in view of Karl and AAPA renders claims 2, 8, 14, and 18 obvious.

a. [2]: “The method of claim 1, wherein the mobile terminal identifier is at least one of a temporary mobile subscriber identity, an international mobile subscriber identify, and a packet temporary mobile subscriber identity”

[8]: “The mobile terminal of claim 7, wherein the mobile terminal identifier is at least one of a temporary mobile subscriber identity, an international mobile subscriber identify, and a packet temporary mobile subscriber identity.”

[14]: “The system of claim 13, wherein the mobile terminal identifier is at least one of a temporary mobile subscriber identity, an international mobile subscriber identify, and a packet temporary mobile subscriber identity.”

[18] “The method of claim 17, wherein the mobile terminal identifier is at least one of a temporary mobile subscriber identity, an international mobile subscriber identify, and a packet temporary mobile subscriber identity.”

This element recites the standard operation of a cellular phone. (‘129 151.

patent, 4:25-27 (admitting “3GPP TS 23.003 V7.1.0 (2006 September) [“TS

23.003”], chapter 2 defines actually valid subscriber identities such as IMSI, TMSI

or P-TMSI.”).) TS 23.003 specifies that “A unique International Mobile Subscriber



71

Identity (IMSI) shall be allocated to each mobile subscriber in the GSM/UMTS

system.” (Ex. 1015, p. 10.) A POSITA would understand that every mobile

subscriber in a wireless network such as a GSM or CDMA network must include

an IMSI. And Collins discloses “subscriber station identification” (the claimed

“mobile terminal identifier”) for establishing a point-to-point communication.

(Collins, 1:26-39.)

At least for the foregoing reasons, Collins in view of AAPA discloses 152.

these limitations.

3. Collins in view of Karl and AAPA renders claims 3 and 9 obvious.

a. [3]: “The method of claim 1, wherein the broadcast mode is a GSM cell-broadcast mode.”

[9]: “The mobile terminal of claim 7, wherein the broadcast mode is a GSM cell-broadcast mode.”

The ‘129 patent admits “an existing broadcast service can be used such 153.

as the GSM Cell-Broadcast Service which is an SMS type broadcast service and

delivers in one session the notification and the message content.” (‘129 patent,

1:46-55; Karl, 3:42-54 (“Currently GSM/GPRS covers most population centers in

the U.S. CDMA2000-1x is rapidly expanding and may soon cover more area than

GSM. . . . GSM technology, because of its worldwide use, is probably the cheapest

to implement.”).)



72

At least for the foregoing reasons, Karl in view of AAPA discloses 154.

these limitations.

4. Collins in view of Karl and AAPA renders claims 4 and 10 obvious.

a. [4]: “The method of claim 1, wherein the mobile terminal notifies and/or displays to a user of the mobile terminal the broadcast content.”

[10]: “The mobile terminal of claim 7, further comprising: an acoustical unit configured to announce the broadcast content; and a display unit configured to display the broadcast content.”

Karl discloses “A text display may be used to provide a text message 155.

to the user. A vibrator 72 may be activated to provide a tactile alert of the warning

signal to the user. Additionally, a speaker or beeper 74 may be activated to provide

an audible alert of the warning signal to the user.” (Karl, 7:18-22.) A POSITA

would recognize that Karl’s output human interface units can be used by Collins.

For example, Collins discloses that “[t]he demodulated broadcast message is

provided to decoder 56 which decodes the broadcast message and provides the

broadcast message to the subscriber station user.” (Collins, 7:60-63.) A POSITA

would understand that providing the broadcast message can be done using Karl’s

text display or speaker.


these limitations.



73


a. [5]: “The method of claim 1, wherein a duration of the broadcast mode is dependent on the at least one specific identifier of the at least two specific identifiers.”

[11]: “The mobile terminal of claim 7, wherein a duration of the broadcast mode is dependent on the at least one specific identifier of the at least two specific identifiers.”

[15]: “The system of claim 13, wherein a duration of the broadcast mode is dependent on the at least one specific identifier of the at least two specific identifiers.”

[19] “The method of claim 17, wherein a duration of the broadcast mode is dependent on the al least one specific identifier of the al least two specific identifiers.”

The ‘129 patent admits that IMSI allows for slotted paging: “The use 157.

of the IMSI allows a staggering of the terminals to be paged into 10 groups,

allowing for large DRX cycles. In GSM ten paging groups exist so that only 10%

(derived from the IMSI) of all terminals in a cell sending the paging message listen

to a paging message.” (‘129 patent, 4:17-22.) Collins discloses receiving a

broadcast message in a “slotted paging” system: “The expression slotted paging

comes from dividing time into slots of a predetermined duration. In a slotted

paging system, the subscriber station monitors a slot, it will again monitor a

subsequent slot an integral number slots in the future. The number of slots between

periodically monitored slots is referred to as the slot cycle.” (Collins, 1:62-67;

1:42-50, (emphasis added).) Also, Karl discloses “‘+TTTT’ indicates the valid time



74

period of the message in 15 minutes increments up to one hour and then in 30

minute increments beyond one hour.” (Karl, 4:63-65.) Thus, a POSITA would

understand that the slotted paging system of Collins allows a user to receive the

broadcast page for a specified time duration based on the type of emergency

indicated by Karl’s EAS event codes.

At least for the foregoing reasons, Collins in view of Karl and AAPA 158.



a. [6]: “The method of claim 5 wherein the duration of the broadcast mode is for an indefinite length of time or for a limited duration of time based on the at least one specific identifier of the at least two specific identifiers.”

[12]: “The mobile terminal of claim 11, wherein the duration of the broadcast mode is for an indefinite length of time or for a limited duration of time based on the at least one specific identifier of the at least two specific identifiers.”

[16]: “The system of claim 15, wherein the duration of the broadcast mode is for an indefinite length of time or for a limited duration of time based on the at least one specific identifier of the at least two specific identifiers.”

[20] “The method of claim 19, wherein the duration of the broadcast mode is for an indefinite length of time or for a limited duration of time based on the at least one specific identifier of the at least two specific identifiers.”

A POSITA would understand the “duration” of broadcast mode recited 159.

in claims 5, 11, 15, and 19 is sufficiently broad to encompass “an indefinite length



75

of time” or “a limited duration of time” for the broadcast mode recited in claims 6,

12, 16, and 20. Thus, at least for the reasons provided above for claims 5, 11, 15,

and 19, Collins in view of Karl and AAPA discloses these limitations.

Based on my review and above analysis of the prior art, it is my 160.

opinion that claims 1-20 of the ‘129 patent are invalid. Claim charts of my analysis

are attached as Appendix B and Appendix C.



76

I declare under penalty of perjury that the foregoing is true and correct.

Executed this _____ day of May, 2017.

Dr. Robert Akl, D.Sc.


APPENDIX A


CV of Robert Akl, D.Sc. Page 2 Printed: 05/26/17

Robert Akl, D.Sc.

Professional Summary Dr. Akl has over 20 years of industry and academic experience. He is currently a Tenured Associate Professor at the University of North Texas and a Senior Member of IEEE. He has designed, implemented, and optimized both hardware and software aspects of several wireless communication systems for CDMA, WiFi, and sensor networks. Dr. Akl has broad expertise in wireless communication, Bluetooth, CDMA/WCDMA network optimization, GSM, LTE, VoIP, telephony, computer architecture, and computer networks. He is a very active researcher and is well published and cited. He has been awarded many research grants by leading companies in the industry and the National Science Foundation. He has developed and taught over 100 courses in his field. Dr. Akl has received several awards and commendation for his work, including the 2008 IEEE Professionalism Award and was the winner of the 2010 Tech Titan of the Future Award. Dr. Akl has extensive experience with patents in the wireless and networking industry. In the past ten years, he has worked as a technical expert in dozens of patent related matters, involving thousands of hours of research, investigation, and study. He has repeatedly been qualified as an expert by Courts, and has provided numerous technology tutorials to Courts, and given testimony by deposition and at trial. He has worked with companies large and small, both for and against the validity and infringement of patents, and has also helped counsel and Courts to understand technology that often seems complex. In doing so, he has become familiar with, and actively worked with, the legal principles that underlie patentability and validity and claim interpretation in the wireless and networking industries.

Areas of Expertise 2G, 3G, 4G, CDMA/WCDMA, GSM, UMTS, LTE, Ad-hoc Networks, Bluetooth, Call Admission Control, Channel Coding, Computer Architecture, Multi-cell Network Optimization, Packet-networks, Telephony, VoIP, Wi-Fi, Wireless Communication, Wireless Sensors.

Education Year College/University Degree GPA 2000 Washington University in Saint Louis D.Sc. in Electrical Engineering 4.0 / 4.0 1996 Washington University in Saint Louis M.S. in Electrical Engineering 4.0 / 4.0 1994 Washington University in Saint Louis B.S. in Electrical Engineering 4.0 / 4.0 1994 Washington University in Saint Louis B.S. in Computer Science 4.0 / 4.0 Graduated summa cum laude and ranked first in undergraduate class. Dissertation: “Cell Design to Maximize Capacity in Cellular Code Division Multiple Access (CDMA) Networks.” Advisors: Dr. Manju Hegde and Dr. Paul Min.



Litigation Support and Expert Witness Experience

L1. 2017 Pillsbury Winthrop Shaw Pittman LLP Case: HTC Corp and ZTE (USA) v. Cellular Communications Equipment

IPR2017-xxx, IPR2017-xxx Matter: Inter Partes Review, LTE, power control, emergency notification Project: Two declarations to support two IPR petitions

L2. 2017 Alston & Bird LLP

Case: Itron, Inc. and Duke Energy Corp. v. Smart Meter Technologies IPR2017-01199

Matter: Inter Partes Review, power meter Project: Declaration to support IPR petition

L3. 2017 Haynes and Boone, LLP

Case: Ericsson Inc. v. Regents of the University of Minnesota IPR2017-01186, IPR2017-01200, IPR2017-01213

Matter: Inter Partes Review, OFDM and MIMO Project: Three declarations to support three IPR petitions

L4. 2017 Quinn Emanuel Urquhart & Sullivan, LLP

Case: GENBAND US, LLC v. Metaswitch Networks Ltd, et al. Eastern district of Texas, Marshal division, Case No. 2:16-cv-582-JRG-RSP

Matter: Patent infringement, Internet protocols and VoIP Project: Expert report regarding essentiality

L5. 2017 Mayer Brown LLP

Case: Uniloc USA, Inc. et al. v. Avaya Inc., and ShoreTel, Inc., et al. Eastern district of Texas, Tyler division, Case Nos. 6:15-cv-1168-JRG

Matter: Patent infringement, instant messaging and conference calling Project: Source code review, non-infringement consulting

L6. 2017 Fish & Richardson P.C.

Case: Nokia Solutions and Networks US LLC, et al. v. Huawei Technologies Co. Ltd., et al. Eastern district of Texas, Marshal division, Case Nos. 2:16-cv-753-JRG-RSP, 2:16-cv-754

Matter: Patent infringement, 4G LTE Project: Claim construction, two declarations

L7. 2017 Rothwell Figg Ernst & Manbeck, PC

Case: Samsung v. Rembrandt Wireless Matter: Ex Parte Reexamination, Bluetooth Project: Validity consulting



L8. 2016 Sidley Austin LLP

Case: Huawei Technologies Co., et al. v. Samsung Electronics Co, et al. and Samsung Research America v. Hisilicon Technologies Co, LTD Northern district of California, San Francisco division, Case No. 3:16-cv-2787-WHO

Matter: Patent infringement, 3G/4G LTE Project: Source code review, validity and invalidity consulting

L9. 2016 Bragalone Conroy PC

Case: Securus Technologies, Inc. v. Global Tel*Link Corporation CBM2017-00034

Matter: Covered Business Method Review, call monitoring and recording Project: Declaration to support CBM petition

L10. 2016 Braxton, Hilton & Perrone PLLC

Case: Biosonix, LLC. v. Hydrowave, LLC et al. Eastern district of Texas, Case No. 2:16-cv-139-RC

Matter: Patent infringement, underwater transceivers Project: Claim construction, Markman hearing testimony

L11. 2016 Gray Reed & McGraw

Case: Optis Cellular Technology, LLC and PanOptis Patent Management, LLC. v. Blackberry Corporation, et al. Eastern district of Texas, Marshal division, Case No. 2:16-cv-59-JRG-RSP, Case No. 2:16-cv-61-JRG-RSP, Case No. 2:16-cv-62-JRG-RSP

Matter: Patent infringement, LTE Project: Claim construction, three declarations regarding claim construction,

deposition

L12. 2016 Davidson Berquist Jackson & Gowdey Case: SIPCO, LLC et al v. Emerson Electric Co. et al

Eastern district of Texas, Tyler division, Case No. 6:15-cv-907 Emerson Electric Co. et al v. SIPCO, LLC et al. Northern district of Georgia, Atlanta division, Case No. 1:15-cv-00319-AT

Matter: Patent infringement, links in wireless networks and remote monitoring Project: Source code review, invalidity consulting

L13. 2016 McKool Smith

Case: Regents of University of Minnesota v. AT&T Mobility LLC, et al. District of Minnesota, Case No. 0:14-cv-04666-JRT-TNL

Matter: Patent infringement, LTE and MIMO Project: Non-infringement and invalidity consulting, declaration



L14. 2016 EIP US LLP Case: GENBAND US, LLC et al. v. Metaswitch Networks Ltd

IPR2015-01456, IPR2015-01457 Matter: Inter Partes Review, media gateways Project: Two declarations to support Patent Owner, two depositions

L15. 2016 Haynes and Boone, LLP

Case: Cox Communications, Inc. v. AT&T Intellectual Property I, II, LP IPR2015-01187, IPR2015-01227, IPR2015-01273, IPR2015-01536

Matter: Inter Partes Review, cable networks Project: Four declarations to support Patent Owner, four depositions

L16. 2016 Mayer Brown LLP

Case: Odyssey Wireless v. Motorola Mobility LLC Eastern district of North Carolina, Western division, Case No. 5:14-cv-491-D Southern district of California, Case No. 3:15-cv-01741-H-RBB

Matter: Patent infringement, LTE Project: Source code review, non-infringement consulting

L17. 2016 Cooley LLP

Case: Saint Lawrence Comm. LLC v. Motorola Mobility LLC, ZTE (USA) Inc. Eastern district of Texas, Marshal division, Case No. 2:15-cv-000351-JRG, Case No. 2:15-cv-000349-JRG

Matter: Patent infringement, speech coding and decoding Project: Invalidity expert report, expert report regarding AMR-WB standard,

expert report regarding Opus and Silk, supplemental expert report regarding invalidity, two-day depositions, jury trial testimony for Motorola

L18. 2015 Sidley Austin LLP Case: Evolved Wireless, LLC v. Microsoft Corp, et al.

District of Delaware, Case No. 15-cv-546 Matter: Patent infringement, LTE Project: Prior art and invalidity consulting


Case: Optis Wireless Technology, LLC and PanOptis Patent Management, LLC. v. ZTE Corporation and ZTE (USA) Inc. Eastern district of Texas, Marshal division, Case No. 2:15-cv-300-JRG-RSP

Matter: Patent infringement, cellular messages and multimedia attachments Project: Source code review, claim construction, declaration



L20. 2015 Fish & Richardson, P.C. Case: Saint Lawrence Comm. LLC v. LG Elec., Inc. et al.

Eastern district of Texas, Marshal division, Case No. 2:14-cv-1055-JRG

Matter: Patent infringement, speech coding and decoding Project: Invalidity expert report

L21. 2015 Finnegan Henderson Farabow Garrett & Dunner LLP

Case: LG Electronics, Inc. v. Cellular Communications Equipment LLC IPR2016-00178

Matter: Inter Partes Review, LTE Project: Declaration to support IPR petition


Case: AT&T, et al. v. Cox Communication, Inc., et al. District of Delaware, Case No. 14-1106-GMS

Matter: Patent infringement, cable networks Project: Claim construction, declaration


Case: Ericsson Inc., et al. v. TCL Communication, et al. Eastern district of Texas, Marshal division, Case No. 2:15-cv-00011-RSP

Matter: Patent infringement, wireless devices and systems Project: Source code review, claim construction, declaration, infringement

expert report, validity expert report, two-day depositions

L24. 2015 Foley & Lardner LLP Case: Kyocera Communications, Inc. v. Cellular Communications

Equipment LLC IPR2015-01559, IPR2015-01564

Matter: Inter Partes Review, LTE Project: Two declarations to support two IPR petitions

L25. 2015 Fish & Richardson, P.C.

Case: Fairfield Industries Inc. v. Wireless Seismic, Inc. Southern district of Texas, Case No. 4:14-cv-02972-KPE

Matter: Patent infringement, wireless sensor networks Project: Non-infringement expert report

L26. 2015 Quinn Emanuel Urquhart & Sullivan, LLP

Case: GENBAND US, LLC v. Metaswitch Networks Ltd, et al. Eastern district of Texas, Marshal division, Case No. 2:14-cv-33-JRG-RSP

Matter: Patent infringement, Internet protocols and VoIP Project: Expert report regarding essentiality, non-infringement expert report,



rebuttal expert report regarding non-practice, supplemental rebuttal expert report, three-day depositions, jury trial testimony

L27. 2015 Foley & Lardner LLP; Duane Morris LLP Case: Mobile Telecommunications Technologies, LLC v. Leap Wireless

International, Cricket Communications, Inc. Eastern district of Texas, Marshal division, Case No. 2:13-cv-00885-RSP

Matter: Patent infringement, OFDM and MIMO Project: Non-infringement expert report, deposition

L28. 2015 Hogan Lovells US LLP; Kenyon & Kenyon LLP

Case: One-E-Way v. Beats Electronics, LLC, Sony Corporation, et al. In the Matter of Certain Wireless Headsets, ITC Investigation No. 337-TA-943

Matter: Patent infringement, wireless communication Project: Claim construction, declaration


Case: Solocron Media, LLC v. AT&T Inc., et al. Eastern district of Texas, Marshal division, Case No. 2:13-cv-1059-JRG

Matter: Patent infringement, ringtone download Project: Claim construction, claim invalidity expert report

L30. 2015 EIP US LLP

Case: Good Technology Software, Inc. v. Mobile Iron, Inc. IPR2015-00833, IPR2015-00836, IPR2015-01090

Matter: Inter Partes Review, software management in wireless devices Project: Three declarations to support three IPR petitions


Case: AirWatch LLC v. Good Technology Corp Northern district of Georgia, Case No. 1:14-cv-02281-SCJ

Matter: Patent infringement, software management in wireless devices Project: Claim construction, declaration

L32. 2015 Simpson Thacher & Bartlett LLP

Case: IXI Mobile (R&D) Ltd. et al. v. Apple Inc. Southern district of New York, Case No. 14-cv-7594-RJS

Matter: Patent infringement, PDA and Bluetooth Project: Invalidity consulting



L33. 2014 Bragalone Conroy PC Case: Global Tel*Link Corporation v. Securus Technologies, Inc.

IPR2014-00785, IPR2014-00810, IPR2014-00824, IPR2014-00825, IPR2014-01278, IPR2014-01282, IPR2014-01283

Matter: Inter Partes Review, VoIP call monitoring and recording, allocating telecommunication resources and information systems

Project: Seven declarations to support seven Patent Owner’s responses, five depositions

L34. 2014 Orrick, Herrington & Sutcliffe LLP Case: Shopkick, Inc. v. Novitaz, Inc.

IPR2015-00277, IPR2015-00278 Matter: Inter Partes Review, wireless customer service management Project: Two declarations to support two IPR petitions

L35. 2014 Paul Hastings LLP

Case: Cellular Communications Equipment LLC v. AT&T, et al. Eastern district of Texas, Tyler division, Case No. 6:13-cv-507-LED (Lead Case for Consolidation)

Matter: Patent infringement, 3G cellular communication Project: Claim construction, declaration

L36. 2014 Baker Botts LLP

Case: Orlando Communications LLC v. AT&T, et al. M.D. Florida, Case No. 6:14-cv-01021

Matter: Patent infringement, 3G/4G cellular communication Project: Non-infringement and claim construction consulting

L37. 2014 EIP US LLP

Case: Good Technology Software, Inc. v. AirWatch, LLC IPR2015-00248, IPR2015-00875

Matter: Inter Partes Review, software management in wireless devices Project: Two declarations to support two IPR petitions

L38. 2014 Bragalone Conroy PC

Case: Securus Technologies, Inc. v. Global Tel*Link Corporation IPR2015-00153, IPR2015-00155, IPR2015-00156

Matter: Inter Partes Review, VoIP call monitoring and recording Project: Three declarations to support three IPR petitions, two depositions

L39. 2014 Andrews Kurth LLP

Case: Sony Mobile Communications (USA) v. Adaptix Inc. IPR2014-01524, IPR2014-01525

Matter: Inter Partes Review, subcarrier selection in LTE Project: Two declarations to support two IPR petitions, deposition



L40. 2014 Steptoe & Johnson LLP, Baker & McKenzie LLP Case: VTech Communications, Inc. and Uniden America Corporations v.

Spherix Incorporated IPR2014-01432

Matter: Inter Partes Review, IP telephony Project: Declaration to support IPR petition, deposition, reply declaration,

deposition

L41. 2014 Steptoe & Johnson LLP, Baker & McKenzie LLP Case: Spherix Inc. v. VTech Telecommunications Ltd., et al.

Spherix Inc. v. Uniden Corp, et al. Northern district of Texas, Dallas Division, Case No. 3:13-cv-3494 and 3:13-cv-3496

Matter: Patent infringement, IP telephony Project: Claim construction, declaration, deposition


Case: Good Technology Corp. v. MobileIron, Inc. Northern district of California, Case No. 5:12-cv-05826-PSG

Matter: Patent infringement, software management in wireless devices Project: Claim construction, three declarations, claim invalidity expert report,

non-infringement expert report, deposition, jury trial testimony

L43. 2014 Lee & Hayes Case: Broadcom Corp. v. Ericsson, Inc.

IPR2013-00601, IPR2013-00602, and IPR2013-00636 Matter: Inter Partes Review, ARQ protocols Project: Three declarations to support Patent Owner’s Response, two

declarations to support Patent Owner’s Motion to Amend, deposition, two reply declarations

L44. 2014 Sidley Austin LLP Case: Adaptix, Inc. v. Huawei Technologies Co., et al.

Eastern district of Texas, Case No. 6:13-cv-00438, 439, 440 and 441 Matter: Patent infringement, subcarrier selection in LTE Project: Non-infringement consulting, source code review

L45. 2014 Finnegan Henderson Farabow Garrett & Dunner LLP

Case: Cell and Network Selection LLC v. Huawei Technologies Co., et al. Eastern district of Texas, Case No. 6:13-cv-00404-LED-JDL

Matter: Patent infringement, base station selection in LTE Project: Non-infringement consulting

L46. 2014 Feinberg Day Alberti & Thompson LLP

Case: DSS Technology Management, Inc. v. Apple Inc. Eastern district of Texas, Tyler division, Case No. 6:13-cv-00919-JDL



Matter: Patent infringement, PDA and Bluetooth Project: Claim construction and invalidity consulting

L47. 2014 Sheppard Mullin Richter & Hampton LLP

Case: Digcom Inc. v. ZTE (USA), Inc. District of Nevada, Case No. 3:13-cv-00178-RCJ-WGC

Matter: Patent infringement, cellular communication Project: Claim construction consulting

L48. 2014 Lott & Fischer

Case: Zenith Electronics, LLC, et al. v. Craig Electronics, Inc. Southern district of Florida, Case No. 9:13-cv-80567-DMM/DLB

Matter: Patent infringement, HDTV transmission and reception Project: Opening expert report regarding nonessentiality


Case: Zenith Electronics, LLC, et al. v. Curtis International Ltd. Southern district of Florida, Case No. 9:13-cv-80568-DMM/DLB

Matter: Patent infringement, HDTV transmission and reception Project: Claim construction, declaration, deposition

L50. 2013 Gibson Dunn

Case: Straight Path IP Group v. Sharp Corp. and Sharp Electronics Corp. In the Matter of Certain Point-to-Point Network Communication Devices and Products Containing Same, ITC Investigation No. 337-TA-892

Matter: Patent infringement, point-to-point network communication Project: Non-infringement consulting

L51. 2013 Kilpatrick Townsend & Stockton LLP

Case: Monec Holding AG v. Motorola Mobility LLC, et al. District of Delaware, Case No. 1:11-cv-798-LPS-SRF

Matter: Patent infringement, displaying books on tablets Project: Non-infringement expert report for Motorola, non-infringement expert

report for HTC, deposition

L52. 2013 Gartman Law Group Case: Lone Star WiFi LLC v. Legacy Stonebriar Hotel, Ltd; et al.

Eastern Dist. Of Texas, Tyler, Case No. 6:12-cv-957 Matter: Patent infringement, levels of access in Wi-Fi networks Project: Claim validity consulting

L53. 2013 White & Case, LLP

Case: Nokia Corp and Nokia, Inc. v. HTC Corp and HTC America, Inc. In the Matter of Certain Portable Electronic Communication Devices, Including Mobile Phones and Components Thereof, ITC Investigation



No. 337-TA-885 Matter: Patent infringement, App download and installation Project: Non-infringement consulting

L54. 2013 Heim, Payne & Chorush, LLP

Case: Rembrandt Wireless v. Samsung Electronics Co., et al. Eastern Dist. of Texas, Marshal, Case No. 2:13-cv-213-JRG-RSP

Matter: Patent infringement, Bluetooth Project: Expert report regarding validity, deposition, jury trial

L55. 2013 Davis Polk & Wardwell LLP; Baker Hostetler

Case: Comcast v. Sprint; and Nextel Inc. Eastern Dist. of Pennsylvania, Case No. 2:12-cv-00859-JD

Matter: Patent infringement, SMS/MMS in Cellular Networks Project: Infringement expert report, validity expert report, reply expert report,

declaration, two-day depositions, jury trial testimony

L56. 2013 McKool Smith Case: Samsung Electronics America v. Ericsson Inc.

In the Matter of Certain Wireless Communications Equipment and Articles Therein, ITC Investigation No. 337-TA-866

Matter: Patent infringement, LTE uplink and downlink Project: Prior art research, source code review, claim construction, claim

invalidity expert report, non-infringement expert report, ITC hearing testimony

L57. 2012 DLA Piper US LLP Case: CSR Technology Inc. v. Freescale Semiconductor, Inc.

USDC-San Francisco, Case No. 3:12-cv-02619-RS Matter: Patent infringement, radio transceivers Project: Claim construction, declaration

L58. 2012 Fish & Richardson PC

Case: GPNE Corp. v. Apple, Inc.; et al. USDC-ND California, Case No. 5:12-cv-02885-LHK

Matter: Patent infringement, resource allocation in wireless networks Project: Prior art research consulting

L59. 2012 Polsinelli Shughart PC

Case: Single Touch Interactive, Inc. v. Zoove Corporation Northern district of California, Case No. 3:12-cv-00831-JSC

Matter: Patent infringement, abbreviated dialing, information delivery Project: Claim construction, Markman hearing testimony, two declarations

L60. 2012 K & L Gates

Case: EON Corp. IP Holdings, LLC v. Novatel Wireless, Inc.; et al.



DC-Tyler, Texas, Case No. 6:11-cv-00015-LED-JDL Matter: Patent infringement, wireless modem and 3G services Project: Non-infringement expert report, deposition

L61. 2012 Simpson Thacher & Bartlett LLP

Case: CSR Technology, Inc. v. Bandspeed, Inc. Western Dist. of Texas, Case No. 1:12-cv-297-LY

Matter: Patent infringement, packet identification in 2.4 GHz and 5 GHz Project: Source code review, Markman hearing testimony, infringement expert

report

L62. 2012 Sheppard Mullin Richter & Hampton LLP Case: Wi-LAN v. HTC America, Inc., et al.

Eastern Dist. of Texas, Case No. 6:10-cv-521-LED Matter: Patent infringement, CDMA, Orthogonal Codes Project: Source code review, non-infringement expert report, deposition, jury

trial testimony

L63. 2012 Dechert LLP Case: Hitachi v. TPV and Vizio, Inc.; and Vizio v. Hitachi, LTD.

Eastern Dist. of Texas, Case No. 2:10-cv-260 Matter: Patent infringement, HD television transmission and reception Project: Prior art research, claim invalidity consulting


Case: InterDigital Commc’n, LLC v. Huawei Tech. Co. LTD; LG Electronics, Inc.; Nokia, Inc.; and ZTE (USA) Inc. Certain Wireless Devices With 3G Capabilities and Components Thereof, ITC Investigation No. 337-TA-800

Matter: Patent infringement, channel coding in UMTS, HSDPA Project: Non-infringement consulting


Case: InterDigital Commc’n, LLC v. Huawei Tech. Co. LTD; LG Electronics, Inc.; Nokia, Inc.; and ZTE (USA) Inc. Dist. of Delaware, Case No. 1:11-cv-00654-UNA

Matter: Patent infringement, channel coding in UMTS, HSDPA Project: Non-infringement consulting

L66. 2011 O’Melveny & Myers LLP

Case: MobileMedia Ideas, LLC v. Apple, Inc. Dist. of Delaware, Case No. 1:10-cv-00258-SLR-MPT

Matter: Patent infringement, voice control, call rejection in mobile phones Project: Source code review, prior art research, declaration, claim invalidity

expert report, non-infringement expert report, deposition, jury trial testimony



L67. 2011 Wilmer Cutler Pickering Hale and Dorr

Case: Apple, Inc. v. Samsung Electronics Co. Northern Dist. of California, Case No. 5:11-cv-01846-LHK

Matter: Patent infringement, channel coding in CDMA, E-AGCH, TFCI Project: Prior art research, claim construction consulting

L68. 2011 Weil, Gotshal & Manges LLP

Case: Vizio, Inc. v. Renesas Electronics America, Inc. ITC Investigation No. 337-TA-789

Matter: Patent infringement, HD television transmission and reception Project: Claim invalidity consulting

L69. 2011 Shapiro Cohen

Case: TenXc Wireless Inc. v. Andrew LLC TenXc Wireless Inc. v. Mobi Antenna Technologies Ltd.

Matter: Patent infringement, antenna design, sectorized cellular network Project: Claim validity consulting

L70. 2010 Fish & Richardson PC Case: Vizio, Inc., v. LG Electronics, Inc.

ITC Investigation No. 337-TA-733 Matter: Patent infringement, HD television transmission and reception Project: Claim charts, claim construction expert report, deposition


Case: Vizio, Inc., v. LG Electronics, Inc. Dist. of Maryland, Case No. 1:09-cv-1481-BEL

Matter: Patent infringement, HD television transmission and reception Project: Claim charts, claim construction expert report, deposition

L72. 2008 Kaye Scholer LLP

Case: eBay Inc. v. IDT. Western Dist. of Arkansas, Case No. 4:08-cv-4015-HFB

Matter: Patent infringement, long distance communication using Internet Project: Prior art research, claim construction consulting

L73. 2008 Simpson Thacher & Bartlett LLP Case: Commil USA, LLC v. Cisco Systems, Inc.

Eastern Dist. of Texas, Case No. 2:07-cv-00341-DF-CE Matter: Patent infringement, two-level wireless protocol Project: Prior art research

L74. 2006 Woodfill and Pressler Case: Charles Russell v. Interinsurance Exchange of the Auto Club

Harris County, Texas, Case No. 2005-19706



Matter: House fire and insurance claim Project: Determining user location using cellular phone records, expert report,

deposition, jury trial testimony

Consulting History From: 1/2013 Heim, Payne & Chorush, LLP To: 3/2013 Houston, TX Duties: Analyze patents on wireless technologies.

From: 4/2007 Collin County Sheriff’s Office To: 5/2007 McKinney, TX Duties: Analyzed cellular record data and determined user location in a

double-homicide investigation. From: 4/2004 Allegiant Integrated Solutions To: 5/2004 Fort Worth, TX Duties: Designed and developed an integrated set of tools for fast deployment

of wireless networks. The tools optimize the placement of Access Points and determine their respective channel allocations to minimize interference and maximize capacity.

From: 3/2002 Input/Output Incorporated To: 4/2002 New Orleans, LA Duties: Designed and implemented an algorithm in MATLAB for optimizing

the frequency selection process used by sonar for scanning the bottom of the ocean.

From: 6/1998 Teleware Corporation To: 7/1998 Seoul, South Korea Duties: Designed and developed a software package for analyzing the capacity

in a CDMA network to maximize the number of subscribers.

Employment History From: 1/2015 University of North Texas To: Present Denton, TX Position: Associate Chair of Graduate Studies Department of Computer Science

and Engineering In charge of all administrative duties related to the Masters and PhD

programs in the department.

From: 5/2008 University of North Texas To: Present Denton, TX Position: Tenured Associate Professor Department of Computer Science and

Engineering



Conducting research on cellular networks and wireless sensor networks. Teaching wireless communication courses. Advising graduate and undergraduate students.

From: 9/2002 University of North Texas To: 5/2008 Denton, TX Position: Assistant Professor Department of Computer Science and Engineering Conducting research on WCDMA/UMTS wireless networks. Teaching

wireless communication and computer architecture courses. Advising graduate and undergraduate students.

From: 1/2002 University of New Orleans To: 8/2002 New Orleans, LA Position: Assistant Professor Department of Electrical Engineering Designed and taught two new courses “Computer Systems Design I

and II”. Developed a Computer Engineering Curriculum with strong hardware-design emphasis. Formed a wireless research group. Advised graduate and undergraduate students.

From: 10/2000 Comspace Corporation To: 12/2001 Coppell, TX Position: Senior Systems Engineer Designed, coded (in Matlab), and simulated Viterbi decoding, Turbo

coding, trellis coded modulation (TCM), and Reed-Muller codes. Optimized soft decision parameters and interleavers for additive white Gaussian and Rayleigh faded channels. Extended the control and trunking of push-to-talk Logic Trunked Radio (LTR) to include one-to-one and one-to-many voice and data messaging.

From: 8/1996 MinMax Corporation To: 8/2000 Saint Louis, MO Position: Research Associate Designed software packages that provide the tools to flexibly allocate

capacity in a CDMA network and maximize the number of subscribers. Validated, simulated (logical and timing), and developed the hardware architecture for an ATM switch capable of channel group switching.

From: 8/1994 Washington University To: 8/2000 Saint Louis, MO Position: Research and Teaching Assistant Taught, consulted, and graded Circuit Analysis at the undergraduate

level and Network Design at the graduate level.

Publications



Conference Proceedings

C1. U. Sawant, R. Akl, “Evaluation of Adaptive and Non Adaptive LTE Fractional Frequency Reuse Mechanisms,” IEEE WOCC 2017 The 26th Annual Wireless and Optical Communications Conference, April 2017, paper no. 1570341174, 6 pgs.

C2. U. Sawant, R. Akl, “A Novel Metric to Study the Performance of Sectorized

Fractional Frequency Reuse Techniques in LTE,” IEEE WTS 2017 The 16th Annual Wireless Telecommunications Symposium, April 2017, paper no. 1570338498, 7 pgs

C3. S. Alotaibi, R. Akl, “Dynamic Frequency Partitioning Scheme for LTE HetNet

Networks Using Fractional Frequency Reuse,” IEEE WCNC ’17 Wireless Communications and Networking Conference, March 2017, paper no. 1570332420, 5 pgs.

C4. U. Sawant, R. Akl, “Performance Evaluation of Network Productivity for LTE Heterogenous Networks with Reward-Penalty Weights Assessment,” IEEE CCWC 2017 The 7th Annual Computing and Communication Workshop Conference, January 2017, paper no. 1570328396, 6 pgs.

C5. S. Alotaibi, R. Akl, “Self-Adjustment Downlink Transmission Power for Femtocells in Co-Channel Deployment in Heterogeneous Networks,” IEEE CCWC 2017 The 7th Annual Computing and Communication Workshop Conference, January 2017, paper no. 1570326815, 6 pgs.

C6. U. Sawant, R. Akl, “Performance Evaluation of Sectorized Fractional Frequency Reuse Techniques Using Novel Metric,” IEEE ISCC 2016 The Twenty-First IEEE Symposium on Computers and Communications, June 2016, paper no. 1570275270, 7 pgs.

C7. R. Tidwell, S. Akumalla, S. Karlaputi, R. Akl, K. Kavi, and D. Struble, “Evaluating the Feasibility of EMG and Bend Sensors for Classifying Hand Gestures,” 1st International Conference on Multimedia and Human Computer Interaction, July 2013, paper no. 63, 8 pgs.

C8. R. Akl, K. Pasupathy, and M. Haidar, “Anchor Nodes Placement for Effective

Passive Localization,” 2011 IEEE International Conference on Selected Topics in Mobile and Wireless Networks (iCOST), October 2011, paper no. 1569490799, pp. 127 - 132.

C9. R. Akl, P. Kadiyala, and M. Haidar, “Non-Uniform Grid-Based Routing in

Sensor Networks”, 9th IEEE Malaysia International Conference on Communications, December 2009, paper no. 1569243649, pp. 536 - 540.



C10. M. Haidar, M. Al-Rizzo, Y. Chan, R. Akl, M. Bouharras, “Throughput Validation of an Advanced Channel Assignment Algorithm in IEEE 802.11 WLAN”, ICCSN 2009 – International Conference on Communication Software and Networks, February 2009, paper no. P385, pp. 801 - 806.

C11. R. Akl and D. Keathly, “Robocamp: Encouraging Young Women to Embrace

STEM,” 4th Annual TETC Best Practices Conference, February 2009, 13 pgs.

C12. M. Haidar, R. Ghimire, M. Al-Rizzo, R. Akl, Y. Chan, “Channel Assignment in an IEEE 802.11 WLAN Based on Signal-to-interference Ratio”, IEEE CCECE – Canadian Conference on Electrical and Computer Engineering: Communications and Networking, May 2008, paper no. 1569092894, pp. 1169 - 1174.

C13. H. Al-Rizzo, M. Haidar, R. Akl, and Y. Chan, “Enhanced Channel Assignment

and Load Distribution in IEEE 802.11 WLANs,” IEEE International Conference on Signal Processing and Communication, November 2007, paper no. 1569042132, pp. 768 - 771.

C14. R. Akl and Y. Saravanos, “Hybrid Energy-Aware Synchronization Algorithm in

Wireless Sensor Networks,” 18th Annual IEEE International Symposium on Personal, Indoor and Mobile Radio Communications, September 2007, paper no 692, 5 pgs.

C15. M. Haidar, R. Akl, and H. Al-Rizzo, “Channel Assignment and Load

Distribution in a Power-Managed WLAN,” 18th Annual IEEE International Symposium on Personal, Indoor and Mobile Radio Communications, September 2007, paper no. 463, 5 pgs.

C16. D. Keathly and R. Akl, “Attracting and Retaining Women in Computer Science

and Engineering: Evaluating the Results,” Proceedings of American Society for Engineering Education: ASEE Annual Conference, June 2007, paper no. AC 2007-1229, 10 pgs.

C17. M. Haidar, R. Akl, H. Al-Rizzo, Y. Chan, R. Adada, “Optimal Load Distribution

in Large Scale WLAN Networks Utilizing a Power Management Algorithm,” Proceedings of IEEE Sarnoff Symposium, May 2007, 5 pgs.

C18. R. Dantu, P. Kolan, R. Akl, and K. Loper, “Classification of Attributes and

Behavior in Risk Management Using Bayesian Networks,” Proceedings of IEEE Intelligence and Security Informatics Conference, May 2007, pp. 71-74.

C19. R. Akl and A. Arepally, “Dynamic Channel Assignment in IEEE 802.11

Networks,” Proceedings of IEEE Portable 2007: International Conference on Portable Information Devices, March 2007, pp 309-313.



C20. R. Akl and U. Sawant, “Grid-based Coordinated Routing in Wireless Sensor Networks,” Proceedings of IEEE CCNC 2007: Consumer Communications and Networking Conference, January 2007, pp. 860-864.

C21. R. Akl and A. Arepally, “Simulation of Throughput in UMTS Networks with

Different Spreading Factors,” Proceedings of IEEE VTC Fall 2006: Vehicular Technology Conference, September 2006, pp. C1-5.

C22. A. Alhabsi, H. Al-Rizzo, and R. Akl, “Parity Assisted Decision Making for

QAM Modulation,” International Conference on Mobile Computing and Wireless Communications, September 2006, paper no. 1568988776, 5 pgs.

C23. R. Akl and R. Garlick, “Retention and Recruitment of Women in Computer

Engineering,” ICEE 2006: International Conference on Engineering Education, July 2006, paper no. 3318, 5 pgs.

C24. R. Garlick and R. Akl, “Intra-Class Competitive Assignments in CS2: A One-

Year Study,” ICEE 2006: International Conference on Engineering Education, July 2006, paper no. 3325, 5 pgs.

C25. R. Akl, D. Tummala, and X. Li, “Indoor Propagation Modeling at 2.4 GHz for

IEEE 802.11 Networks,” WNET 2006: Wireless Networks and Emerging Technologies, July 2006, paper no. 510-014, 6 pgs.

C26. P. Chen, K. Kavi, and R. Akl, “Performance Enhancement by Eliminating

Redundant Function Execution,” Proceedings of IEEE: 39th Annual Simulation Symposium, April 2006, pp. 143-150.

C27. R. Akl and S. Nguyen, “Capacity Allocation in Multi-cell UMTS Networks for

Different Spreading Factors with Perfect and Imperfect Power Control,” Proceedings of IEEE CCNC 2006: Consumer Communications and Networking Conference, January 2006, vol. 2, pp. 928-932.

C28. W. Li, K. Kavi, and R. Akl, “An Efficient Non-Preemptive Real-Time

Scheduling,” 18th International Conference on Parallel and Distributed Computing Systems, Las Vegas, NV, September 2005, pp. 154-160.

C29. S. Nguyen and R. Akl, “Approximating User Distributions in WCDMA

Networks Using 2-D Gaussian,” CCCC20T 05: International Conference on Computing, Communications, and Control Technologies, July 2005, 5 pgs.

C30. R. Akl and S. Park, “Optimal Access Point Selection and Traffic Allocation in

IEEE 802.11 Networks,” Proceedings of 9th World Multiconference on Systemics, Cybernetics and Informatics (WMSCI 2005): Communication and Network Systems, Technologies and Applications, July 2005, vol. 8, pp. 75-79.



C31. R. Akl, M. Naraghi-Pour, M. Hegde, “Throughput Optimization in Multi-Cell CDMA Networks,” IEEE WCNC 2005 - Wireless Communications, and Networking Conference, March 2005, vol. 3, pp. 1292-1297.

C32. R. Akl, “Subscriber Maximization in CDMA Cellular Networks,” Proceedings

of CCCT 04: International Conference on Computing, Communications, and Control Technologies, August 2004, vol. 3, pp. 234-239.

C33. R. Akl and A. Parvez, “Global versus Local Call Admission Control in CDMA

Cellular Networks,” Proceedings of CITSA 04: Communications, Information and Control Systems, Technologies and Applications, July 2004, vol. 2, pp. 283-288.

C34. R. Akl and A. Parvez, “Impact of Interference Model on Capacity in CDMA

Cellular Networks,” Proceedings of SCI 04: Communication and Network Systems, Technologies and Applications, July 2004, vol. 3, pp. 404-408. Selected as best paper of those presented in the session: Tele-Communication Systems, Technologies and Application II.

C35. R.G. Akl, M.V. Hegde, M. Naraghi-Pour, P.S. Min, “Call Admission Control

Scheme for Arbitrary Traffic Distribution in CDMA Cellular Systems,” IEEE Wireless Communications and Networking Conference, September 2000, vol. 1, pp. 465-470.

C36. R.G. Akl, M.V. Hegde, M. Naraghi-Pour, P.S. Min, “Cell Placement in a

CDMA Network,” IEEE Wireless Communications and Networking Conference, September 1999, vol. 2, pp. 903-907.

C37. R.G. Akl, M.V. Hegde, P.S. Min, “Effects of Call Arrival Rate and Mobility on

Network Throughput in Multi-Cell CDMA,” IEEE International Conference on Communications, June 1999, vol. 3, pp. 1763-1767.

C38. R.G. Akl, M.V. Hegde, M. Naraghi-Pour, P.S. Min, “Flexible Allocation of

Capacity in Multi-Cell CDMA Networks,” IEEE Vehicular Technology Conference, May 1999, vol. 2, pp. 1643-1647.

Journal Publications

J1. M. Haidar, H.M. Al-Rizzo, R. Akl, and Z. Elbazzal, “The Effect of an Enhanced Channel Assignment Algorithm in an IEEE 802.11 WLAN,” World Scientific and Engineering Academy and Society Transactions on Communications, WSEAS, Vol. 8, Issue 12, December 2009.

J2. R. Akl, P. Kadiyala, and M. Haidar, “Non-Uniform Grid-Based Coordinated Routing in Wireless Sensor Networks”, Journal of Sensors, article ID 491349, volume 2009, 11 pages.



J3. M. Haidar, M. Al-Rizzo, Y. Chan, R. Akl, “User-Based Channel Assignment Algorithm in a Load-Balanced IEEE 802.11 WLAN”, International Journal of Interdisciplinary Telecommunications & Networking (IJITN), April-June 2009, 1(2), pp. 66-81.

J4. R. Akl, D. Keathly, and R. Garlick, “Strategies for Retention and Recruitment of Women and Minorities in Computer Science and Engineering,” iNEER Special Volume: Innovations 2007- World Innovations in Engineering Education and Research, 9 pgs., 2007.

J5. R. Garlick and R. Akl, “Motivating and Retaining CS2 Students with a

Competitive Game Programming Project,” iNEER Special Volume: Innovations 2007- World Innovations in Engineering Education and Research, 9 pgs., 2007.

J6. R. Akl and S. Nguyen, “UMTS Capacity and Throughput Maximization for

Different Spreading Factors,” Journal of Networks, July 2006, vol. 1, issue 3, pp. 40-49. ISSN: 1796-2056

J7. W. Li, K. Kavi, and R. Akl, “A Non-preemptive Scheduling Algorithm for Soft

Real-time Systems,” Journal of Computer and Electrical Engineering, 2006, vol. 32, 18 pgs. ISSN: 0045-7906

J8. R. Akl, A. Parvez, and S. Nguyen, “Effects of Interference on Capacity in Multi-

Cell CDMA Networks,” Journal of Systemics, Cybernetics and Informatics, 2006, vol. 3, no. 1, p825612, 7 pgs. ISSN: 1690-4524

J9. R.G. Akl, M. Hegde and M. Naraghi-Pour, “Mobility-based CAC Algorithm for

Arbitrary Traffic Distribution in CDMA Cellular Systems,” IEEE Transactions on Vehicular Technology, March 2005, vol. 54, no. 2, pp. 639-651.

J10. R.G. Akl, M.V. Hegde, M. Naraghi-Pour, P.S. Min, “Multi-Cell CDMA

Network Design,” IEEE Transactions on Vehicular Technology, May 2001, vol. 50, no. 3, pp. 711-722.

Technical Papers

T1. J. Williams, R. Akl, et al, “Flight Control Subsystem,” The Eagle Feather, Special Section: Undergraduate Research Initiative in Engineering, University of North Texas, Vol. 7, 2010.

T2. R.G. Akl, M.V. Hegde, A. Chandra, P.S. Min, “CDMA Capacity Allocation and

Planning,” Technical Document, Washington University Department of Electrical Engineering WUEE-98, April 1998.

Book Chapters



B1. R. Akl, Y. Saravanos, and M. Haidar, “Chapter 18: Hybrid Approach for Energy-Aware Synchronization in Sensor Networks,” Sustainable Wireless Sensor Networks, December 2010, pgs. 413-429, ISBN: 978-953-307-297-5.

B2. K. Kavi, R. Akl and A. Hurson, “Real-Time Systems: An Introduction and the

State-of-the-Art,” Encyclopedia of Computer Science and Engineering, John Wiley & Sons, Volume 4, January 2009, pgs. 2369-2377.

B3. R. Akl and K. Kavi, “Chapter 12: Modeling and Analysis using Computational

Tools,” Introduction to Queuing Theory: Modeling and Analysis, Birkhauser Boston, December 2008, pgs. 295-320.

Technical Presentations

P1. “Bio-Com Project,” Raytheon, Richardson TX, May 2012, (invited). P2. “Bio-Com Project,” Net-Centric Software and Systems I/UCRC Meeting,

Denton TX, December 2011, (invited). P3. “Student Outreach Report: Robocamp,” College of Engineering Advisory Board

Meeting, Denton TX, May 2011, (invited). P4. “Robocamp: Encouraging Young Women to Embrace STEM,” 4th Annual

TETC Best Practices Conference, Austin TX, February 2009, (invited). P5. “Self-Configuring Wireless MEMS Network (demo),” Southern Methodist

University, Dallas TX, January 2008, (invited). P6. “Energy-aware Routing and Hybrid Synchronization in Sensor Networks,”

Southern Methodist University, Dallas TX, September 2007, (invited). P7. “Retention and Recruitment of Women in Computer Engineering,” ICEE 2006:

International Conference on Engineering Education, Puerto Rico, July 2006, (refereed).

P8. “Capacity Allocation in Multi-cell UMTS Networks for Different Spreading

Factors with Perfect and Imperfect Power Control,” IEEE CCNC 2006: Consumer Communications and Networking Conference, Las Vegas, NV, January 2006, (refereed).

P9. “Research, Teaching, and Outreach,” CSE Advisory Council Meeting, UNT

Research Park, Denton, TX, December 2005, (invited). P10. “WiFi and WCDMA Network Design,” University of Arkansas, Little Rock, AR,

April 2005, (invited).



P11. “WiFi and WCDMA Network Design,” Southern Methodist University, Dallas, TX, March 2005, (invited).

P12. “Current Research in Wireless at UNT,” Nortel Networks, Richardson, TX,

October 2004, (invited). P13. “Subscriber Maximization in CDMA Cellular Networks,” International

Conference on Computing, Communications, and Control Technologies, Austin, TX, August 2004, (refereed).

P14. “Global versus Local Call Admission Control in CDMA Cellular Networks,”

International Conference on Cybernetics and Information Technologies, Systems and Applications, Orlando, FL, July 2004, (refereed).

P15. “Impact of Interference Model on Capacity in CDMA Cellular Networks,” 8th

World Multi-Conference on Systemics, Cybernetics, and Informatics, Orlando, FL, July 2004, (refereed).

P16. “CDMA Network Design,” IEEE Communications Society – New Orleans

Chapter, New Orleans, LA, May 2002, (invited). P17. “Cell Design to Maximize Capacity in CDMA Networks,” Louisiana State

University, Baton Rouge, LA, April 2002, (invited). P18. “Call Admission Control Scheme for Arbitrary Traffic Distribution in CDMA

Cellular Systems,” IEEE Wireless Communications and Networking Conference, Chicago, IL, September 2000, (refereed).

P19. “Cell Placement in a CDMA Network,” IEEE Wireless Communications and

Networking Conference, September 1999, (refereed). P20. “Effects of Call Arrival Rate and Mobility on Network Throughput in Multi-Cell

CDMA,” IEEE International Conference on Communications, June 1999, (refereed).

P21. “Flexible Allocation of Capacity in Multi-Cell CDMA Networks,” IEEE

Vehicular Technology Conference, May 1999, (refereed). P22. “CCAP: A Strategic Tool for Managing Capacity of CDMA Networks,”

Teleware Co. Ltd., Seoul, South Korea, 1998, (invited).

Courses Developed

• CSCE 5933: LTE Physical Layer Using MATLAB. Research issues in the design of LTE physical layer and simulate using MATLAB. Topics include modulation and coding, OFDM, channel modeling, MIMO, and



link adaption.

• CSCE 6590: Advanced Topics in Wireless Communications & Networks: 4G/LTE. Research issues in the design of next generation wireless networks: cellular systems, medium access techniques, signaling, mobility management, control and management for mobile networks, wireless data networks, Internet mobility, quality-of-service for multimedia applications, caching for wireless web access, and ad hoc networks.

• CSCE 5933: Fundamentals of VoIP.

Fundamentals of VoIP, with emphasis on network infrastructure implementation and security. Topics include IP protocol suite, SS7, speech-coding techniques, quality of service, session initiation protocol, and security issues.

• CSCE 5540: Introduction to Sensor Networks.

Topics include: design implications of energy (hardware and software), and otherwise resource-constrained nodes; network self-configuration; services such as routing under network dynamics, localization, time-synchronization and calibration; distributed data management, in-network aggregation and collaborative signal processing, programming tools and language support.

• CSCE 5510. Wireless Communication.

Point-to-point signal transmission through a wireless channel, channel capacity, channel encoding, and multi-user transmissions. First, second, and third generation cellular systems, and mobility management.

• CSCE 3510. Introduction to Wireless Communication.

Fundamentals of wireless communications and networking, with emphasis on first, second, and third generation cellular systems. Topics include point-to-point signal transmission through a wireless channel, cellular capacity, multi-user transmissions, and mobility management.

• CSCE 3020. Communications Systems.

Introduction to the concepts of transmission of information via communication channels. Amplitude and angle modulation for the transmission of continuous-time signals. Analog-to-digital conversion and pulse code modulation. Transmission of digital data. Introduction to random signals and noise and their effects on communication. Optimum detection systems in the presence of noise.

• ENEE 3583. Computer Systems Design I (UNO).

The design process of digital computer systems is studied from the instruction set level, system architecture level, and digital logic level. Topics include machine organization, register transfer notation, processor design, memory design, and input/output considerations. Includes semester project.



• ENEE 3584. Computer Systems Design II (UNO). The design and evaluation of contemporary computer systems are analyzed to compare the performance of different architectures. Topics include performance metrics, computer arithmetic, pipelining, memory hierarchies, and multiprocessor systems.

• ENEE 3514. Computer Architecture Laboratory (UNO).

Selected experiments examining programmable logic, VHDL and logic synthesis, and including a final design project, to accompany and complement the lecture course ENEE 3584. Three hours of laboratory.

Courses Taught

Fall 2016 • CSCE 5933.3: LTE Physical Layer Using MATLAB (4.7 / 5.0)

Spring 2016 • CSCE 5950.743: Thesis (no evaluation done) • CSCE 6950.743: Dissertation (no evaluation done)

Fall 2015 • CSCE 3010.1: Signals and Systems (5.7 / 7.0)

Spring 2015 • CSCE 5934.743: Directed Study (no evaluation done)

Fall 2014 • CSCE 3010.1: Signals and Systems (3.32 / 4.00) • CSCE 6590.1: Advanced Topics in Wireless Communications & Networks:

4G/LTE (3.79 / 4.00) Spring 2014

• CSCE 3510.1: Intro to Wireless Communication (808 – Highly Effective) • CSCE 5510.1: Wireless Communications (808 – Highly Effective)

Fall 2013 • CSCE 6590.1: Advanced Topics in Wireless Communications & Networks:

4G/LTE (804 – Highly Effective) Spring 2013

• CSCE 4890.743: Directed Study (no evaluation done) • CSCE 6940.743: Individual Research (no evaluation done)

Fall 2012 • CSCE 3010.1: Signals and Systems (793 – Highly Effective) • CSCE 5540.1: Intro to Sensor Networks (814 – Highly Effective)

Spring 2012 • CSCE 3020.1: Communication Systems (809 – Highly Effective) • CSCE 3510.1: Intro to Wireless Communication (811 – Highly Effective) • CSCE 5510.1: Wireless Communications (817 – Highly Effective) • EENG 3810.1: Communication Systems (801 – Highly Effective)

Fall 2011 • CSCE 3010.1: Signals and Systems (793 – Highly Effective)



• CSCE 5540.1: Intro to Sensor Networks (824 – Highly Effective) Spring 2011

• CSCE 3020.1: Communication Systems (820 – Highly Effective) • CSCE 3510.1: Intro to Wireless Communication (812 – Highly Effective) • CSCE 5510.1: Wireless Communications (812 – Highly Effective) • EENG 3810.1: Communication Systems (826 – Highly Effective)

Fall 2010 • CSCE 3010.1: Signals and Systems (857 – Highly Effective) • CSCE 5540.1: Intro to Sensor Networks (831 – Highly Effective)

Spring 2010 • CSCE 3020.1: Communication Systems (792 – Highly Effective) • CSCE 3510.1: Intro to Wireless Communication (793 – Highly Effective) • CSCE 5510.1: Wireless Communications (834 – Highly Effective) • EENG 3810.1: Communication Systems (854 – Highly Effective)

Fall 2009 • CSCE 3010.1: Signals and Systems (4.40 / 5.00) • CSCE 5540.1: Intro to Sensor Networks (4.70 / 5.00) • EENG 2620.1: Signals and Systems (4.40 / 5.00)

Spring 2009 • CSCE 3020.1: Communication Systems (4.87 / 5.00) • CSCE 3510.1: Intro to Wireless Communication (4.65 / 5.00) • CSCE 5510.1: Wireless Communications (4.79 / 5.00)


Spring 2008 • CSCE 3020.1: Communication Systems (4.68 / 5.00) • CSCE 3510.1: Intro to Wireless Communication (3.96 / 5.00) • CSCE 5510.1: Wireless Communications (4.75 / 5.00)

Fall 2007 • CSCE 3010.1: Signals and Systems (4.57 / 5.00) • CSCE 5540.2: Intro to Sensor Networks (4.01 /5.00)

Summer 2007 • CSCE 3020.1: Fund. of Communication Theory (no evaluation done) • EENG 3810.1: Communication Systems (no evaluation done)

Spring 2007 • CSCE 5510.2: Wireless Communications (4.75 / 5.00) • CSCE 5933.6: Fundamentals of VoIP (4.70 / 5.00)


Summer 2006



• CSCE 3020.1: Fund. of Communication Theory (no evaluation done) • CSCE 3510.21: Intro to Wireless Communications (no evaluation done) • CSCE 5510.21: Intro to Wireless Communications (no evaluation done) • EENG 3810.1: Communication Systems (no evaluation done)

Spring 2006 • CSCE 2610.2: Computer Organization (3.69 / 5.00) • CSCE 3010.1: Signals and Systems (4.41 / 5.00) • EENG 2620.1: Signals and Systems (4.41 / 5.00)

Fall 2005 • CSCE 3510.1: Intro to Wireless Communications (4.52 / 5.00) • CSCE 5510.1: Wireless Communications (4.46 / 5.00) • CSCE 5933.6: Intro to Sensor Networks (4.60 / 5.00)

Summer 2005 • CSCE 3010.21: Signals and Systems (no evaluation done) • CSCE 3510.21: Intro to Wireless Communications (no evaluation done)

Spring 2005 • CSCE 3510.02: Intro to Wireless Communications (4.46 / 5.00) • CSCI 3100.02: Computer Organization (4.14 / 5.00)

Fall 2004 • CSCE 3510.01: Intro to Wireless Communications (4.15 / 5.00) • CSCI 4510.01: Machine Structures (4.55 / 5.00) • CSCI 5330.02: Intro to Wireless Communications (4.05 / 5.00)

Summer 2004 • CSCI 4330.22: Intro to Wireless Communications (no evaluation done) • CSCI 4330.23: Intro to Wireless Communications (no evaluation done) • CSCI 5330.22: Intro to Wireless Communications (no evaluation done)

Spring 2004 • CSCI 3100: Computer Organization (4.64 / 5.00) • CSCI 4330: Intro to Wireless Communications (4.22 / 5.00)

Fall 2003 • CSCI 4510: Machine Structures (4.49 / 5.00) • CSCI 5330: Intro to Wireless Communications (4.83 / 5.00)

Summer 2003 • CSCI 3100: Computer Organization (no evaluation done)

Spring 2003 • CSCI 3100: Computer Organization (3.84 / 5.00)

Fall 2002 • CSCI 4510: Machine Structures (4.38 / 5.00)

Funded Proposals

R1. “UNT GenCyber Summer Program: Inspiring the Next Generation of Cyber Stars in North Texas,” National Security Agency (NSA). Requested amount is $85,000. Submitted 11/4/2016. Robert Akl (co-PI), awarded $85,000.



R2. “App Design Summer Camp” under Texas Higher Education Coordinating Board: Engineering Summer Program. Requested amount is $12,900. Submitted 5/6/16. Robert Akl (PI), awarded $12,900.

R3. “Robotics, Game and App Programming Summer Camps” under Texas

Workforce Commission: Summer Merit Program. Requested amount is $63,000. Submitted 11/16/15. Robert Akl (PI), awarded $63,000.

R4. “App Design Summer Camp” under Texas Higher Education Coordinating

Board: Engineering Summer Program. Requested amount is $13,998. Submitted 5/1/15. Robert Akl (PI), awarded $13,988.

R5. “App Design Summer Camp” under Texas Higher Education Coordinating

Board: Engineering Summer Program. Requested amount is $12,500. Submitted 5/2/14. Robert Akl (PI), awarded $12,500.

R6. “Robotics, Game and App Programming Summer Camps” under Texas

Workforce Commission: Summer Merit Program. Requested amount is $63,000. Submitted 12/14/12. Robert Akl (PI), awarded $63,000.

R7. “Bio-Com Project,” funded by Raytheon under Net-Centric Software and

Systems I/UCRC 2nd year. Requested amount is $30,000. Submitted 5/12/12. Krishna Kavi (PI), Robert Akl (co-PI), awarded $30,000.

R8. “Bio-Com Project,” funded by Raytheon under Net-Centric Software and

Systems I/UCRC. Requested amount is $30,000. Submitted 5/12/11. Krishna Kavi (PI), Robert Akl (co-PI), awarded $30,000.

R9. “Game Programming for Xbox 360 Summer Camp” under Texas Higher

Education Coordinating Board: Engineering Summer Program. Requested amount is $20,000. Submitted 3/21/11. Robert Akl (PI), awarded $20,000.

R10. “RoboCamps and Game Programming Summer Camps” under Texas Workforce

Commission: Summer Merit Program. Requested amount is $63,000. Submitted 2/17/11. Robert Akl (PI), awarded $63,000.

R11. “Game Programming for Xbox 360 Summer Camp” under Texas Higher Education Coordinating Board: Engineering Summer Program. Requested amount is $13,000. Submitted 2/22/10. Robert Akl (PI), awarded $18,000.

R12. “Robotics and Game Programming Summer Camps” under Texas Workforce

Commission: Summer Merit Program. Requested amount is $63,000. Submitted 10/16/09. Robert Akl (PI), awarded $63,000.

R13. “Micro Air Vehicle Design: A Collaborative Undergraduate Project for

Electrical Engineering, Computer Engineering, and Computer Science Students,”



under UNT Undergraduate Research Initiative. Submitted 9/25/2009. Robert Akl (co-PI), awarded $8,000.

R14. “Summer Merit Program” under Texas Workforce Commission. Requested

amount is $42,000. Submitted 3/20/09. Robert Akl (PI), awarded $42,000.

R15. “Robocamp at Stewpot” under Dallas Women's Foundation. Requested amount is $20,000. Submitted 2/23/09. Robert Akl (PI), awarded $18,600.

R16. “Robocamp Jump Start” under Motorola Foundation Innovation Generation

Grant. Requested amount is $29,852. Submitted 2/12/09. Robert Akl (PI), awarded $30,700.

R17. “Engineering Summer Program” under Texas Higher Education Coordinating

Board. Requested amount is $7,944. Submitted 2/13/09. Robert Akl (PI), awarded $11,111.

R18. “Texas Youth in Technology” under Texas Workforce Commission. Requested


R19. “IUCRC Center Proposal: Net-Centric Software and Systems,” under NSF-07-537: Industry/University Cooperative Research Centers. Requested amount is $349,482. Submitted 9/26/08. Krishna Kavi (PI), Robert Akl (co-PI), awarded $60,000 per year for 5 years.

R20. “Robocamp and Beyond” under Motorola Foundation Innovation Generation


R21. Texas Youth in Technology” under Texas Workforce Commission. Requested amount is $30,000. Submitted 2/27/08. Robert Akl (PI), awarded $31,500.

R22. “Robocamp Program for Young Women” under RGK foundation. Requested


R23. “Texas Youth in Technology” under Texas Workforce Commission. Requested amount is $102,514. Submitted 10/22/07. Robert Akl (PI), awarded $102,514.

R24. “Women Art Technology” under Hispanic and Global Studies Initiatives Fund.

Requested amount is $14,125. Submitted 9/30/07. Jennifer Way (PI), Robert Akl (co-PI), awarded $12,785.

R25. “Robocamp Mobile Unit” under Motorola Foundation Innovation Generation




R26. “ICER: UNT Engineering Challenge Camps” under NSF 0547299. Requested amount is $35,000. Submitted 4/27/07. Oscar Garcia (PI), Robert Akl (senior personnel), awarded $32,792.

R27. “IUCRC-Planning Proposal: UNT Research Site Proposal to join Embedded

Systems I/UCRC,” under NSF-01-116: Industry/University Cooperative Research Centers. Requested amount is $10,000. Submitted 3/31/07. Krishna Kavi (PI), Robert Akl (co-PI), awarded $10,000.

R28. “High-assurance NCCS: Ultra Dependability Integration Engineering,”

Department of Defense. Requested amount is $20,000. Submitted 3/12/07. Krishna Kavi (PI), Robert Akl (co-PI), awarded $20,000.

R29. “Recruiting and Retention Strategies for Computer Science at UNT” under Texas

Technology Workforce Development Grant Program – 2005. Requested amount is $163,322. Submitted 3/17/05. Robert Akl (PI), awarded $125,322.

R30. UNT Faculty Research Grant for Fall 2003, Robert Akl (PI), $5,000, awarded

$4,000.

R31. UNT Junior Faculty Summer Research Fellowship for Summer 2003, Robert Akl (PI), $5,000, awarded $5,000.

Professional Associations and Achievements Membership in Professional Organizations

• Senior Member IEEE • Member, Federation Council of North Texas Universities • Member, Eta Kappa Nu Electrical Engineering Honor Society • Member, Golden Key National Honor Society • Member, Tau Beta Pi Engineering Honor Society

Offices and Committee Assignments in Professional Organizations

• Technical Program Committee Member, IEEE Wireless Communications and Networking Conference, IEEE WCNC

• Technical Program Committee Member, International Wireless Symposium, IWS • Technical Program Committee Member, IEEE International Conference on

Computational Science, IEEE ICCS • Technical Program Committee Member, IASTED International Conference on

Wireless Communications, WC • Technical Program Committee Member, WTS Wireless Telecommunications

Symposium • Technical Program Committee Member, Mosharaka International Conference on

Computer Science and Engineering, Amman



• Invitation to serve as an NSF reviewer/panelist for Engineering Research Centers (ERC) proposals

• Technical Program Committee Member, 18th IEEE International Symposium on Personal, Indoor and Mobile Radio Communication, Greece

• International Program Committee, IASTED International Conference on Wireless and Optical Communication, Canada

• Program Committee Member, Fifth Annual Wireless Telecommunications Symposium, CA

• Technical Publications Chair, IEEE Vehicular Technology Conference, Dallas TX • Session Chair, International Conference on Computing, Commun. and Control

Tech., Austin TX • Session Chair, International Conference on Cybernetics and Information

Technologies, Orlando FL • Session Chair, 8th World Multi Conference on Systemics, Cybernetic, and

Informatics, Orlando FL Additional Responsibilities and Activities

• Reviewer, Wireless Communications and Mobile Computing, 2012 – present • Reviewer, Journal of Sensor and Actuator Networks, 2012 – present • Reviewer, IEEE Transactions on Vehicular Technology, 2011 – present • Reviewer, Elsevier Journal of Computers & Electrical Engineering, 2008 –

present • Reviewer, IEEE Globecom, 2007 – present • Reviewer, IEEE International Conference on Advanced Networks and

Telecommunication Systems (ANTS), 2008 – present • Reviewer, The International Wireless Communications and Mobile Computing

Conference, 2007 – present • Reviewer, Journal on Wireless Communications and Networking, 2007 – present • Reviewer, IEEE Transactions on Communications, 2007 - present • Reviewer, International Journal of Communication Systems, 2007 – present • Reviewer, IEEE Communications Magazine, 2005 – present • Reviewer, Journal of Wireless Networks, 2004 – present • Reviewer, IEEE Transactions on Mobile Computing, 2004 – present • Reviewer, IEEE Transactions on Wireless Communications, 2004 – present • Reviewer, ACM Crossroads, 2004 – present

Honors and Awards

• Who's Who in America, 2012 Edition • Winner of Tech Titan of the Future – University Level Award for UNT

Robocamps for Girls, Metroplex Technology Business Council, 2010 with $15,000 cash prize.

• IEEE Professionalism Award, Ft Worth Chapter, 2008 • UNT College of Engineering Outstanding Teacher Award, 2008



• Certificate of Appreciation: IEEE Vehicular Technology Conference, Dallas, TX, 2005

• Certificate of Appreciation: Denton County Boosting Engineering, Science and Technology (BEST) Robotics Competition, 2004

• Summa Cum Laude Graduate, Ranked First in Undergraduate Class • The Computer Science Departmental Award for Academic Excellence,

Washington University, 1993 • The Dual Degree Engineering Award for Outstanding Senior, Washington

University, 1993 • The 1992 Technical Writing Competition Award, The Society for Technical

Communication


Claims 1, 7, 13, and 17 Exemplary Disclosure of Prior Art [1pre]: “A method of communicating in a bi-directional cellular wireless communication system between a base station and a plurality of mobile terminals supporting an emergency warning, the method comprising:” [7pre]: “A mobile terminal configured for operating in a bi-directional cellular wireless communication system having a base station and a plurality of other mobile terminals supporting an emergency warning, the mobile terminal comprising:” [13pre]: “A bi-directional cellular wireless communication system adapted to implement a cell broadcast service and a paging mode, the system comprising: a transmitter configured to broadcast content and transmit at least one paging message to a plurality of mobile terminals in a cell; and the plurality of mobile terminals, each of the plurality of mobile terminals comprising:” [17pre]: “A method of communicating with a plurality of mobile terminals in a bi-directional

Sennett-286 discloses “Systems and methods for providing alerts to end users of networked enabled portable devices are provided so that the end users are made aware when broadcast emergency alerts are issued.” Ex. 1003 at Abstract. Sennett-286 discloses “A Cell Broadcast Center (CBC) 633 communicates cell broadcast messages that are typically delivered to multiple users in a specified area. Cell Broadcast … enables messages to be communicated to multiple mobile phone customers ….” Ex. 1003 at 9:22-28. “The system information messages dictate a MS [mobile station] where to listen for paging messages ….” (claimed “paging message and “paging mode”). Ex. 1003 at 9:58-10:6. Sennett-286’s Base Station Subsystems 400 (claimed “base station” or “transmitter”) is configured to transmit or broadcast content and messages to portable device 20, mobile subscribers 555 or mobile station 602 (claimed “mobile terminals”) capable of receiving paging or emergency messages in a GSM, GPRS, etc. network (claimed “bi-directional cellular wireless communication system”). Ex. 1003 at FIG. 1, 3:25-27; 5:10-34; 7:4-7.


2

Claims 1, 7, 13, and 17 Exemplary Disclosure of Prior Art cellular wireless communication system between a base station and the plurality of mobile terminals, the method comprising: broadcasting, at the base station, content to the plurality of mobile terminals in a cell; transmitting, at the base station, at least one paging message to the plurality of mobile terminals in the cell;” [1A]: “storing, at a mobile terminal of the plurality of mobile terminals, at least two specific identifiers common to the plurality of mobile terminals, the at least two specific identifiers being for different types of emergencies;” [7A]: “a memory unit configured to store at least two specific identifiers common to the plurality of other mobile terminals, the at least two specific identifiers being for different types of emergencies;” [13A]: “a memory unit configured to store at least two specific identifiers supporting an emergency warning, the at least two specific identifiers being

Sennett-286 discloses receiving and storing information indicative of “occurrence” and “relevance” of an emergency broadcast. Ex. 1003 at Claims 8-10, 12-13. Sennett-286 discloses storage device 22 (FIG. 1) and Subscriber Identify Module (SIM; Ex. 1003 at 8:14-19) (claimed “memory unit”) that store subscriber identifiers, “emergency broadcast information”, and emergency alert messages (claimed “paging message”) “via an SMS message, control channel, or data channel.” Ex. 1003 at 3:4-10; 3:50-52. The emergency broadcast information can include, e.g.:

(A) information about available broadcast technologies (e.g., Cell Broadcast, MBMS, DVB-H, MediaFLO, etc.), (B) information concerning which broadcast technologies or network(s), such as broadcast network 60, are specifically supported by the device 20, (C) information about emergency broadcast channels associated with each available broadcast technology, or a combination thereof.

Ex. 1003 at 3:54-62.


3

Claims 1, 7, 13, and 17 Exemplary Disclosure of Prior Art for different types of emergencies;” [17A]: “storing, at one of the plurality of mobile terminals, at least two specific identifiers common to the plurality of mobile terminals supporting an emergency warning, the at least two specific identifiers being for different types of emergencies;”

Sennett-286 discloses “the telephony radio network 30 informs the telephony processor 24 of portable device 20 that an emergency alert message is being broadcast, e.g., using a pre-defined, standardized indicator bit on at least one telephony network control channel, an SMS message, a data channel if available, or the like.” Ex. 1003 at 4:10-15. Sennett-286’s invention is directed to “notification and reporting of emergency alerts, such as those issued by the Emergency Alert System ("EAS"), to networked portable devices” Ex. 1003 at 1:22-25. Sennett-286’s Abstract states “In various embodiments, a portable device is enabled to receive information about an emergency alert broadcast of which the user should be aware, e.g., from the EAS, and to notify the user of the emergency alert.” Sennett-280 has the same inventors as Sennett-286. Similar to Sennett-286, Sennett-280’s invention is directed to “broadcast of Emergency Alert System (EAS) notifications and messages.” Ex. 1005 at 1:16-17. Both Sennett-286 and Sennett-280 have the same inventors, are in the same field of endeavor, and disclose the same telephony radio networks and operating environments for the EAS alert reporting services of the notification system for alerting users of portable devices of emergencies. (Compare Figures 4-6 and 5:10-10:67 of Ex. 1003 with Figures 8-10 and 11:39-17:26 of Ex. 1003.) A POSITA would look to Sennett-280 to implement the “notification and reporting of emergency alerts, such as those issued by the Emergency Alert System ("EAS"), to networked portable devices” (Ex. 1003


4

Claims 1, 7, 13, and 17 Exemplary Disclosure of Prior Art at 1:22-25) of Sennett-286. Sennett-280 discloses selective processing of broadcast emergency messages based on user preferences:

A subscriber is provided the capability to tailor the type of EAS alerts to be received, the time period, or periods, during which EAS alerts can be received, and actions to be taken with respect to received alerts. … In an example embodiment, an enhanced emergency alert message contains parameters indicative of the type of alert. The parameters are used to allow the subscriber to configure the reception of the alert tailored to the subscriber's preferences.

Ex. 1005 at 1:50-58; emphasis added. Sennett-280 discloses an enhanced EAS message that includes parameters, which indicate various types of emergencies: “In an example embodiment, an EAS message, referred to as an enhanced EAS message, comprises a parameter, or parameters, indicative of the type of alert, such as for example, weather, AMBER, government issued, geophysical e.g., landslide, meteorological, e.g., flood, general emergency and public safety, ….” Ex. 1005 at 2:43-55; emphasis added. Sennett-280 discloses storing the type of emergency alert in the user preferences: “A subscriber can indicate which types of alerts are to be ignored, which types of alerts are to be saved for subsequent review, and which alerts are to be rendered (e.g., visual, audio, mechanical) via the mobile device.” Ex. 1005 at 2:64-67; emphasis added; and “The EAS processor 34 contains therein, preferences, or instructions, previously provided, by the subscriber, for example. The EAS processor 34, upon extracting the parameters from the


5

Claims 1, 7, 13, and 17 Exemplary Disclosure of Prior Art enhanced alert message, processes the emergency alert message in accordance with the predetermined instructions, or rules, and the extracted parameters.” Ex. 1005 at 4:27-33; emphasis added. Sennett-280’s parameters are analyzed and compared with stored user preferences: “In one embodiment, the parameters are in a header of the enhanced EAS message. Upon receipt, by a mobile device or the like, the header is analyzed to determine the type of alert, and the message is handled in accordance with the type of alert and instructions provided to the mobile device.” Ex. 1005 at 2:56-61; emphasis added. A POSITA would understand that the user preferences, instructions, or rules are stored in the mobile device in order for the processor to determine which type of emergency alert to display according to user preferences. [Cite to Akl Declaration.] A POSITA would further understand that the “non-exhaustive, non-limiting, types of emergency alerting information” stored in the user device database of Sennett-286 (4:20-22) can include the EAS information in accordance with the objective of Sennett-286, which is “notification and reporting of emergency alerts, such as those issued by the Emergency Alert System ("EAS"), to networked portable devices.” Ex. 1003 at 1:21-25. Additionally, a POSITA would understand the storage of EAS information can include storage of the parameters indicating which types of emergencies the user prefers to receive.

[1B]: “checking, by the mobile terminal, whether a paging message received from the base station

Sennett-286 discloses: In an example embodiment, the notification system adds an emergency alert indicator bit on control channel(s) of a telephony network with


6

Claims 1, 7, 13, and 17 Exemplary Disclosure of Prior Art includes at least one specific identifier of the at least two specific identifiers;” [7B]: “a control unit configured to: check whether a paging message received from the base station includes at least one specific identifier of the at least two specific identifiers;” [13B]: “a control unit configured to: check whether the at least one paging message received from the transmitter includes at least one specific identifier of the at least two specific identifiers;” [17B]: “checking, by the one of the plurality of mobile terminals, whether the at least one paging message received from the base station includes at least one specific identifier of the at least two specific identifiers;”

which the device communicates. When the user device detects the setting of the emergency alert indicator bit on the control channel(s) that it is monitoring, the user device is able to immediately lead the user to the emergency information, or instruct the user with pre-provisioned information about the emergency alert, and any associated broadcast channels that contain the emergency alert.

Ex. 1003 at 2:54-62 (emphasis added). Further, Sennett-286 discloses an emergency alert message (claimed “paging message”):

In another example embodiment, a message is received, e.g., via an SMS message, control channel, or data channel, which modifies a storage location, e.g., a bit, on the user device when the message is processed. Thus, when modified, the storage location indicates that an emergency alert has been issued that is intended for the user, and the user is notified.

Ex. 1003 at 3:4-10. Sennett-286 discloses:

… means for determining, in accordance with the received information, whether the emergency broadcast is relevant; means for retrieving a least a subset of the stored emergency broadcast information if it is determined that the emergency broadcast is relevant; a broadcast processor that automatically tunes to the emergency broadcast upon determining that the emergency broadcast is relevant; ….

Ex. 1003 at Claim 8 (emphasis added). Sennett-286 also discloses “At step 220, the telephony radio network 30 informs the telephony processor 24 of portable device 20 that an emergency alert message is being broadcast, e.g., using a pre-


7

Claims 1, 7, 13, and 17 Exemplary Disclosure of Prior Art defined, standardized indicator bit on at least one telephony network control channel, an SMS message, a data channel if available, or the like.” Ex. 1003 at 4:10-15 (emphasis added). Sennett-280 discloses: “At step 42, upon receipt of the broadcast message (e.g., received by the broadcast processor 32 of the mobile device 38), the received message is analyzed to determine if the message comprises a parameter indicative of a characteristic of the emergency alert.” Ex. 1005 at 5:57-63; FIG. 2. A POSITA would understand Sennett-286’s “means for determining … whether the emergency broadcast is relevant” could include analyzing Sennett-280’s enhanced EAS message, which includes parameters indicative of the types of emergencies.

[1C]: “switching, by the mobile terminal, to a broadcast mode for receiving broadcast content on a broadcast channel when the received paging message includes the at least one specific identifier of the at least two specific identifiers;” [7C]: “switch to a broadcast mode for receiving broadcast content on a broadcast channel when the paging message received from the base station includes the at least one specific identifier of the at least two specific identifiers;” [13C]: “switch to a

Sennett-286 discloses: In various embodiments, a portable device is enabled to receive information about an emergency alert broadcast of which the user should be aware, e.g., from the EAS, and to notify the user of the emergency alert. The user can be automatically taken to the emergency alert information by having the portable device automatically tune to the emergency broadcast information, ….

Ex. 1003 at Abstract. Further, Sennett-286 discloses:

For example, special alert tones may be activated and special display graphics, symbols, text, etc. may be portrayed on a display of the user device 20 that inform the user that an emergency broadcast is being sent and to which channel or channels the user should tune for the emergency broadcast. In a non-limiting embodiment, a programmed soft key (or hardware control) may


8

Claims 1, 7, 13, and 17 Exemplary Disclosure of Prior Art broadcast support mode for receiving the content transmitted by the transmitter on a broadcast channel when the at least one paging message transmitted by the transmitter includes the at least one specific identifier of the at least two specific identifiers;” [17C]: “switching, by the one of the plurality of mobile terminals, to a broadcast mode for receiving broadcast content on a broadcast channel when the received paging message includes the at least one specific identifier of the at least Iwo specific identifiers;”

be provided for the end user to access the emergency broadcast immediately, or, optionally, subsequent to receiving notification, the user device 20 may automatically tune to the emergency broadcast.

Ex. 1003 at 4:34-44 (emphasis added); See also Ex. 1003 at Claim 8. Also, Sennett-286 discloses:

In FIG. 3, at step 300, the broadcast network(s) 60 receives an emergency alert from the emergency alert network 50, such as the EAS. At step 310, the broadcast network starts broadcasting the received emergency alert. At step 320, whether activation occurs automatically or optionally at the behest of a user that has been notified of the alert (e.g., via the process depicted in FIG. 2), the associated emergency broadcast channel of the user device 20 is activated.

Ex. 1003 at 4:51-59 (emphasis added).

[1D]: “establishing, by the mobile terminal, at least one of a physical channel and a logical channel when the received paging message includes a mobile terminal identifier allocated to the mobile terminal.” [7D]: “establish at least one of a physical channel and a logical channel when the received paging message includes a mobile terminal identifier allocated to the mobile terminal.”

[13D]: “establish at least one of a physical channel

Both Sennett-286 and Sennett-280 disclose the same exemplary telephony radio networks and operating environments for the EAS alert reporting services for alerting users of portable devices of emergencies. Sennett-286 discloses storing the IMSI (claimed “mobile terminal identifier”) in the SIM of the mobile device:

The MS 602 is physical equipment or Mobile Equipment (ME), such as a mobile phone or a laptop computer (e.g., portable device 20) that is used by mobile subscribers, with a Subscriber identity Module (SIM). The SIM includes an International Mobile Subscriber Identity [IMSI], which is a unique identifier of a subscriber.

Ex. 1003 at 8:14-19 (emphasis added); see also Ex.


9

Claims 1, 7, 13, and 17 Exemplary Disclosure of Prior Art and a logical channel when the received paging message includes a mobile terminal identifier allocated to the mobile terminal.” [17D]: “establishing, by the one of the plurality of mobile terminals, at least one of a physical channel and a logical channel when the received paging message includes a mobile terminal identifier allocated to the one of the plurality of mobile terminals.”

1005 at 14:38-43. The ‘129 patent admits that "terminals receive a TMSI derived from the international mobile subscriber identity, IMSI" (Ex. 1001 at 4:16-17); and that “3GPP TS 23.003 V7.1.0 (2006 September), chapter 2 defines actually valid subscriber identities such as IMSI, TMSI or P-TMSI.” Ex. 1001 at 4:25-27. The ’129 patent also admits that it was “customary” for a base station to send a terminal a TMSI (the claimed “temporary mobile subscriber identity”) in a paging message, and when the terminal detected the TMSI in the paging message, the terminal would establish a physical and/or logical channel. The ‘129 patent discloses:

When the terminal detects, in step S52 that the TMSI in the paging message corresponds to the temporary TMSI allocated from the network to the terminal, the process proceeds to step S53 wherein the terminal establishes a physical and/or logical channel in the customary manner.

Ex. 1001 at 3:41-46. Sennett-286 discloses “To gain access to GSM services, such as speech, data, and short message service (SMS), the MS first registers with the network to indicate its current location by performing a location update and IMSI attach procedure.” Ex. 1003 at 9:1-4 (emphasis added); see also Ex. 1005 at 15:26-29. Sennett-286 also discloses “The HLR 574 is a centralized database for users to register to the GPRS network. HLR 574 stores static information about the subscribers such as the International Mobile Subscriber Identity ("IMSI"), subscribed


10

Claims 1, 7, 13, and 17 Exemplary Disclosure of Prior Art services, and a key for authenticating the subscriber.” Ex. 1003 at 6:61-65 (emphasis added); see also Ex. 1005 at 13:20-24. Sennett-286 also discloses “When a mobile subscriber turns on his or her mobile device, the mobile device goes through an attach process by which the mobile device attaches to an SGSN of the GPRS network. … The SGSN 576 queries another SGSN, to which mobile subscriber 555 was attached before, for the identity of mobile subscriber 555.” Ex. 1003 at 7:7-16 (emphasis added); see also Ex. 1005 at 13:33-42. Sennett-286 further discloses establishing a user session (i.e., a point-to-point communication of the ‘129 Patent) by the mobile device: “Next, the mobile subscriber 555 establishes a user session with the destination network, corporate network 589, by going through a Packet Data Protocol ("PDP") activation process.” Ex. 1003 at 7:40-43; see also Ex. 1005 at 13:66-14:2.

Claims 2, 8, 14, and 18 Exemplary Disclosure of Prior Art [2] “The method of claim 1, wherein the mobile terminal identifier is at least one of a temporary mobile subscriber identity, an international mobile subscriber identify, and a packet temporary mobile subscriber identity.” [8] “The mobile terminal of claim 7, wherein the mobile terminal identifier is at least one of a temporary mobile subscriber identity, an

Both Sennett-286 and Sennett-280 disclose the same exemplary telephony radio networks and operating environments for the EAS alert reporting services of the notification system for alerting users of portable devices of emergencies. Sennett-286 discloses:

The MS 602 is physical equipment or Mobile Equipment (ME), such as a mobile phone or a laptop computer (e.g., portable device 20) that is used by mobile subscribers, with a Subscriber identity Module (SIM). The SIM includes an International Mobile Subscriber Identity [IMSI], which is a unique identifier of a subscriber.


11

Claims 2, 8, 14, and 18 Exemplary Disclosure of Prior Art international mobile subscriber identify, and a packet temporary mobile subscriber identity.” [14] “The system of claim 13, wherein the mobile terminal identifier is at least one of a temporary mobile subscriber identity, an international mobile subscriber identify, and a packet temporary mobile subscriber identity.” [18] “The method of claim 17, wherein the mobile terminal identifier is at least one of a temporary mobile subscriber identity, an international mobile subscriber identify, and a packet temporary mobile subscriber identity.”

Ex. 1003 at 8:14-19 (emphasis added); see also Ex. 1005 at 14:38-43. Sennett-286 discloses “To gain access to GSM services, such as speech, data, and short message service (SMS), the MS first registers with the network to indicate its current location by performing a location update and IMSI attach procedure.” Ex. 1003 at 9:1-4 (emphasis added); see also Ex. 1005 at 15:26-29. Sennett-286 also discloses “The HLR 574 is a centralized database for users to register to the GPRS network. HLR 574 stores static information about the subscribers such as the International Mobile Subscriber Identity ("IMSI"), subscribed services, and a key for authenticating the subscriber.” Ex. 1003 at 6:61-65 (emphasis added); see also Ex. 1005 at 13:20-24.

Claims 3 and 9 Exemplary Disclosure of Prior Art [3] “The method of claim 1, wherein the broadcast mode is a GSM cell-broadcast mode.” [9] “The mobile terminal of claim 7, wherein the broadcast mode is a GSM cell-broadcast mode.”

Sennett-286 discloses “To gain access to GSM services, such as speech, data, and short message service (SMS), the MS first registers with the network to indicate its current location by performing a location update and IMSI attach procedure.” Ex. 1003 at 9:1-4 (emphasis added); see also Ex. 1005 at 15:26-29. “A Cell Broadcast Center (CBC) 633 communicates cell broadcast messages that are typically delivered to multiple users in a specified area. Cell Broadcast … enables messages to be communicated to multiple mobile phone customers ….” Ex. 1003 at 9:22-28; Ex. 1005 at 15:47-53.


12

Claims 4 and 10 Exemplary Disclosure of Prior Art [4] “The method of claim 1, wherein the mobile terminal notifies and/or displays to a user of the mobile terminal the broadcast content.” [10] “The mobile terminal of claim 7, further comprising: an acoustical unit configured to announce the broadcast content; and a display unit configured to display the broadcast content.”

Sennett-286 discloses “the telephony processor 24 interacts with the user interface 28 of the user device 20 to inform the end user that an emergency alert is being broadcast. The user interface 28 is not limited to display of information, however. Any known output device for a user device 20 may be utilized, whether visual, auditory and/or mechanical in operation. For example, special alert tones may be activated and special display graphics, symbols, text, etc. may be portrayed on a display of the user device 20 that inform the user that an emergency broadcast is being sent and to which channel or channels the user should tune for the emergency broadcast” Ex. 1003 at 4:29-39 (emphasis added).

Claims 5, 11, 15, and 19 Exemplary Disclosure of Prior Art [5] “The method of claim 1, wherein a duration of the broadcast mode is dependent on the at least one specific identifier of the at least two specific identifiers.” [11] “The mobile terminal of claim 7, wherein a duration of the broadcast mode is dependent on the at least one specific identifier of the at least two specific identifiers.” [15] “The system of claim 13, wherein a duration of the broadcast mode is dependent on the at least one specific identifier of the at least two specific identifiers.”

Sennett-280 discloses “The message is processed in accordance with the preconfigured instructions and the characteristics pertaining to the message. A user of the mobile device can tailor the type of EAS alerts to be received, the time period, or periods, during which EAS alerts can be received, and actions to be taken with respect to received alerts.” Ex. 1005 at Abstract (emphasis added). Sennett-280 also discloses “processing the received broadcast emergency alert message in accordance with predetermined instructions that define how to process the received broadcast emergency alert message based on the at least one parameter and a user-defined time frame in which the broadcast emergency alert message is received.” Ex. 1005 at Claim 1 (emphasis added). Sennett-280 further discloses:

A subscriber is provided the capability to tailor the type of EAS alerts to be received, the time


13

Claims 5, 11, 15, and 19 Exemplary Disclosure of Prior Art [19] “The method of claim 17, wherein a duration of the broadcast mode is dependent on the al least one specific identifier of the al least two specific identifiers.”

period, or periods, during which EAS alerts can be received, and actions to be taken with respect to received alerts. The subscriber can select any combination of type, time, and/or action. In an example embodiment, an enhanced emergency alert message contains parameters indicative of the type of alert. The parameters are used to allow the subscriber to configure the reception of the alert tailored to the subscriber's preferences.

Ex. 1005 at 1:50-58.

Claims 6, 12, 16, and 20 Exemplary Disclosure of Prior Art [6] “The method of claim 5 wherein the duration of the broadcast mode is for an indefinite length of time or for a limited duration of time based on the at least one specific identifier of the at least two specific identifiers.” [12] “The mobile terminal of claim 11, wherein the duration of the broadcast mode is for an indefinite length of time or for a limited duration of time based on the at least one specific identifier of the at least two specific identifiers.” [16] “The system of claim 15, wherein the duration of the broadcast mode is for an indefinite length of time or for a limited duration of time based on the at least one specific identifier of the at least two specific

Sennett-280 discloses “The message is processed in accordance with the preconfigured instructions and the characteristics pertaining to the message. A user of the mobile device can tailor the type of EAS alerts to be received, the time period, or periods, during which EAS alerts can be received, and actions to be taken with respect to received alerts.” Ex. 1005 at Abstract (emphasis added). Sennett-280 also discloses “processing the received broadcast emergency alert message in accordance with predetermined instructions that define how to process the received broadcast emergency alert message based on the at least one parameter and a user-defined time frame in which the broadcast emergency alert message is received.” Ex. 1005 at Claim 1 (emphasis added). Sennett-280 further discloses:

A subscriber is provided the capability to tailor the type of EAS alerts to be received, the time period, or periods, during which EAS alerts can be received, and actions to be taken with respect to received alerts. The subscriber can select any combination of type, time, and/or action. In an example embodiment, an enhanced emergency alert message contains parameters indicative of


14

Claims 6, 12, 16, and 20 Exemplary Disclosure of Prior Art identifiers.” [20] “The method of claim 19, wherein the duration of the broadcast mode is for an indefinite length of time or for a limited duration of time based on the at least one specific identifier of the at least two specific identifiers.”

the type of alert. The parameters are used to allow the subscriber to configure the reception of the alert tailored to the subscriber's preferences.

Ex. 1005 at 1:50-58.


Claims 1, 7, 13, and 17 Exemplary Disclosure of Prior Art [1pre]: “A method of communicating in a bi-directional cellular wireless communication system between a base station and a plurality of mobile terminals supporting an emergency warning, the method comprising:” [7pre]: “A mobile terminal configured for operating in a bi-directional cellular wireless communication system having a base station and a plurality of other mobile terminals supporting an emergency warning, the mobile terminal comprising:” [13pre]: “A bi-directional cellular wireless communication system adapted to implement a cell broadcast service and a paging mode, the system comprising: a transmitter configured to broadcast content and transmit at least one paging message to a plurality of mobile terminals in a cell; and the plurality of mobile terminals, each of the plurality of mobile terminals comprising:” [17pre]: “A method of

Collins discloses: The present invention is a novel and improved method for providing broadcast short message services (SMS) in a communication network. It is an objective of the present invention to provide a method and apparatus that insures the successful transmission of the broadcast message while minimizing the impact of providing the short messaging service on overall system capacity. It is further the objective of the present invention to provide a method and apparatus for receiving broadcast messages without depriving the receiver of the benefit of reduced power consumption gained by slotted paging.

Ex. 1007 at 2:16-27. Collins further discloses:

The broadcast messages are then broadcast by central communication center 10 to subscriber stations 12, 14 and 16. Subscriber stations 12, 14 and 16 receive the broadcast messages and selectively provide the messages to the subscriber station user. In the exemplary embodiment, the signals are transmitted by the central communication center 10 to subscriber stations 12, 14 and 16 in accordance with a CDMA communication format as detailed in the US. Pat. Nos. 4,901,307 and 5,103,459, both assigned to the assignee of the present invention.

Ex. 1007 at FIG. 1, 4:7-16. Collins’ central communication center 10 (claimed “base station” or “transmitter”) is configured to transmit or broadcast content and messages to subscriber stations 12, 14, and 16 (claimed “mobile terminals”) capable of receiving paging or emergency messages in a CDMA network (claimed “bi-directional cellular wireless communication system”). Id.


2

Claims 1, 7, 13, and 17 Exemplary Disclosure of Prior Art communicating with a plurality of mobile terminals in a bi-directional cellular wireless communication system between a base station and the plurality of mobile terminals, the method comprising: broadcasting, at the base station, content to the plurality of mobile terminals in a cell; transmitting, at the base station, at least one paging message to the plurality of mobile terminals in the cell;”

Collins discloses “paging message”: e.g., “a broadcast page is provided on every paging channel and in every slot in a predetermined maximum slot cycle. The broadcast page advertises a forthcoming broadcast message to all subscriber stations.” Ex. 1007 at 2:43-46. Collins further discloses

It may be desirable to provide paging using a combination of the abovementioned techniques. For example it may be desirable to employ a more efficient broadcast paging method in general situations, but to provide an explicit page on all slots in a broadcast cycle in the event of an emergency message.

Ex. 1007 at 12:34-39. Karl discloses that its invention can operate within CDMA networks, 3G networks (e.g., CDMA2000-1x, WCDMA, or UMTS), and GPRS networks, among others. Ex. 1008 at 2:16-3:54; Ex. 1009 at 10. Karl discloses multiple user devices for its networks, such as mobile phone 36 and E-FOB 38, constituting the claimed “mobile terminals.” See Ex. 1008 at FIG. 1. For example, Karl discloses:

The emergency notification system 20 provides a quick method for delivering emergency messages to a large number of mobile and static devices of different types in a localized area.

Ex. 1008 at 4:12-15; Ex. 1009 at 5-6.

[1A]: “storing, at a mobile terminal of the plurality of mobile terminals, at least two specific identifiers common to the plurality

Collins discloses: Decoder 56 decodes the broadcast page and provides the decoded broadcast page to page receive controller 62. Page receive controller 62 determines in accordance with a predetermined set of user preferences if the forthcoming


3

Claims 1, 7, 13, and 17 Exemplary Disclosure of Prior Art of mobile terminals, the at least two specific identifiers being for different types of emergencies;” [7A]: “a memory unit configured to store at least two specific identifiers common to the plurality of other mobile terminals, the at least two specific identifiers being for different types of emergencies;” [13A]: “a memory unit configured to store at least two specific identifiers supporting an emergency warning, the at least two specific identifiers being for different types of emergencies;” [17A]: “storing, at one of the plurality of mobile terminals, at least two specific identifiers common to the plurality of mobile terminals supporting an emergency warning, the at least two specific identifiers being for different types of emergencies;”

broadcast message will be of interest to the subscriber station user.

Ex. 1007 at 7:40-44; 8:54-59 (emphasis added). A POSITA would understand Collins’ “predetermined set of user preferences” must be stored in the mobile device to allow processing of the broadcast message. Karl discloses:

Processor instructions may be stored in a flash memory device 66 which define how broadcast messages should be processed. The process includes determination of the level of the emergency. For example, a high level warning requiring the user to take shelter and/or terrorist alert may activate a red LED.

Ex. 1008 at 7:3-8; Ex. 1009 at 9-10. Further, Karl discloses EAS event codes (which are the same event codes disclosed in FCC 94-288 (Ex. 1011)). For example, Karl discloses:

“EEE” is the Event code which indicates the nature of the EAS activation. The event codes are compatible with the codes used by the National Weather Service (NWS) Weather Radio Specific Area Message Encoder (WRSAME). There are over 30 Event codes such as EAN— Emergency Action Notification (National only); TOR—Tornado Warning; HUW—Hurricane Warning; and TSW—Tsunami Warning, for example.

Ex. 1008 at 4:45-52; Ex. 1009 at 6-7; see also Ex. 1011 at 83-84. Collins’ disclosure pertains to CDMA systems. Ex. 1007 at FIG. 2, 4:3-16. Karl discloses that its techniques can be implemented in CDMA systems. Ex. 1008 at 6:53-67. Collins’ broadcast handle is meant to “specif[y] the


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Claims 1, 7, 13, and 17 Exemplary Disclosure of Prior Art nature of the corresponding broadcast message.” Ex. 1007 at 3:40-41; 6:25-28.

Collins’ broadcast handle can include a “function code” which “indicates the subject matter of the message.” Ex. 1007 at 12:8-12. Collins discloses:

Furthermore, the broadcast page contains a broadcast handle that specifies the nature of the corresponding broadcast message. This broadcast message may contain information as to the source of the message, the function of the message, the language in which the message is provided and a sequence number. The broadcast handle provides sufficient information to allow the subscriber station to determine whether or not to receive the related broadcast message.

Ex. 1007 at 3:40-48 (emphasis added). [1B]: “checking, by the mobile terminal, whether a paging message received from the base station includes at least one specific identifier of the at least two specific identifiers;” [7B]: “a control unit configured to: check whether a paging message received from the base station includes at least one specific identifier of the at least two specific identifiers;” [13B]: “a control unit configured to: check whether the at least one paging message received from the transmitter includes at least one

Collins discloses: In a slotted paging system, the subscriber station ‘wakes up’ or ‘powers up’ at predetermined time intervals, referred to as slot cycles, to monitor its assigned paging channel for traffic pages.

Ex. 1007 at 4:66-5:2. Further, Collins discloses:

Furthermore, the broadcast page contains a broadcast handle that specifies the nature of the corresponding broadcast message. This broadcast message may contain information as to the source of the message, the function of the message, the language in which the message is provided and a sequence number. The broadcast handle provides sufficient information to allow the subscriber station to determine whether or not to receive the related broadcast message.

Ex. 1007 at 3:40-48 (emphasis added). Also, Collins discloses:

Page receive controller 62 determines in


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Claims 1, 7, 13, and 17 Exemplary Disclosure of Prior Art specific identifier of the at least two specific identifiers;” [17B]: “checking, by the one of the plurality of mobile terminals, whether the at least one paging message received from the base station includes at least one specific identifier of the at least two specific identifiers;”

accordance with a predetermined set of user preferences if the forthcoming broadcast message will be of interest to the subscriber station user.

Ex. 1007 at 7:40-44; 8:54-59. As noted above, Karl discloses EAS event codes (Ex. 1008 at 4:45-52) that are the same event codes described in FCC 94-288 (Ex. 1011 at 83-84) and can be implemented in the broadcast handle of Collins.

[1C]: “switching, by the mobile terminal, to a broadcast mode for receiving broadcast content on a broadcast channel when the received paging message includes the at least one specific identifier of the at least two specific identifiers;” [7C]: “switch to a broadcast mode for receiving broadcast content on a broadcast channel when the paging message received from the base station includes the at least one specific identifier of the at least two specific identifiers;” [13C]: “switch to a broadcast support mode for receiving the content transmitted by the transmitter on a broadcast channel when the at least

Collins discloses: If page receive controller 62 determines that the forthcoming broadcast message will be of interest to the subscriber station user, then it generates signals to receive the broadcast message. Page receive controller 62 determines the slot in which the broadcast message will be provided. The slot containing the broadcast message may be extracted from the broadcast page or determined in accordance with a deterministic algorithm. Page receive controller 62 provides a slot timing signal to receiver 52 that cause the receiver to monitor the paging channel at the time appropriate for receiving the broadcast message.

Ex. 1007 at 7:48-56; 8:60-9:4 (emphasis added). Further, Collins discloses:

[T]he broadcast page contains a broadcast handle that specifies the nature of the corresponding broadcast message . . . The broadcast handle provides sufficient information to allow the subscriber station to determine whether or not to receive the related broadcast message.

Ex. 1007 at 3:40-48. In particular, the broadcast handle includes a “function code [that] indicates the subject matter of the


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Claims 1, 7, 13, and 17 Exemplary Disclosure of Prior Art one paging message transmitted by the transmitter includes the at least one specific identifier of the at least two specific identifiers;” [17C]: “switching, by the one of the plurality of mobile terminals, to a broadcast mode for receiving broadcast content on a broadcast channel when the received paging message includes the at least one specific identifier of the at least two specific identifiers;”

message.” Ex. 1007 at 12:11-12. Collins also discloses:

In the exemplary embodiment, the broadcast page consists essentially of two fields. The first field referred to as the broadcast handle is used by the subscriber station to discriminate between those messages that it wishes to receive and those that it does not. The second field is referred to as the delivery vector and as described previously tells the subscriber station to which channel and sub-band to tune and in which slot to receive the corresponding broadcast message.

Ex. 1008 at 11:66-12:7 (emphasis added). As noted above, Karl discloses EAS event codes (Ex. 1008 at 4:45-52) that are the same event codes described in FCC 94-288 (Ex. 1011 at 83-84) and can be implemented in the broadcast handle of Collins.

[1D]: “establishing, by the mobile terminal, at least one of a physical channel and a logical channel when the received paging message includes a mobile terminal identifier allocated to the mobile terminal.” [7D]: “establish at least one of a physical channel and a logical channel when the received paging message includes a mobile terminal identifier allocated to the mobile terminal.”

[13D]: “establish at least one of a physical channel

Collins discloses “subscriber station identification” (the claimed “mobile terminal identifier”) and establishing point-to-point communications:

Typically, when a subscriber station registers with the central communications center, the central communications center informs the subscriber station which paging channel of the plurality of available paging channels to monitor. When the central communications center needs to set up a point to point communication with a subscriber station it transmits a traffic page on the paging channel being monitored by the subscriber station. The traffic page would typically comprise subscriber station identification information and traffic channel identification information. In response to the received traffic page, the identified subscriber station would prepare to conduct point to point communications on the identified traffic channel.

Ex. 1007 at 1:26-39; emphasis added.


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Claims 1, 7, 13, and 17 Exemplary Disclosure of Prior Art and a logical channel when the received paging message includes a mobile terminal identifier allocated to the mobile terminal.” [17D]: “establishing, by the one of the plurality of mobile terminals, at least one of a physical channel and a logical channel when the received paging message includes a mobile terminal identifier allocated to the one of the plurality of mobile terminals.”

The ‘129 patent distinguishes between point-to-point connection and broadcast reception mode: “the terminals are adapted to switch to the broadcast reception mode when detecting the specific identifier in the paging message, instead of establishing a point to point connection” (Ex. 1001 at 5:10-12); and “When a mobile receives a valid E-TMSI, it does not establish a PtP [Point-to-Point] connection. Instead it switches to Cell-Broadcast mode and starts to monitor the Cell-Broadcast Notification channels for emergency information contents.” (Ex. 1001 at 5:20-24; emphasis added). The ’129 patent also admits that it was “customary” for a base station to send a terminal a TMSI (“temporary mobile subscriber identity”) in a paging message, and when the terminal detected the TMSI in the paging message, the terminal would establish a physical and/or logical channel. The ‘129 patent discloses:

When the terminal detects, in step S52 that the TMSI in the paging message corresponds to the temporary TMSI allocated from the network to the terminal, the process proceeds to step S53 wherein the terminal establishes a physical and/or logical channel in the customary manner.

Ex. 1001 at 3:41-46. The ‘129 patent admits that "terminals receive a TMSI derived from the international mobile subscriber identity, IMSI" (Ex. 1001 at 4:16-17); and that “3GPP TS 23.003 V7.1.0 (2006 September), chapter 2 defines actually valid subscriber identities such as IMSI, TMSI or P-TMSI.” Ex. 1001 at 4:25-27. Collins discloses slotted paging (Ex. 1007 at 1:42-61) and the ‘129 patent admits that IMSI allows for slotted


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Claims 1, 7, 13, and 17 Exemplary Disclosure of Prior Art paging:

The use of the IMSI allows a staggering of the terminals to be paged into 10 groups, allowing for large DRX cycles. In GSM ten paging groups exist so that only 10% (derived from the IMSI) of all terminals in a cell sending the paging message listen to a paging message.

Ex. 1001 at 4:17-22.

Claims 2, 8, 14, and 18 Exemplary Disclosure of Prior Art [2] “The method of claim 1, wherein the mobile terminal identifier is at least one of a temporary mobile subscriber identity, an international mobile subscriber identify, and a packet temporary mobile subscriber identity.” [8] “The mobile terminal of claim 7, wherein the mobile terminal identifier is at least one of a temporary mobile subscriber identity, an international mobile subscriber identify, and a packet temporary mobile subscriber identity.” [14] “The system of claim 13, wherein the mobile terminal identifier is at least one of a temporary mobile subscriber identity, an international mobile subscriber identify, and a packet

The ‘129 patent admits “3GPP TS 23.003 V7.1.0 (2006 September) [“TS 23.003”], chapter 2 defines actually valid subscriber identities such as IMSI, TMSI or P-TMSI.” Ex. 1001 at 4:25-27. TS 23.003 discloses “A unique International Mobile Subscriber Identity (IMSI) shall be allocated to each mobile subscriber in the GSM/UMTS system.” (Ex. 1015 at 10.) TS 23.003 further discloses:

In order to support the subscriber identity confidentiality service the VLRs and SGSNs may allocate Temporary Mobile Subscriber Identities (TMSI) to visiting mobile subscribers. The VLR and SGSNs must be capable of correlating an allocated TMSI with the IMSI of the MS [Mobile Subscriber] to which it is allocated.

Id. A POSITA would understand that every mobile subscriber in a wireless network such as a GSM or CDMA network must include an IMSI. Collins discloses “subscriber station identification” (the claimed “temporary mobile subscriber identity allocated to the terminal”) and establishing point-to-point communications:


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Claims 2, 8, 14, and 18 Exemplary Disclosure of Prior Art temporary mobile subscriber identity.” [18] “The method of claim 17, wherein the mobile terminal identifier is at least one of a temporary mobile subscriber identity, an international mobile subscriber identify, and a packet temporary mobile subscriber identity.”

Typically, when a subscriber station registers with the central communications center, the central communications center informs the subscriber station which paging channel of the plurality of available paging channels to monitor. When the central communications center needs to set up a point to point communication with a subscriber station it transmits a traffic page on the paging channel being monitored by the subscriber station. The traffic page would typically comprise subscriber station identification information and traffic channel identification information. In response to the received traffic page, the identified subscriber station would prepare to conduct point to point communications on the identified traffic channel.

Ex. 1007 at 1:26-39; emphasis added.

Claims 3 and 9 Exemplary Disclosure of Prior Art [3] “The method of claim 1, wherein the broadcast mode is a GSM cell-broadcast mode.” [9] “The mobile terminal of claim 7, wherein the broadcast mode is a GSM cell-broadcast mode.”

The ‘129 patent admits “an existing broadcast service can be used such as the GSM Cell-Broadcast Service which is an SMS type broadcast service and delivers in one session the notification and the message content.” Ex. 1001 at 1:46-55. Karl discloses:

Currently GSM/GPRS covers most population centers in the U.S. CDMA2000-1x is rapidly expanding and may soon cover more area than GSM. . . . GSM technology, because of its world wide use, is probably the cheapest to implement. However, CDMA technologies, especially UMTS, are likely to be supported for the longest time and would not need to be replaced as soon.

Ex. 1008 at 3:42-54.

Claims 4 and 10 Exemplary Disclosure of Prior Art


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Claims 4 and 10 Exemplary Disclosure of Prior Art [4] “The method of claim 1, wherein the mobile terminal notifies and/or displays to a user of the mobile terminal the broadcast content.” [10] “The mobile terminal of claim 7, further comprising: an acoustical unit configured to announce the broadcast content; and a display unit configured to display the broadcast content.”

Karl discloses: A text display may be used to provide a text message to the user. A vibrator 72 may be activated to provide a tactile alert of the warning signal to the user. Additionally, a speaker or beeper 74 may be activated to provide an audible alert of the warning signal to the user.

Ex. 1008 at 7:18-22; Ex. 1009 at 9-10. An ordinary artisan would recognize that Karl’s output human interface units can be used by Collins. Collins discloses:

The demodulated broadcast message is provided to decoder 56 which decodes the broadcast message and provides the broadcast message to the subscriber station user.

Ex. 1007 at 7:60-63.

Claims 5, 11, 15, and 19 Exemplary Disclosure of Prior Art [5] “The method of claim 1, wherein a duration of the broadcast mode is dependent on the at least one specific identifier of the at least two specific identifiers.” [11] “The mobile terminal of claim 7, wherein a duration of the broadcast mode is dependent on the at least one specific identifier of the at least two specific identifiers.” [15] “The system of claim 13, wherein a duration of the broadcast mode is dependent on the at least one specific identifier of

The ‘129 patent admits that IMSI allows for slotted paging:


Ex. 1001 at 4:17-22. Collins discloses receiving a broadcast message in a “slotted paging” method:

The expression slotted paging comes from dividing time into slots of a predetermined duration. In a slotted paging system, the subscriber station monitors a slot, it will again monitor a subsequent slot an integral number slots in the future. The number of slots between periodically monitored slots is referred to as the


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Claims 5, 11, 15, and 19 Exemplary Disclosure of Prior Art the at least two specific identifiers.” [19] “The method of claim 17, wherein a duration of the broadcast mode is dependent on the al least one specific identifier of the al least two specific identifiers.”

slot cycle. Ex. 1007 at 1:62-67; 1:42-50 (emphasis added). Karl discloses “"+TTTT" indicates the valid time period of the message in 15 minutes increments up to one hour and then in 30 minute increments beyond one hour.” Ex. 1008 at 4:63-65.

Claims 6, 12, 16, and 20 Exemplary Disclosure of Prior Art [6] “The method of claim 5 wherein the duration of the broadcast mode is for an indefinite length of time or for a limited duration of time based on the at least one specific identifier of the at least two specific identifiers.” [12] “The mobile terminal of claim 11, wherein the duration of the broadcast mode is for an indefinite length of time or for a limited duration of time based on the at least one specific identifier of the at least two specific identifiers.” [16] “The system of claim 15, wherein the duration of the broadcast mode is for an indefinite length of time or for a limited duration of time based on the at least one specific identifier of the at least two specific identifiers.”

The ‘129 patent admits that IMSI allows for slotted paging:


Ex. 1001 at 4:17-22. Collins discloses receiving a broadcast message in a “slotted paging” method:

The expression slotted paging comes from dividing time into slots of a predetermined duration. In a slotted paging system, the subscriber station monitors a slot, it will again monitor a subsequent slot an integral number slots in the future. The number of slots between periodically monitored slots is referred to as the slot cycle.

Ex. 1007 at 1:62-67; 1:42-50 (emphasis added). Karl discloses “"+TTTT" indicates the valid time period of the message in 15 minutes increments up to one hour and then in 30 minute increments beyond one hour.” Ex. 1008 at 4:63-65.


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Claims 6, 12, 16, and 20 Exemplary Disclosure of Prior Art [20] “The method of claim 19, wherein the duration of the broadcast mode is for an indefinite length of time or for a limited duration of time based on the at least one specific identifier of the at least two specific identifiers.”


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