Case 2:22-cv-11403-TGB ECF No. 1-11, PageID.244 Filed 03/29/22 Page 1 of 29
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`Exhibit 11
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`Exhibit 11
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`Case 2:22-cv-11403-TGB ECF No. 1-11, PageID.245 Filed 03/29/22 Page 2 of 29
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`Exhibit 11
`Claim 15 of U.S. Patent No. 10,965,512
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`Case 2:22-cv-11403-TGB ECF No. 1-11, PageID.246 Filed 03/29/22 Page 3 of 29
`U.S. Patent No. 10,965,512: Claim 15(a)
`"15. An orthogonal frequency division multiple access (OFDMA)-compatible mobile station that uses subcarriers in a frequency domain and time slots in
`a time domain, the OFDMA-compatible mobile station comprising:"
`Honda’s Accused Products include vehicles equipped with components and/or devices that enable
`connectivity to 4G/LTE networks and services, including services sold and provided by Honda.
`
`To the extent the preamble is considered a limitation, Honda’s Accused Products meet the preamble of
`the ’512 patent. E.g.,
`
`The LTE release 8 standard and subsequent releases (“LTE”) include an orthogonal frequency division
`multiple access (OFDMA)-compatible mobile station that uses subcarriers in a frequency domain and time
`slots in a time domain.
`
`For example, the LTE specification (Series 36, Release 8) supports user equipment (UEs) to communicate
`with eNodeBs.
`
`
`An orthogonal frequency division
`15.
`multiple access (OFDMA)-compatible
`mobile station that uses subcarriers in a
`frequency domain and time slots in a time
`domain, the OFDMA-compatible mobile
`station comprising:
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`2
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`Case 2:22-cv-11403-TGB ECF No. 1-11, PageID.247 Filed 03/29/22 Page 4 of 29
`U.S. Patent No. 10,965,512: Claim 15(a)
`"15. An orthogonal frequency division multiple access (OFDMA)-compatible mobile station that uses subcarriers in a frequency domain and time slots in
`a time domain, the OFDMA-compatible mobile station comprising:"
`
`See e.g., 3GPP TS 36.300 V8.12.0 at pg. 15.
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`LTE uses OFDMA in the downlink transmission.
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`Case 2:22-cv-11403-TGB ECF No. 1-11, PageID.248 Filed 03/29/22 Page 5 of 29
`U.S. Patent No. 10,965,512: Claim 15(a)
`"15. An orthogonal frequency division multiple access (OFDMA)-compatible mobile station that uses subcarriers in a frequency domain and time slots in
`a time domain, the OFDMA-compatible mobile station comprising:"
`
`See e.g., 3GPP TS 36.300 V8.12.0 at pg. 25.
`
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`Each frame structure has time slots. For example, Frame structure type 1 for FDD includes 20 time slots.
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`Case 2:22-cv-11403-TGB ECF No. 1-11, PageID.249 Filed 03/29/22 Page 6 of 29
`U.S. Patent No. 10,965,512: Claim 15(a)
`"15. An orthogonal frequency division multiple access (OFDMA)-compatible mobile station that uses subcarriers in a frequency domain and time slots in
`a time domain, the OFDMA-compatible mobile station comprising:"
`
`See e.g., 3GPP TS 36.211 V8.9.0 at pgs. 9-10.
`
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`The mobile station receives signals in the form of subcarriers having a time domain and frequency domain
`component.
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`5
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`Case 2:22-cv-11403-TGB ECF No. 1-11, PageID.250 Filed 03/29/22 Page 7 of 29
`U.S. Patent No. 10,965,512: Claim 15(a)
`"15. An orthogonal frequency division multiple access (OFDMA)-compatible mobile station that uses subcarriers in a frequency domain and time slots in
`a time domain, the OFDMA-compatible mobile station comprising:"
`
`See e.g., 3GPP TS 36.211 V8.9.0 at pg. 45.
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`Case 2:22-cv-11403-TGB ECF No. 1-11, PageID.251 Filed 03/29/22 Page 8 of 29
`U.S. Patent No. 10,965,512: Claim 15(a)
`"15. An orthogonal frequency division multiple access (OFDMA)-compatible mobile station that uses subcarriers in a frequency domain and time slots in
`a time domain, the OFDMA-compatible mobile station comprising:"
`
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`
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`See e.g., 3GPP TS 36.211 V8.9.0 at pgs. 45-46.
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`Case 2:22-cv-11403-TGB ECF No. 1-11, PageID.252 Filed 03/29/22 Page 9 of 29
`U.S. Patent No. 10,965,512: Claim 15(a)
`"15. An orthogonal frequency division multiple access (OFDMA)-compatible mobile station that uses subcarriers in a frequency domain and time slots in
`a time domain, the OFDMA-compatible mobile station comprising:"
`A physical resource block (PRB) corresponds to a plurality of consecutive OFDM symbols in the time
`domain and a plurality of consecutive subcarriers in the frequency domain, which correspond to a block of
`resource elements. The block of resource elements correspond to one time slot in the time domain and 180
`kHz in the frequency domain.
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`
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`See e.g., 3GPP TS 36.211 V8.9.0 at pgs. 46-47.
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`Case 2:22-cv-11403-TGB ECF No. 1-11, PageID.253 Filed 03/29/22 Page 10 of 29
`U.S. Patent No. 10,965,512: Claim 15(a)
`"15. An orthogonal frequency division multiple access (OFDMA)-compatible mobile station that uses subcarriers in a frequency domain and time slots in
`a time domain, the OFDMA-compatible mobile station comprising:"
`
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`See e.g., 3GPP TS 36.211 V8.9.0 at pg. 76.
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`9
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`Case 2:22-cv-11403-TGB ECF No. 1-11, PageID.254 Filed 03/29/22 Page 11 of 29
`U.S. Patent No. 10,965,512: Claim 15(b)
`"at least one antenna; and a receiver; and the at least one antenna and the receiver are configured to:
`receive first pilots of a first type on a first plurality of subcarriers, wherein the first pilots are cell-specific pilots; and
`receive second pilots of a second type and data on a second plurality of subcarriers, wherein the first plurality of subcarriers and the second plurality of
`subcarriers are received in at least one of the time slots;"
`Honda’s Accused Products each include at least one antenna and a receiver, wherein the at least one antenna
`and the receiver are configured first and second pilots of first and second types, respectively. E.g.,
`
`The UE receives first pilots of a first type on a first plurality of subcarriers, wherein the first pilots are cell-
`specific pilots and receive second pilots of a second type and data on a second plurality of subcarriers,
`wherein the first plurality of subcarriers and the second plurality of subcarriers are received in at least one of
`the time slots.
`
`For example, the LTE UE receives cell-specific reference signals and UE-specific reference signals via at
`least one antenna on a plurality of subcarriers in at least one time slot.
`
`
`
`at least one antenna; and
`a receiver; and
`the at least one antenna and the receiver
`are configured to:
`receive first pilots of a first type on a first
`plurality of subcarriers, wherein the first
`pilots are cell-specific pilots; and
`receive second pilots of a second type and
`data on a second plurality of subcarriers,
`wherein the first plurality of subcarriers
`and the second plurality of subcarriers are
`received in at least one of the time slots;
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`See e.g., 3GPP TS 36.300 V8.12.0 at pg. 23.
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`Case 2:22-cv-11403-TGB ECF No. 1-11, PageID.255 Filed 03/29/22 Page 12 of 29
`U.S. Patent No. 10,965,512: Claim 15(b)
`"at least one antenna; and a receiver; and the at least one antenna and the receiver are configured to:
`receive first pilots of a first type on a first plurality of subcarriers, wherein the first pilots are cell-specific pilots; and
`receive second pilots of a second type and data on a second plurality of subcarriers, wherein the first plurality of subcarriers and the second plurality of
`subcarriers are received in at least one of the time slots;"
`
`See e.g., 3GPP TS 36.211 V8.9.0 at pg.65.
`
`The mapping of the cell-specific reference signals are to resource elements that correspond to a subcarrier
`and symbol in a slot.
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`See e.g., 3GPP TS 36.211 V8.9.0 at pg.65.
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`Case 2:22-cv-11403-TGB ECF No. 1-11, PageID.256 Filed 03/29/22 Page 13 of 29
`U.S. Patent No. 10,965,512: Claim 15(b)
`"at least one antenna; and a receiver; and the at least one antenna and the receiver are configured to:
`receive first pilots of a first type on a first plurality of subcarriers, wherein the first pilots are cell-specific pilots; and
`receive second pilots of a second type and data on a second plurality of subcarriers, wherein the first plurality of subcarriers and the second plurality of
`subcarriers are received in at least one of the time slots;"
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`Case 2:22-cv-11403-TGB ECF No. 1-11, PageID.257 Filed 03/29/22 Page 14 of 29
`U.S. Patent No. 10,965,512: Claim 15(b)
`"at least one antenna; and a receiver; and the at least one antenna and the receiver are configured to:
`receive first pilots of a first type on a first plurality of subcarriers, wherein the first pilots are cell-specific pilots; and
`receive second pilots of a second type and data on a second plurality of subcarriers, wherein the first plurality of subcarriers and the second plurality of
`subcarriers are received in at least one of the time slots;"
`
`See e.g., 3GPP TS 36.211 V8.9.0 at pg.66-67.
`
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`The UE-specific reference signals are transmitted on resource elements, which include the second plurality
`of subcarriers, upon which a corresponding PDSCH, data, is mapped.
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`Case 2:22-cv-11403-TGB ECF No. 1-11, PageID.258 Filed 03/29/22 Page 15 of 29
`U.S. Patent No. 10,965,512: Claim 15(b)
`"at least one antenna; and a receiver; and the at least one antenna and the receiver are configured to:
`receive first pilots of a first type on a first plurality of subcarriers, wherein the first pilots are cell-specific pilots; and
`receive second pilots of a second type and data on a second plurality of subcarriers, wherein the first plurality of subcarriers and the second plurality of
`subcarriers are received in at least one of the time slots;"
`
`See e.g., 3GPP TS 36.211 V8.9.0 at pg. 70.
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`Case 2:22-cv-11403-TGB ECF No. 1-11, PageID.259 Filed 03/29/22 Page 16 of 29
`U.S. Patent No. 10,965,512: Claim 15(b)
`"at least one antenna; and a receiver; and the at least one antenna and the receiver are configured to:
`receive first pilots of a first type on a first plurality of subcarriers, wherein the first pilots are cell-specific pilots; and
`receive second pilots of a second type and data on a second plurality of subcarriers, wherein the first plurality of subcarriers and the second plurality of
`subcarriers are received in at least one of the time slots;"
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`See e.g., 3GPP TS 36.211 V8.9.0 at pg.71-72
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`Case 2:22-cv-11403-TGB ECF No. 1-11, PageID.260 Filed 03/29/22 Page 17 of 29
`U.S. Patent No. 10,965,512: Claim 15(b)
`"at least one antenna; and a receiver; and the at least one antenna and the receiver are configured to:
`receive first pilots of a first type on a first plurality of subcarriers, wherein the first pilots are cell-specific pilots; and
`receive second pilots of a second type and data on a second plurality of subcarriers, wherein the first plurality of subcarriers and the second plurality of
`subcarriers are received in at least one of the time slots;"
`
`
`See e.g., LTE - The UMTS Long Term Evolution - FROM THEORY TO PRACTICE - 2nd Edition pg. 171.
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`Case 2:22-cv-11403-TGB ECF No. 1-11, PageID.261 Filed 03/29/22 Page 18 of 29
`U.S. Patent No. 10,965,512: Claim 15(c)
`"wherein at least some subcarriers of the first plurality of subcarriers or the second plurality of subcarriers are beam-formed; and
`wherein at least some subcarriers of the
`At least some of the first or second plurality subcarriers used to receive the first or second pilots by Honda’s
`first plurality of subcarriers or the second
`Accused Products are beamformed. E.g.,
`plurality of subcarriers are beam-formed;
`
`and
`For example, one of the usage of the UE-specific RSs is to enable beamforming of the data transmissions to
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`specific UEs via the second plurality of subcarriers.
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`See e.g., 3GPP TS 36.300 V8.12.0 at pg. 30.
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`In LTE, subcarriers are beam-formed through precoding.
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`Case 2:22-cv-11403-TGB ECF No. 1-11, PageID.262 Filed 03/29/22 Page 19 of 29
`U.S. Patent No. 10,965,512: Claim 15(c)
`"wherein at least some subcarriers of the first plurality of subcarriers or the second plurality of subcarriers are beam-formed; and
`
`See e.g., 3GPP TS 36.211 V8.9.0 at pg. 52.
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`Case 2:22-cv-11403-TGB ECF No. 1-11, PageID.263 Filed 03/29/22 Page 20 of 29
`U.S. Patent No. 10,965,512: Claim 15(c)
`"wherein at least some subcarriers of the first plurality of subcarriers or the second plurality of subcarriers are beam-formed; and
`
`
`See e.g., LTE - The UMTS Long Term Evolution - FROM THEORY TO PRACTICE - 2nd Edition pg. 171.
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`Case 2:22-cv-11403-TGB ECF No. 1-11, PageID.264 Filed 03/29/22 Page 21 of 29
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`U.S. Patent No. 10,965,512: Claim 15(d)
`"the receiver is further configured to:
`recover the data using channel estimates from at least the second pilots; and recover cell-specific information using the cell-specific pilots;”
`the receiver is further configured to:
`The receiver of Honda’s Accused Products is further configured to recover the data using channel estimates
`and cell-specific information using the pilots. E.g.,
`recover the data using channel estimates
`
`from at least the second pilots; and
`recover cell-specific information using the
`The UE is further configured to recover the data using channel estimates from at least the second pilots and
`cell-specific pilots;
`recover cell-specific information using the cell-specific pilots.
`
`For example, the LTE UE uses the UE-specific reference signals embedded in the received PRBs to derive
`the channel estimation for demodulating the data in the corresponding PDSCH resource blocks.
`
`
`See e.g., 3GPP TS 36.211 V8.9.0 at pg. 70.
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`See e.g., LTE - The UMTS Long Term Evolution - FROM THEORY TO PRACTICE - 2nd Edition pg. 171.
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`Case 2:22-cv-11403-TGB ECF No. 1-11, PageID.265 Filed 03/29/22 Page 22 of 29
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`U.S. Patent No. 10,965,512: Claim 15(d)
`"the receiver is further configured to:
`recover the data using channel estimates from at least the second pilots; and recover cell-specific information using the cell-specific pilots;”
`The LTE UE recovers cell-specific information, such as the cell ID, using the cell-specific pilots. The Cell
`
`ID (NIDcell) is used for generating the cell-specific reference signal sequence.
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`See e.g., 3GPP TS 36.211 V8.9.0 at pgs.65-66.
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`The LTE cell-specific reference signal is also used to recover cell-specific information from the
`MasterInformationBlock, which is transmitted via the broadcast channel (BCH). The cell-specific reference
`signal is used, inter alia, to estimate the channel corresponding to the center part of the carrier where the
`BCH is transmitted.
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`Case 2:22-cv-11403-TGB ECF No. 1-11, PageID.266 Filed 03/29/22 Page 23 of 29
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`U.S. Patent No. 10,965,512: Claim 15(d)
`"the receiver is further configured to:
`recover the data using channel estimates from at least the second pilots; and recover cell-specific information using the cell-specific pilots;”
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`See e.g., 3GPP TS 36.331 V8.21.0 at pgs.85-86.
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`Case 2:22-cv-11403-TGB ECF No. 1-11, PageID.267 Filed 03/29/22 Page 24 of 29
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`U.S. Patent No. 10,965,512: Claim 15(d)
`"the receiver is further configured to:
`recover the data using channel estimates from at least the second pilots; and recover cell-specific information using the cell-specific pilots;”
`
`
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`See e.g., 4G, LTE ADVANCED PRO AND THE ROAD TO 5G, Third Edition, pg. 104
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`Case 2:22-cv-11403-TGB ECF No. 1-11, PageID.268 Filed 03/29/22 Page 25 of 29
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`U.S. Patent No. 10,965,512: Claim 15(e)
`
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`" wherein the second type is different than the first type and wherein the first pilots do not interfere with the second pilots.”
`wherein the second type is different than
`The second type of pilots used with Honda’s Accused Products are different than the first type of pilots and
`the first type and wherein the first pilots
`the first pilots do not interfere with the second pilots. E.g.,
`do not interfere with the second pilots.
`
`For example, cell-specific reference signals, the first pilots, are different than the UE-specific reference
`signals, second pilots.
`
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`See e.g., 3GPP TS 36.211 V8.9.0 at pg.65.
`
`The UE-specific reference signals are not transmitted in resource elements in which other physical signals,
`such as the cell-specific reference signal, are transmitted. Thus, they do not interfere.
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`See e.g., 3GPP TS 36.211 V8.9.0 at pg. 70.
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`Case 2:22-cv-11403-TGB ECF No. 1-11, PageID.269 Filed 03/29/22 Page 26 of 29
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`U.S. Patent No. 10,965,512: Claim 15(e)
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`" wherein the second type is different than the first type and wherein the first pilots do not interfere with the second pilots.”
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`Case 2:22-cv-11403-TGB ECF No. 1-11, PageID.270 Filed 03/29/22 Page 27 of 29
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`U.S. Patent No. 10,965,512: Claim 15(e)
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`" wherein the second type is different than the first type and wherein the first pilots do not interfere with the second pilots.”
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`
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`See e.g., 3GPP TS 36.211 V8.9.0 at pg.71-72
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`See e.g., 3GPP TS 36.211 V8.9.0 at pg.65.
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`Case 2:22-cv-11403-TGB ECF No. 1-11, PageID.271 Filed 03/29/22 Page 28 of 29
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`U.S. Patent No. 10,965,512: Claim 15(e)
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`" wherein the second type is different than the first type and wherein the first pilots do not interfere with the second pilots.”
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`Case 2:22-cv-11403-TGB ECF No. 1-11, PageID.272 Filed 03/29/22 Page 29 of 29
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`U.S. Patent No. 10,965,512: Claim 15(e)
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`" wherein the second type is different than the first type and wherein the first pilots do not interfere with the second pilots.”
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`See e.g., 3GPP TS 36.211 V8.9.0 at pg.66-67.
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