Case 2:22-cv-11408-TGB ECF No. 10-12, PageID.285 Filed 07/20/22 Page 1 of 29
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`Amended
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`Exhibit 11
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`Case 2:22-cv-11408-TGB ECF No. 10-12, PageID.286 Filed 07/20/22 Page 2 of 29
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`Exhibit 11
`Claim 15 of U.S. Patent No. 10,965,512
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`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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`Case 2:22-cv-11408-TGB ECF No. 10-12, PageID.287 Filed 07/20/22 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:"
`Tesla’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 Tesla.
`
`To the extent the preamble is considered a limitation, Tesla’s Accused Products meet the preamble of
`the ’512 patent. E.g.,
`
`For clarity, release 8 of the 36 series 3GPP specifications was frozen in December of 2008 and that release
`was used as the basis for the first wave of LTE equipment. The LTE marketplace currently supports a mix of
`releases from Release 8 through Release 17. Though for ease of review release 8 of the LTE specification is
`cited below, the same or functionally identical content exists in each corresponding release on the market.
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`The LTE specification (starting at Series 36, Release 8) supports user equipment (UEs) to communicate with
`eNodeBs.
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`Case 2:22-cv-11408-TGB ECF No. 10-12, PageID.288 Filed 07/20/22 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-11408-TGB ECF No. 10-12, PageID.289 Filed 07/20/22 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-11408-TGB ECF No. 10-12, PageID.290 Filed 07/20/22 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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`Case 2:22-cv-11408-TGB ECF No. 10-12, PageID.291 Filed 07/20/22 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-11408-TGB ECF No. 10-12, PageID.292 Filed 07/20/22 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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`See e.g., 3GPP TS 36.211 V8.9.0 at pgs. 45-46.
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`Case 2:22-cv-11408-TGB ECF No. 10-12, PageID.293 Filed 07/20/22 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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`See e.g., 3GPP TS 36.211 V8.9.0 at pgs. 46-47.
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`Case 2:22-cv-11408-TGB ECF No. 10-12, PageID.294 Filed 07/20/22 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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`Case 2:22-cv-11408-TGB ECF No. 10-12, PageID.295 Filed 07/20/22 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;"
`Tesla’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.,
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`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 is configured to receive 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. In particular, the
`Accused Products are configured to receive downlink data in multiple transmission modes, including at least
`transmission mode 7 using UE-specific reference signals.
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`
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`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-11408-TGB ECF No. 10-12, PageID.296 Filed 07/20/22 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;"
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`
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`See e.g., 3GPP TS 36.211 V8.9.0 at pg.65.
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`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-11408-TGB ECF No. 10-12, PageID.297 Filed 07/20/22 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-11408-TGB ECF No. 10-12, PageID.298 Filed 07/20/22 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-11408-TGB ECF No. 10-12, PageID.299 Filed 07/20/22 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;"
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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-11408-TGB ECF No. 10-12, PageID.300 Filed 07/20/22 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-11408-TGB ECF No. 10-12, PageID.301 Filed 07/20/22 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;"
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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-11408-TGB ECF No. 10-12, PageID.302 Filed 07/20/22 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 Tesla’s
`first plurality of subcarriers or the second
`Accused Products are beamformed. E.g.,
`plurality of subcarriers are beam-formed;
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`and
`For example, on information and belief, the Accused Products employ UE-specific RSs to enable
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`beamforming of the data transmissions to 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-11408-TGB ECF No. 10-12, PageID.303 Filed 07/20/22 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
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`See e.g., 3GPP TS 36.211 V8.9.0 at pg. 52.
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`Case 2:22-cv-11408-TGB ECF No. 10-12, PageID.304 Filed 07/20/22 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
`
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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-11408-TGB ECF No. 10-12, PageID.305 Filed 07/20/22 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 Tesla’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
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`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.
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`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.
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`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-11408-TGB ECF No. 10-12, PageID.306 Filed 07/20/22 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
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`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-11408-TGB ECF No. 10-12, PageID.307 Filed 07/20/22 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-11408-TGB ECF No. 10-12, PageID.308 Filed 07/20/22 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-11408-TGB ECF No. 10-12, PageID.309 Filed 07/20/22 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 Tesla’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.
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`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.
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`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-11408-TGB ECF No. 10-12, PageID.310 Filed 07/20/22 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-11408-TGB ECF No. 10-12, PageID.311 Filed 07/20/22 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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`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-11408-TGB ECF No. 10-12, PageID.312 Filed 07/20/22 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-11408-TGB ECF No. 10-12, PageID.313 Filed 07/20/22 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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