Case 2:22-cv-11408-TGB ECF No. 10-13, PageID.314 Filed 07/20/22 Page 1 of 35
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`Amended
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`Exhibit 12
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`Amended
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`Exhibit 12
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`Case 2:22-cv-11408-TGB ECF No. 10-13, PageID.315 Filed 07/20/22 Page 2 of 35
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`Exhibit 12
`Claim 23 of U.S. Patent No. 10,771,302
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`Case 2:22-cv-11408-TGB ECF No. 10-13, PageID.316 Filed 07/20/22 Page 3 of 35
`U.S. Patent No. 10,771,302: Claim 23(a)
`"23. A mobile device in an Orthogonal Frequency Division Multiplexing (OFDM) communication system, the mobile device comprising:”
`23. A mobile device in an Orthogonal
`Tesla’s Accused Products include vehicles equipped with components and/or devices that enable connectivity
`Frequency Division Multiplexing
`to 4G/LTE networks and services, including services sold and provided by Tesla.
`(OFDM) communication system, the
`
`mobile device comprising:
`To the extent the preamble is considered a limitation, Tesla’s Accused Products meet the preamble of the ’302
`
`patent. E.g.,
`
`
`The LTE specification (Series 36, Release 8) supports user equipment (UE) to perform a sounding reference
`signal (SRS) procedure.
`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.
`An LTE communication system has user equipments (UEs) transmit to and receive signals from eNodeBs.
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`Case 2:22-cv-11408-TGB ECF No. 10-13, PageID.317 Filed 07/20/22 Page 4 of 35
`U.S. Patent No. 10,771,302: Claim 23(a)
`"23. A mobile device in an Orthogonal Frequency Division Multiplexing (OFDM) communication system, the mobile device comprising:”
`
`See e.g., 3GPP TS 36.300 V8.12.0 at pg. 15.
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`Case 2:22-cv-11408-TGB ECF No. 10-13, PageID.318 Filed 07/20/22 Page 5 of 35
`U.S. Patent No. 10,771,302: Claim 23(a)
`"23. A mobile device in an Orthogonal Frequency Division Multiplexing (OFDM) communication system, the mobile device comprising:”
`
`See e.g., 3GPP TS 36.300 V8.12.0 at pg. 18.
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`LTE uses OFDM for both the downlink and the uplink. For the uplink, LTE uses a specific type of OFDM
`referred to a discrete Fourier Transform Spread (DFTS)-OFDM.
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`See e.g., 3GPP TS 36.300 V8.12.0 at pg. 25.
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`Case 2:22-cv-11408-TGB ECF No. 10-13, PageID.319 Filed 07/20/22 Page 6 of 35
`U.S. Patent No. 10,771,302: Claim 23(a)
`"23. A mobile device in an Orthogonal Frequency Division Multiplexing (OFDM) communication system, the mobile device comprising:”
`
`See e.g., 3GPP TS 36.300 V8.12.0 at pg. 27.
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`5
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`Case 2:22-cv-11408-TGB ECF No. 10-13, PageID.320 Filed 07/20/22 Page 7 of 35
`U.S. Patent No. 10,771,302: Claim 23(a)
`"23. A mobile device in an Orthogonal Frequency Division Multiplexing (OFDM) communication system, the mobile device comprising:”
`LTE uses an uplink channel bandwidth divided into physical resource blocks.
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`See e.g., 3GPP TS 36.101 V8.29.0 at pg. 15.
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`Case 2:22-cv-11408-TGB ECF No. 10-13, PageID.321 Filed 07/20/22 Page 8 of 35
`U.S. Patent No. 10,771,302: Claim 23(a)
`"23. A mobile device in an Orthogonal Frequency Division Multiplexing (OFDM) communication system, the mobile device comprising:”
`Each physical resource block (PRB) has 12 subcarriers.
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`
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`See e.g., 3GPP TS 36.211 V8.9.0 at pg. 13.
`IP packets, voice and other user plane data is sent over dedicated traffic channels (DTCHs), which are sent
`over the uplink shared channel (UL-SCH) transport channel.
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`Case 2:22-cv-11408-TGB ECF No. 10-13, PageID.322 Filed 07/20/22 Page 9 of 35
`U.S. Patent No. 10,771,302: Claim 23(a)
`"23. A mobile device in an Orthogonal Frequency Division Multiplexing (OFDM) communication system, the mobile device comprising:”
`
`See e.g., 3GPP TS 36.300 V8.12.0 at pg. 34.
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`8
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`Case 2:22-cv-11408-TGB ECF No. 10-13, PageID.323 Filed 07/20/22 Page 10 of 35
`U.S. Patent No. 10,771,302: Claim 23(a)
`"23. A mobile device in an Orthogonal Frequency Division Multiplexing (OFDM) communication system, the mobile device comprising:”
`The UL-SCH transport channel is sent over the physical uplink shared channel (PUSCH) and control is sent
`over the physical uplink control channel (PUCCH).
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`See e.g., 3GPP TS 36.300 V8.12.0 at pg. 31.
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`See e.g., 3GPP TS 36.211 V8.9.0 at pg. 16.
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`The PUCCH is transmitted using the outer PRBs/subcarriers of the uplink bandwidth and the PUSCH is
`transmitted using the PRBs/subcarriers between the PUCCH subcarriers.
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`See e.g., 3GPP TS 36.211 V8.9.0 at pg. 20.
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`Case 2:22-cv-11408-TGB ECF No. 10-13, PageID.324 Filed 07/20/22 Page 11 of 35
`U.S. Patent No. 10,771,302: Claim 23(a)
`"23. A mobile device in an Orthogonal Frequency Division Multiplexing (OFDM) communication system, the mobile device comprising:”
`
`
`See e.g., 3GPP TS 36.211 V8.9.0 at pg. 21.
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`Case 2:22-cv-11408-TGB ECF No. 10-13, PageID.325 Filed 07/20/22 Page 12 of 35
`U.S. Patent No. 10,771,302: Claim 23(a)
`"23. A mobile device in an Orthogonal Frequency Division Multiplexing (OFDM) communication system, the mobile device comprising:”
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`See e.g., 4G LTE=Advanced Pro and The Road to 5G, Third Edition, Dahlman et al, §7.4.1.6.
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`Case 2:22-cv-11408-TGB ECF No. 10-13, PageID.326 Filed 07/20/22 Page 13 of 35
`U.S. Patent No. 10,771,302: Claim 23(b)
`" a receiver configured to receive a request for a probing signal from a base station in the system;”
`a receiver configured to receive a request
`Tesla’s Accused Products include a receiver configured to receive a request for a probing signal from a base
`for a probing signal from a base station in
`station in the system. E.g.,
`the system;
`
`For example, the Accused Products are configured to receive from the eNB an RRC message
`(RRCConnectionReconfiguration message or SystemInformation message) including SRS configuration
`parameters in the SoundingRS-UL-Config information element, which instructs the UE to periodically transmit
`SRS.
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`Case 2:22-cv-11408-TGB ECF No. 10-13, PageID.327 Filed 07/20/22 Page 14 of 35
`U.S. Patent No. 10,771,302: Claim 23(b)
`" a receiver configured to receive a request for a probing signal from a base station in the system;”
`See e.g., 3GPP TS 36.331 V8.21.0 at p. 89.
`
`See e.g., 3GPP TS 36.331 V8.21.0 at p. 129.
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`See e.g., 3GPP TS 36.331 V8.21.0 at p. 122.
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`Case 2:22-cv-11408-TGB ECF No. 10-13, PageID.328 Filed 07/20/22 Page 15 of 35
`U.S. Patent No. 10,771,302: Claim 23(b)
`" a receiver configured to receive a request for a probing signal from a base station in the system;”
`
`See e.g., 3GPP TS 36.331 V8.21.0 at p. 100.
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`Case 2:22-cv-11408-TGB ECF No. 10-13, PageID.329 Filed 07/20/22 Page 16 of 35
`U.S. Patent No. 10,771,302: Claim 23(b)
`" a receiver configured to receive a request for a probing signal from a base station in the system;”
`
`See e.g., 3GPP TS 36.331 V8.21.0 at p. 105.
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`Case 2:22-cv-11408-TGB ECF No. 10-13, PageID.330 Filed 07/20/22 Page 17 of 35
`U.S. Patent No. 10,771,302: Claim 23(b)
`" a receiver configured to receive a request for a probing signal from a base station in the system;”
`
`See e.g., 3GPP TS 36.331 V8.21.0 at p. 128.
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`Case 2:22-cv-11408-TGB ECF No. 10-13, PageID.331 Filed 07/20/22 Page 18 of 35
`U.S. Patent No. 10,771,302: Claim 23(b)
`" a receiver configured to receive a request for a probing signal from a base station in the system;”
`
`3GPP TS 36.331 V8.21.0 at p. 132.
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`For LTE-A UEs, those UEs can also be instructed to send an aperiodic SRS by the eNB as part of downlink
`control information (DCI) formats 0, 1A, 2B, 2C, and 4.
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`See e.g., 3GPP TS 36.213 V10.13.0 at pg. 81.
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`17
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`Case 2:22-cv-11408-TGB ECF No. 10-13, PageID.332 Filed 07/20/22 Page 19 of 35
`U.S. Patent No. 10,771,302: Claim 23(b)
`" a receiver configured to receive a request for a probing signal from a base station in the system;”
`
`See e.g., 3GPP TS 36.212 V10.9.0 at pg. 58.
`
`
`See e.g., 3GPP TS 36.212 V10.9.0 at pg. 60.
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`Case 2:22-cv-11408-TGB ECF No. 10-13, PageID.333 Filed 07/20/22 Page 20 of 35
`U.S. Patent No. 10,771,302: Claim 23(c)
`"a transmitter configured to form and transmit, in response to the received request, the probing signal with a code sequence modulated in the frequency
`domain, wherein:"
`Tesla’s Accused Products each include a transmitter configured to form and transmit the probing signal with a
`code sequence modulated in the frequency domain. E.g.,
`
`For example, in response to the RRC signaling (periodic SRS) or the SRS request (aperiodic SRS), the UE
`generates a phase shifted SRS sequence that is modulated onto subcarriers in the frequency domain.
`
`
`a transmitter configured to form and
`transmit, in response to the received
`request, the probing signal with a code
`sequence modulated in the frequency
`domain, wherein:
`
`See e.g., 3GPP TS 36.211 V8.9.0 at pg. 21.
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`19
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`Case 2:22-cv-11408-TGB ECF No. 10-13, PageID.334 Filed 07/20/22 Page 21 of 35
`U.S. Patent No. 10,771,302: Claim 23(c)
`"a transmitter configured to form and transmit, in response to the received request, the probing signal with a code sequence modulated in the frequency
`domain, wherein:"
`
`See e.g., 3GPP TS 36.211 V8.9.0 at pg. 28.
`
`The UE transmits the SRS to the eNodeB.
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`20
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`Case 2:22-cv-11408-TGB ECF No. 10-13, PageID.335 Filed 07/20/22 Page 22 of 35
`U.S. Patent No. 10,771,302: Claim 23(c)
`"a transmitter configured to form and transmit, in response to the received request, the probing signal with a code sequence modulated in the frequency
`domain, wherein:"
`See e.g., 3GPP TS 36.211 V8.9.0 at pg. 31.
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`Case 2:22-cv-11408-TGB ECF No. 10-13, PageID.336 Filed 07/20/22 Page 23 of 35
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`U.S. Patent No. 10,771,302: Claim 23(d)
`" the probing signal is configured to overlap, in the time domain, with uplink signals transmitted over an uplink frequency band by other mobile devices in
`the system; and"
`The probing signal transmitted by Tesla’s Accused Products is configured to overlap, in the time domain, with
`uplink signals transmitted over an uplink frequency band by other mobile devices in the system. E.g.,
`
`For example, the SRS is mapped to one symbol in the time domain but over many subcarriers in the frequency
`domain. The Accused Products are configured to support simultaneous transmission of SRS and PUCCH,
`allowing the SRS to overlap in the time domain with PUCCH signals transmitted by other mobile devices.
`
`
`the probing signal is configured to
`overlap, in the time domain, with
`uplink signals transmitted over an
`uplink frequency band by other mobile
`devices in the system; and
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`
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`See e.g., 3GPP TS 36.211 V8.9.0 at pg. 28.
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`22
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`Case 2:22-cv-11408-TGB ECF No. 10-13, PageID.337 Filed 07/20/22 Page 24 of 35
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`U.S. Patent No. 10,771,302: Claim 23(d)
`" the probing signal is configured to overlap, in the time domain, with uplink signals transmitted over an uplink frequency band by other mobile devices in
`the system; and"
`
`
`The UE transmits the SRS to the eNodeB.
`
`
`See e.g., 3GPP TS 36.211 V8.9.0 at pg. 31.
`
`
`See e.g., 3GPP TS 36.211 V8.9.0 at pg. 21.
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`See e.g., 3GPP TS 36.211 V8.9.0 at pg. 30.
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`Case 2:22-cv-11408-TGB ECF No. 10-13, PageID.338 Filed 07/20/22 Page 25 of 35
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`U.S. Patent No. 10,771,302: Claim 23(d)
`" the probing signal is configured to overlap, in the time domain, with uplink signals transmitted over an uplink frequency band by other mobile devices in
`the system; and"
`
`
`
`
`See e.g.,
`http://rfmw.em.keysight.com/wireless/helpfiles/89600b/webhelp/subsystems/lte/content/lte_overview.htm
`(showing that the SRS transmitted by User 3 overlaps in the time domain with the PUCCH signal transmitted
`by User 2).
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`24
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`Case 2:22-cv-11408-TGB ECF No. 10-13, PageID.339 Filed 07/20/22 Page 26 of 35
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`U.S. Patent No. 10,771,302: Claim 23(e)
`" the probing signal is configured to occupy a portion of spectrum in the uplink frequency band not designated for transmission of uplink control signals in
`the system."
`The probing signal transmitted by Tesla’s Accused Products is configured to occupy a portion of spectrum in
`the uplink frequency band not designated for transmission of uplink control signals in the system.. E.g.,
`
`For example, SRS transmissions are sent using a portion of the uplink bandwidth.
`
`
`the probing signal is configured to occupy
`a portion of spectrum in the uplink
`frequency band not designated for
`transmission of uplink control signals in
`the system.
`
`
`See e.g., 3GPP TS 36.213 V8.8.0 at pg. 55.
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`SRS does not overlap in the frequency domain with PUCCH subcarriers.
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`25
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`Case 2:22-cv-11408-TGB ECF No. 10-13, PageID.340 Filed 07/20/22 Page 27 of 35
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`U.S. Patent No. 10,771,302: Claim 23(e)
`" the probing signal is configured to occupy a portion of spectrum in the uplink frequency band not designated for transmission of uplink control signals in
`the system."
`
`
`See Sesia, Toufik and Baker, “LTE: The UMTS Long Term Evolution From Theory to Practice”, at p. 338.
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`Case 2:22-cv-11408-TGB ECF No. 10-13, PageID.341 Filed 07/20/22 Page 28 of 35
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`U.S. Patent No. 10,771,302: Claim 23(e)
`" the probing signal is configured to occupy a portion of spectrum in the uplink frequency band not designated for transmission of uplink control signals in
`the system."
`
`
`See e.g., Sesia, Toufik and Baker, “LTE: The UMTS Long Term Evolution From Theory to Practice”, at p.
`358.
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`Case 2:22-cv-11408-TGB ECF No. 10-13, PageID.342 Filed 07/20/22 Page 29 of 35
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`U.S. Patent No. 10,771,302: Claim 23(e)
`" the probing signal is configured to occupy a portion of spectrum in the uplink frequency band not designated for transmission of uplink control signals in
`the system."
`
`See e.g.,
`http://rfmw.em.keysight.com/wireless/helpfiles/89600b/webhelp/subsystems/lte/content/lte_overview.htm
`
`For example, the PUCCH is mapped into a resource block a single resource block in each time slot that is
`located near the top or the bottom of the uplink bandwidth.
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`Case 2:22-cv-11408-TGB ECF No. 10-13, PageID.343 Filed 07/20/22 Page 30 of 35
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`U.S. Patent No. 10,771,302: Claim 23(e)
`" the probing signal is configured to occupy a portion of spectrum in the uplink frequency band not designated for transmission of uplink control signals in
`the system."
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`Case 2:22-cv-11408-TGB ECF No. 10-13, PageID.344 Filed 07/20/22 Page 31 of 35
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`U.S. Patent No. 10,771,302: Claim 23(e)
`" the probing signal is configured to occupy a portion of spectrum in the uplink frequency band not designated for transmission of uplink control signals in
`the system."
`
`
`
`
`
`See e.g., 3GPP TS 36.211 V8.9.0 at pg. 20-21.
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`Case 2:22-cv-11408-TGB ECF No. 10-13, PageID.345 Filed 07/20/22 Page 32 of 35
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`U.S. Patent No. 10,771,302: Claim 23(e)
`" the probing signal is configured to occupy a portion of spectrum in the uplink frequency band not designated for transmission of uplink control signals in
`the system."
`
`
`The SRS signal may be mapped to a variety of locations in the frequency domain depending on the
`configuration of the system. Tables 5.5.3.2-1 through 5.5.3.2-4 provide the available LTE configurations.
`These configurations map the SRS in blocks towards the middle of uplink bandwidth and avoid the resource
`blocks at the ends of the uplink bandwidth that carry the PUCCH.
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`Case 2:22-cv-11408-TGB ECF No. 10-13, PageID.346 Filed 07/20/22 Page 33 of 35
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`U.S. Patent No. 10,771,302: Claim 23(e)
`" the probing signal is configured to occupy a portion of spectrum in the uplink frequency band not designated for transmission of uplink control signals in
`the system."
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`Case 2:22-cv-11408-TGB ECF No. 10-13, PageID.347 Filed 07/20/22 Page 34 of 35
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`U.S. Patent No. 10,771,302: Claim 23(e)
`" the probing signal is configured to occupy a portion of spectrum in the uplink frequency band not designated for transmission of uplink control signals in
`the system."
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`Case 2:22-cv-11408-TGB ECF No. 10-13, PageID.348 Filed 07/20/22 Page 35 of 35
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`U.S. Patent No. 10,771,302: Claim 23(e)
`" the probing signal is configured to occupy a portion of spectrum in the uplink frequency band not designated for transmission of uplink control signals in
`the system."
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`See e.g., 3GPP TS 36.211 V8.9.0 at pg. 28-31.
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