Case 2:22-cv-11408-TGB ECF No. 10-8, PageID.191 Filed 07/20/22 Page 1 of 27
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`Amended
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`Exhibit 7
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`Amended
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`Exhibit 7
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`Case 2:22-cv-11408-TGB ECF No. 10-8, PageID.192 Filed 07/20/22 Page 2 of 27
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`Exhibit 7
`Claim 1 of U.S. Patent No. 8,467,366
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`1
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`Case 2:22-cv-11408-TGB ECF No. 10-8, PageID.193 Filed 07/20/22 Page 3 of 27
`U.S. Patent No. 8,467,366: Claim 1(a)
`"In a multi-cell orthogonal frequency division multiple access (OFDMA) wireless communication system comprising a plurality of base stations and mobile
`stations, a mobile station configured to communicate with a serving base station in a cell via a communication channel, the mobile station comprising: "
`1. In a multi-cell orthogonal frequency
`Tesla’s Accused Products include vehicles equipped with components and/or devices that enable connectivity
`division multiple access (OFDMA)
`to 4G/LTE networks and services, including services sold and provided by Tesla.
`wireless communication system
`
`comprising a plurality of base stations and
`To the extent the preamble is considered a limitation, Tesla’s Accused Products meet the preamble of the ’366
`mobile stations, a mobile station
`patent. E.g.,
`configured to communicate with a serving
`
`base station in a cell via a communication
`The LTE specification (Series 36, Release 8) supports user equipment (UE) to perform a random access
`channel, the mobile station comprising:
`procedure.
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`
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`For clarity, release 8 of the 36 series 3GPP specifications was frozen in December of 2008 and that release was
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`used as the basis for the first wave of LTE equipment. The LTE marketplace currently supports a mix of
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`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 network has many eNodeBs, base stations.
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`Case 2:22-cv-11408-TGB ECF No. 10-8, PageID.194 Filed 07/20/22 Page 4 of 27
`U.S. Patent No. 8,467,366: Claim 1(a)
`"In a multi-cell orthogonal frequency division multiple access (OFDMA) wireless communication system comprising a plurality of base stations and mobile
`stations, a mobile station configured to communicate with a serving base station in a cell via a communication channel, the mobile station comprising: "
`
`See e.g., 3GPP TS 36.300 V8.12.0 at pg. 15.
`The user equipment (UE), mobile station, communicates with a corresponding eNodeB.
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`Case 2:22-cv-11408-TGB ECF No. 10-8, PageID.195 Filed 07/20/22 Page 5 of 27
`U.S. Patent No. 8,467,366: Claim 1(a)
`"In a multi-cell orthogonal frequency division multiple access (OFDMA) wireless communication system comprising a plurality of base stations and mobile
`stations, a mobile station configured to communicate with a serving base station in a cell via a communication channel, the mobile station comprising: "
`
`See e.g., 3GPP TS 36.300 V8.12.0 at pg. 18.
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`LTE uses OFDMA 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. 10-8, PageID.196 Filed 07/20/22 Page 6 of 27
`U.S. Patent No. 8,467,366: Claim 1(a)
`"In a multi-cell orthogonal frequency division multiple access (OFDMA) wireless communication system comprising a plurality of base stations and mobile
`stations, a mobile station configured to communicate with a serving base station in a cell via a communication channel, the mobile station comprising: "
`
`See e.g., 3GPP TS 36.300 V8.12.0 at pgs. 27-28.
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`In LTE, data is transmitted using the physical uplink shared channel.
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`See e.g., 3GPP TS 36.211 V8.9.0 at pg. 13.
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`Case 2:22-cv-11408-TGB ECF No. 10-8, PageID.197 Filed 07/20/22 Page 7 of 27
`U.S. Patent No. 8,467,366: Claim 1(b)
`"an apparatus configured to transmit a data signal to the serving base station in the cell over a data subchannel, wherein the data subchannel comprises a
`plurality of adjacent or non-adjacent subcarriers within the communication channel; and"
`an apparatus configured to transmit a data
`Tesla’s Accused Products each include an apparatus configured to transmit a data signal to the serving base
`signal to the serving base station in the
`station in the cell over a data subchannel, wherein the data subchannel comprises a plurality of adjacent or non-
`cell over a data subchannel, wherein the
`adjacent subcarriers within the communication channel. E.g.,
`data subchannel comprises a plurality of
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`adjacent or non-adjacent subcarriers
`In LTE, data is transmitted using the physical uplink shared channel.
`within the communication channel; and
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`See e.g., 3GPP TS 36.211 V8.9.0 at pg. 13.
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`The LTE uplink is divided into physical resource blocks (PRBs). Each PRB has 12 adjacent subcarriers.
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`Case 2:22-cv-11408-TGB ECF No. 10-8, PageID.198 Filed 07/20/22 Page 8 of 27
`U.S. Patent No. 8,467,366: Claim 1(b)
`"an apparatus configured to transmit a data signal to the serving base station in the cell over a data subchannel, wherein the data subchannel comprises a
`plurality of adjacent or non-adjacent subcarriers within the communication channel; and"
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`See e.g., 3GPP TS 36.211 V8.9.0 at pg. 13.
`The eNodeB assigns the UE a set of contiguous or adjacent PRBs using PDCCH format 0, thereby forming a
`data subchannel.
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`See e.g., 3GPP TS 36.213 V8.8.0 at pg. 55.
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`Case 2:22-cv-11408-TGB ECF No. 10-8, PageID.199 Filed 07/20/22 Page 9 of 27
`U.S. Patent No. 8,467,366: Claim 1(b)
`"an apparatus configured to transmit a data signal to the serving base station in the cell over a data subchannel, wherein the data subchannel comprises a
`plurality of adjacent or non-adjacent subcarriers within the communication channel; and"
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`See: Rumney, Moray, LTE and the Evolution to 4G Wireless § 3.2.8.3 at pg. 103.
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`Case 2:22-cv-11408-TGB ECF No. 10-8, PageID.200 Filed 07/20/22 Page 10 of 27
`U.S. Patent No. 8,467,366: Claim 1(c)
`"an apparatus configured to transmit a ranging signal to the serving base station in the cell over a ranging subchannel for random access, wherein:"
`an apparatus configured to transmit a
`Tesla’s Accused Products each include an apparatus configured to transmit a ranging signal to the serving base
`ranging signal to the serving base station
`station in the cell over a ranging subchannel for random access. E.g.,
`in the cell over a ranging subchannel for
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`random access, wherein:
`The UE transmits a preamble, ranging signal, to the eNodeB over a physical random access channel.
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`See e.g., 3GPP TS 36.300 V8.7.0 at pgs. 24 and 25.
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`The eNodeB defines physical frequency resources, ranging subchannel, for the PRACH. The UE also receives
`a random access response.
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`See e.g., 3GPP TS 36.213 V8.8.0 at pg. 16.
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`Case 2:22-cv-11408-TGB ECF No. 10-8, PageID.201 Filed 07/20/22 Page 11 of 27
`U.S. Patent No. 8,467,366: Claim 1(c)
`"an apparatus configured to transmit a ranging signal to the serving base station in the cell over a ranging subchannel for random access, wherein:"
`
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`See e.g., 3GPP TS 36.211 V8.9.0 at pg. 35.
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`The random access response has an uplink timing adjustment, which is adjusted based on the UE’s range to the
`eNodeB.
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`Case 2:22-cv-11408-TGB ECF No. 10-8, PageID.202 Filed 07/20/22 Page 12 of 27
`U.S. Patent No. 8,467,366: Claim 1(c)
`"an apparatus configured to transmit a ranging signal to the serving base station in the cell over a ranging subchannel for random access, wherein:"
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`See e.g., 3GPP TS 36.321 V8.12.0 at pg. 17.
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`Case 2:22-cv-11408-TGB ECF No. 10-8, PageID.203 Filed 07/20/22 Page 13 of 27
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`U.S. Patent No. 8,467,366: Claim 1(d)
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`"the ranging signal is formed from a ranging sequence selected from a set of ranging sequences associated with the cell for identifying the mobile station;"
`the ranging signal is formed from a
`The ranging signal used with Tesla’s Accused Products is formed from a ranging sequence selected from a set
`ranging sequence selected from a set of
`of ranging sequences associated with the cell for identifying the mobile station. E.g.,
`ranging sequences associated with the cell
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`for identifying the mobile station;
`The transmitted PRACH preamble is a selected Zadoff-Chu sequence. Each cell has a set of 64 sequences.
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`See e.g., 3GPP TS 36.211 V8.9.0 at pg. 39.
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`In response to the transmitted preamble, the eNodeB sends back the RA-preamble identifier, so that the UE
`knows its selected preamble was received by the eNodeB and the received random access response is for the
`UE.
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`Case 2:22-cv-11408-TGB ECF No. 10-8, PageID.204 Filed 07/20/22 Page 14 of 27
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`U.S. Patent No. 8,467,366: Claim 1(d)
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`"the ranging signal is formed from a ranging sequence selected from a set of ranging sequences associated with the cell for identifying the mobile station;"
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`See e.g., 3GPP TS 36.300 V8.7.0 at pgs. 52 and 53.
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`Case 2:22-cv-11408-TGB ECF No. 10-8, PageID.205 Filed 07/20/22 Page 15 of 27
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`U.S. Patent No. 8,467,366: Claim 1(d)
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`"the ranging signal is formed from a ranging sequence selected from a set of ranging sequences associated with the cell for identifying the mobile station;"
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`Case 2:22-cv-11408-TGB ECF No. 10-8, PageID.206 Filed 07/20/22 Page 16 of 27
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`U.S. Patent No. 8,467,366: Claim 1(d)
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`"the ranging signal is formed from a ranging sequence selected from a set of ranging sequences associated with the cell for identifying the mobile station;"
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`See e.g., 3GPP TS 36.300 V8.7.0 at pgs. 54 and 55.
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`Case 2:22-cv-11408-TGB ECF No. 10-8, PageID.207 Filed 07/20/22 Page 17 of 27
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`U.S. Patent No. 8,467,366: Claim 1(e)
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`"the ranging signal lasts over a period of one or multiple orthogonal frequency division multiplexing (OFDM) symbols and"
`the ranging signal lasts over a period of
`The ranging signal used with Tesla’s Accused Products lasts over a period of one or multiple orthogonal
`one or multiple orthogonal frequency
`frequency division multiplexing (OFDM) symbols. E.g.,
`division multiplexing (OFDM) symbols
`
`and
`The PRACH preamble has a defined length, such as 3168 TS+ 24576 TS.
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`See e.g., 3GPP TS 36.211 V8.9.0 at pg. 33.
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`The time unit Ts is 1/(15000*2048) seconds. The preamble length is for configurations 0-3 from 0.9 to 2.28
`ms.
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`Case 2:22-cv-11408-TGB ECF No. 10-8, PageID.208 Filed 07/20/22 Page 18 of 27
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`U.S. Patent No. 8,467,366: Claim 1(e)
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`"the ranging signal lasts over a period of one or multiple orthogonal frequency division multiplexing (OFDM) symbols and"
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`See e.g., 3GPP TS 36.211 V8.9.0 at pg. 9.
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`Case 2:22-cv-11408-TGB ECF No. 10-8, PageID.209 Filed 07/20/22 Page 19 of 27
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`U.S. Patent No. 8,467,366: Claim 1(e)
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`"the ranging signal lasts over a period of one or multiple orthogonal frequency division multiplexing (OFDM) symbols and"
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`See: Dahlman, Parkvall, Skold, 4G LTE-Advanced Pro and The Road to 5G, Third Edition, § 11.3.1.2.
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`Case 2:22-cv-11408-TGB ECF No. 10-8, PageID.210 Filed 07/20/22 Page 20 of 27
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`U.S. Patent No. 8,467,366: Claim 1(e)
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`"the ranging signal lasts over a period of one or multiple orthogonal frequency division multiplexing (OFDM) symbols and"
`The LTE frame has 0.5 ms slots.
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`See e.g., 3GPP TS 36.211 V8.9.0 at pg. 10.
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`Each slot has 6 or 7 symbols, so the duration of a symbol is 0.083 ms or 0.071 ms.
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`Case 2:22-cv-11408-TGB ECF No. 10-8, PageID.211 Filed 07/20/22 Page 21 of 27
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`U.S. Patent No. 8,467,366: Claim 1(e)
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`"the ranging signal lasts over a period of one or multiple orthogonal frequency division multiplexing (OFDM) symbols and"
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`See e.g., 3GPP TS 36.211 V8.9.0 at pg. 13.
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`Case 2:22-cv-11408-TGB ECF No. 10-8, PageID.212 Filed 07/20/22 Page 22 of 27
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`U.S. Patent No. 8,467,366: Claim 1(f)
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`"the ranging signal exhibits a low peak-to-average power ratio in the time domain; and"
`the ranging signal exhibits a low peak-to-
`The ranging signal used with Tesla’s Accused Products exhibits a low peak-to-average power ratio in the time
`average power ratio in the time domain;
`domain. E.g.,
`and
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`The RACH preamble is generated from a Zadoff-Chu sequence.
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`See e.g., 3GPP TS 36.211 V8.9.0 at pg. 39.
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`Zadoff-Chu sequences have a low peak-to-average power ratio.
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`See: Dahlman, Parkvall, Skold, 4G LTE-Advanced Pro and The Road to 5G, Third Edition, § 11.3.1.4.
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`Case 2:22-cv-11408-TGB ECF No. 10-8, PageID.213 Filed 07/20/22 Page 23 of 27
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`U.S. Patent No. 8,467,366: Claim 1(f)
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`"the ranging signal exhibits a low peak-to-average power ratio in the time domain; and"
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`See: Sesia, Toufik, Baker, LTE, The UMTS Long Term Evolution from Theory to Practice (2009), § 7.2.1.
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`Case 2:22-cv-11408-TGB ECF No. 10-8, PageID.214 Filed 07/20/22 Page 24 of 27
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`U.S. Patent No. 8,467,366: Claim 1(g)
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`"the ranging subchannel comprises at least one block of subcarriers within the communication channel and "
`the ranging subchannel comprises at least
`The ranging subchannel used with Tesla’s Accused Products comprises at least one block of subcarriers within
`one block of subcarriers within the
`the communication channel. E.g.,
`communication channel and
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`The PRACH uses 6 PRBs.
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`See e.g., 3GPP TS 36.213 V8.8.0 at pg. 16.
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`The 6 PRBs used for the PRACH are divided such as into 864 subcarriers for preamble formats 0-3.
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`Case 2:22-cv-11408-TGB ECF No. 10-8, PageID.215 Filed 07/20/22 Page 25 of 27
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`U.S. Patent No. 8,467,366: Claim 1(g)
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`"the ranging subchannel comprises at least one block of subcarriers within the communication channel and "
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`Source: Kahn, Farooq, LTE for 4G Mobile Broadband § 10.2.
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`Case 2:22-cv-11408-TGB ECF No. 10-8, PageID.216 Filed 07/20/22 Page 26 of 27
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`power levels of subcarriers at both ends of
`a block are set to zero.
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`The power levels of subcarriers at both ends of a block are set to zero. E.g.,
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`Out of the 864 subcarriers within the six PRBs, only 839 subcarriers are used with 12.5 subcarriers on each
`side nulled, that is, set to zero.
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`See e.g., 3GPP TS 36.211 V8.9.0 at pg. 40.
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`See e.g., 3GPP TS 36.211 V8.9.0 at pg. 43.
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`Case 2:22-cv-11408-TGB ECF No. 10-8, PageID.217 Filed 07/20/22 Page 27 of 27
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`Source: Kahn, Farooq, LTE for 4G Mobile Broadband § 10.2.
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