Case 2:22-cv-11408-TGB ECF No. 10-9, PageID.218 Filed 07/20/22 Page 1 of 25
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`Amended
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`Exhibit 8
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`Amended
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`Exhibit 8
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`Case 2:22-cv-11408-TGB ECF No. 10-9, PageID.219 Filed 07/20/22 Page 2 of 25
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`Exhibit 8
`Claim 11 of U.S. Patent No. 10,833,908
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`Case 2:22-cv-11408-TGB ECF No. 10-9, PageID.220 Filed 07/20/22 Page 3 of 25
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`US Patent No. 10,833,908: Claim 11(a)
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` A method performed by a mobile station, the method comprising:”
`"11.
` A method performed by a mobile
`Tesla’s Accused Products include vehicles equipped with components and/or devices that enable
`11.
`station, the method comprising:
`connectivity to 4G/LTE networks and services, including services sold and provided by Tesla.
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`To the extent the preamble is considered a limitation, Tesla’s Accused Products meet the preamble of
`the ’908 patent. E.g.,
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`The LTE specification (Series 36, Release 8) supports user equipment (UE) to perform a random access
`(RACH) 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 provides access to multiple users (user equipments (UEs)) through multiple
`cells associated with multiple eNodeBs.
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`Case 2:22-cv-11408-TGB ECF No. 10-9, PageID.221 Filed 07/20/22 Page 4 of 25
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`"11.
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`US Patent No. 10,833,908: Claim 11(a)
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` A method performed by a mobile station, the method comprising:”
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`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. 10-9, PageID.222 Filed 07/20/22 Page 5 of 25
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`US Patent No. 10,833,908: Claim 11(b)
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`“transmitting, to the base station, an random access signal followed by a guard period in only a portion of the frequency band, wherein the random
`access signal includes a sequence associated with the base station,”
`transmitting, to a base station, a first uplink
`Tesla’s Accused Products transmit, to a base station, a first uplink signal within a frequency band, wherein
`signal within a frequency band, wherein the
`the first uplink signal is an OFDM signal and utilizes a frame format comprising a plurality of timeslots,
`first uplink signal
`is an orthogonal
`each timeslot comprising a plurality of OFDM symbols. E.g.,
`frequency division multiplexing (OFDM)
`signal and utilizes a
`frame
`format
`comprising a plurality of timeslots, each
`timeslot comprising a plurality of OFDM
`symbols;
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` frequency band used for LTE communication has an associated channel bandwidth over which uplink and
`downlink communication is transmitted between the UEs and the eNodeBs.
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`Case 2:22-cv-11408-TGB ECF No. 10-9, PageID.223 Filed 07/20/22 Page 6 of 25
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`US Patent No. 10,833,908: Claim 11(b)
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`“transmitting, to the base station, an random access signal followed by a guard period in only a portion of the frequency band, wherein the random
`access signal includes a sequence associated with the base station,”
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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. 10-9, PageID.224 Filed 07/20/22 Page 7 of 25
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`US Patent No. 10,833,908: Claim 11(b)
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`“transmitting, to the base station, an random access signal followed by a guard period in only a portion of the frequency band, wherein the random
`access signal includes a sequence associated with the base station,”
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`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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`See e.g., 3GPP TS 36.300 V8.12.0 at pgs. 27-28.
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`The UE transmits OFDM signals carrying data on the physical uplink shared channel (PUSCH).
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`Case 2:22-cv-11408-TGB ECF No. 10-9, PageID.225 Filed 07/20/22 Page 8 of 25
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`US Patent No. 10,833,908: Claim 11(b)
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`“transmitting, to the base station, an random access signal followed by a guard period in only a portion of the frequency band, wherein the random
`access signal includes a sequence associated with the base station,”
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`See e.g., 3GPP TS 36.211 V8.9.0 at pg. 13.
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`In LTE, both the type 1 and type 2 frame structures include multiple time slots.
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`Case 2:22-cv-11408-TGB ECF No. 10-9, PageID.226 Filed 07/20/22 Page 9 of 25
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`US Patent No. 10,833,908: Claim 11(b)
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`“transmitting, to the base station, an random access signal followed by a guard period in only a portion of the frequency band, wherein the random
`access signal includes a sequence associated with the base station,”
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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. 10-9, PageID.227 Filed 07/20/22 Page 10 of 25
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`US Patent No. 10,833,908: Claim 11(b)
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`“transmitting, to the base station, an random access signal followed by a guard period in only a portion of the frequency band, wherein the random
`access signal includes a sequence associated with the base station,”
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`See e.g., 3GPP TS 36.211 V8.9.0 at pg. 10.
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`Each time slot includes 7 symbols for a normal cyclic prefix (6 for extended).
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`Case 2:22-cv-11408-TGB ECF No. 10-9, PageID.228 Filed 07/20/22 Page 11 of 25
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`US Patent No. 10,833,908: Claim 11(b)
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`“transmitting, to the base station, an random access signal followed by a guard period in only a portion of the frequency band, wherein the random
`access signal includes a sequence associated with the base station,”
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`See e.g., 3GPP TS 36.211 V8.9.0 at pg. 12.
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`Case 2:22-cv-11408-TGB ECF No. 10-9, PageID.229 Filed 07/20/22 Page 12 of 25
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`transmitting, to the base station, an
`random access signal followed by a guard
`period in only a portion of the frequency
`band, wherein the random access signal
`includes a sequence associated with the
`base station,
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`US Patent No. 10,833,908: Claim 11(c)
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`“transmitting, to the base station, an random access signal followed by a guard period in only a portion of the frequency band, wherein the random access
`signal includes a sequence associated with the base station,”
`Tesla’s Accused Products transmit, to the base station, an random access signal followed by a guard period
`in only a portion of the frequency band, wherein the random access signal includes a sequence associated
`with the base station. E.g.,
`
`The random access preamble transmitted on the PRACH occupies a bandwidth corresponding to 6
`consecutive resource blocks in both the type 1 and type 2 frame structures, which is a fraction of the overall
`channel bandwidth (frequency band) for any other bandwidth than the smallest. The range of the overall
`channel bandwidth is the bandwidth of 6 to 100 resource blocks, corresponding to bandwidths 1.4MHz to
`20MHz, with 20MHz being the most commonly used bandwidth. The Accused Products are configured to
`operate within a channel bandwidth of more than 6 resource blocks.
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`...
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`Case 2:22-cv-11408-TGB ECF No. 10-9, PageID.230 Filed 07/20/22 Page 13 of 25
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`US Patent No. 10,833,908: Claim 11(c)
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`“transmitting, to the base station, an random access signal followed by a guard period in only a portion of the frequency band, wherein the random access
`signal includes a sequence associated with the base station,”
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`See e.g., 3GPP TS 36.211 V8.9.0 at pgs. 33, 35-36.
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`Case 2:22-cv-11408-TGB ECF No. 10-9, PageID.231 Filed 07/20/22 Page 14 of 25
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`US Patent No. 10,833,908: Claim 11(c)
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`“transmitting, to the base station, an random access signal followed by a guard period in only a portion of the frequency band, wherein the random access
`signal includes a sequence associated with the base station,”
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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. 10-9, PageID.232 Filed 07/20/22 Page 15 of 25
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`US Patent No. 10,833,908: Claim 11(c)
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`“transmitting, to the base station, an random access signal followed by a guard period in only a portion of the frequency band, wherein the random access
`signal includes a sequence associated with the base station,”
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`See e.g., 3GPP TS 36.211 V8.9.0 at pg. 13.
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`The random access burst includes a guard time added after the preamble transmission.
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`See e.g., 3GPP TS 36.300 V8.12.0 at pg. 29.
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`...
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`Case 2:22-cv-11408-TGB ECF No. 10-9, PageID.233 Filed 07/20/22 Page 16 of 25
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`US Patent No. 10,833,908: Claim 11(c)
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`“transmitting, to the base station, an random access signal followed by a guard period in only a portion of the frequency band, wherein the random access
`signal includes a sequence associated with the base station,”
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`See Sesia, Toufik and Baker, “LTE: The UMTS Long Term Evolution From Theory to Practice”, at pgs.
`377-378.
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`Case 2:22-cv-11408-TGB ECF No. 10-9, PageID.234 Filed 07/20/22 Page 17 of 25
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`US Patent No. 10,833,908: Claim 11(c)
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`“transmitting, to the base station, an random access signal followed by a guard period in only a portion of the frequency band, wherein the random access
`signal includes a sequence associated with the base station,”
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`See e.g., 3GPP TS 36.211 V8.9.0 at p. 39.
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`See e.g., 3GPP TS 36.211 V8.9.0 at p. 40.
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`Case 2:22-cv-11408-TGB ECF No. 10-9, PageID.235 Filed 07/20/22 Page 18 of 25
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`US Patent No. 10,833,908: Claim 11(d)
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`“wherein a time duration of a combination of the random access signal and the guard period is greater than a time duration of at least one of the plurality of
`OFDM symbols; and”
`The time duration of a combination of the random access signal and the guard period implemented using
`Tesla’s Accused Products is greater than a time duration of at least one of the plurality of OFDM symbols.
`E.g.,
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`LTE defines a basic time unit (Ts ) and is equal to 1/ (15000 x 2048) seconds. The symbol time is 2048 *Ts
`or 66.7 µs.
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`wherein a time duration of a
`combination of the random access
`signal and the guard period is
`greater than a time duration of at
`least one of the plurality of OFDM
`symbols; and
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` ...
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` ...
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`See e.g., 3GPP TS 36.211 V8.9.0 at pgs. 7-8.
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`An LTE slot typically has 7 symbols, except for extended cyclic prefix which has 6 symbols. As a result, a
`symbol for a typical slot is ~2192 base time intervals and for extended cyclic prefix is ~2560 basic time
`intervals.
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`...
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`See e.g., 3GPP TS 36.300 V8.12.0 at pgs. 27-28.
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`Case 2:22-cv-11408-TGB ECF No. 10-9, PageID.236 Filed 07/20/22 Page 19 of 25
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`US Patent No. 10,833,908: Claim 11(d)
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`“wherein a time duration of a combination of the random access signal and the guard period is greater than a time duration of at least one of the plurality of
`OFDM symbols; and”
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`Case 2:22-cv-11408-TGB ECF No. 10-9, PageID.237 Filed 07/20/22 Page 20 of 25
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`US Patent No. 10,833,908: Claim 11(d)
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`“wherein a time duration of a combination of the random access signal and the guard period is greater than a time duration of at least one of the plurality of
`OFDM symbols; and”
`See e.g., 3GPP TS 36.211 V8.9.0 at pg. 12.
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`See e.g., 3GPP TS 36.211 V8.9.0 at pg. 13.
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`Preamble formats 0-4 have sequence lengths of 4096 to 49,152 basic time intervals.
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`Case 2:22-cv-11408-TGB ECF No. 10-9, PageID.238 Filed 07/20/22 Page 21 of 25
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`US Patent No. 10,833,908: Claim 11(d)
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`“wherein a time duration of a combination of the random access signal and the guard period is greater than a time duration of at least one of the plurality of
`OFDM symbols; and”
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`See e.g., 3GPP TS 36.211 V8.9.0 at pg. 33.
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`Case 2:22-cv-11408-TGB ECF No. 10-9, PageID.239 Filed 07/20/22 Page 22 of 25
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`US Patent No. 10,833,908: Claim 11(e)
`“receiving, from the base station, a response message.”
`Tesla’s Accused Products receive, from the base station, a response message. E.g.,
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`Once the Random Access Preamble is transmitted, the UE shall monitor the PDCCH for Random Access
`Response(s) identified by the RA-RNTI. The random access response is sent by the eNB and received by
`the UE via the PDSCH and addresses with the RA-RNTI ID.
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`receiving, from the base station, a response
`message.
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`Case 2:22-cv-11408-TGB ECF No. 10-9, PageID.240 Filed 07/20/22 Page 23 of 25
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`US Patent No. 10,833,908: Claim 11(e)
`“receiving, from the base station, a response message.”
`See e.g., 3GPP TS 36.300 V8.12.0 at pgs. 52-53.
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`Case 2:22-cv-11408-TGB ECF No. 10-9, PageID.241 Filed 07/20/22 Page 24 of 25
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`US Patent No. 10,833,908: Claim 11(e)
`“receiving, from the base station, a response message.”
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`See e.g., 3GPP TS 36.300 V8.7.0 at pgs. 54 and 55.
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`See e.g., 3GPP TS 36.300 V8.12.0 at pg. 14.
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`Case 2:22-cv-11408-TGB ECF No. 10-9, PageID.242 Filed 07/20/22 Page 25 of 25
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`US Patent No. 10,833,908: Claim 11(e)
`“receiving, from the base station, a response message.”
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`See Sesia, Toufik and Baker, “LTE: The UMTS Long Term Evolution From Theory to Practice”, at pg. 374.
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