Case 2:22-md-03034-TGB ECF No. 114-1, PageID.8772 Filed 01/18/23 Page 1 of 7
`
`Exhibit A
`
`
`
`Exhibit A
`
`
`
`Case 2:22-md-03034-TGB ECF No. 114-1, PageID.8773 Filed 01/18/23 Page 2 of 7
`
`Exhibit A
`
`Agreed Claim Terms12
`Claims
`’366 Patent, Claim 1
`
`Joint Proposed Construction
`The preamble is limiting. Plain and
`ordinary meaning.
`
`#
`
`1
`
`Claim Term
`“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
`
`1 Volkswagen Grp. of Am., Inc. and Volkswagen Grp. of Am. Chattanooga Operations, LLC, do not take a
`position on the proposed constructions for any of the Agreed Claim Terms. That said, Volkswagen Grp. of Am.,
`Inc. and Volkswagen Grp. of Am. Chattanooga Operations, LLC understand that they will be bound by any claim
`construction ruling set forth by the Court.
`2 Neo Wireless objects to the Volkswagen Defendants’ decision to take no position on any claim terms
`(contravening the parties’ agreed Discovery Plan, which Volkswagen signed). This is an attempt by the
`Volkswagen Defendants, in the IPRs that they alone filed, to adopt broad interpretations to support their invalidity
`positions; while accepting the benefit of the other Defendants’ narrow, incompatible interpretations in this Court to
`support their non-infringement positions. It is especially bizarre in the context of this Exhibit, which presents
`agreed claim constructions (that one defendant apparently does not agree to). Neo is continuing to meet and confer
`with Volkswagen about this issue.
`
`
`
`1
`
`
`
`Case 2:22-md-03034-TGB ECF No. 114-1, PageID.8774 Filed 01/18/23 Page 3 of 7
`
`Exhibit A
`
`channel, the mobile
`station comprising:”
`
`“In an orthogonal
`frequency division
`multiple access
`(OFDMA) wireless
`communication system,
`a method for signal
`transmission by a
`mobile station to a
`serving base station via
`a communication
`channel, the method
`comprising:”
`
`
`“A mobile station
`comprising:”
`
`“A mobile device in a
`wireless packet system
`using a frame structure
`of multiple frames for
`transmission, each
`frame comprising a
`plurality of time
`intervals, each time
`
`2
`
`3
`
`4
`
`
`
`’366 Patent, Claim 17
`
`The preamble is limiting. Plain and
`ordinary meaning.
`
`’908 Patent, Claim 1
`
`’450 Patent, Claim 7
`
`The preamble is limiting. Plain and
`ordinary meaning.
`
`The preamble is limiting. Plain and
`ordinary meaning.
`
`2
`
`
`
`Case 2:22-md-03034-TGB ECF No. 114-1, PageID.8775 Filed 01/18/23 Page 4 of 7
`
`Exhibit A
`
`interval comprising a
`plurality of orthogonal
`frequency division
`multiplexing (OFDM)
`symbols, and each
`OFDM symbol
`containing a plurality of
`frequency subcarriers,
`the mobile device
`configured to:”
`
`“A link adaption
`method by a mobile
`station served by a
`serving base station in
`an Orthogonal
`Frequency Division
`Multiplexing (OFDM)
`communication system,
`the communication
`system utilizing a
`transmission structure
`with time slots in the
`time domain and
`frequency subchannels
`in the frequency
`domain, the method
`comprising:”
`
`5
`
`
`
`’941 Patent, Claim 8
`
`The preamble is limiting. Plain and
`ordinary meaning.
`
`3
`
`
`
`Case 2:22-md-03034-TGB ECF No. 114-1, PageID.8776 Filed 01/18/23 Page 5 of 7
`
`Exhibit A
`
`6
`
`7
`
`8
`
`
`
`
`“A mobile station
`served by a serving base
`station in an Orthogonal
`Frequency Division
`Multiplexing (OFDM)
`communication system,
`the communication
`system utilizing a
`transmission structure
`with time slots in the
`time domain and
`frequency subchannels
`in the frequency
`domain, the mobile
`station comprising a
`receiver configured to:”
`
`“A mobile device in an
`Orthogonal Frequency
`Division Multiplexing
`(OFDM)
`communication system,
`the mobile device
`comprising”
`“An orthogonal
`frequency division
`multiple access
`
`’941 Patent, Claim 13
`
`The preamble is limiting. Plain and
`ordinary meaning.
`
`’302 Patent, Claim 23
`
`The preamble is limiting. Plain and
`ordinary meaning.
`
`’512 Patent, Claim 15
`
`The preamble is limiting. Plain and
`ordinary meaning.
`
`4
`
`
`
`Case 2:22-md-03034-TGB ECF No. 114-1, PageID.8777 Filed 01/18/23 Page 6 of 7
`
`Exhibit A
`
`(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 method performed by
`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 method
`comprising:
`
`“time-frequency
`coordinate”
`
`“wherein modular
`coding is applied to the
`time-frequency resource
`units in the segment of
`
`9
`
`10
`
`11
`
`
`
`’512 Patent, Claim 23
`
`The preamble is limiting. Plain and
`ordinary meaning.
`
`’450 Patent, Claim 7
`
`“one-dimensional time-frequency
`coordinate”
`
`’450 Patent, Claim 11
`
`“wherein a modular coding scheme is
`applied to the time-frequency resource
`units in the segment of time-frequency
`resource”
`
`5
`
`
`
`Case 2:22-md-03034-TGB ECF No. 114-1, PageID.8778 Filed 01/18/23 Page 7 of 7
`
`Exhibit A
`
`time-frequency
`resource”
`
`
`
`
`
`6
`
`
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