Case 2:22-md-03034-TGB ECF No. 265-8, PageID.28619 Filed 07/18/24 Page 1 of 7
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`Exhibit G
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`Exhibit G
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`Case 2:22-md-03034-TGB ECF No. 265-8, PageID.28620 Filed 07/18/24 Page 2 of 7
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`Page 1
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`UNITED STATES PATENT AND TRADEMARK OFFICE
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
` VOLKSWAGEN GROUP OF AMERICA, INC.
` Petitioner,
`
` V.
`
` NEO WIRELESS LLC,
` Owner.
`
` Case IPR 2022-01537
` U.S. Patent No. 10,075,941
`
`IPR2022-01537
`Neo Wireless LLC Exhibit 2027
`Page 1
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`
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`Case 2:22-md-03034-TGB ECF No. 265-8, PageID.28621 Filed 07/18/24 Page 3 of 7
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`Page 103
` MR. RIFFE: Objection. Calls for a legal
`conclusion.
` A. Well, here the claim language itself
`provides a guide for what a subchannel configuration
`is. So it's right in the wherein clause. Starting
`at line 25 it says: "The corresponding subchannel
`configuration characterized by distributed
`subcarriers or localized carriers in the frequency
`domain."
` BY MR. HENDIFAR:
` Q. Right. I'm not asking you what the
`configuration entails -- well, I think I may -- let
`me ask you a more fundamental question then.
` Is it your opinion that claim 1 requires
`the control message that is transmitted to the mobile
`station to include an actual indicator that specifies
`whether the subchannel configuration is distributed
`or localized?
` MR. RIFFE: Objection. Calls for a legal
`conclusion.
` A. I don't think that's what the claim says.
`It says that there's an indicator. That's at Line
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`IPR2022-01537
`Neo Wireless LLC Exhibit 2027
`Page 103
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`Case 2:22-md-03034-TGB ECF No. 265-8, PageID.28622 Filed 07/18/24 Page 4 of 7
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`Page 104
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`21. It's an indicator of the corresponding
`subchannel configuration. That's in lines 21 and 22.
` The last part of the claim starting at
`lines 25 through 28 just require that the
`corresponding subchannel configuration is
`characterized by distributed subcarriers or localized
`subcarriers.
` That's what's within the scope of the
`claim. So starting at line 25, that's just
`indicating a characterization of the alternative
`subcarrier or subchannel configurations.
` BY MR. HENDIFAR:
` Q. So if I understood you correctly -- and
`please correct me if I'm wrong -- in your opinion,
`claim 1 does not require that the indicator in the
`control message actually indicates in the control
`message whether the subchannel configuration is
`localized or distributed, correct?
` MR. RIFFE: Objection. Mischaracterizes
`testimony. Calls for a legal conclusion.
` A. Well, what the claim language requires is
`an indicator of the corresponding subchannel
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`IPR2022-01537
`Neo Wireless LLC Exhibit 2027
`Page 104
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`Case 2:22-md-03034-TGB ECF No. 265-8, PageID.28623 Filed 07/18/24 Page 5 of 7
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`Page 105
`configuration. That's what the indicator is. The
`claim language then further defines what is meant by
`subchannel configuration in terms of its
`characteristic.
` BY MR. HENDIFAR:
` Q. I don't believe that was responsive to my
`question, but let me start more fundamentally.
` Do you believe that the claim requires,
`for example, a bit in the control message that
`indicates whether the subchannel configuration is
`localized or distributed?
` MR. RIFFE: Objection. Calls for a legal
`conclusion.
` A. No. I don't think that this claim
`requires that said bit. It just requires an
`indicator of the subchannel configuration. It
`doesn't say that the indicator has to indicate what
`kind of configuration. It just has to be an
`indicator of the subchannel configuration.
` BY MR. HENDIFAR:
` Q. So then, if I understood you correctly, in
`your opinion claim 1 does not require that the
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`IPR2022-01537
`Neo Wireless LLC Exhibit 2027
`Page 105
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`Case 2:22-md-03034-TGB ECF No. 265-8, PageID.28624 Filed 07/18/24 Page 6 of 7
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`Page 108
`the control message only needs to indicate the bitmap
`of the assigned or allocated subcarriers, but it
`doesn't actually have to indicate whether those
`subcarriers are distributed or localized, correct?
` MR. RIFFE: Objection. Calls for a legal
`conclusion. Incomplete hypothetical.
` A. Well, in terms of the claim language, the
`claim language doesn't state that there needs to be
`an expressed indication of whether distributed or
`localized subcarriers are used.
` So under this hypothetical, then you have
`a bitmap. That bitmap could be indicating a
`subcarrier configuration. I think there's not enough
`there to completely analyze the claim because then
`you would also have to look at whether the subcarrier
`configuration that's indicated can be characterized
`by distributed subcarriers or localized subcarriers.
` BY MR. HENDIFAR:
` Q. Thank you for that. Let me then complete
`my hypothetical.
` If a control message contains a bitmap of
`subcarriers that are allocated to a user and those
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`IPR2022-01537
`Neo Wireless LLC Exhibit 2027
`Page 108
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`Case 2:22-md-03034-TGB ECF No. 265-8, PageID.28625 Filed 07/18/24 Page 7 of 7
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`Page 109
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`allocated subcarriers can as a matter of
`characteristics be either distributed or localized,
`does claim 1 require the control message to also
`expressly inform the mobile user or have an
`indication to the mobile user that the allocated
`subcarriers are distributed or localized?
` MR. RIFFE: Objection. Form. Calls for a
`legal conclusion. Incomplete hypothetical.
` A. I think I may have already answered this.
`If I understand your question, you're asking if the
`claim language requires a specific explicit
`indication of whether the subchannel configuration is
`distributed or localized by, for instance, a bit
`indicating that.
` I think we discussed this already, and
`looking at the claim language that does not appear to
`be a requirement.
` BY MR. HENDIFAR:
` Q. That was my question, and I appreciate the
`explanation.
` Staying on that same portion of the claim,
`the claim states that "the antenna transmission
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`IPR2022-01537
`Neo Wireless LLC Exhibit 2027
`Page 109
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