Case 2:22-md-03034-TGB ECF No. 30-13, PageID.1012 Filed 07/20/22 Page 1 of 35
`
`Amended
`
`Exhibit 12
`
`
`
`Amended
`
`Exhibit 12
`
`
`
`Case 2:22-md-03034-TGB ECF No. 30-13, PageID.1013 Filed 07/20/22 Page 2 of 35
`
`
`
`
`
`
`Exhibit 12
`Claim 23 of U.S. Patent No. 10,771,302
`
`
`
`
`
`1
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`Case 2:22-md-03034-TGB ECF No. 30-13, PageID.1014 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
`VW’s Accused Products include vehicles equipped with components and/or devices that enable connectivity to
`Frequency Division Multiplexing
`4G/LTE networks and services, including services sold and provided by VW.
`(OFDM) communication system, the
`
`mobile device comprising:
`To the extent the preamble is considered a limitation, VW’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.
`
`
`
`
`
`
`
`2
`
`
`
`
`
`
`Case 2:22-md-03034-TGB ECF No. 30-13, PageID.1015 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.
`
`
`
`
`
`
`
`
`
`
`3
`
`
`
`
`
`
`Case 2:22-md-03034-TGB ECF No. 30-13, PageID.1016 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.
`
`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.
`
`
`
`
`See e.g., 3GPP TS 36.300 V8.12.0 at pg. 25.
`
`
`
`
`
`
`
`
`
`
`4
`
`
`
`
`
`
`Case 2:22-md-03034-TGB ECF No. 30-13, PageID.1017 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.
`
`
`
`
`
`
`
`
`
`
`5
`
`
`
`
`
`
`Case 2:22-md-03034-TGB ECF No. 30-13, PageID.1018 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.
`
`
`
`
`
`See e.g., 3GPP TS 36.101 V8.29.0 at pg. 15.
`
`
`
`
`6
`
`
`
`
`
`
`
`
`Case 2:22-md-03034-TGB ECF No. 30-13, PageID.1019 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.
`
`
`
`
`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.
`
`
`
`
`
`
`
`
`
`
`7
`
`
`
`
`
`
`Case 2:22-md-03034-TGB ECF No. 30-13, PageID.1020 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.
`
`
`
`
`
`
`
`
`
`
`8
`
`
`
`
`
`
`Case 2:22-md-03034-TGB ECF No. 30-13, PageID.1021 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).
`
`
`See e.g., 3GPP TS 36.300 V8.12.0 at pg. 31.
`
`
`
`
`See e.g., 3GPP TS 36.211 V8.9.0 at pg. 16.
`
`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.
`
`
`
`
`
`
`
`
`See e.g., 3GPP TS 36.211 V8.9.0 at pg. 20.
`
`
`
`
`9
`
`
`
`
`
`
`
`
`Case 2:22-md-03034-TGB ECF No. 30-13, PageID.1022 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.
`
`
`
`
`
`
`
`
`
`
`10
`
`
`
`
`
`
`
`
`Case 2:22-md-03034-TGB ECF No. 30-13, PageID.1023 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:”
`
`
`
`
`
`
`
`
`
`See e.g., 4G LTE=Advanced Pro and The Road to 5G, Third Edition, Dahlman et al, §7.4.1.6.
`
`
`
`
`
`11
`
`
`
`
`
`
`Case 2:22-md-03034-TGB ECF No. 30-13, PageID.1024 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
`VW’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.
`
`
`
`
`
`
`
`
`
`12
`
`
`
`
`
`
`
`
`Case 2:22-md-03034-TGB ECF No. 30-13, PageID.1025 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.
`
`
`
`
`
`See e.g., 3GPP TS 36.331 V8.21.0 at p. 122.
`
`13
`
`
`
`
`
`
`
`
`
`
`Case 2:22-md-03034-TGB ECF No. 30-13, PageID.1026 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.
`
`
`
`
`
`
`
`
`
`14
`
`
`
`
`
`
`Case 2:22-md-03034-TGB ECF No. 30-13, PageID.1027 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.
`
`
`
`
`
`
`
`
`
`15
`
`
`
`
`
`
`Case 2:22-md-03034-TGB ECF No. 30-13, PageID.1028 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.
`
`
`
`
`
`
`
`
`
`16
`
`
`
`
`
`
`Case 2:22-md-03034-TGB ECF No. 30-13, PageID.1029 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.
`
`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.
`
`
`
`
`
`
`
`
`
`See e.g., 3GPP TS 36.213 V10.13.0 at pg. 81.
`
`
`
`
`17
`
`
`
`
`
`
`
`
`Case 2:22-md-03034-TGB ECF No. 30-13, PageID.1030 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.
`
`
`
`
`
`
`
`
`
`
`
`18
`
`
`
`
`
`
`Case 2:22-md-03034-TGB ECF No. 30-13, PageID.1031 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:"
`VW’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.
`
`
`
`
`
`
`
`
`
`19
`
`
`
`
`
`
`Case 2:22-md-03034-TGB ECF No. 30-13, PageID.1032 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.
`
`
`
`
`
`
`
`
`20
`
`
`
`
`
`
`
`
`
`
`Case 2:22-md-03034-TGB ECF No. 30-13, PageID.1033 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.
`
`
`
`
`
`
`
`21
`
`
`
`
`
`
`Case 2:22-md-03034-TGB ECF No. 30-13, PageID.1034 Filed 07/20/22 Page 23 of 35
`
`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 VW’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
`
`
`
`
`
`
`See e.g., 3GPP TS 36.211 V8.9.0 at pg. 28.
`
`22
`
`
`
`
`
`
`
`
`Case 2:22-md-03034-TGB ECF No. 30-13, PageID.1035 Filed 07/20/22 Page 24 of 35
`
`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.
`
`
`See e.g., 3GPP TS 36.211 V8.9.0 at pg. 30.
`
`
`
`23
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`Case 2:22-md-03034-TGB ECF No. 30-13, PageID.1036 Filed 07/20/22 Page 25 of 35
`
`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).
`
`
`
`
`
`24
`
`
`
`
`
`
`
`
`
`
`
`
`Case 2:22-md-03034-TGB ECF No. 30-13, PageID.1037 Filed 07/20/22 Page 26 of 35
`
`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 VW’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.
`
`SRS does not overlap in the frequency domain with PUCCH subcarriers.
`
`
`
`
`
`
`
`
`
`25
`
`
`
`
`
`
`Case 2:22-md-03034-TGB ECF No. 30-13, PageID.1038 Filed 07/20/22 Page 27 of 35
`
`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.
`
`
`
`
`
`
`
`
`
`
`26
`
`
`
`
`
`
`Case 2:22-md-03034-TGB ECF No. 30-13, PageID.1039 Filed 07/20/22 Page 28 of 35
`
`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.
`
`
`
`
`
`
`
`
`
`27
`
`
`
`
`
`
`Case 2:22-md-03034-TGB ECF No. 30-13, PageID.1040 Filed 07/20/22 Page 29 of 35
`
`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.
`
`
`
`
`
`
`
`
`
`28
`
`
`
`
`
`
`Case 2:22-md-03034-TGB ECF No. 30-13, PageID.1041 Filed 07/20/22 Page 30 of 35
`
`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."
`
`
`
`
`
`
`
`
`
`29
`
`
`
`
`
`
`Case 2:22-md-03034-TGB ECF No. 30-13, PageID.1042 Filed 07/20/22 Page 31 of 35
`
`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.
`
`
`
`
`30
`
`
`
`
`
`
`
`
`Case 2:22-md-03034-TGB ECF No. 30-13, PageID.1043 Filed 07/20/22 Page 32 of 35
`
`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.
`
`
`
`
`
`
`
`
`
`31
`
`
`
`
`
`
`Case 2:22-md-03034-TGB ECF No. 30-13, PageID.1044 Filed 07/20/22 Page 33 of 35
`
`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."
`
`
`
`
`
`
`
`32
`
`
`
`
`
`
`
`
`Case 2:22-md-03034-TGB ECF No. 30-13, PageID.1045 Filed 07/20/22 Page 34 of 35
`
`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."
`
`
`
`
`
`
`
`33
`
`
`
`
`
`
`
`
`Case 2:22-md-03034-TGB ECF No. 30-13, PageID.1046 Filed 07/20/22 Page 35 of 35
`
`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. 28-31.
`
`
`
`
`
`
`34
`
`
`
`
`
Accessing this document will incur an additional charge of $.
After purchase, you can access this document again without charge.
Accept $ Charge
Still Working On It
This document is taking longer than usual to download. This can happen if we need to contact the court directly to obtain the document and their servers are running slowly.
Give it another minute or two to complete, and then try the refresh button.
A few More Minutes ... Still Working
It can take up to 5 minutes for us to download a document if the court servers are running slowly.
Thank you for your continued patience.
This document could not be displayed.
We could not find this document within its docket. Please go back to the docket page and check the link. If that does not work, go back to the docket and refresh it to pull the newest information.
Your account does not support viewing this document.
You need a Paid Account to view this document. Click here to change your account type.
Your account does not support viewing this document.
Set your membership
status to view this document.
With a Docket Alarm membership, you'll
get a whole lot more, including:
- Up-to-date information for this case.
- Email alerts whenever there is an update.
- Full text search for other cases.
- Get email alerts whenever a new case matches your search.
One Moment Please
The filing “” is large (MB) and is being downloaded.
Please refresh this page in a few minutes to see if the filing has been downloaded. The filing will also be emailed to you when the download completes.
Your document is on its way!
If you do not receive the document in five minutes, contact support at support@docketalarm.com.
Sealed Document
We are unable to display this document, it may be under a court ordered seal.
If you have proper credentials to access the file, you may proceed directly to the court's system using your government issued username and password.
Access Government Site
