Case 2:22-md-03034-TGB ECF No. 96-2, PageID.2816 Filed 10/21/22 Page 1 of 721
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`EXHIBIT A
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`Case 2:22-md-03034-TGB ECF No. 96-2, PageID.2817 Filed 10/21/22 Page 2 of 721
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`Plaintiff’s Infringement
`Contentions to Ford
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`Case 2:22-md-03034-TGB ECF No. 96-2, PageID.2818 Filed 10/21/22 Page 3 of 721
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`Exhibit 366
`U.S. Patent No. 8,467,366
`Claims 1-5, 17, 20, 21
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`Case 2:22-md-03034-TGB ECF No. 96-2, PageID.2819 Filed 10/21/22 Page 4 of 721
`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
`To the extent the preamble is considered a limitation, Ford’s Accused Instrumentalities meet the preamble of
`division multiple access (OFDMA)
`claim 1 of the ’366 patent. E.g.,
`wireless communication system
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`comprising a plurality of base stations and
`Ford’s Accused Instrumentalities include vehicles equipped with cellular communication capabilities and
`mobile stations, a mobile station
`services made available thereupon for use and actually used in a wireless system compliant with the LTE
`configured to communicate with a serving
`standard starting at least at Release 8.
`base station in a cell via a communication
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`channel, the mobile station comprising:
`For example, Ford offers for sale, sells, and/or imports various vehicle models that are marketed and released
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`with LTE cellular functionality and perform methods thereof, including but not limited to the models listed in
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`the Plaintiff’s Disclosure Of Asserted Claims And Infringement Contentions.
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`The LTE specification (Series 36, Release 8) supports user equipment (UE) to perform a random access
`procedure.
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`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.
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`LTE networks, a wireless communication systems, have many eNodeBs, base stations.
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`Case 2:22-md-03034-TGB ECF No. 96-2, PageID.2820 Filed 10/21/22 Page 5 of 721
`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: "
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`See e.g., 3GPP TS 36.300 V8.12.0 at pg. 15.
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`The user equipment (UE), mobile stations, communicate with corresponding eNodeBs.
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`Case 2:22-md-03034-TGB ECF No. 96-2, PageID.2821 Filed 10/21/22 Page 6 of 721
`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: "
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`See e.g., 3GPP TS 36.300 V8.12.0 at pg. 18.
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`The LTE physical layer (PHY) uses OFDM (Orthogonal Frequency Division Multiplexing) for both the
`downlink and the uplink. For the uplink, LTE uses a specific type of OFDMA (Orthogonal Frequency
`Division Multiple Access) referred to as either discrete Fourier Transform Spread (DFTS)-OFDM, or as SC-
`FDMA (Single Carrier – Frequency Division Multiple Access) .
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`See e.g., 3GPP TS 36.300 V8.12.0 at pg. 25.
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`Case 2:22-md-03034-TGB ECF No. 96-2, PageID.2822 Filed 10/21/22 Page 7 of 721
`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: "
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`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-md-03034-TGB ECF No. 96-2, PageID.2823 Filed 10/21/22 Page 8 of 721
`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
`Ford’s Accused Instrumentalities each include an apparatus configured to transmit a data signal to the serving
`signal to the serving base station in the
`base station in the cell over a data subchannel, wherein the data subchannel comprises a plurality of adjacent or
`cell over a data subchannel, wherein the
`non-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, where the data is sent over a data
`within the communication channel; and
`subchannel formed at least form the set of assigned contiguous or adjacent Physical Resource Blocks (PRBs).
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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-md-03034-TGB ECF No. 96-2, PageID.2824 Filed 10/21/22 Page 9 of 721
`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 in the uplink.
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`See e.g., 3GPP TS 36.213 V8.8.0 at pg. 55.
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`Case 2:22-md-03034-TGB ECF No. 96-2, PageID.2825 Filed 10/21/22 Page 10 of 721
`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 (illustrating data subchannels
`in the uplink PUSCH)
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`Case 2:22-md-03034-TGB ECF No. 96-2, PageID.2826 Filed 10/21/22 Page 11 of 721
`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
`Ford’s Accused Instrumentalities each include an apparatus configured to transmit a ranging signal to the
`ranging signal to the serving base station
`serving base 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 random access preamble, a ranging signal, to the serving base station, the eNodeB, over a
`physical random access channel, a ranging subchannel for random access.
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`See e.g., 3GPP TS 36.300 V8.7.0 at pgs. 24 and 25.
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`See e.g., 3GPP TS 36.211 V8.9.0 at pg. 11.
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`The eNodeB defines physical frequency resources for the PRACH, the ranging subchannel. 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-md-03034-TGB ECF No. 96-2, PageID.2827 Filed 10/21/22 Page 12 of 721
`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-md-03034-TGB ECF No. 96-2, PageID.2828 Filed 10/21/22 Page 13 of 721
`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-md-03034-TGB ECF No. 96-2, PageID.2829 Filed 10/21/22 Page 14 of 721
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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 Ford’s Accused Instrumentalities is formed from a ranging sequence selected
`ranging sequence selected from a set of
`from a set 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 ranging signal is a transmitted PRACH preamble, which is a selected Zadoff-Chu sequence from a set of
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`Zadoff-Chu ranging sequences. 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. The response from the cell also includes ranging information, e.g., timing/alignment information.
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`Case 2:22-md-03034-TGB ECF No. 96-2, PageID.2830 Filed 10/21/22 Page 15 of 721
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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-md-03034-TGB ECF No. 96-2, PageID.2831 Filed 10/21/22 Page 16 of 721
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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-md-03034-TGB ECF No. 96-2, PageID.2832 Filed 10/21/22 Page 17 of 721
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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-md-03034-TGB ECF No. 96-2, PageID.2833 Filed 10/21/22 Page 18 of 721
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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 Ford’s Accused Instrumentalities lasts over a period of one or multiple
`one or multiple orthogonal frequency
`orthogonal frequency division multiplexing (OFDM) symbols. E.g.,
`division multiplexing (OFDM) symbols
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`and
`The PRACH preamble has a defined length, such as 3168 TS+ 24576 TS and lasts over a period of one or
`multiple orthogonal frequency division multiplexing (OFDM) symbols.
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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-md-03034-TGB ECF No. 96-2, PageID.2834 Filed 10/21/22 Page 19 of 721
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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-md-03034-TGB ECF No. 96-2, PageID.2835 Filed 10/21/22 Page 20 of 721
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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-md-03034-TGB ECF No. 96-2, PageID.2836 Filed 10/21/22 Page 21 of 721
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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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`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 compared to the longer
`preamble length of 0.9 to 2.28 ms for configurations 0-3. Accordingly, the ranging signal lasts over a period of
`one or multiple orthogonal frequency division multiplexing (OFDM) symbols.
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`Case 2:22-md-03034-TGB ECF No. 96-2, PageID.2837 Filed 10/21/22 Page 22 of 721
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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-md-03034-TGB ECF No. 96-2, PageID.2838 Filed 10/21/22 Page 23 of 721
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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 Ford’s Accused Instrumentalities exhibits a low peak-to-average power ratio in
`average power ratio in the time domain;
`the time 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-md-03034-TGB ECF No. 96-2, PageID.2839 Filed 10/21/22 Page 24 of 721
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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-md-03034-TGB ECF No. 96-2, PageID.2840 Filed 10/21/22 Page 25 of 721
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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 Ford’s Accused Instrumentalities comprises at least one block of subcarriers
`one block of subcarriers within the
`within 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. Thereby,
`the ranging subchannel includes at least one block of subcarriers.
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`Case 2:22-md-03034-TGB ECF No. 96-2, PageID.2841 Filed 10/21/22 Page 26 of 721
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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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`power levels of subcarriers at both ends of
`a block are set to zero.
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`Case 2:22-md-03034-TGB ECF No. 96-2, PageID.2842 Filed 10/21/22 Page 27 of 721
`U.S. Patent No. 8,467,366: Claim 1(h)
`“power levels of subcarriers at both ends of a block are set to zero.”
`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-md-03034-TGB ECF No. 96-2, PageID.2843 Filed 10/21/22 Page 28 of 721
`U.S. Patent No. 8,467,366: Claim 1(h)
`“power levels of subcarriers at both ends of a block are set to zero.”
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`Source: Kahn, Farooq, LTE for 4G Mobile Broadband § 10.2.
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`Case 2:22-md-03034-TGB ECF No. 96-2, PageID.2844 Filed 10/21/22 Page 29 of 721
`U.S. Patent No. 8,467,366: Claim 2
`“The mobile station of claim 1, wherein the subcarrier configuration of the ranging subchannel for the cell is different from subcarrier configurations of
`ranging subchannels for other cells.”
`The subcarrier configuration of the cell used by Ford’s Accused Instrumentalities is different from subcarrier
`configurations of ranging subchannels for other cells. E.g.,
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`Each cell uses a different preamble format and/or frame structure configuration as defined in the LTE
`specification. The starting PRB for the PRACH is defined by the parameter prach-FrequencyOffset
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`nRAPRBoffset and varies from cell-to-cell.
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`2. The mobile station of claim 1, wherein
`the subcarrier configuration of the ranging
`subchannel for the cell is different from
`subcarrier configurations of ranging
`subchannels for other cells.
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`See e.g., 3GPP TS 36.211 V8.9.0 at pg. 33.
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`Case 2:22-md-03034-TGB ECF No. 96-2, PageID.2845 Filed 10/21/22 Page 30 of 721
`U.S. Patent No. 8,467,366: Claim 2
`“The mobile station of claim 1, wherein the subcarrier configuration of the ranging subchannel for the cell is different from subcarrier configurations of
`ranging subchannels for other cells.”
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`Case 2:22-md-03034-TGB ECF No. 96-2, PageID.2846 Filed 10/21/22 Page 31 of 721
`U.S. Patent No. 8,467,366: Claim 2
`“The mobile station of claim 1, wherein the subcarrier configuration of the ranging subchannel for the cell is different from subcarrier configurations of
`ranging subchannels for other cells.”
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`Case 2:22-md-03034-TGB ECF No. 96-2, PageID.2847 Filed 10/21/22 Page 32 of 721
`U.S. Patent No. 8,467,366: Claim 2
`“The mobile station of claim 1, wherein the subcarrier configuration of the ranging subchannel for the cell is different from subcarrier configurations of
`ranging subchannels for other cells.”
`See e.g., 3GPP TS 36.211 V8.9.0 at pg. 33-34.
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`Case 2:22-md-03034-TGB ECF No. 96-2, PageID.2848 Filed 10/21/22 Page 33 of 721
`U.S. Patent No. 8,467,366: Claim 2
`“The mobile station of claim 1, wherein the subcarrier configuration of the ranging subchannel for the cell is different from subcarrier configurations of
`ranging subchannels for other cells.”
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`See e.g., 3GPP TS 36.211 V8.9.0 at pg. 34-35. See also generally id. at Section 5.7 (PRACH).
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`Case 2:22-md-03034-TGB ECF No. 96-2, PageID.2849 Filed 10/21/22 Page 34 of 721
`U.S. Patent No. 8,467,366: Claim 3
`" The mobile station of claim 1, wherein the set of ranging sequences for the cell is different from sets of ranging sequences for other cells."
`3. The mobile station of claim 1, wherein
`The set of ranging sequences for the cell used by Ford’s Accused Instrumentalities is different from sets of
`the set of ranging sequences for the cell is
`ranging sequences for other cells. E.g.,
`different from sets of ranging sequences
`
`for other cells.
`For LTE, the random access preamble are generated using Zadoff-Chu sequences, which are generated using
`various parameters that vary across cells:
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`
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`See e.g., 3GPP TS 36.211 V8.9.0 at pg. 39.
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`Case 2:22-md-03034-TGB ECF No. 96-2, PageID.2850 Filed 10/21/22 Page 35 of 721
`U.S. Patent No. 8,467,366: Claim 3
`" The mobile station of claim 1, wherein the set of ranging sequences for the cell is different from sets of ranging sequences for other cells."
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`Case 2:22-md-03034-TGB ECF No. 96-2, PageID.2851 Filed 10/21/22 Page 36 of 721
`U.S. Patent No. 8,467,366: Claim 3
`" The mobile station of claim 1, wherein the set of ranging sequences for the cell is different from sets of ranging sequences for other cells."
`
`See e.g., 3GPP TS 36.211 V8.9.0 at pg. 40-41.
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`Case 2:22-md-03034-TGB ECF No. 96-2, PageID.2852 Filed 10/21/22 Page 37 of 721
`U.S. Patent No. 8,467,366: Claim 3
`" The mobile station of claim 1, wherein the set of ranging sequences for the cell is different from sets of ranging sequences for other cells."
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`Case 2:22-md-03034-TGB ECF No. 96-2, PageID.2853 Filed 10/21/22 Page 38 of 721
`U.S. Patent No. 8,467,366: Claim 3
`" The mobile station of claim 1, wherein the set of ranging sequences for the cell is different from sets of ranging sequences for other cells."
`
`
`
`See e.g., 3GPP TS 36.211 V8.9.0 at pg. 42.
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`
` –
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`
`
`PRACH-Config
`
`The IE PRACH-ConfigSIB and IE PRACH-Config are used to specify the PRACH configuration in the system
`information and in the mobility control information, respectively.
`PRACH-Config information elements
`
`
`
`
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`-- ASN1START
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`36
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`Case 2:22-md-03034-TGB ECF No. 96-2, PageID.2854 Filed 10/21/22 Page 39 of 721
`U.S. Patent No. 8,467,366: Claim 3
`" The mobile station of claim 1, wherein the set of ranging sequences for the cell is different from sets of ranging sequences for other cells."
`PRACH-ConfigSIB ::=
`
`SEQUENCE {
`
`rootSequenceIndex
`
`
`
`INTEGER (0..837),
`
`prach-ConfigInfo
`
`
`
`
`PRACH-ConfigInfo
`}
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`
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`PRACH-Config ::=
`
`rootSequenceIndex
`
`prach-ConfigInfo
`
`}
`
`
`
`
`PRACH-ConfigInfo ::=
`
`
`
`prach-ConfigIndex
`
`
`
`highSpeedFlag
`
`
`zeroCorrelationZoneConfig
`
`prach-FreqOffset
`
`
`
`}
`
`-- ASN1STOP
`
`
`
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`
`
`SEQUENCE {
`
`
`INTEGER (0..837),
`
`
`PRACH-ConfigInfo
`
`SEQUENCE {
`
`INTEGER (0..63),
`
`BOOLEAN,
`
`INTEGER (0..15),
`
`INTEGER (0..94)
`
`
`
`
`
`
`
`
`
`OPTIONAL
`
`-- Need ON
`
`PRACH-Config field descriptions
`
`rootSequenceIndex
`Parameter: RACH_ROOT_SEQUENCE, see TS 36.211 [21, 5.7.1].
`prach-ConfigIndex
`Parameter: prach-ConfigurationIndex, see TS 36.211 [21, 5.7.1].
`highSpeedFlag
`Parameter: High-speed-flag, see TS 36.211, [21, 5.7.2].TRUE corresponds to Restricted set and FALSE to
`Unrestricted set.
`zeroCorrelationZoneConfig
`Parameter: NCS configuration, see TS 36.211, [21, 5.7.2: table 5.7.2-2] for preamble format 0..3 and TS 36.211, [21,
`5.7.2: table 5.7.2-3] for preamble format 4.
`prach-FreqOffset
`Parameter: prach-FrequencyOffset, see TS 36.211, [21, 5.7.1]. For TDD the value range is dependent on the value of
`prach-ConfigIndex.
`
`
`See e.g., 3GPP TS 36.331 V8.21.0, at pages 123-12.4
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`Case 2:22-md-03034-TGB ECF No. 96-2, PageID.2855 Filed 10/21/22 Page 40 of 721
`U.S. Patent No. 8,467,366: Claim 4
`"The mobile station of claim 1, wherein subcarriers in a block are contiguous in frequency."
`4. The mobile station of claim 1, wherein
`The subcarriers in the data subchannel used by Ford’s Accused Instrumentalities in a block are contiguous in
`subcarriers in a block are contiguous in
`frequency. E.g.,
`frequency.
`
`See Claim 1, element 1(b).
`
`The PRACH comprises 6 consecutive resource blocks where each PRB comprises 12 adjacent uplink data
`transmission subcarriers. The PRACH uses the 6 PRBs with a different subcarrier spacing than the uplink data
`transmission, but still uses contiguous subcarriers in frequency.
`
`See e.g., 3GPP TS 36.211 V8.9.0 at pg. 42.
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`
`
`See e.g., 3GPP TS 36.211 V8.9.0 at pg. 13.
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`Case 2:22-md-03034-TGB ECF No. 96-2, PageID.2856 Filed 10/21/22 Page 41 of 721
`U.S. Patent No. 8,467,366: Claim 4
`"The mobile station of claim 1, wherein subcarriers in a block are contiguous in frequency."
`
`
`See: Rumney, Moray, LTE and the Evolution to 4G Wireless § 3.2.8.3 at pg. 103.
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`
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`
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`See e.g., 3GPP TS 36.211 V8.9.0 at pg. 43.
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`Case 2:22-md-03034-TGB ECF No. 96-2, PageID.2857 Filed 10/21/22 Page 42 of 721
`U.S. Patent No. 8,467,366: Claim 4
`"The mobile station of claim 1, wherein subcarriers in a block are contiguous in frequency."
`
`
`
`Source: Kahn, Farooq, LTE for 4G Mobile Broadband § 10.2.
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`Case 2:22-md-03034-TGB ECF No. 96-2, PageID.2858 Filed 10/21/22 Page 43 of 721
`U.S. Patent No. 8,467,366: Claim 4
`"The mobile station of claim 1, wherein subcarriers in a block are contiguous in frequency."
`
`Sesia, Toufik, Baker, LTE, The UMTS Long Term Evolution from Theory to Practice (2009), § 17.4.1.
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`Case 2:22-md-03034-TGB ECF No. 96-2, PageID.2859 Filed 10/21/22 Page 44 of 721
`
`U.S. Patent No. 8,467,366: Claim 5(a)
`
`
`" The mobile station of claim 1, further comprising an apparatus configured to control a transmission power of the ranging signal using an open-loop power
`control method by:"
`
`5. The mobile station of claim 1, further
`comprising an apparatus configured to
`control a transmission power of the
`ranging signal using an open-loop power
`control method by:
`
`
`See Claim 1.
`
`Ford’s Accused Instrumentalities include an apparatus configured to control the transmission power in the
`physical uplink control channel as described in the standard. E.g.,
`
`The UE implements in hardware and/or software power control component(s) that control the transmission
`power of the ranging signal using an open control method:
`
`
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`
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`See e.g., 3GPP TS 36.213 V8.8.0 at pgs. 16-17.
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`42
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`Case 2:22-md-03034-TGB ECF No. 96-2, PageID.2860 Filed 10/21/22 Page 45 of 721
`
`U.S. Patent No. 8,467,366: Claim 5(b)
`
`"estimating a path loss between the serving base station and the mobile station based on a received downlink signal"
`
`estimating a path loss between the serving
`base station and the mobile station based
`on a received downlink signal
`
`The open-loop power control method used by Ford’s Accused Instrumentalities includes estimating a path loss
`between the serving base station and the mobile station based on a received downlink signal. E.g.,
`
`The standard-defined procedure includes estimating a pathloss:
`
`
`See e.g., 3GPP TS 36.213 V8.8.0 at pg. 17.
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`Case 2:22-md-03034-TGB ECF No. 96-2, PageID.2861 Filed 10/21/22 Page 46 of 721
`
`setting the transmission power of the
`ranging signal based on the path loss
`
`U.S. Patent No. 8,467,366: Claim 5(c)
`
`"setting the transmission power of the ranging signal based on the path loss"
`The open-loop power control method used by Ford’s Accused Instrumentalities includes setting the
`transmission power of the ranging signal based on the path loss. E.g.,
`
`The transmission PRACH is set by the equation P_PRACH = min{P_CMAX,
`PREAMBLE_RECEIVED_TARGET_POWER + PL}, which is based on the path loss.
`
`See e.g., 3GPP TS 36.213 V8.8.0 at pg. 17.
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`Case 2:22-md-03034-TGB ECF No. 96-2, PageID.2862 Filed 10/21/22 Page 47 of 721
`
`
`
`U.S. Patent No. 8,467,366: Claim 5(d)
`
`“increasing the transmission power of the ranging signal for retransmission”
`increasing the transmission power of the
`The open-loop power control method used by Ford’s Accused Instrumentalities includes increasing the
`ranging signal for retransmission.
`transmission power of the ranging signal for retransmission. E.g.,
`
`The random access preamble power is increased when the transmission counter increases, i.e., when
`retransmitted, by a power-ramping factor:
`
`
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`
`
`See e.g., 3GPP TS 36.321 V8.12.0 at pg. 14.
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`Case 2:22-md-03034-TGB ECF No. 96-2, PageID.2863 Filed 10/21/22 Page 48 of 721
`
`
`
`17. 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:
`
`
`U.S. Patent No. 8,467,366: Claim 17(a)
`“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:”
`
`
`To the extent the preamble is considered a limitation, Ford’s Accused Instrumentalities meet the preamble of
`claim 17 of the ’366 patent. E.g.,
`
`Ford’s Accused Instrumentalities include vehicles equipped with cellular communication capabilities and
`services made available thereupon for use and actually used in a wireless system compliant with the LTE
`standard starting at least at Release 8.
`
`For example, Ford offers for sale, sells, and/or imports various vehicle models that are marketed and released
`with LTE cellular functionality and perform methods thereof, including but not limited to the models listed in
`the Plaintiff’s Disclosure Of Asserted Claims And Infringement Contentions.
`
`The LTE specification (Series 36, Release 8) supports user equipment (UE) to perform a random access
`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.
`
`LTE networks, a wireless communication systems, have many eNodeBs, base stations.
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`Case 2:22-md-03034-TGB ECF No. 96-2, PageID.2864 Filed 10/21/22 Page 49 of 721
`
`
`
`U.S. Patent No. 8,467,366: Claim 17(a)
`“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:”
`
`
`
`See e.g., 3GPP TS 36.300 V8.12.0 at pg. 15.
`
`
`The user equipment (UE), mobile stations, communicate with corresponding eNodeBs.
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`Case 2:22-md-03034-TGB ECF No. 96-2, PageID.2865 Filed 10/21/22 Page 50 of 721
`
`
`
`U.S. Patent No. 8,467,366: Claim 17(a)
`“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:”
`
`
`
`See e.g., 3GPP TS 36.300 V8.12.0 at pg. 18.
`
`The LTE physical layer (PHY) uses OFDM (Orthogonal Frequency Division Multiplexing) for both the
`downlink and the uplink. For the uplink, LTE uses a specific type of OFDMA (Orthogonal Frequency
`Division Multiple Access) referred to as either discrete Fourier Transform Spread (DFTS)-OFDM, or as SC-
`FDMA (Single Carrier – Frequency Division Multiple Access) .
`
`
`
`
`See e.g., 3GPP TS 36.300 V8.12.0 at pg. 25.
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`Case 2:22-md-03034-TGB ECF No. 96-2, PageID.2866 Filed 10/21/22 Page 51 of 721
`
`
`
`U.S. Patent No. 8,467,366: Claim 17(a)
`“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:”
`
`
`
`See e.g., 3GPP TS 36.300 V8.12.0 at pgs. 27-28.
`
`In LTE, data is transmitted using the physical uplink shared channel.
`
`
`
`See e.g., 3GPP TS 36.211 V8.9.0 at pg. 13.
`
`See also Claim 1(a).
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`Case 2:22-md-03034-TGB ECF No. 96-2, PageID.2867 Filed 10/21/22 Page 52 of 721
`
`
`
`U.S. Patent No. 8,467,366: Claim 17(b)
`
`“transmitting a data signal over a data subchannel to the serving base station, w