Case 2:22-md-03034-TGB ECF No. 96-4, PageID.3961 Filed 10/21/22 Page 1 of 280
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`EXHIBIT C
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`Case 2:22-md-03034-TGB ECF No. 96-4, PageID.3962 Filed 10/21/22 Page 2 of 280
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`Plaintiff’s Infringement
`Contentions to Ford
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`Case 2:22-md-03034-TGB ECF No. 96-4, PageID.3963 Filed 10/21/22 Page 3 of 280
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`Exhibit 450
`U.S. Patent No. 10,447,450
`Claims 7, 8, 10, 11
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`1
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`Case 2:22-md-03034-TGB ECF No. 96-4, PageID.3964 Filed 10/21/22 Page 4 of 280
`U.S. Patent No. 10,447,450: Claim 7(a)
`"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 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"
`7. A mobile device in a wireless packet
`To the extent the preamble is considered a limitation, Ford’s Accused Instrumentalities meet the preamble of
`system using a frame structure of multiple
`claim 7 of the ’450 patent. E.g.,
`frames
`for
`transmission, each
`frame
`
`comprising a plurality of time intervals,
`Ford’s Accused Instrumentalities include vehicles equipped with cellular communication capabilities and
`each time interval comprising a plurality of
`services made available thereupon for use and actually used in a wireless system compliant with the LTE
`orthogonal
`frequency
`division
`standard starting at least at Release 8.
`multiplexing (OFDM) symbols, and each
`
`OFDM symbol containing a plurality of
`For example, Ford offers for sale, sells, and/or imports various vehicle models that are marketed and released
`frequency subcarriers, the mobile device
`with LTE cellular functionality and perform methods thereof, including but not limited to the models listed in
`configured to:
`the Plaintiff’s Disclosure Of Asserted Claims And Infringement Contentions.
`
`
` A
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` release 8 (and later release) compliant Long Term Evolution (LTE) user equipment (UE) uses a frame
`structure that is 10 ms long with ten subframes, time intervals, of 1 ms long each. Each subframe includes two
`slots.
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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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`Case 2:22-md-03034-TGB ECF No. 96-4, PageID.3965 Filed 10/21/22 Page 5 of 280
`U.S. Patent No. 10,447,450: Claim 7(a)
`"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 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"
`
`
`See e.g., 3GPP TS 36.300 V8.12.0 at pg. 23.
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`The LTE downlink uses orthogonal frequency division multiplexing (OFDM). During a subframe, multiple
`OFDM symbols are transmitted.
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`Case 2:22-md-03034-TGB ECF No. 96-4, PageID.3966 Filed 10/21/22 Page 6 of 280
`U.S. Patent No. 10,447,450: Claim 7(a)
`"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 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"
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`See e.g., 3GPP TS 36.300 V8.12.0 at pg. 25.
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` A
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` subframe contains two slots, and in each slot multiple OFDM symbols are transmitted. Each symbol
`includes a plurality of subcarriers.
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`See e.g., 3GPP TS 36.211 V8.9.0 at pg. 45.
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`Case 2:22-md-03034-TGB ECF No. 96-4, PageID.3967 Filed 10/21/22 Page 7 of 280
`U.S. Patent No. 10,447,450: Claim 7(b)
`"receive an identifier from a base station in a cell in which the mobile device is operating; and"
`receive an identifier from a base station in
`Ford’s Accused Instrumentalities receive an identifier from a base station in a cell in which the mobile device
`a cell in which the mobile device is
`is operating. E.g.,
`operating; and
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`The UE receives a cell radio network temporary identifier (C-RNTI) from an eNodeB, an LTE base station,
`which may be assigned and transmitted to the UE during an earlier signaling exchange, e.g., during the random
`access process or during a handover procedure.
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`Case 2:22-md-03034-TGB ECF No. 96-4, PageID.3968 Filed 10/21/22 Page 8 of 280
`U.S. Patent No. 10,447,450: Claim 7(b)
`"receive an identifier from a base station in a cell in which the mobile device is operating; and"
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`See e.g., 3GPP TS 36.300 V8.12.0 at pg. 52-53.
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`Case 2:22-md-03034-TGB ECF No. 96-4, PageID.3969 Filed 10/21/22 Page 9 of 280
`U.S. Patent No. 10,447,450: Claim 7(b)
`"receive an identifier from a base station in a cell in which the mobile device is operating; and"
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`Case 2:22-md-03034-TGB ECF No. 96-4, PageID.3970 Filed 10/21/22 Page 10 of 280
`U.S. Patent No. 10,447,450: Claim 7(b)
`"receive an identifier from a base station in a cell in which the mobile device is operating; and"
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`
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`See e.g., 3GPP TS 36.300 V8.7.0 at pgs. 54 and 55.
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`See also 3GPP TS 36.300 V8.12.0 at pp. 44-47 (describing 3GPP handover (HO) procedure including the
`target eNB “generates the RRC message to perform the handover, i.e. RRCConnectionReconfiguration” which
`is received by the UE “with the necessary parameters (i.e. new C-RNTI, target eNB security algorithm
`identifiers, and optionally dedicated RACH preamble, target eNB SIBs, etc.)” when commanded to perform
`the handover.)
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`The C-RNTI is an identifier used to identify the UE at the cell level.
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`Case 2:22-md-03034-TGB ECF No. 96-4, PageID.3971 Filed 10/21/22 Page 11 of 280
`U.S. Patent No. 10,447,450: Claim 7(b)
`"receive an identifier from a base station in a cell in which the mobile device is operating; and"
`See e.g., 3GPP TS 36.300 V8.12.0 at pg. 39.
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`Case 2:22-md-03034-TGB ECF No. 96-4, PageID.3972 Filed 10/21/22 Page 12 of 280
`U.S. Patent No. 10,447,450: Claim 7(c)
`"receive a signal containing information from the base station over a segment of time-frequency resource,"
`receive a signal containing information
`Ford’s Accused Instrumentalities receive a signal containing information from the base station over a segment
`from the base station over a segment of
`of time-frequency resource. E.g.,
`time-frequency resource,
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`Resource information is sent from the base station to the UE over a physical downlink control channel
`(PDCCH).
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` ...
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` ...
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`See e.g., 3GPP TS 36.300 V8.12.0 at pg. 24.
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`The PDCCH carries downlink control information (DCI), a control message.
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` ...
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`See e.g., 3GPP TS 36.212 V8.8.0 at pg. 8.
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`Case 2:22-md-03034-TGB ECF No. 96-4, PageID.3973 Filed 10/21/22 Page 13 of 280
`U.S. Patent No. 10,447,450: Claim 7(c)
`"receive a signal containing information from the base station over a segment of time-frequency resource,"
`See e.g., 3GPP TS 36.212 V8.8.0 at pg. 43.
`The PDCCH is received over the first n OFDM symbols, wherein n ≤ 4. A PDCCH is formed by an
`aggregation of control channel elements (CCEs). Each CCE consists of a set of resource elements.
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`
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`See e.g., 3GPP TS 36.300 V8.12.0 at pg. 26.
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`Resource elements make up a resource grid that defines a resource block that is transmitted during a slot, each
`resource element being uniquely identifiable by an index pair (k, l).
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`Case 2:22-md-03034-TGB ECF No. 96-4, PageID.3974 Filed 10/21/22 Page 14 of 280
`U.S. Patent No. 10,447,450: Claim 7(c)
`"receive a signal containing information from the base station over a segment of time-frequency resource,"
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`See e.g., 3GPP TS 36.211 V8.9.0 at pgs. 45-46.
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`Case 2:22-md-03034-TGB ECF No. 96-4, PageID.3975 Filed 10/21/22 Page 15 of 280
`U.S. Patent No. 10,447,450: Claim 7(c)
`"receive a signal containing information from the base station over a segment of time-frequency resource,"
`Resource-element groups are used for defining the mapping of the PDCCH to resource elements.
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`
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`See e.g., 3GPP TS 36.211 V8.9.0 at pg. 48.
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` A
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` PDCCH is an aggregation of CCEs. Each CCE corresponds to 9 resource element groups that map the
`PDCCH to resource element that define a segment of time-frequency resource.
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`See e.g., 3GPP TS 36.211 V8.9.0 at pg. 58.
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`Case 2:22-md-03034-TGB ECF No. 96-4, PageID.3976 Filed 10/21/22 Page 16 of 280
`U.S. Patent No. 10,447,450: Claim 7(c)
`"receive a signal containing information from the base station over a segment of time-frequency resource,"
`
`
`See e.g., E. Dahlman, S. Parkvall, J. Skold, 4G: LTE/LTE-Advanced for Mobile Broadband (2014) at p. 210
`(describing the structure of CCEs).
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`Case 2:22-md-03034-TGB ECF No. 96-4, PageID.3977 Filed 10/21/22 Page 17 of 280
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`the segment having a starting
`frequency coordinate
`
`
`time-
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`U.S. Patent No. 10,447,450: Claim 7(d)
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`"the segment having a starting time-frequency coordinate"
`The segment over which the signal containing information from the base station is received by Ford’s Accused
`Instrumentalities has a starting time-frequency coordinate. E.g.,
`
`The PDCCH has a starting time-frequency coordinate. It starts at a CCE fulfilling i mod n = 0, where i is the
`CCE number. The CCE corresponds to resource element groups which map CCEs to resource elements, which
`are uniquely identified by a time-frequency index pair.
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`
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`See e.g., 3GPP TS 36.211 V8.9.0 at pg. 58.
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`See e.g., 3GPP TS 36.211 V8.9.0 at pg. 48.
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`The PDCCH is located in the first n OFDM symbols, starting at the first symbol.
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`Case 2:22-md-03034-TGB ECF No. 96-4, PageID.3978 Filed 10/21/22 Page 18 of 280
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`U.S. Patent No. 10,447,450: Claim 7(d)
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`"the segment having a starting time-frequency coordinate"
`
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`See e.g., 3GPP TS 36.300 V8.12.0 at pg. 26.
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`Case 2:22-md-03034-TGB ECF No. 96-4, PageID.3979 Filed 10/21/22 Page 19 of 280
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`the segment comprising N time-frequency
`resource units within a time interval, each
`unit containing a set of frequency
`subcarriers in a group of OFDM symbols,
`where N=2, 4, or 8; and
`
`U.S. Patent No. 10,447,450: Claim 7(e)
`
`"the segment comprising N time-frequency resource units within a time interval, each unit containing a set of frequency subcarriers in a group of OFDM
`symbols, where N=2, 4, or 8; and"
`The segment over which the signal containing information from the base station is received by Ford’s Accused
`Instrumentalities comprises N time-frequency resource units within a time interval, each unit containing a set
`of frequency subcarriers in a group of OFDM symbols, where N=2, 4, or 8. E.g.,
`
`Ford’s Accused Products support each PDCCH format in complying with the 3GPP LTE specification. The
`PDCCH comprises 2 CCEs for a PDCCH format 1, 4 CCEs for a PDCCH format 2, and 8 CCEs for a PDCCH
`format 3. The PDCCH comprises 2, 4, or 8 CCEs depending on the aggregation level. All the PDCCH formats
`must be supported by Ford’s Accused Products in order to comply with the standards. Thus, the Accused
`Products are configured to receive a segment wherein N=2, 4, or 8 (in addition to other values), meeting this
`claim element.
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`
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`See e.g., 3GPP TS 36.211 V8.9.0 at pg. 58.
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`Each CCE is a set of 36 resource elements, which are a set of frequency subcarriers in a group of OFDM
`symbols.
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`Case 2:22-md-03034-TGB ECF No. 96-4, PageID.3980 Filed 10/21/22 Page 20 of 280
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`U.S. Patent No. 10,447,450: Claim 7(e)
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`"the segment comprising N time-frequency resource units within a time interval, each unit containing a set of frequency subcarriers in a group of OFDM
`symbols, where N=2, 4, or 8; and"
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`Case 2:22-md-03034-TGB ECF No. 96-4, PageID.3981 Filed 10/21/22 Page 21 of 280
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`U.S. Patent No. 10,447,450: Claim 7(e)
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`"the segment comprising N time-frequency resource units within a time interval, each unit containing a set of frequency subcarriers in a group of OFDM
`symbols, where N=2, 4, or 8; and"
`
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`See e.g., 4G LTE-Advanced Pro and The Road to 5G, Third Edition, Dahlman et al.. at pgs. 141-142.
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`The PDCCH is received during the control region of a subframe which is the initial time interval of the
`subframe. The number of OFDM symbols constituting this region, or the duration of the time interval, is
`signaled on the Physical Control Format Indicator Channel (PCFICH). The time interval of the control region
`can be 1-4 OFDM symbols in length, but typically is 1-3 OFDM symbols in length.
`
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`See e.g., 3GPP TS 36.211 V8.9.0 at pg. 58.
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`Case 2:22-md-03034-TGB ECF No. 96-4, PageID.3982 Filed 10/21/22 Page 22 of 280
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`U.S. Patent No. 10,447,450: Claim 7(e)
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`"the segment comprising N time-frequency resource units within a time interval, each unit containing a set of frequency subcarriers in a group of OFDM
`symbols, where N=2, 4, or 8; and"
`
`
`See e.g., 4G LTE-Advanced Pro and The Road to 5G, Third Edition, Dahlman et al.. Section 6.4 Downlink
`L1/L2 Control Signaling.
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`Case 2:22-md-03034-TGB ECF No. 96-4, PageID.3983 Filed 10/21/22 Page 23 of 280
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`U.S. Patent No. 10,447,450: Claim 7(f)
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`"recover the information from the received signal using the starting time-frequency coordinate and N in conjunction with the received identifier."
`recover the information from the received
`Ford’s Accused Instrumentalities also recover the information from the received signal using the starting time-
`signal using the starting time-frequency
`frequency coordinate and N in conjunction with the received identifier. E.g.,
`coordinate and N in conjunction with the
`
`received identifier.
`The PDCCH is recovered by the UE using the first OFDM symbol of the first n OFDM symbols and
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`subcarriers corresponding to the resource elements mapped to the CCEs of the PDCCH. The UE uses N, the
`number of CCEs, to receive the full PDCCH in the supported PDCCH format.
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`
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`See e.g., 3GPP TS 36.300 V8.12.0 at pg. 26.
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`See e.g., 3GPP TS 36.211 V8.9.0 at pg. 58.
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`The UE also uses the RNTI to recover the PDCCH.
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`Case 2:22-md-03034-TGB ECF No. 96-4, PageID.3984 Filed 10/21/22 Page 24 of 280
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`U.S. Patent No. 10,447,450: Claim 7(f)
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`"recover the information from the received signal using the starting time-frequency coordinate and N in conjunction with the received identifier."
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`Case 2:22-md-03034-TGB ECF No. 96-4, PageID.3985 Filed 10/21/22 Page 25 of 280
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`U.S. Patent No. 10,447,450: Claim 7(f)
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`"recover the information from the received signal using the starting time-frequency coordinate and N in conjunction with the received identifier."
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`See e.g., 3GPP TS 36.213 V8.8.0 at pgs. 63-64.
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`Additionally, the PDCCH may be decoded with CRC scrambled by RNTI, such as the C-RNTI. E.g.,
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`Case 2:22-md-03034-TGB ECF No. 96-4, PageID.3986 Filed 10/21/22 Page 26 of 280
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`U.S. Patent No. 10,447,450: Claim 7(f)
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`"recover the information from the received signal using the starting time-frequency coordinate and N in conjunction with the received identifier."
`
`
`See 3GPP TS 36.213 V8.8.0 at pgs. 19-20 (see also section 7.1 generally for decoding CRC with additional or
`alternative RNTI, such as SI-RNTI and P-RNTI).
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`8. The mobile device of claim 7, wherein
`the starting time-frequency coordinate
`indicates a starting OFDM symbol of the
`segment of time-frequency resource.
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`Case 2:22-md-03034-TGB ECF No. 96-4, PageID.3987 Filed 10/21/22 Page 27 of 280
`U.S. Patent No. 10,447,450: Claim 8
`"The mobile device of claim 7, wherein the starting time-frequency coordinate indicates a starting OFDM symbol of the segment of time-frequency
`resource"
`The starting time-frequency coordinate used with Ford’s Accused Instrumentalities indicates a starting OFDM
`symbol of the segment of time-frequency resource. E.g.,
`
`See Claim 7.
`
`The PDCCH’s starting time-frequency coordinate indicates a starting OFDM symbol. For example, the
`starting time-frequency coordinate starts at a CCE uniquely identified by a time-frequency index pair.
`
`
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`See e.g., 3GPP TS 36.211 V8.9.0 at pg. 58.
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`
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`See e.g., 3GPP TS 36.211 V8.9.0 at pg. 48.
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`The PDCCH is located in the first n OFDM symbols, starting at a first OFDM symbol.
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`Case 2:22-md-03034-TGB ECF No. 96-4, PageID.3988 Filed 10/21/22 Page 28 of 280
`U.S. Patent No. 10,447,450: Claim 8
`"The mobile device of claim 7, wherein the starting time-frequency coordinate indicates a starting OFDM symbol of the segment of time-frequency
`resource"
`
`
`See e.g., 3GPP TS 36.300 V8.12.0 at pg. 26.
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`Each CCE is a set of 36 resource elements, which are a set of frequency subcarriers in a group of OFDM
`symbols.
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`Case 2:22-md-03034-TGB ECF No. 96-4, PageID.3989 Filed 10/21/22 Page 29 of 280
`U.S. Patent No. 10,447,450: Claim 8
`"The mobile device of claim 7, wherein the starting time-frequency coordinate indicates a starting OFDM symbol of the segment of time-frequency
`resource"
`
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`
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`See e.g., 4G LTE-Advanced Pro and The Road to 5G, Third Edition, Dahlman et al.. at pgs. 141-142.
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`10. The mobile device of claim 7, wherein
`the starting time-frequency coordinate
`indicates a starting group of subcarriers of
`the segment of time-frequency resource.
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`Case 2:22-md-03034-TGB ECF No. 96-4, PageID.3990 Filed 10/21/22 Page 30 of 280
`U.S. Patent No. 10,447,450: Claim 10
`“The mobile device of claim 7, wherein the starting time-frequency coordinate indicates a starting group of subcarriers of the segment of time-frequency
`resource."
`The starting time-frequency coordinate used with Ford’s Accused Instrumentalities indicates a starting group
`of subcarriers of the segment of time-frequency resource. E.g.,
`
`
`See Claim 7.
`
`The PDCCH has a starting time-frequency coordinate starting at a CCE defining asset of 36 resource elements,
`which are a set of frequency subcarriers in a group of OFDM symbols.
`
`
`
`See e.g., 3GPP TS 36.211 V8.9.0 at pg. 58.
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`
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`See e.g., 3GPP TS 36.211 V8.9.0 at pg. 48.
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`Case 2:22-md-03034-TGB ECF No. 96-4, PageID.3991 Filed 10/21/22 Page 31 of 280
`U.S. Patent No. 10,447,450: Claim 10
`“The mobile device of claim 7, wherein the starting time-frequency coordinate indicates a starting group of subcarriers of the segment of time-frequency
`resource."
`
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`
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`See e.g., 4G LTE-Advanced Pro and The Road to 5G, Third Edition, Dahlman et al.. at pgs. 141-142.
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`Case 2:22-md-03034-TGB ECF No. 96-4, PageID.3992 Filed 10/21/22 Page 32 of 280
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`U.S. Patent No. 10,447,450: Claim 11
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`“11. The mobile device of claim 7, wherein modular coding is applied to the time-frequency resource units in the segment of time-frequency resource.”
`
`Modular coding is applied to the time-frequency resource units in the segment of time-frequency resource over
`which Ford’s Accused Instrumentalities receive the signal. E.g.,
`
`See Claim 7.
`
`The time-frequency resource units in the PDCCH are modulated according to at least a QPSK scheme.
`
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`11. The mobile device of claim 7, wherein
`modular coding is applied to the time-
`frequency resource units in the segment of
`time-frequency resource.
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`See e.g., 3GPP TS 36.211 V8.9.0 at pg. 59.
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`Case 2:22-md-03034-TGB ECF No. 96-4, PageID.3993 Filed 10/21/22 Page 33 of 280
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`Plaintiff’s Infringement
`Contentions to Honda
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`Case 2:22-md-03034-TGB ECF No. 96-4, PageID.3994 Filed 10/21/22 Page 34 of 280
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`Exhibit 450
`U.S. Patent No. 10,447,450
`Claims 7, 8, 10, 11
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`1
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`Case 2:22-md-03034-TGB ECF No. 96-4, PageID.3995 Filed 10/21/22 Page 35 of 280
`U.S. Patent No. 10,447,450: Claim 7(a)
`"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 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"
`7. A mobile device in a wireless packet
`To the extent the preamble is considered a limitation, Honda’s Accused Instrumentalities meet the preamble of
`system using a frame structure of multiple
`claim 7 of the ’450 patent. E.g.,
`frames
`for
`transmission, each
`frame
`
`comprising a plurality of time intervals,
`Honda’s Accused Instrumentalities include vehicles equipped with cellular communication capabilities and
`each time interval comprising a plurality of
`services made available thereupon for use and actually used in a wireless system compliant with the LTE
`orthogonal
`frequency
`division
`standard starting at least at Release 8.
`multiplexing (OFDM) symbols, and each
`
`OFDM symbol containing a plurality of
`For example, Honda offers for sale, sells, and/or imports various vehicle models that are marketed and released
`frequency subcarriers, the mobile device
`with LTE cellular functionality and perform methods thereof, including but not limited to the models listed in
`configured to:
`the Plaintiff’s Disclosure Of Asserted Claims And Infringement Contentions.
`
`
` A
`
` release 8 (and later release) compliant Long Term Evolution (LTE) user equipment (UE) uses a frame
`structure that is 10 ms long with ten subframes, time intervals, of 1 ms long each. Each subframe includes two
`slots.
`
`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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`2
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`Case 2:22-md-03034-TGB ECF No. 96-4, PageID.3996 Filed 10/21/22 Page 36 of 280
`U.S. Patent No. 10,447,450: Claim 7(a)
`"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 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"
`
`
`See e.g., 3GPP TS 36.300 V8.12.0 at pg. 23.
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`The LTE downlink uses orthogonal frequency division multiplexing (OFDM). During a subframe, multiple
`OFDM symbols are transmitted.
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`3
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`Case 2:22-md-03034-TGB ECF No. 96-4, PageID.3997 Filed 10/21/22 Page 37 of 280
`U.S. Patent No. 10,447,450: Claim 7(a)
`"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 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"
`
`
`
`
`See e.g., 3GPP TS 36.300 V8.12.0 at pg. 25.
`
` A
`
` subframe contains two slots, and in each slot multiple OFDM symbols are transmitted. Each symbol
`includes a plurality of subcarriers.
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`See e.g., 3GPP TS 36.211 V8.9.0 at pg. 45.
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`4
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`Case 2:22-md-03034-TGB ECF No. 96-4, PageID.3998 Filed 10/21/22 Page 38 of 280
`U.S. Patent No. 10,447,450: Claim 7(b)
`"receive an identifier from a base station in a cell in which the mobile device is operating; and"
`receive an identifier from a base station in
`Honda’s Accused Instrumentalities receive an identifier from a base station in a cell in which the mobile
`a cell in which the mobile device is
`device is operating. E.g.,
`operating; and
`
`The UE receives a cell radio network temporary identifier (C-RNTI) from an eNodeB, an LTE base station,
`which may be assigned and transmitted to the UE during an earlier signaling exchange, e.g., during the random
`access process or during a handover procedure.
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`5
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`Case 2:22-md-03034-TGB ECF No. 96-4, PageID.3999 Filed 10/21/22 Page 39 of 280
`U.S. Patent No. 10,447,450: Claim 7(b)
`"receive an identifier from a base station in a cell in which the mobile device is operating; and"
`
`See e.g., 3GPP TS 36.300 V8.12.0 at pg. 52-53.
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`6
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`Case 2:22-md-03034-TGB ECF No. 96-4, PageID.4000 Filed 10/21/22 Page 40 of 280
`U.S. Patent No. 10,447,450: Claim 7(b)
`"receive an identifier from a base station in a cell in which the mobile device is operating; and"
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`7
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`Case 2:22-md-03034-TGB ECF No. 96-4, PageID.4001 Filed 10/21/22 Page 41 of 280
`U.S. Patent No. 10,447,450: Claim 7(b)
`"receive an identifier from a base station in a cell in which the mobile device is operating; and"
`
`
`
`See e.g., 3GPP TS 36.300 V8.7.0 at pgs. 54 and 55.
`
`See also 3GPP TS 36.300 V8.12.0 at pp. 44-47 (describing 3GPP handover (HO) procedure including the
`target eNB “generates the RRC message to perform the handover, i.e. RRCConnectionReconfiguration” which
`is received by the UE “with the necessary parameters (i.e. new C-RNTI, target eNB security algorithm
`identifiers, and optionally dedicated RACH preamble, target eNB SIBs, etc.)” when commanded to perform
`the handover.)
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`The C-RNTI is an identifier used to identify the UE at the cell level.
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`8
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`Case 2:22-md-03034-TGB ECF No. 96-4, PageID.4002 Filed 10/21/22 Page 42 of 280
`U.S. Patent No. 10,447,450: Claim 7(b)
`"receive an identifier from a base station in a cell in which the mobile device is operating; and"
`See e.g., 3GPP TS 36.300 V8.12.0 at pg. 39.
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`9
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`Case 2:22-md-03034-TGB ECF No. 96-4, PageID.4003 Filed 10/21/22 Page 43 of 280
`U.S. Patent No. 10,447,450: Claim 7(c)
`"receive a signal containing information from the base station over a segment of time-frequency resource,"
`receive a signal containing information
`Honda’s Accused Instrumentalities receive a signal containing information from the base station over a
`from the base station over a segment of
`segment of time-frequency resource. E.g.,
`time-frequency resource,
`
`Resource information is sent from the base station to the UE over a physical downlink control channel
`(PDCCH).
`
` ...
`
` ...
`
`
`See e.g., 3GPP TS 36.300 V8.12.0 at pg. 24.
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`The PDCCH carries downlink control information (DCI), a control message.
`
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` ...
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`See e.g., 3GPP TS 36.212 V8.8.0 at pg. 8.
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`10
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`Case 2:22-md-03034-TGB ECF No. 96-4, PageID.4004 Filed 10/21/22 Page 44 of 280
`U.S. Patent No. 10,447,450: Claim 7(c)
`"receive a signal containing information from the base station over a segment of time-frequency resource,"
`See e.g., 3GPP TS 36.212 V8.8.0 at pg. 43.
`The PDCCH is received over the first n OFDM symbols, wherein n ≤ 4. A PDCCH is formed by an
`aggregation of control channel elements (CCEs). Each CCE consists of a set of resource elements.
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`
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`See e.g., 3GPP TS 36.300 V8.12.0 at pg. 26.
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`Resource elements make up a resource grid that defines a resource block that is transmitted during a slot, each
`resource element being uniquely identifiable by an index pair (k, l).
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`11
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`Case 2:22-md-03034-TGB ECF No. 96-4, PageID.4005 Filed 10/21/22 Page 45 of 280
`U.S. Patent No. 10,447,450: Claim 7(c)
`"receive a signal containing information from the base station over a segment of time-frequency resource,"
`
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`
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`See e.g., 3GPP TS 36.211 V8.9.0 at pgs. 45-46.
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`12
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`Case 2:22-md-03034-TGB ECF No. 96-4, PageID.4006 Filed 10/21/22 Page 46 of 280
`U.S. Patent No. 10,447,450: Claim 7(c)
`"receive a signal containing information from the base station over a segment of time-frequency resource,"
`Resource-element groups are used for defining the mapping of the PDCCH to resource elements.
`
`
`
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`See e.g., 3GPP TS 36.211 V8.9.0 at pg. 48.
`
` A
`
` PDCCH is an aggregation of CCEs. Each CCE corresponds to 9 resource element groups that map the
`PDCCH to resource element that define a segment of time-frequency resource.
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`
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`See e.g., 3GPP TS 36.211 V8.9.0 at pg. 58.
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`13
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`Case 2:22-md-03034-TGB ECF No. 96-4, PageID.4007 Filed 10/21/22 Page 47 of 280
`U.S. Patent No. 10,447,450: Claim 7(c)
`"receive a signal containing information from the base station over a segment of time-frequency resource,"
`
`
`See e.g., E. Dahlman, S. Parkvall, J. Skold, 4G: LTE/LTE-Advanced for Mobile Broadband (2014) at p. 210
`(describing the structure of CCEs).
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`14
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`Case 2:22-md-03034-TGB ECF No. 96-4, PageID.4008 Filed 10/21/22 Page 48 of 280
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`the segment having a starting
`frequency coordinate
`
`
`time-
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`U.S. Patent No. 10,447,450: Claim 7(d)
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`"the segment having a starting time-frequency coordinate"
`The segment over which the signal containing information from the base station is received by Honda’s
`Accused Instrumentalities has a starting time-frequency coordinate. E.g.,
`
`The PDCCH has a starting time-frequency coordinate. It starts at a CCE fulfilling i mod n = 0, where i is the
`CCE number. The CCE corresponds to resource element groups which map CCEs to resource elements, which
`are uniquely identified by a time-frequency index pair.
`
`
`
`See e.g., 3GPP TS 36.211 V8.9.0 at pg. 58.
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`
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`See e.g., 3GPP TS 36.211 V8.9.0 at pg. 48.
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`The PDCCH is located in the first n OFDM symbols, starting at the first symbol.
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`Case 2:22-md-03034-TGB ECF No. 96-4, PageID.4009 Filed 10/21/22 Page 49 of 280
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`U.S. Patent No. 10,447,450: Claim 7(d)
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`"the segment having a starting time-frequency coordinate"
`
`
`See e.g., 3GPP TS 36.300 V8.12.0 at pg. 26.
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`16
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`Case 2:22-md-03034-TGB ECF No. 96-4, PageID.4010 Filed 10/21/22 Page 50 of 280
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`
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`the segment comprising N time-frequency
`resource units within a time interval, each
`unit containing a set of frequency
`subcarriers in a group of OFDM symbols,
`where N=2, 4, or 8; and
`
`U.S. Patent No. 10,447,450: Claim 7(e)
`
`"the segment comprising N time-frequency resource units within a time interval, each unit containing a set of frequency subcarriers in a group of OFDM
`symbols, where N=2, 4, or 8; and"
`The segment over which the signal containing information from the base station is received by Honda’s
`Accused Instrumentalities comprises N time-frequency resource units within a time interval, each unit
`containing a set of frequency subcarriers in a group of OFDM symbols, where N=2, 4, or 8. E.g.,
`
`Honda’s Accused Products support each PDCCH format in complying with the 3GPP LTE specification. The
`PDCCH comprises 2 CCEs for a PDCCH format 1, 4 CCEs for a PDCCH format 2, and 8 CCEs for a PDCCH
`format 3. The PDCCH comprises 2, 4, or 8 CCEs depending on the aggregation level. All the PDCCH formats
`must be supported by Honda’s Accused Products in order to comply with the standards. Thus, the Accused
`Products are configured to receive a segment wherein N=2, 4, or 8 (in addition to other values), meeting this
`claim element.
`
`
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`See e.g., 3GPP TS 36.211 V8.9.0 at pg. 58.
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`Each CCE is a set of 36 resource elements, which are a set of frequency subcarriers in a group of OFDM
`symbols.
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`Case 2:22-md-03034-TGB ECF No. 96-4, PageID.4011 Filed 10/21/22 Page 51 of 280
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`U.S. Patent No. 10,447,450: Claim 7(e)
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`"the seg