Case 2:22-md-03034-TGB ECF No. 96-5, PageID.4241 Filed 10/21/22 Page 1 of 975
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`EXHIBIT D
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`EXHIBIT D
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`Case 2:22-md-03034-TGB ECF No. 96-5, PageID.4242 Filed 10/21/22 Page 2 of 975
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`Plaintiff’s Infringement
`Contentions to Ford
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`Case 2:22-md-03034-TGB ECF No. 96-5, PageID.4243 Filed 10/21/22 Page 3 of 975
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`Exhibit 302
`U.S. Patent No. 10,771,302
`Claims 1, 2, 4-7, 23, 24, and 26-29
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`1
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`A communication method for a
`1.
`mobile device in an Orthogonal Frequency
`Division Multiplexing (OFDM)
`communication system, the method
`comprising:
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`Case 2:22-md-03034-TGB ECF No. 96-5, PageID.4244 Filed 10/21/22 Page 4 of 975
`U.S. Patent No. 10,771,302: Claim 1(a)
`"1. A communication method for a mobile device in an Orthogonal Frequency Division Multiplexing (OFDM) communication system, the method
`comprising:”
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`Ford’s Accused Products include vehicles equipped with components and/or devices that perform methods to
`enable connectivity to 4G/LTE networks and services, including services sold and provided by Ford.
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`To the extent the preamble is considered a limitation, Ford’s Accused Products meet the preamble of the ’302
`patent. E.g.,
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`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.
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`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.
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`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 equipment (UEs) transmit to and receive signals from eNodeBs.
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`Case 2:22-md-03034-TGB ECF No. 96-5, PageID.4245 Filed 10/21/22 Page 5 of 975
`U.S. Patent No. 10,771,302: Claim 1(a)
`"1. A communication method for a mobile device in an Orthogonal Frequency Division Multiplexing (OFDM) communication system, the method
`comprising:”
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`See e.g., 3GPP TS 36.300 V8.12.0 at pg. 15.
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`Case 2:22-md-03034-TGB ECF No. 96-5, PageID.4246 Filed 10/21/22 Page 6 of 975
`U.S. Patent No. 10,771,302: Claim 1(a)
`"1. A communication method for a mobile device in an Orthogonal Frequency Division Multiplexing (OFDM) communication system, the method
`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 different version of OFDM (Orthogonal Frequency Division
`Multiplexing) for 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. 96-5, PageID.4247 Filed 10/21/22 Page 7 of 975
`U.S. Patent No. 10,771,302: Claim 1(a)
`"1. A communication method for a mobile device in an Orthogonal Frequency Division Multiplexing (OFDM) communication system, the method
`comprising:”
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`See e.g., 3GPP TS 36.300 V8.12.0 at pg. 27.
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`Case 2:22-md-03034-TGB ECF No. 96-5, PageID.4248 Filed 10/21/22 Page 8 of 975
`U.S. Patent No. 10,771,302: Claim 1(a)
`"1. A communication method for a mobile device in an Orthogonal Frequency Division Multiplexing (OFDM) communication system, the method
`comprising:”
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`LTE uses an uplink channel bandwidth divided into physical resource blocks.
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`See e.g., 3GPP TS 36.101 V8.29.0 at pg. 15.
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`Case 2:22-md-03034-TGB ECF No. 96-5, PageID.4249 Filed 10/21/22 Page 9 of 975
`U.S. Patent No. 10,771,302: Claim 1(a)
`"1. A communication method for a mobile device in an Orthogonal Frequency Division Multiplexing (OFDM) communication system, the method
`comprising:”
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`Each physical resource block (PRB) has 12 subcarriers.
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`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.
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`Case 2:22-md-03034-TGB ECF No. 96-5, PageID.4250 Filed 10/21/22 Page 10 of 975
`U.S. Patent No. 10,771,302: Claim 1(a)
`"1. A communication method for a mobile device in an Orthogonal Frequency Division Multiplexing (OFDM) communication system, the method
`comprising:”
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`See e.g., 3GPP TS 36.300 V8.12.0 at pg. 34.
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`Case 2:22-md-03034-TGB ECF No. 96-5, PageID.4251 Filed 10/21/22 Page 11 of 975
`U.S. Patent No. 10,771,302: Claim 1(a)
`"1. A communication method for a mobile device in an Orthogonal Frequency Division Multiplexing (OFDM) communication system, the method
`comprising:”
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`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).
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`See e.g., 3GPP TS 36.300 V8.12.0 at pg. 31.
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`See e.g., 3GPP TS 36.211 V8.9.0 at pg. 16.
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`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.
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`See e.g., 3GPP TS 36.211 V8.9.0 at pg. 20.
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`Case 2:22-md-03034-TGB ECF No. 96-5, PageID.4252 Filed 10/21/22 Page 12 of 975
`U.S. Patent No. 10,771,302: Claim 1(a)
`"1. A communication method for a mobile device in an Orthogonal Frequency Division Multiplexing (OFDM) communication system, the method
`comprising:”
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`See e.g., 3GPP TS 36.211 V8.9.0 at pg. 21.
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`Case 2:22-md-03034-TGB ECF No. 96-5, PageID.4253 Filed 10/21/22 Page 13 of 975
`U.S. Patent No. 10,771,302: Claim 1(a)
`"1. A communication method for a mobile device in an Orthogonal Frequency Division Multiplexing (OFDM) communication system, the method
`comprising:”
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`See e.g., 4G, LTE-Advanced Pro and The Road to 5G, Third Edition, (2016) Dahlman et al, §7.4.1.6.
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`Case 2:22-md-03034-TGB ECF No. 96-5, PageID.4254 Filed 10/21/22 Page 14 of 975
`U.S. Patent No. 10,771,302: Claim 1(b)
`"receiving a request for a probing signal from a base station in the system;”
`receiving a request for a probing signal
`Ford’s Accused Products receive a request for a probing signal from a base station in the system. E.g.,
`from a base station in the system; and
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`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
`a SRS.
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`See e.g., 3GPP TS 36.331 V8.21.0 at p. 89-90.
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`Case 2:22-md-03034-TGB ECF No. 96-5, PageID.4255 Filed 10/21/22 Page 15 of 975
`U.S. Patent No. 10,771,302: Claim 1(b)
`"receiving a request for a probing signal from a base station in the system;”
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`See e.g., 3GPP TS 36.331 V8.21.0 at p. 129.
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`See e.g., 3GPP TS 36.331 V8.21.0 at p. 122.
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`Case 2:22-md-03034-TGB ECF No. 96-5, PageID.4256 Filed 10/21/22 Page 16 of 975
`U.S. Patent No. 10,771,302: Claim 1(b)
`"receiving a request for a probing signal from a base station in the system;”
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`See e.g., 3GPP TS 36.331 V8.21.0 at p. 100.
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`Case 2:22-md-03034-TGB ECF No. 96-5, PageID.4257 Filed 10/21/22 Page 17 of 975
`U.S. Patent No. 10,771,302: Claim 1(b)
`"receiving a request for a probing signal from a base station in the system;”
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`See e.g., 3GPP TS 36.331 V8.21.0 at p. 105.
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`Case 2:22-md-03034-TGB ECF No. 96-5, PageID.4258 Filed 10/21/22 Page 18 of 975
`U.S. Patent No. 10,771,302: Claim 1(b)
`"receiving a request for a probing signal from a base station in the system;”
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`See e.g., 3GPP TS 36.331 V8.21.0 at p. 128.
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`Case 2:22-md-03034-TGB ECF No. 96-5, PageID.4259 Filed 10/21/22 Page 19 of 975
`U.S. Patent No. 10,771,302: Claim 1(b)
`"receiving a request for a probing signal from a base station in the system;”
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`3GPP TS 36.331 V8.21.0 at p. 132.
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`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.
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`See e.g., 3GPP TS 36.213 V10.13.0 at pg. 81.
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`Case 2:22-md-03034-TGB ECF No. 96-5, PageID.4260 Filed 10/21/22 Page 20 of 975
`U.S. Patent No. 10,771,302: Claim 1(b)
`"receiving a request for a probing signal from a base station in the system;”
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`See e.g., 3GPP TS 36.212 V10.9.0 at pg. 58.
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`See e.g., 3GPP TS 36.212 V10.9.0 at pg. 60.
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`Case 2:22-md-03034-TGB ECF No. 96-5, PageID.4261 Filed 10/21/22 Page 21 of 975
`U.S. Patent No. 10,771,302: Claim 1(c)
`"transmitting, in response to the received request, the probing signal with a code sequence modulated in the frequency domain, wherein:"
`transmitting, in response to the received
`Ford’s Accused Products transmit the probing signal with a code sequence modulated in the frequency domain
`request, the probing signal with a code
`in response to the received request. E.g.,
`sequence modulated in the frequency
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`domain, wherein:
`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.
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`See e.g., 3GPP TS 36.211 V8.9.0 at pg. 21.
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`Case 2:22-md-03034-TGB ECF No. 96-5, PageID.4262 Filed 10/21/22 Page 22 of 975
`U.S. Patent No. 10,771,302: Claim 1(c)
`"transmitting, in response to the received request, the probing signal with a code sequence modulated in the frequency domain, wherein:"
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`See e.g., 3GPP TS 36.211 V8.9.0 at pg. 28.
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`The UE transmits the SRS to the eNodeB.
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`See e.g., 3GPP TS 36.211 V8.9.0 at pg. 31.
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`Case 2:22-md-03034-TGB ECF No. 96-5, PageID.4263 Filed 10/21/22 Page 23 of 975
`U.S. Patent No. 10,771,302: Claim 1(c)
`"transmitting, in response to the received request, the probing signal with a code sequence modulated in the frequency domain, wherein:"
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`See e.g., Dahlman, Parkvall and Skold, “4G: LTE/LTE-Advanced for Mobile Broadband, Second Edition” (2014), at p.
`257.
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`Case 2:22-md-03034-TGB ECF No. 96-5, PageID.4264 Filed 10/21/22 Page 24 of 975
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`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
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`U.S. Patent No. 10,771,302: Claim 1(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 Ford’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.,
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`For example, the SRS is mapped to one symbol in the time domain but over many subcarriers in the frequency
`domain, e.g., to provide channel information across various frequencies. The Accused Products are configured
`to support simultaneous transmission of SRS and other uplink signals, (e.g., other SRS signals or other signals
`on PUCCH), allowing the SRS to overlap in the time domain with uplink signals transmitted by other mobile
`devices.
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`Case 2:22-md-03034-TGB ECF No. 96-5, PageID.4265 Filed 10/21/22 Page 25 of 975
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`U.S. Patent No. 10,771,302: Claim 1(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"
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`See e.g., 3GPP TS 36.211 V8.9.0 at pg. 28.
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`The UE transmits the SRS to the eNodeB.
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`See e.g., 3GPP TS 36.211 V8.9.0 at pg. 31.
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`See e.g., 3GPP TS 36.211 V8.9.0 at pg. 21.
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`Case 2:22-md-03034-TGB ECF No. 96-5, PageID.4266 Filed 10/21/22 Page 26 of 975
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`U.S. Patent No. 10,771,302: Claim 1(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"
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`See e.g., 3GPP TS 36.211 V8.9.0 at pg. 30.
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`The SRS can overlap with other SRS signals and/or other uplink signals, such as on the PUCCH, in the time
`domain.
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`Case 2:22-md-03034-TGB ECF No. 96-5, PageID.4267 Filed 10/21/22 Page 27 of 975
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`U.S. Patent No. 10,771,302: Claim 1(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"
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`See e.g., Dahlman, Parkvall and Skold, “4G: LTE/LTE-Advanced for Mobile Broadband, Second Edition”
`(2014), at p. 257-260 (see also “Aperiodic SRS transmission” at pp. 260-261).
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`Case 2:22-md-03034-TGB ECF No. 96-5, PageID.4268 Filed 10/21/22 Page 28 of 975
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`U.S. Patent No. 10,771,302: Claim 1(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"
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`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).
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`Case 2:22-md-03034-TGB ECF No. 96-5, PageID.4269 Filed 10/21/22 Page 29 of 975
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`U.S. Patent No. 10,771,302: Claim 1(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 Ford’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.,
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`For example, SRS transmissions are sent using a portion of the uplink bandwidth.
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`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.
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`See e.g., 3GPP TS 36.213 V8.8.0 at pg. 55.
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`SRS does not overlap in the frequency domain with PUCCH subcarriers, see e.g.:
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`Case 2:22-md-03034-TGB ECF No. 96-5, PageID.4270 Filed 10/21/22 Page 30 of 975
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`U.S. Patent No. 10,771,302: Claim 1(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."
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`See Sesia, Toufik and Baker, “LTE: The UMTS Long Term Evolution From Theory to Practice,” at p. 339-
`340.
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`Case 2:22-md-03034-TGB ECF No. 96-5, PageID.4271 Filed 10/21/22 Page 31 of 975
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`U.S. Patent No. 10,771,302: Claim 1(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."
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`See e.g., Sesia, Toufik and Baker, “LTE: The UMTS Long Term Evolution From Theory to Practice, Second
`Edition,” at p. 358.
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`Case 2:22-md-03034-TGB ECF No. 96-5, PageID.4272 Filed 10/21/22 Page 32 of 975
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`U.S. Patent No. 10,771,302: Claim 1(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."
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`See e.g.,
`http://rfmw.em.keysight.com/wireless/helpfiles/89600b/webhelp/subsystems/lte/content/lte_overview.htm
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`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.
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`Case 2:22-md-03034-TGB ECF No. 96-5, PageID.4273 Filed 10/21/22 Page 33 of 975
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`U.S. Patent No. 10,771,302: Claim 1(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."
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`Case 2:22-md-03034-TGB ECF No. 96-5, PageID.4274 Filed 10/21/22 Page 34 of 975
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`U.S. Patent No. 10,771,302: Claim 1(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."
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`See e.g., 3GPP TS 36.211 V8.9.0 at pg. 20-21.
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`Case 2:22-md-03034-TGB ECF No. 96-5, PageID.4275 Filed 10/21/22 Page 35 of 975
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`U.S. Patent No. 10,771,302: Claim 1(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."
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`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.
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`Case 2:22-md-03034-TGB ECF No. 96-5, PageID.4276 Filed 10/21/22 Page 36 of 975
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`U.S. Patent No. 10,771,302: Claim 1(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."
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`
`Case 2:22-md-03034-TGB ECF No. 96-5, PageID.4277 Filed 10/21/22 Page 37 of 975
`
`U.S. Patent No. 10,771,302: Claim 1(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."
`
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`35
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`Case 2:22-md-03034-TGB ECF No. 96-5, PageID.4278 Filed 10/21/22 Page 38 of 975
`
`U.S. Patent No. 10,771,302: Claim 1(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.
`
`
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`
`
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`
`36
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`
`"2.
`
`Case 2:22-md-03034-TGB ECF No. 96-5, PageID.4279 Filed 10/21/22 Page 39 of 975
`U.S. Patent No. 10,771,302: Claim 2
`The method of claim 1, wherein the probing signal provides information for the base station to estimate a channel profile in the frequency domain.”
`
`
`The probing signal used with Ford’s Accused Products provides information for the base station to estimate a
`channel profile in the frequency domain. E.g.,
`
`The UE generates a phase shifted SRS sequence that is modulated onto subcarriers in the frequency domain.
`
`
`The method of claim 1, wherein
`2.
`the probing signal provides information
`for the base station to estimate a channel
`profile in the frequency domain.
`
`
`
`See e.g., 3GPP TS 36.211 V8.9.0 at pg. 21.
`
`The generated SRS is transmitted to the base station, e.g., to the eNodeB.
`
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`37
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`"2.
`
`Case 2:22-md-03034-TGB ECF No. 96-5, PageID.4280 Filed 10/21/22 Page 40 of 975
`U.S. Patent No. 10,771,302: Claim 2
`The method of claim 1, wherein the probing signal provides information for the base station to estimate a channel profile in the frequency domain.”
`
`
`
`See e.g., 3GPP TS 36.211 V8.9.0 at pg. 31.
`
`The base station uses the SRS for channel estimation at particular frequencies, e.g.,
`
`
`
`
`
`See e.g., Dahlman, Parkvall and Skold, “4G: LTE/LTE-Advanced for Mobile Broadband, Second Edition” (2014), at p.
`257.
`
`
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`
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`
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`38
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`
`
`"2.
`
`Case 2:22-md-03034-TGB ECF No. 96-5, PageID.4281 Filed 10/21/22 Page 41 of 975
`U.S. Patent No. 10,771,302: Claim 2
`The method of claim 1, wherein the probing signal provides information for the base station to estimate a channel profile in the frequency domain.”
`
`
`
`
`See e.g., Sesia, Toufik and Baker, “LTE: The UMTS Long Term Evolution From Theory to Practice, Second
`Edition,” at p. 337.
`
`See also Claim 1.
`
`
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`39
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`
`
`"4.
`
`Case 2:22-md-03034-TGB ECF No. 96-5, PageID.4282 Filed 10/21/22 Page 42 of 975
`U.S. Patent No. 10,771,302: Claim 4
`The method of claim 1, wherein the probing signal provides information for the base station to determine a transmission format for a subsequent
`transmission.”
`The probing signal used with Ford’s Accused Products provides information for the base station to determine a
`transmission format for a subsequent transmission. E.g.,
`
`The UE generates a phase shifted SRS sequence that is modulated onto subcarriers in the frequency domain.
`
`
`The method of claim 1, wherein
`4.
`the probing signal provides information
`for the base station to determine a
`transmission format for a subsequent
`transmission.
`
`See e.g., 3GPP TS 36.211 V8.9.0 at pg. 21.
`
`The generated SRS is transmitted to the base station, e.g., to the eNodeB.
`
`
`
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`
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`40
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`
`
`"4.
`
`Case 2:22-md-03034-TGB ECF No. 96-5, PageID.4283 Filed 10/21/22 Page 43 of 975
`U.S. Patent No. 10,771,302: Claim 4
`The method of claim 1, wherein the probing signal provides information for the base station to determine a transmission format for a subsequent
`transmission.”
`
`See e.g., 3GPP TS 36.211 V8.9.0 at pg. 31.
`
`The base station uses the SRS for channel estimation, which can be used to select transmission parameters,
`including a transmission format for subsequent transmissions, such as those by the UE.
`
`
`
`
`
`See e.g., Dahlman, Parkvall and Skold, “4G: LTE/LTE-Advanced for Mobile Broadband, Second Edition” (2014), at p.
`257.
`
`
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`
`
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`41
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`
`
`"4.
`
`Case 2:22-md-03034-TGB ECF No. 96-5, PageID.4284 Filed 10/21/22 Page 44 of 975
`U.S. Patent No. 10,771,302: Claim 4
`The method of claim 1, wherein the probing signal provides information for the base station to determine a transmission format for a subsequent
`transmission.”
`
`
`See e.g., Sesia, Toufik and Baker, “LTE: The UMTS Long Term Evolution From Theory to Practice, Second
`Edition,” at p. 337.
`
`See also Claim 1.
`
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`42
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`T
`p
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` S
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` I
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`J
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`Case 2:22-md-03034-TGB ECF No. 96-5, PageID.4285 Filed 10/21/22 Page 45 of 975
`U.S. Patent No. 10,771,302: Claim 5
`The method of claim 4, wherein the transmission format comprises a modulation/coding or pilot pattern.”
`"5.
`The method of claim 4, wherein
`The probing signal used with Ford’s Accused Products provides information for the base station to determine a
`5.
`the transmission format comprises a
`transmission format for a subsequent transmission. E.g.,
`modulation/coding or pilot pattern.
`
`See Claim 4.
`
`The base station uses the SRS for channel estimation, which can be used to select transmission parameters,
`including a transmission format with a modulation/coding or pilot pattern for subsequent transmissions, such
`as those by the UE.
`
`
`See e.g., 3GPP TS 36.300 V8.12.0 at pg. 67.
`
`
`See e.g., 3GPP TS 36.300 V8.12.0 at pg. 67.
`
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`43
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`Case 2:22-md-03034-TGB ECF No. 96-5, PageID.4286 Filed 10/21/22 Page 46 of 975
`U.S. Patent No. 10,771,302: Claim 5
`The method of claim 4, wherein the transmission format comprises a modulation/coding or pilot pattern.”
`
`"5.
`
`
`
`
`
`See e.g., 3GPP TS 36.212 V8.8.0 at pgs. 43-44.
`
`
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`44
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`Case 2:22-md-03034-TGB ECF No. 96-5, PageID.4287 Filed 10/21/22 Page 47 of 975
`U.S. Patent No. 10,771,302: Claim 5
`The method of claim 4, wherein the transmission format comprises a modulation/coding or pilot pattern.”
`
`"5.
`
`
`See e.g., Dahlman, Parkvall and Skold, “4G: LTE/LTE-Advanced for Mobile Broadband, Second Edition” (2014), at p.
`257.
`
`
`
`See e.g., Sesia, Toufik and Baker, “LTE: The UMTS Long Term Evolution From Theory to Practice, Second
`Edition,” at p. 337.
`
`See also Claim 1.
`
`
`
`
`
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`45
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`
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`Case 2:22-md-03034-TGB ECF No. 96-5, PageID.4288 Filed 10/21/22 Page 48 of 975
`
`"6.
`
`U.S. Patent No. 10,771,302: Claim 6
`The method of claim 1, wherein the portion of spectrum is available for transmission of uplink data signals by other mobile devices in the system
`during a time period when the portion of the spectrum is not occupied by the probing signal.”
`The method of claim 1, wherein
`The portion of spectrum on which the probing signal transmitted by Ford’s Accused Products is configured to
`6.
`the portion of spectrum is available for
`occupy is available for transmission of uplink data signals by other mobile devices in the system during a time
`transmission of uplink data signals by
`period when the portion of the spectrum is not occupied by the probing signal. E.g.,
`other mobile devices in the system
`
`during a time period when the portion
`For example, the SRS is mapped to a range of frequency subcarriers that overlap with frequency subcarriers
`of the spectrum is not occupied by the
`used for the PUSCH (Physical Uplink Shared Channel), which is a shared channel for mobile devices within
`probing signal.
`the cell of the base station to transmit uplink data, in an OFDM symbol that is not used for SRS transmission.
`
`
`See e.g., 3GPP TS 36.211 V8.9.0 at pg. 15.
`
`
`
`
`
`
`
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`
`46
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`
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`Case 2:22-md-03034-TGB ECF No. 96-5, PageID.4289 Filed 10/21/22 Page 49 of 975
`
`"6.
`
`U.S. Patent No. 10,771,302: Claim 6
`The method of claim 1, wherein the portion of spectrum is available for transmission of uplink data signals by other mobile devices in the system
`during a time period when the portion of the spectrum is not occupied by the probing signal.”
`
`
`See e.g., Dahlman, Parkvall and Skold, “4G: LTE/LTE-Advanced for Mobile Broadband, Second Edition” (2014), at p.
`257.
`
`
`
`
`
`
`
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`47
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`
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`
`
`Case 2:22-md-03034-TGB ECF No. 96-5, PageID.4290 Filed 10/21/22 Page 50 of 975
`
`"6.
`
`U.S. Patent No. 10,771,302: Claim 6
`The method of claim 1, wherein the portion of spectrum is available for transmission of uplink data signals by other mobile devices in the system
`during a time period when the portion of the spectrum is not occupied by the probing signal.”
`
`See e.g.,
`http://rfmw.em.keysight.com/wireless/helpfiles/89600b/webhelp/subsystems/lte/content/lte_overview.htm
`
`See also Claim 1.
`
`
`
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`48
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`U.S. Patent No. 10,771,302: Claim 7
`Case 2:22-md-03034-TGB ECF No. 96-5, PageID.4291 Filed 10/21/22 Page 51 of 975
`"7. The method of claim 1, wherein the portion of spectrum is within a center portion of the uplink frequency band and subcarriers for the transmission of
`uplink control signals are within an outer portion of the uplink frequency band.”
`
`The method of claim 1, wherein
`7.
`the portion of spectrum is within a center
`portion of the uplink frequency band and
`subcarriers for the transmission of uplink
`control signals are within an outer portion
`of the uplink frequency band.
`
`The portion of spectrum on which the probing signal transmitted by Ford’s Accused Products is within a center
`portion of the uplink frequency band and subcarriers for the transmission of uplink control signals are within
`an outer portion of the uplink frequency band. E.g.,
`
`The SRS is generated and mapped to frequency subcarriers in the middle portion of the uplink frequency band.
`
`
`
`
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`49
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`U.S. Patent No. 10,771,302: Claim 7
`Case 2:22-md-03034-TGB ECF No. 96-5, PageID.4292 Filed 10/21/22 Page 52 of 975
`"7. The method of claim 1, wherein the portion of spectrum is within a center portion of the uplink frequency band and subcarriers for the transmission of
`uplink control signals are within an outer portion of the uplink frequency band.”
`
`See e.g., 3GPP TS 36.211 V8.9.0 at pg. 28-29.
`
`The PUCCH is mapped to frequency subcarriers that are at the edges of the uplink frequency band, or at least
`below and/or above the frequency subcarriers used for the SRS. See e.g.,
`
`
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`50
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`U.S. Patent No. 10,771,302: Claim 7
`Case 2:22-md-03034-TGB ECF No. 96-5, PageID.4293 Filed 10/21/22 Page 53 of 975
`"7. The method of claim 1, wherein the portion of spectrum is within a center portion of the uplink frequency band and subcarriers for the transmission of
`uplink control signals are within an outer portion of the uplink frequency band.”
`
`
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`51
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`U.S. Patent No. 10,771,302: Claim 7
`Case 2:22-md-03034-TGB ECF No. 96-5, PageID.4294 Filed 10/21/22 Page 54 of 975
`"7. The method of claim 1, wherein the portion of spectrum is within a center portion of the uplink frequency band and subcarriers for the transmission of
`uplink control signals are within an outer portion of the uplink frequency band.”
`
`
`See e.g., 3GPP TS 36.211 V8.9.0 at pgs. 20-21.
`
`
`
`
`52
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`U.S. Patent No. 10,771,302: Claim 7
`Case 2:22-md-03034-TGB ECF No. 96-5, PageID.4295 Filed 10/21/22 Page 55 of 975
`"7. The method of claim 1, wherein the portion of spectrum is within a center portion of the uplink frequency band and subcarriers for the transmission of
`uplink control signals are within an outer portion of the uplink frequency band.”
`
`See e.g.,
`http://rfmw.em.keysight.com/wireless/helpfiles/89600b/webhelp/subsystems/lte/content/lte_overview.htm
`
`
`
`
`
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`53
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`
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`U.S. Patent No. 10,771,302: Claim 7
`Case 2:22-md-03034-TGB ECF No. 96-5, PageID.4296 Filed 10/21/22 Page 56 of 975
`"7. The method of claim 1, wherein the portion of spectrum is within a center portion of the uplink frequency band and subcarriers for the transmission of
`uplink control signals are within an outer portion of the uplink frequency band.”
`
`
`See e.g., Sesia, Toufik and Baker, “LTE: The UMTS Long Term Evolution From Theory to Practice,” at p.
`358.
`
`See also Claim 1.
`
`
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`54
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`Case 2:22-md-03034-TGB ECF No. 96-5, PageID.4297 Filed 10/21/22 Page 57 of 975
`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
`To the extent the preamble is considered a limitation, Ford’s Accused Products meet the preamble of the ’302
`Frequency Division Multiplexing
`patent. E.g.,
`(OFDM) communication system, the
`
`mobile device comprising
`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 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 re
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