Case 2:22-md-03034-TGB ECF No. 96-7, PageID.7143 Filed 10/21/22 Page 1 of 685
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`EXHIBIT F
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`Case 2:22-md-03034-TGB ECF No. 96-7, PageID.7144 Filed 10/21/22 Page 2 of 685
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`Plaintiff’s Infringement
`Contentions to Ford
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`Case 2:22-md-03034-TGB ECF No. 96-7, PageID.7145 Filed 10/21/22 Page 3 of 685
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`Exhibit 512
`U.S. Patent No. 10,965,512
`Claims 15, 20, 21, 23, 28, 29
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`1
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`An orthogonal frequency division
`15.
`multiple access (OFDMA)-compatible
`mobile station that uses subcarriers in a
`frequency domain and time slots in a time
`domain, the OFDMA-compatible mobile
`station comprising:
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`Case 2:22-md-03034-TGB ECF No. 96-7, PageID.7146 Filed 10/21/22 Page 4 of 685
`U.S. Patent No. 10,965,512: Claim 15(a)
`"15. An orthogonal frequency division multiple access (OFDMA)-compatible mobile station that uses subcarriers in a frequency domain and time slots in
`a time domain, the OFDMA-compatible mobile station comprising:"
`To the extent the preamble is considered a limitation, Ford’s Accused Products meet the preamble of
`the ’512 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 release 8 standard and subsequent releases (“LTE”) include an orthogonal frequency division
`multiple access (OFDMA)-compatible mobile station that uses subcarriers in a frequency domain and time
`slots in a time domain.
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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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`For example, the LTE specification (Series 36, Release 8) supports user equipment (UEs) to communicate
`with eNodeBs.
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`Case 2:22-md-03034-TGB ECF No. 96-7, PageID.7147 Filed 10/21/22 Page 5 of 685
`U.S. Patent No. 10,965,512: Claim 15(a)
`"15. An orthogonal frequency division multiple access (OFDMA)-compatible mobile station that uses subcarriers in a frequency domain and time slots in
`a time domain, the OFDMA-compatible mobile station comprising:"
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`See e.g., 3GPP TS 36.300 V8.12.0 at pg. 15.
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`LTE uses OFDMA in the downlink transmission.
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`Case 2:22-md-03034-TGB ECF No. 96-7, PageID.7148 Filed 10/21/22 Page 6 of 685
`U.S. Patent No. 10,965,512: Claim 15(a)
`"15. An orthogonal frequency division multiple access (OFDMA)-compatible mobile station that uses subcarriers in a frequency domain and time slots in
`a time domain, the OFDMA-compatible mobile station comprising:"
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`See e.g., 3GPP TS 36.300 V8.12.0 at pg. 25.
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`Each frame structure has time slots. For example, Frame structure type 1 for FDD includes 20 time slots.
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`Case 2:22-md-03034-TGB ECF No. 96-7, PageID.7149 Filed 10/21/22 Page 7 of 685
`U.S. Patent No. 10,965,512: Claim 15(a)
`"15. An orthogonal frequency division multiple access (OFDMA)-compatible mobile station that uses subcarriers in a frequency domain and time slots in
`a time domain, the OFDMA-compatible mobile station comprising:"
`
`See e.g., 3GPP TS 36.211 V8.9.0 at pgs. 9-10.
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`The mobile station receives signals in the form of subcarriers having a time domain and frequency domain
`component.
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`Case 2:22-md-03034-TGB ECF No. 96-7, PageID.7150 Filed 10/21/22 Page 8 of 685
`U.S. Patent No. 10,965,512: Claim 15(a)
`"15. An orthogonal frequency division multiple access (OFDMA)-compatible mobile station that uses subcarriers in a frequency domain and time slots in
`a time domain, the OFDMA-compatible mobile station comprising:"
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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. 96-7, PageID.7151 Filed 10/21/22 Page 9 of 685
`U.S. Patent No. 10,965,512: Claim 15(a)
`"15. An orthogonal frequency division multiple access (OFDMA)-compatible mobile station that uses subcarriers in a frequency domain and time slots in
`a time domain, the OFDMA-compatible mobile station comprising:"
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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. 96-7, PageID.7152 Filed 10/21/22 Page 10 of 685
`U.S. Patent No. 10,965,512: Claim 15(a)
`"15. An orthogonal frequency division multiple access (OFDMA)-compatible mobile station that uses subcarriers in a frequency domain and time slots in
`a time domain, the OFDMA-compatible mobile station comprising:"
`A physical resource block (PRB) corresponds to a plurality of consecutive OFDM symbols in the time
`domain (typically 7 OFDM symbols) and a plurality of consecutive subcarriers (typically 12 subcarriers) in
`the frequency domain, which correspond to a block of resource elements. The block of resource elements
`correspond to one time slot in the time domain and 180 kHz in the frequency domain.
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`See e.g., 3GPP TS 36.211 V8.9.0 at pgs. 46-47.
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`Case 2:22-md-03034-TGB ECF No. 96-7, PageID.7153 Filed 10/21/22 Page 11 of 685
`U.S. Patent No. 10,965,512: Claim 15(a)
`"15. An orthogonal frequency division multiple access (OFDMA)-compatible mobile station that uses subcarriers in a frequency domain and time slots in
`a time domain, the OFDMA-compatible mobile station comprising:"
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`See e.g., 3GPP TS 36.211 V8.9.0 at pg. 76.
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`Case 2:22-md-03034-TGB ECF No. 96-7, PageID.7154 Filed 10/21/22 Page 12 of 685
`U.S. Patent No. 10,965,512: Claim 15(b)
`"at least one antenna; and a receiver; and the at least one antenna and the receiver are configured to:
`receive first pilots of a first type on a first plurality of subcarriers, wherein the first pilots are cell-specific pilots; and
`receive second pilots of a second type and data on a second plurality of subcarriers, wherein the first plurality of subcarriers and the second plurality of
`subcarriers are received in at least one of the time slots;"
`Ford’s Accused Products each include at least one antenna and a receiver, wherein the at least one antenna
`and the receiver are configured first and second pilots of first and second types, respectively. E.g.,
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`The UE receives first pilots of a first type on a first plurality of subcarriers, wherein the first pilots are cell-
`specific pilots and receive second pilots of a second type and data on a second plurality of subcarriers,
`wherein the first plurality of subcarriers and the second plurality of subcarriers are received in at least one of
`the time slots.
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`For example, the LTE UE is configured to receive both a first set of pilots, e.g., the cell-specific reference
`signals, and a second set pilots, e.g., UE-specific reference signals, via at least one antenna on a plurality of
`subcarriers in at least one time slot. In particular, the Accused Products are configured to receive downlink
`data in multiple transmission modes, including at least transmission mode 7 using UE-specific reference
`signals.
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`at least one antenna; and
`a receiver; and
`the at least one antenna and the receiver
`are configured to:
`receive first pilots of a first type on a first
`plurality of subcarriers, wherein the first
`pilots are cell-specific pilots; and
`receive second pilots of a second type and
`data on a second plurality of subcarriers,
`wherein the first plurality of subcarriers
`and the second plurality of subcarriers are
`received in at least one of the time slots;
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`Case 2:22-md-03034-TGB ECF No. 96-7, PageID.7155 Filed 10/21/22 Page 13 of 685
`U.S. Patent No. 10,965,512: Claim 15(b)
`"at least one antenna; and a receiver; and the at least one antenna and the receiver are configured to:
`receive first pilots of a first type on a first plurality of subcarriers, wherein the first pilots are cell-specific pilots; and
`receive second pilots of a second type and data on a second plurality of subcarriers, wherein the first plurality of subcarriers and the second plurality of
`subcarriers are received in at least one of the time slots;"
`See e.g., 3GPP TS 36.300 V8.12.0 at pg. 23.
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`See e.g., 3GPP TS 36.211 V8.9.0 at pg.65.
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`The mapping of the cell-specific reference signals are to resource elements that correspond to a subcarrier
`and symbol in a slot.
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`See e.g., 3GPP TS 36.211 V8.9.0 at pg.65.
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`Case 2:22-md-03034-TGB ECF No. 96-7, PageID.7156 Filed 10/21/22 Page 14 of 685
`U.S. Patent No. 10,965,512: Claim 15(b)
`"at least one antenna; and a receiver; and the at least one antenna and the receiver are configured to:
`receive first pilots of a first type on a first plurality of subcarriers, wherein the first pilots are cell-specific pilots; and
`receive second pilots of a second type and data on a second plurality of subcarriers, wherein the first plurality of subcarriers and the second plurality of
`subcarriers are received in at least one of the time slots;"
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`Case 2:22-md-03034-TGB ECF No. 96-7, PageID.7157 Filed 10/21/22 Page 15 of 685
`U.S. Patent No. 10,965,512: Claim 15(b)
`"at least one antenna; and a receiver; and the at least one antenna and the receiver are configured to:
`receive first pilots of a first type on a first plurality of subcarriers, wherein the first pilots are cell-specific pilots; and
`receive second pilots of a second type and data on a second plurality of subcarriers, wherein the first plurality of subcarriers and the second plurality of
`subcarriers are received in at least one of the time slots;"
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`See e.g., 3GPP TS 36.211 V8.9.0 at pg.66-67 (illustrating mapping of cell-specific reference signals).
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`The UE-specific reference signals are transmitted on resource elements, which include the second plurality
`of subcarriers, upon which a corresponding PDSCH, data, is mapped.
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`Case 2:22-md-03034-TGB ECF No. 96-7, PageID.7158 Filed 10/21/22 Page 16 of 685
`U.S. Patent No. 10,965,512: Claim 15(b)
`"at least one antenna; and a receiver; and the at least one antenna and the receiver are configured to:
`receive first pilots of a first type on a first plurality of subcarriers, wherein the first pilots are cell-specific pilots; and
`receive second pilots of a second type and data on a second plurality of subcarriers, wherein the first plurality of subcarriers and the second plurality of
`subcarriers are received in at least one of the time slots;"
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`See e.g., 3GPP TS 36.211 V8.9.0 at pg. 70.
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`Case 2:22-md-03034-TGB ECF No. 96-7, PageID.7159 Filed 10/21/22 Page 17 of 685
`U.S. Patent No. 10,965,512: Claim 15(b)
`"at least one antenna; and a receiver; and the at least one antenna and the receiver are configured to:
`receive first pilots of a first type on a first plurality of subcarriers, wherein the first pilots are cell-specific pilots; and
`receive second pilots of a second type and data on a second plurality of subcarriers, wherein the first plurality of subcarriers and the second plurality of
`subcarriers are received in at least one of the time slots;"
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`See e.g., 3GPP TS 36.211 V8.9.0 at pg.71-72
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`Case 2:22-md-03034-TGB ECF No. 96-7, PageID.7160 Filed 10/21/22 Page 18 of 685
`U.S. Patent No. 10,965,512: Claim 15(b)
`"at least one antenna; and a receiver; and the at least one antenna and the receiver are configured to:
`receive first pilots of a first type on a first plurality of subcarriers, wherein the first pilots are cell-specific pilots; and
`receive second pilots of a second type and data on a second plurality of subcarriers, wherein the first plurality of subcarriers and the second plurality of
`subcarriers are received in at least one of the time slots;"
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`See e.g., LTE - The UMTS Long Term Evolution - FROM THEORY TO PRACTICE - 2nd Edition pg. 171.
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`Case 2:22-md-03034-TGB ECF No. 96-7, PageID.7161 Filed 10/21/22 Page 19 of 685
`U.S. Patent No. 10,965,512: Claim 15(c)
`"wherein at least some subcarriers of the first plurality of subcarriers or the second plurality of subcarriers are beam-formed; and
`wherein at least some subcarriers of the
`At least some of the first or second plurality subcarriers used to receive the first or second pilots by Ford’s
`first plurality of subcarriers or the second
`Accused Products are beamformed. E.g.,
`plurality of subcarriers are beam-formed;
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`and
`For example, the Accused Products emply UE-specific RSs is to enable beamforming of the data
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`transmissions to specific UEs via the second plurality of subcarriers.
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`See e.g., 3GPP TS 36.300 V8.12.0 at pg. 30.
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`In LTE, subcarriers are beam-formed through precoding.
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`Case 2:22-md-03034-TGB ECF No. 96-7, PageID.7162 Filed 10/21/22 Page 20 of 685
`U.S. Patent No. 10,965,512: Claim 15(c)
`"wherein at least some subcarriers of the first plurality of subcarriers or the second plurality of subcarriers are beam-formed; and
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`See e.g., 3GPP TS 36.211 V8.9.0 at pg. 52.
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`Case 2:22-md-03034-TGB ECF No. 96-7, PageID.7163 Filed 10/21/22 Page 21 of 685
`U.S. Patent No. 10,965,512: Claim 15(c)
`"wherein at least some subcarriers of the first plurality of subcarriers or the second plurality of subcarriers are beam-formed; and
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`See e.g., Sesia, LTE - The UMTS Long Term Evolution - FROM THEORY TO PRACTICE - 2nd Edition
`pg. 171.
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`Case 2:22-md-03034-TGB ECF No. 96-7, PageID.7164 Filed 10/21/22 Page 22 of 685
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`U.S. Patent No. 10,965,512: Claim 15(d)
`"the receiver is further configured to:
`recover the data using channel estimates from at least the second pilots; and recover cell-specific information using the cell-specific pilots;”
`the receiver is further configured to:
`The receiver of Ford’s Accused Products is further configured to recover the data using channel estimates
`and cell-specific information using the pilots. E.g.,
`recover the data using channel estimates
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`from at least the second pilots; and
`recover cell-specific information using the
`The UE is further configured to recover the data using channel estimates from at least the second pilots and
`cell-specific pilots;
`recover cell-specific information using the cell-specific pilots.
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`For example, the LTE UE uses the UE-specific reference signals embedded in the received PRBs to derive
`the channel estimation for demodulating the data in the corresponding PDSCH resource blocks.
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`See e.g., 3GPP TS 36.211 V8.9.0 at pg. 70.
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`See e.g., Sesia, LTE - The UMTS Long Term Evolution - FROM THEORY TO PRACTICE - 2nd Edition
`pg. 171.
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`Case 2:22-md-03034-TGB ECF No. 96-7, PageID.7165 Filed 10/21/22 Page 23 of 685
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`U.S. Patent No. 10,965,512: Claim 15(d)
`"the receiver is further configured to:
`recover the data using channel estimates from at least the second pilots; and recover cell-specific information using the cell-specific pilots;”
`The LTE UE recovers cell-specific information, such as the cell ID, using the cell-specific pilots. The Cell
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`ID (NIDcell) is used for generating the cell-specific reference signal sequence.
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`See e.g., 3GPP TS 36.211 V8.9.0 at pgs.65-66.
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`The LTE cell-specific reference signal is also used to recover cell-specific information from the
`MasterInformationBlock, which is transmitted via the broadcast channel (BCH). The cell-specific reference
`signal is used, inter alia, to estimate the channel corresponding to the center part of the carrier where the
`BCH is transmitted.
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`Case 2:22-md-03034-TGB ECF No. 96-7, PageID.7166 Filed 10/21/22 Page 24 of 685
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`U.S. Patent No. 10,965,512: Claim 15(d)
`"the receiver is further configured to:
`recover the data using channel estimates from at least the second pilots; and recover cell-specific information using the cell-specific pilots;”
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`See e.g., 3GPP TS 36.331 V8.21.0 at pgs.85-86.
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`Case 2:22-md-03034-TGB ECF No. 96-7, PageID.7167 Filed 10/21/22 Page 25 of 685
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`U.S. Patent No. 10,965,512: Claim 15(d)
`"the receiver is further configured to:
`recover the data using channel estimates from at least the second pilots; and recover cell-specific information using the cell-specific pilots;”
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`See e.g., Sesia, 4G, LTE ADVANCED PRO AND THE ROAD TO 5G, Third Edition, pg. 104
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`Case 2:22-md-03034-TGB ECF No. 96-7, PageID.7168 Filed 10/21/22 Page 26 of 685
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`wherein the second type is different than
`the first type and wherein the first pilots
`do not interfere with the second pilots.
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`U.S. Patent No. 10,965,512: Claim 15(e)
`“wherein the second type is different than the first type and wherein the first pilots do not interfere with the second pilots.”
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`The second type of pilots used with Ford’s Accused Products are different than the first type of pilots and
`the first pilots do not interfere with the second pilots. E.g.,
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`For example, cell-specific reference signals, the first pilots, are different than the UE-specific reference
`signals, second pilots.
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`See e.g., 3GPP TS 36.211 V8.9.0 at pg.65.
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`Case 2:22-md-03034-TGB ECF No. 96-7, PageID.7169 Filed 10/21/22 Page 27 of 685
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`U.S. Patent No. 10,965,512: Claim 15(e)
`“wherein the second type is different than the first type and wherein the first pilots do not interfere with the second pilots.”
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`See e.g., 3GPP TS 36.211 V8.9.0 at pgs.65-66.
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`Case 2:22-md-03034-TGB ECF No. 96-7, PageID.7170 Filed 10/21/22 Page 28 of 685
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`U.S. Patent No. 10,965,512: Claim 15(e)
`“wherein the second type is different than the first type and wherein the first pilots do not interfere with the second pilots.”
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`See e.g., 3GPP TS 36.211 V8.9.0 at pgs. 71.
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`The UE-specific reference signals are not transmitted in resource elements in which other physical signals,
`such as the cell-specific reference signal, are transmitted. Thus, they do not interfere.
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`Case 2:22-md-03034-TGB ECF No. 96-7, PageID.7171 Filed 10/21/22 Page 29 of 685
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`U.S. Patent No. 10,965,512: Claim 15(e)
`“wherein the second type is different than the first type and wherein the first pilots do not interfere with the second pilots.”
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`See e.g., 3GPP TS 36.211 V8.9.0 at pg.71-72
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`Case 2:22-md-03034-TGB ECF No. 96-7, PageID.7172 Filed 10/21/22 Page 30 of 685
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`U.S. Patent No. 10,965,512: Claim 15(e)
`“wherein the second type is different than the first type and wherein the first pilots do not interfere with the second pilots.”
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`Case 2:22-md-03034-TGB ECF No. 96-7, PageID.7173 Filed 10/21/22 Page 31 of 685
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`U.S. Patent No. 10,965,512: Claim 15(e)
`“wherein the second type is different than the first type and wherein the first pilots do not interfere with the second pilots.”
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`See e.g., 3GPP TS 36.211 V8.9.0 at pg.66-67.
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`Case 2:22-md-03034-TGB ECF No. 96-7, PageID.7174 Filed 10/21/22 Page 32 of 685
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`U.S. Patent No. 10,965,512: Claim 15(e)
`“wherein the second type is different than the first type and wherein the first pilots do not interfere with the second pilots.”
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`* * *
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`Sesia, Toufik and Baker, “LTE: The UMTS Long Term Evolution From Theory to Practice,” at p. 171-72
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`Case 2:22-md-03034-TGB ECF No. 96-7, PageID.7175 Filed 10/21/22 Page 33 of 685
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`U.S. Patent No. 10,965,512: Claim 20
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`"20. The OFDMA-compatible mobile station of claim 15, wherein the second plurality of subcarriers are beamformed.”
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`20. The OFDMA-compatible mobile
`station of claim 15, wherein the second
`plurality of subcarriers are beamformed.
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`The second plurality of subcarriers one which second pilots are received by Ford’s Accused Products are
`beamformed. E.g.,
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`The second plurality of subcarriers carrying the UE-specific reference signals and/or data are sent using a
`beamformed signal to target the UE. See also,
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`See e.g., 3GPP TS 36.211 V8.9.0 at pg. 70.
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`Case 2:22-md-03034-TGB ECF No. 96-7, PageID.7176 Filed 10/21/22 Page 34 of 685
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`U.S. Patent No. 10,965,512: Claim 20
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`"20. The OFDMA-compatible mobile station of claim 15, wherein the second plurality of subcarriers are beamformed.”
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`Case 2:22-md-03034-TGB ECF No. 96-7, PageID.7177 Filed 10/21/22 Page 35 of 685
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`U.S. Patent No. 10,965,512: Claim 20
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`"20. The OFDMA-compatible mobile station of claim 15, wherein the second plurality of subcarriers are beamformed.”
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`
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`See e.g., 3GPP TS 36.211 V8.9.0 at pg.71-72
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`Case 2:22-md-03034-TGB ECF No. 96-7, PageID.7178 Filed 10/21/22 Page 36 of 685
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`U.S. Patent No. 10,965,512: Claim 20
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`"20. The OFDMA-compatible mobile station of claim 15, wherein the second plurality of subcarriers are beamformed.”
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`Case 2:22-md-03034-TGB ECF No. 96-7, PageID.7179 Filed 10/21/22 Page 37 of 685
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`U.S. Patent No. 10,965,512: Claim 20
`
`"20. The OFDMA-compatible mobile station of claim 15, wherein the second plurality of subcarriers are beamformed.”
`
`
`
`Sesia, Toufik and Baker, “LTE: The UMTS Long Term Evolution From Theory to Practice,” at p. 171; see
`also at pp. 171-74 (the extension for dual layer beamforming in Release 9 and later that is backward
`compatible).
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`See also claim 15.
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`Case 2:22-md-03034-TGB ECF No. 96-7, PageID.7180 Filed 10/21/22 Page 38 of 685
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`U.S. Patent No. 10,965,512: Claim 21
`
`"21. The OFDMA-compatible mobile station of claim 15, wherein the first plurality of subcarriers are not aligned in frequency with subcarriers of at
`least another cell onto which respective cell-specific pilots are inserted.”
`
`
`The OFDMA-compatible mobile
`21.
`station of claim 15, wherein the first
`plurality of subcarriers are not aligned in
`frequency with subcarriers of at least
`another cell onto which respective cell-
`specific pilots are inserted.
`
`The first plurality of subcarriers used with Ford’s Accused Products are not aligned in frequency with
`subcarriers of at least another cell onto which respective cell-specific pilots are inserted. E.g.,
`
`The first plurality of subcarriers used to carry the cell-specific pilots are shifted in frequency based on the
`cell, e.g., based on the cell’s physical layer cell identity. See,
`
`
`See e.g., 3GPP TS 36.211 V8.9.0 at pg.65.
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`Case 2:22-md-03034-TGB ECF No. 96-7, PageID.7181 Filed 10/21/22 Page 39 of 685
`
`U.S. Patent No. 10,965,512: Claim 21
`
`"21. The OFDMA-compatible mobile station of claim 15, wherein the first plurality of subcarriers are not aligned in frequency with subcarriers of at
`least another cell onto which respective cell-specific pilots are inserted.”
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`Case 2:22-md-03034-TGB ECF No. 96-7, PageID.7182 Filed 10/21/22 Page 40 of 685
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`U.S. Patent No. 10,965,512: Claim 21
`
`"21. The OFDMA-compatible mobile station of claim 15, wherein the first plurality of subcarriers are not aligned in frequency with subcarriers of at
`least another cell onto which respective cell-specific pilots are inserted.”
`
`
`See e.g., 3GPP TS 36.211 V8.9.0 at pg.66-67.
`
`See also claim 15.
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`23. A method performed by an orthogonal
`frequency division multiple access
`(OFDMA)-compatible mobile station that
`uses subcarriers in a frequency domain
`and time slots in a time domain, the
`method comprising:
`
`
`
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`Case 2:22-md-03034-TGB ECF No. 96-7, PageID.7183 Filed 10/21/22 Page 41 of 685
`U.S. Patent No. 10,965,512: Claim 23(a)
`"23. A method performed by an orthogonal frequency division multiple access (OFDMA)-compatible mobile station that uses subcarriers in a frequency
`domain and time slots in a time domain, the method comprising:"
`To the extent the preamble is considered a limitation, Ford’s Accused Products meet the preamble of
`the ’512 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 release 8 standard and subsequent releases (“LTE”) include an orthogonal frequency division
`multiple access (OFDMA)-compatible mobile station that uses subcarriers in a frequency domain and time
`slots in a time domain.
`
`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.
`
`For example, the LTE specification (Series 36, Release 8) supports user equipment (UEs) to communicate
`with eNodeBs.
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`Case 2:22-md-03034-TGB ECF No. 96-7, PageID.7184 Filed 10/21/22 Page 42 of 685
`U.S. Patent No. 10,965,512: Claim 23(a)
`"23. A method performed by an orthogonal frequency division multiple access (OFDMA)-compatible mobile station that uses subcarriers in a frequency
`domain and time slots in a time domain, the method comprising:"
`
`See e.g., 3GPP TS 36.300 V8.12.0 at pg. 15.
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`
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`LTE uses OFDMA in the downlink transmission.
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`Case 2:22-md-03034-TGB ECF No. 96-7, PageID.7185 Filed 10/21/22 Page 43 of 685
`U.S. Patent No. 10,965,512: Claim 23(a)
`"23. A method performed by an orthogonal frequency division multiple access (OFDMA)-compatible mobile station that uses subcarriers in a frequency
`domain and time slots in a time domain, the method comprising:"
`
`See e.g., 3GPP TS 36.300 V8.12.0 at pg. 25.
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`Each frame structure has time slots. For example, Frame structure type 1 for FDD includes 20 time slots.
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`Case 2:22-md-03034-TGB ECF No. 96-7, PageID.7186 Filed 10/21/22 Page 44 of 685
`U.S. Patent No. 10,965,512: Claim 23(a)
`"23. A method performed by an orthogonal frequency division multiple access (OFDMA)-compatible mobile station that uses subcarriers in a frequency
`domain and time slots in a time domain, the method comprising:"
`
`See e.g., 3GPP TS 36.211 V8.9.0 at pgs. 9-10.
`
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`The mobile station receives signals in the form of subcarriers having a time domain and frequency domain
`component.
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`Case 2:22-md-03034-TGB ECF No. 96-7, PageID.7187 Filed 10/21/22 Page 45 of 685
`U.S. Patent No. 10,965,512: Claim 23(a)
`"23. A method performed by an orthogonal frequency division multiple access (OFDMA)-compatible mobile station that uses subcarriers in a frequency
`domain and time slots in a time domain, the method comprising:"
`
`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. 96-7, PageID.7188 Filed 10/21/22 Page 46 of 685
`U.S. Patent No. 10,965,512: Claim 23(a)
`"23. A method performed by an orthogonal frequency division multiple access (OFDMA)-compatible mobile station that uses subcarriers in a frequency
`domain and time slots in a time domain, the method comprising:"
`
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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. 96-7, PageID.7189 Filed 10/21/22 Page 47 of 685
`U.S. Patent No. 10,965,512: Claim 23(a)
`"23. A method performed by an orthogonal frequency division multiple access (OFDMA)-compatible mobile station that uses subcarriers in a frequency
`domain and time slots in a time domain, the method comprising:"
`A physical resource block (PRB) corresponds to a plurality of consecutive OFDM symbols in the time
`domain (typically 7 OFDM symbols) and a plurality of consecutive subcarriers (typically 12 subcarriers) in
`the frequency domain, which correspond to a block of resource elements. The block of resource elements
`correspond to one time slot in the time domain and 180 kHz in the frequency domain.
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`See e.g., 3GPP TS 36.211 V8.9.0 at pgs. 46-47.
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`Case 2:22-md-03034-TGB ECF No. 96-7, PageID.7190 Filed 10/21/22 Page 48 of 685
`U.S. Patent No. 10,965,512: Claim 23(a)
`"23. A method performed by an orthogonal frequency division multiple access (OFDMA)-compatible mobile station that uses subcarriers in a frequency
`domain and time slots in a time domain, the method comprising:"
`
`
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`See e.g., 3GPP TS 36.211 V8.9.0 at pg. 76.
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`See also Claim 15(a)
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`Case 2:22-md-03034-TGB ECF No. 96-7, PageID.7191 Filed 10/21/22 Page 49 of 685
`U.S. Patent No. 10,965,512: Claim 23(b)
`"receiving first pilots of a first type on a first plurality of subcarriers, wherein the first pilots are cell-specific pilots;
`receiving second pilots of a second type and data on a second plurality of subcarriers, wherein the first plurality of subcarriers and the second plurality of
`subcarriers are received in at least one of the time slots;"
`Ford’s Accused Products receive first and second pilots of first and second types, respectively, wherein the
`first pilots are cell-specific pilots. E.g.,
`
`The UE receives first pilots of a first type on a first plurality of subcarriers, wherein the first pilots are cell-
`specific pilots and receive second pilots of a second type and data on a second plurality of subcarriers,
`wherein the first plurality of subcarriers and the second plurality of subcarriers are received in at least one of
`the time slots.
`
`For example, the LTE UE is configured to receive a first set of pilots, e.g., the cell-specific reference signals,
`and a second set pilots, e.g., UE-specific reference signals, via at least one antenna on a plurality of
`subcarriers in at least one time slot. In particular, the Accused Products are configured to receive downlink
`data in multiple transmission modes, including at least transmission mode 7 using UE-specific reference
`signals.
`
`
`
`receiving first pilots of a first type on a
`first plurality of subcarriers, wherein the
`first pilots are cell-specific pilots;
`receiving second pilots of a second type
`and data on a second plurality of
`subcarriers, wherein the first plurality of
`subcarriers and the second plurality of
`subcarriers are received in at least one of
`the time slots;
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`See e.g., 3GPP TS 36.300 V8.12.0 at pg. 23.
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`Case 2:22-md-03034-TGB ECF No. 96-7, PageID.7192 Filed 10/21/22 Page 50 of 685
`U.S. Patent No. 10,965,512: Claim 23(b)
`"receiving first pilots of a first type on a first plurality of subcarriers, wherein the first pilots are cell-specific pilots;
`receiving second pilots of a second type and data on a second plurality of subcarriers, wherein the first plurality of subcarriers and the second plurality of
`subcarriers are received in at least one of the time slots;"
`
`
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`See e.g., 3GPP TS 36.211 V8.9.0 at pg.65.
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`The mapping of the cell-specific reference signals are to resource elements that correspond to a subcarrier
`and symbol in a slot.
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`See e.g., 3GPP TS 36.211 V8.9.0 at pg.65.
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`Case 2:22-md-03034-TGB ECF No. 96-7, PageID.7193 Filed 10/21/22 Page 51 of 685
`U.S. Patent No. 10,965,512: Claim 23(b)
`"receiving first