`
`Exhibit B
`Disputed Constructions for U.S. 5,590,403, U.S. 5,915,210, and U.S. 5,659,891
`
`’403 and ’210 Patent
`MTel
`Proposed Construction
`No construction necessary; plain
`and ordinary meaning
`
`T-Mobile
`Proposed Construction
`
`plain and ordinary meaning, with
`the understanding that
`transmitting multiple signals or
`outputs from a single structural
`unit cannot suffice as multiple
`transmitters
`
`one or more [base] transmitter[s]
`
`a set of at least two (base)
`transmitters
`
`transmit / transmitting /
`transmitted . . . the same
`information at the same time
`
`Claim Term
`
`transmitter[s] /
`base transmitter[s]
`[’403: Claims 1, 10, 11]
`[’210: Claims 1, 10]
`
`set of transmitters /
`set of base transmitter[s]
`[’403: Claim 1, 10]
`
`“transmit / transmitting /
`transmitted… in
`simulcast”
`[’403: Claims 1, 10]
`[’210: Claims 1, 10, 19]
`
`transmit / transmitting /
`transmitted the same information
`at the same time from a plurality
`of transmitters by modulating a
`plurality of carrier signals by the
`same information signal, with
`the understanding that a single
`transmitter cannot operate in
`simulcast with itself by using
`multi-carrier modulation
`
`a discrete portion of an
`electromagnetic signal that
`comprises a message or
`messages for transmission
`
`block of information
`[’403: Claim 1]
`
`No construction necessary; plain
`and ordinary meaning.
`
`1
`
`TMO2021
`
`
`
`Case 2:13-cv-00886-JRG-RSP Document 54-2 Filed 08/12/14 Page 3 of 5 PageID #: 401
`
`’403 and ’210 Patent
`MTel
`Proposed Construction
`function: agreed
`
`structure: a transmitter, and
`equivalents
`
`function: agreed
`
`structure: a transmitter, and
`equivalents
`
`Claim Term
`
`means for transmitting a
`first plurality of carrier
`signals within the desired
`frequency band, each of
`the first plurality of carrier
`signals representing a
`portion of the information
`signal substantially not
`represented by others of
`the first plurality of carrier
`signals
`[’210: Claim 19]
`
`means for transmitting a
`second plurality of carrier
`signals in simulcast with
`the first plurality of carrier
`signals, each of the second
`plurality of carrier signals
`corresponding to and
`representing substantially
`the same information
`as a respective carrier
`signal of the first plurality
`of carrier signals
`[’210: Claim 19]
`
`
`
`
`
`T-Mobile
`Proposed Construction
`
`function: agreed
`
`Structure:
`“base transmitter 1300 including
`data input 1302, control logic
`1304, modulators 1306-1314,
`combiner 1316, power amplifier
`1318, and an antenna 1320, as
`depicted in Figure 13; and
`equivalents thereof”; or “base
`transmitter 1400 including data
`input 1402, control logic 1404,
`modulators 1406-1414, power
`amplifiers 1416-1424,
`combiner 1426, and an antenna
`1428, as depicted in Figure 14;
`and equivalents thereof”
`
`function: agreed
`
`Structure:
`“base transmitter 1300 including
`data input 1302, control logic
`1304, modulators 1306-1314,
`combiner 1316, power amplifier
`1318, and an antenna 1320, as
`depicted in Figure 13; and
`equivalents thereof”; or
`“base transmitter 1400 including
`data input 1402, control logic
`1404, modulators 1406-1414,
`power amplifiers 1416-1424,
`combiner 1426, and an antenna
`1428, as
`in Figure 14; and
`depicted
`equivalents thereof”
`
`2
`
`
`
`Case 2:13-cv-00886-JRG-RSP Document 54-2 Filed 08/12/14 Page 4 of 5 PageID #: 402
`
`Claim Term
`
`single mask-defined,
`bandlimited channel
`[Claim 1, 3, 5]
`
`independently receiving
`one of said plurality of
`carriers
`[Claim 5]
`
`paging carriers /
`modulated carriers
`[Claims 1, 3]
`
`’891 Patent
`MTel
`Proposed Construction
`No construction necessary; plain
`and ordinary meaning.
`
`T-Mobile
`Proposed Construction
`
`a channel confined to a
`frequency range meeting the
`FCC paging requirements
`
`No construction necessary; plain
`and ordinary meaning.
`
`receiving only one carrier of the
`plurality of carriers
`
`radio frequency transmission
`signals that are capable of being
`modulated to carry paging
`information
`
`radio frequency transmission
`signals that are capable of being
`modulated to carry paging
`information and are not
`orthogonally multiplexed
`
`same location
`[Claims 1, 3]
`
`No construction necessary; plain
`and ordinary meaning.
`
`same antenna
`
`said plurality of carriers
`can be emanated from the
`same transmission source
`[Claim 5]
`
`frequency difference
`between the center
`frequencies of each
`adjacent carrier
`[Claims 1, 3, 5]
`
`subchannel(s)
`[Claims 3, 4, 5]
`
`adjacent carriers overlap /
`adjacent subchannels
`overlap
`[Claims 2, 4]
`
`No construction necessary; plain
`and ordinary meaning.
`
`Indefinite
`
`No construction necessary; plain
`and ordinary meaning.
`
`Indefinite
`
`No construction necessary; plain
`and ordinary meaning.
`
`a defined portion of a radio
`frequency channel corresponding
`to a single subcarrier
`
`No construction necessary; plain
`and ordinary meaning.
`
`Indefinite
`
`spaced within the mask
`[Claim 5]
`
`No construction necessary; plain
`and ordinary meaning.
`
`spaced asymmetrically within
`the mask
`
`3
`
`
`
`Case 2:13-cv-00886-JRG-RSP Document 54-2 Filed 08/12/14 Page 5 of 5 PageID #: 403
`
`’891 Patent
`MTel
`Proposed Construction
`No construction necessary.
`
`
`
`T-Mobile
`Proposed Construction
`
`Claim Term
`
`Preamble is limiting
`[Claim 1, 3, 5]
`
`
`741403v.2
`
`4