1
`
`
`
`having the second length”
`a circular shift to the code sequence
`having a first length, and performing
`cyclic extension of a code sequence
`sequence having a second length by
`Function: “generating a code
`
`governed by Section 112(6).
`This is a means plus function term
`
`
`
`
`therefore invalid as indefinite.
`corresponding structure, and
`Structure: Lacks sufficient
`
`
`
`
`
`
`length”
`code sequence having the second
`and performing a circular shift to the
`a code sequence having a first length,
`second length by cyclic extension of
`generating a code sequence having a
`apparatus that is capable of
`“hardware and/or software in the
`
`
`
`the function.
`name for the structure that performs
`sufficiently definite meaning as the
`would understand the term to have a
`the art reading the specification
`because a person of ordinary skill in
`Section 112(6) does not apply
`
`
`
`having the second length”
`a circular shift to the code sequence
`having a first length, and performing
`cyclic extension of a code sequence
`sequence having a second length by
`Function: “generating a code
`
`
`
`
`
`If section 112(6) applies:
`
`length”
`code sequence having the second
`and performing a circular shift to the
`a code sequence having a first length,
`second length by cyclic extension of
`generating a code sequence having a
`“a code sequence generator for
`
`Defendants’ Proposal
`
`Evolved Wireless’s Proposal
`
`Terms/Elements for Construction
`
`Proposed Constructions of Claim Terms/Phrases of the ’916 Patent
`
`
`
`Case 1:15-cv-00546-SLR-SRF Document 57-1 Filed 05/17/16 Page 2 of 21 PageID #: 1178
`
`6
`
`(’916)
`Claims
`
`PETITIONERS 1048-0001
`IPR2016-00758
`
`

`

`second length”
`shifted code sequence having the
`Function: “transmitting the circular
`
`therefore invalid as indefinite.
`corresponding structure, and
`Structure: Lacks sufficient
`
`
`
`
`
`governed by Section 112(6).
`This is a means plus function term
`
`
`
`2
`
`sequence having the second length”
`transmitting the circular shifted code
`apparatus that is capable of
`“hardware and/or software in the
`
`having the second length”
`a circular shift to the code sequence
`having a first length, and performing
`cyclic extension of a code sequence
`sequence having a second length by
`capable of generating a code
`software in the apparatus that is
`Structure: “hardware and/or
`
`
`
`
`
`the function.
`name for the structure that performs
`sufficiently definite meaning as the
`would understand the term to have a
`the art reading the specification
`because a person of ordinary skill in
`Section 112(6) does not apply
`
`second length”
`shifted code sequence having the
`Function: “transmitting the circular
`
`software in the apparatus that is
`Structure: “hardware and/or
`
`
`
`
`
`If section 112(6) applies:
`
`
`
`having the second length”
`the circular shifted code sequence
`“a transmitting unit for transmitting
`
`
`
`6
`
`Defendants’ Proposal
`
`Evolved Wireless’s Proposal
`
`Terms/Elements for Construction
`
`(’916)
`Claims
`
`Case 1:15-cv-00546-SLR-SRF Document 57-1 Filed 05/17/16 Page 3 of 21 PageID #: 1179
`
`PETITIONERS 1048-0002
`IPR2016-00758
`
`

`

`3
`
`second length”
`shifted code sequence having the
`capable of transmitting the circular
`
`
`
`
`
`Defendants’ Proposal
`
`Evolved Wireless’s Proposal
`
`Terms/Elements for Construction
`
`(’916)
`Claims
`
`Case 1:15-cv-00546-SLR-SRF Document 57-1 Filed 05/17/16 Page 4 of 21 PageID #: 1180
`
`
`
`
`
`PETITIONERS 1048-0003
`IPR2016-00758
`
`

`

`4
`
`
`
`access sequence set”
`sequence within the selected random
`randomly selecting a specific
`and a degree of a path loss, and
`to be transmitted by the apparatus
`at least one of a size of information
`preamble sequence sets considering
`the predetermined random access
`preamble sequence set from among
`sets, selecting one random access
`random access preamble sequence
`about predetermined two or more
`Function: “acquiring information
`
`therefore invalid as indefinite.
`corresponding structure, and
`Structure: Lacks sufficient
`
`
`
`
`
`
`
`governed by 112(6):
`to be a means plus function term
`To the extent this limitation is found
`
`Indefinite.
`
`
`
`sequence set”
`within the selected random access
`randomly select a specific sequence
`and a degree of a path loss, and
`to be transmitted by the apparatus
`at least one of a size of information
`preamble sequence sets considering
`predetermined random access
`sequence set from among the
`one random access preamble
`access preamble sequence sets, select
`predetermined two or more random
`acquire information about
`performing the following algorithm:
`equipment that is capable of
`“hardware and/or software in the user
`
`the function.
`name for the structure that performs
`sufficiently definite meaning as the
`would understand the term to have a
`the art reading the specification
`because a person of ordinary skill in
`Section 112(6) does not apply
`
`
`
`
`
`Not indefinite.
`
`
`
`random access sequence set”
`specific sequence within the selected
`randomly selecting a
`and a degree of a path loss, and
`to be transmitted by the apparatus
`at least one of a size of information
`preamble sequence sets considering
`the predetermined random access
`preamble sequence set from among
`selecting one random access
`access preamble sequence sets,
`predetermined two or more random
`acquiring information about
`“a sequence selecting module
`
`
`
`Defendants’ Proposal
`
`Evolved Wireless’s Proposal
`
`Terms/Elements for Construction
`
`Proposed Constructions of Claim Terms/Phrases of the ’965 Patent
`
`
`
`Case 1:15-cv-00546-SLR-SRF Document 57-1 Filed 05/17/16 Page 5 of 21 PageID #: 1181
`
`8
`
`(’965)
`Claims
`
`PETITIONERS 1048-0004
`IPR2016-00758
`
`

`

`5
`
`
`
`randomly select a specific sequence
`and a degree of a path loss, and
`to be transmitted by the apparatus
`at least one of a size of information
`preamble sequence sets considering
`predetermined random access
`sequence set from among the
`one random access preamble
`access preamble sequence sets, select
`predetermined two or more random
`algorithm: acquire information about
`capable of performing the following
`software in the user equipment that is
`Structure: “hardware and/or
`
`
`
`access sequence set”
`sequence within the selected random
`randomly selecting a specific
`and a degree of a path loss, and
`to be transmitted by the apparatus
`at least one of a size of information
`preamble sequence sets considering
`the predetermined random access
`preamble sequence set from among
`sets, selecting one random access
`random access preamble sequence
`about predetermined two or more
`Function: “acquiring information
`
`If section 112(6) applies:
`
`
`
`Defendants’ Proposal
`
`Evolved Wireless’s Proposal
`
`Terms/Elements for Construction
`
`(’965)
`Claims
`
`Case 1:15-cv-00546-SLR-SRF Document 57-1 Filed 05/17/16 Page 6 of 21 PageID #: 1182
`
`PETITIONERS 1048-0005
`IPR2016-00758
`
`

`

`6
`
`
`
`governed by 112(6):
`to be a means plus function term
`To the extent this limitation is found
`
`selecting module”
`sequence selected by the sequence
`access channel using the specific
`Function: “accessing a random
`
`therefore invalid as indefinite.
`corresponding structure, and
`Structure: Lacks sufficient
`
`
`
`
`
`
`
`Indefinite.
`
`
`
`channel to the base station.”
`sequence on the random access
`transmitting the specific selected
`equipment that is capable of
`“hardware and/or software in the user
`
`Not indefinite.
`sequence set”
`within the selected random access
`
`
`
`
`
`the function.
`name for the structure that performs
`sufficiently definite meaning as the
`would understand the term to have a
`the art reading the specification
`because a person of ordinary skill in
`Section 112(6) does not apply
`
`access channel to the base station.”
`selected sequence on the random
`capable of transmitting the specific
`software in the user equipment that is
`Structure: “hardware and/or
`
`
`
`selecting module”
`sequence selected by the sequence
`access channel using the specific
`Function: “accessing a random
`
`
`
`If section 112(6) applies:
`
`
`
`sequence selecting module”
`specific sequence selected by the
`random access channel using the
`“an access module accessing a
`
`
`
`Defendants’ Proposal
`
`Evolved Wireless’s Proposal
`
`Terms/Elements for Construction
`
`Case 1:15-cv-00546-SLR-SRF Document 57-1 Filed 05/17/16 Page 7 of 21 PageID #: 1183
`
`8
`
`(’965)
`Claims
`
`PETITIONERS 1048-0006
`IPR2016-00758
`
`

`

`limitation.
`source base station” into this claim
`improperly inserts the words “by the
`Wireless’s proposed construction
`No construction necessary. Evolved
`transferred”
`terminal’s connection may be
`means “base station to which a
`construction, “target base station”
`To the extent this term requires
`base station”
`with a source base station to a target
`to transfer a terminal’s connection
`“handover request” means “a request
`
`
`
`base station to a target base station”
`terminal’s connection with a source
`“handover” means “transfer of a
`
`
`
`7
`
`the source base station to determine”
`“the measurement report is used by
`
`determine”
`“the measurement report is used to
`
`
`
`17
`
`terminal will be transferred”
`base station determines the mobile
`“the base station to which the source
`
`“target base station”
`
`18, 20, 23-25
`1, 3, 8, 15,
`
`a noun and as an adjective.
`meaning of “handover” when used as
`construed in order to specify the
`“handover request” should both be
`construction, “handover” and
`To the extent this term requires
`
`station has ceased”
`connection with the source base
`the target base station after radio
`establishing radio connection with
`telecommunication link by
`“a process to transfer a
`
`“handover”
`
`15, 17, 23-24
`1, 4, 7, 8, 13,
`
`Defendants’ Proposal
`
`Evolved Wireless’s Proposal
`
`Terms/Elements for Construction
`
`Proposed Constructions of Claim Terms/Phrases of the ’373 Patent
`
`(’373)
`Claims
`
`
`
`Case 1:15-cv-00546-SLR-SRF Document 57-1 Filed 05/17/16 Page 8 of 21 PageID #: 1184
`
`PETITIONERS 1048-0007
`IPR2016-00758
`
`

`

`8
`
`
`
`by Section 112(6):
`a means plus function term governed
`To the extent this term is found to be
`
`Indefinite.
`
`
`
`accepted by the target base station”
`station after a handover request is
`information from a source base
`Function: “receiving access
`
`therefore invalid as indefinite.
`corresponding structure, and
`Structure: Lacks sufficient
`
`
`
`
`
`
`
`station”
`determined by the target base
`wherein the dedicated preamble is
`used only for a specific terminal, and
`information is a dedicated preamble
`procedure, wherein the preamble
`information for the random access
`information includes preamble
`station, wherein the access
`the terminal to access the target base
`information is configured to permit
`information, such that the access
`using the received access
`procedure with the target base station
`and to perform a random access
`is accepted by the target base station
`base station after a handover request
`access information from a source
`mobile terminal adapted to receive
`“hardware and/or software in the
`
`the function.
`name for the structure that performs
`sufficiently definite meaning as the
`would understand the term to have a
`the art reading the specification
`because a person of ordinary skill in
`Section 112(6) does not apply
`
`
`
`Not indefinite.
`
`
`
`station”
`the terminal to access the target base
`information is configured to permit
`information, such that the access
`using the received access
`procedure with the target base station
`and to perform a random access
`is accepted by the target base station
`base station after a handover request
`access information from a source
`“a radio protocol adapted to receive
`
`Defendants’ Proposal
`
`Evolved Wireless’s Proposal
`
`Terms/Elements for Construction
`
`Case 1:15-cv-00546-SLR-SRF Document 57-1 Filed 05/17/16 Page 9 of 21 PageID #: 1185
`
`24
`
`(’373)
`Claims
`
`PETITIONERS 1048-0008
`IPR2016-00758
`
`

`

`9
`
`
`
`received access information”
`with the target base station using the
`perform a random access procedure
`from a source base station and to
`adapted to receive access information
`software in the mobile terminal
`Structure: “hardware and/or
`
`
`
`station”
`determined by the target base
`wherein the dedicated preamble is
`used only for a specific terminal, and
`information is a dedicated preamble
`procedure, wherein the preamble
`information for the random access
`information includes preamble
`station, wherein the access
`the terminal to access the target base
`information is configured to permit
`information, such that the access
`using the received access
`procedure with the target base station
`and (2) to perform a random access
`accepted by the target base station,
`station after a handover request is
`information from a source base
`Function: “(1) to receive access
`
`If section 112(6) applies:
`
`
`
`
`
`
`Defendants’ Proposal
`
`Evolved Wireless’s Proposal
`
`Terms/Elements for Construction
`
`(’373)
`Claims
`
`Case 1:15-cv-00546-SLR-SRF Document 57-1 Filed 05/17/16 Page 10 of 21 PageID #: 1186
`
`PETITIONERS 1048-0009
`IPR2016-00758
`
`

`

`10
`
`
`
`Indefinite.
`
`Indefinite.
`
`Not indefinite.
`
`Not indefinite.
`
`UMTS)”
`Telecommunication System (E-
`“an Evolved Universal Mobile
`station”
`determined by the target base
`“wherein the dedicated preamble is
`
`
`
`Defendants’ Proposal
`
`Evolved Wireless’s Proposal
`
`Terms/Elements for Construction
`
`
`
`25
`
`24
`
`(’373)
`Claims
`
`Case 1:15-cv-00546-SLR-SRF Document 57-1 Filed 05/17/16 Page 11 of 21 PageID #: 1187
`
`PETITIONERS 1048-0010
`IPR2016-00758
`
`

`

`governed by Section 112(6).
`This is a means plus function term
`
`
`
`on a specific message”
`(UL Grant) signal from a base station
`Function: “receiving an uplink grant
`
`governed by Section 112(6).
`This is a means plus function term
`
`
`
`
`therefore invalid as indefinite.
`corresponding structure, and
`Structure: Lacks sufficient
`
`
`
`
`
`transmitting data to the base station
`equipment that is capable of
`“hardware and/or software in the user
`on aspecific message”
`(UL Grant) signal from a base station
`capable of receiving an uplink grant
`software in the user equipment that is
`Structure: “hardware and/or
`
`
`
`on a specific message”
`(UL Grant) signal from a base station
`Function: “receiving an uplink grant
`
`
`
`11
`
`station using the UL Grant signal
`adapted to transmit data to the base
`“a transmission module
`
`
`
`7
`
`If section 112(6) applies:
`
`Defendants’ Proposal
`
`Evolved Wireless’s Proposal
`
`Terms/Elements for Construction
`
`Proposed Constructions of Claim Terms/Phrases of the ’236 Patent
`
`
`
`Case 1:15-cv-00546-SLR-SRF Document 57-1 Filed 05/17/16 Page 12 of 21 PageID #: 1188
`
`a base station on a specific message.
`receiving an uplink grant signal from
`equipment that is capable of
`“hardware and/or software in the user
`
`specific message”
`signal from a base station on a
`receive an uplink grant (UL Grant)
`“a reception module adapted to
`
`
`
`the function.
`name for the structure that performs
`sufficiently definite meaning as the
`would understand the term to have a
`the art reading the specification
`because a person of ordinary skill in
`Section 112(6) does not apply
`
`
`
`7
`
`(’236)
`Claims
`
`PETITIONERS 1048-0011
`IPR2016-00758
`
`

`

`12
`
`governed by 112(6):
`to be a means plus function term
`To the extent this limitation is found
`
`Function: “determining whether
`
`
`
`Indefinite.
`
`
`
`
`received on the specific message”
`station using the UL Grant signal
`Function: “transmit data to the base
`
`therefore invalid as indefinite.
`corresponding structure, and
`Structure: Lacks sufficient
`
`
`
`
`
`reception module receives the UL
`stored in the Msg3 buffer when the
`determining whether there is data
`equipment that is capable of
`“hardware and/or software in the user
`
`
`
`Not indefinite.
`message.
`signal received on the specific
`base station using the UL Grant
`is capable of transmitting data to the
`software in the user equipment that
`Structure: “hardware and/or
`
`
`
`received on the specific message”
`station using the UL Grant signal
`Function: “transmit data to the base
`
`the function.
`name for the structure that performs
`sufficiently definite meaning as the
`would understand the term to have a
`the art reading the specification
`because a person of ordinary skill in
`Section 112(6) does not apply
`
`on the specific message”
`using the UL Grant signal received
`
`
`
`
`
`If section 112(6) applies:
`
`
`
`access response message, acquiring
`and the specific message is a random
`module receives the UL Grant signal
`Msg3 buffer when the reception
`whether there is data stored in the
`(HARQ) entity adapted to determine
`“a Hybrid Automatic Repeat Request
`
`
`
`7
`
`received on the specific message”
`
`Defendants’ Proposal
`
`Evolved Wireless’s Proposal
`
`Terms/Elements for Construction
`
`(’236)
`Claims
`
`Case 1:15-cv-00546-SLR-SRF Document 57-1 Filed 05/17/16 Page 13 of 21 PageID #: 1189
`
`PETITIONERS 1048-0012
`IPR2016-00758
`
`

`

`13
`
`
`
`module on the specific message”
`signal received by the reception
`base station using the UL Grant
`data stored in the Msg3 buffer to the
`transmission module to transmit the
`message, and controlling the
`is the random access response
`Grant signal and the specific message
`the reception module receives the UL
`data stored in the Msg3 buffer when
`stored in the Msg3 buffer if there is
`response message, acquiring the data
`specific message is a random access
`receives the UL Grant signal and the
`buffer when the reception module
`there is data stored in the Msg3
`
`
`
`therefore invalid as indefinite.
`corresponding structure, and
`Structure: Lacks sufficient
`
`
`
`specific message.
`by the reception module on the
`using the UL Grant signal received
`the Msg3 buffer to the base station
`module to transmit the data stored in
`and controlling the transmission
`random access response message,
`and the specific message is the
`module receives the UL Grant signal
`Msg3 buffer when the reception
`buffer if there is data stored in the
`acquiring the data stored in the Msg3
`is a random access response message,
`Grant signal and the specific message
`
`
`
`specific message is a random access
`receives the UL Grant signal and the
`buffer when the reception module
`there is data stored in the Msg3
`Function: “determining whether
`
`
`
`If section 112(6) applies:
`
`
`
`the function.
`name for the structure that performs
`sufficiently definite meaning as the
`would understand the term to have a
`the art reading the specification
`because a person of ordinary skill in
`Section 112(6) does not apply
`
`message”
`reception module on the specific
`the UL Grant signal received by the
`Msg3 buffer to the base station using
`to transmit the data stored in the
`controlling the transmission module
`access response message, and
`specific message is the random
`receives the UL Grant signal and the
`buffer when the reception module
`there is data stored in the Msg3
`the data stored in the Msg3 buffer if
`
`Defendants’ Proposal
`
`Evolved Wireless’s Proposal
`
`Terms/Elements for Construction
`
`(’236)
`Claims
`
`Case 1:15-cv-00546-SLR-SRF Document 57-1 Filed 05/17/16 Page 14 of 21 PageID #: 1190
`
`PETITIONERS 1048-0013
`IPR2016-00758
`
`

`

`14
`
`
`
`base station using the UL Grant
`data stored in the Msg3 buffer to the
`transmission module to transmit the
`message, and controlling the
`is the random access response
`Grant signal and the specific message
`reception module receives the UL
`in the Msg3 buffer when the
`the Msg3 buffer if there is data stored
`message, acquiring the data stored in
`message is a random access response
`the UL Grant signal and the specific
`when the reception module receives
`is data stored in the Msg3 buffer
`capable of determining whether there
`software in the user equipment that is
`Structure: “hardware and/or
`
`module on the specific message”
`signal received by the reception
`base station using the UL Grant
`data stored in the Msg3 buffer to the
`transmission module to transmit the
`message, and controlling the
`is the random access response
`Grant signal and the specific message
`the reception module receives the UL
`data stored in the Msg3 buffer when
`stored in the Msg3 buffer if there is
`response message, acquiring the data
`
`
`
`Defendants’ Proposal
`
`Evolved Wireless’s Proposal
`
`Terms/Elements for Construction
`
`(’236)
`Claims
`
`Case 1:15-cv-00546-SLR-SRF Document 57-1 Filed 05/17/16 Page 15 of 21 PageID #: 1191
`
`PETITIONERS 1048-0014
`IPR2016-00758
`
`

`

`15
`
`Indefinite.
`
`governed by Section 112(6):
`to be a means plus function term
`To the extent this limitation is found
`
`Function: “transmitting new data”
`
`therefore invalid as indefinite.
`corresponding structure, and
`Structure: Lacks sufficient
`
`
`
`
`
`
`
`
`Indefinite.
`
`
`
`
`transmitting new data”
`equipment that is capable of
`“hardware and/or software in the user
`
`Not indefinite.
`module on the specific message”
`signal received by the reception
`
`
`
`
`
`the function.
`name for the structure that performs
`sufficiently definite meaning as the
`would understand the term to have a
`the art reading the specification
`because a person of ordinary skill in
`Section 112(6) does not apply
`
`Not indefinite.
`capable of transmitting new data”
`software in the user equipment that is
`Structure: “hardware and/or
`
`
`
`Function: “transmitting new data”
`
`
`
`If section 112(6) applies:
`
`
`
`specific message or the received
`receives the UL Grant signal on the
`buffer when the reception module
`if there is no data stored in the Msg3
`the multiplexing and assembly entity
`the new data to be transmitted from
`“wherein the HARQ entity acquires
`
`
`
`7
`
`used for transmission of new data”
`“a multiplexing and assembly entity
`
`7
`
`Defendants’ Proposal
`
`Evolved Wireless’s Proposal
`
`Terms/Elements for Construction
`
`(’236)
`Claims
`
`Case 1:15-cv-00546-SLR-SRF Document 57-1 Filed 05/17/16 Page 16 of 21 PageID #: 1192
`
`PETITIONERS 1048-0015
`IPR2016-00758
`
`

`

`16
`
`Indefinite.
`
`Not indefinite.
`
`Indefinite.
`
`Not indefinite.
`
`transmission module”
`to be transmitted through the
`specific HARQ buffer is controlled
`process, and the data copied into the
`corresponding to the specific HARQ
`copied into a specific HARQ buffer
`in the Msg3 buffer is controlled to be
`transmission module, the data stored
`the Msg3 buffer through the
`process transmits the data stored in
`“wherein, when the specific HARQ
`through the transmission module”
`assembly entity or the Msg3 buffer
`acquired from the multiplexing and
`HARQ process to transmit the data
`processes and controls the specific
`process of the one or more HARQ
`the Msg3 buffer to a specific HARQ
`multiplexing and assembly entity or
`the data acquired from the
`“wherein the HARQ entity transfers
`specific message”
`by the reception module on the
`using the UL Grant signal received
`multiplexing and assembly entity
`new data acquired from the
`transmission module to transmit the
`response message, and controls the
`message is not the random access
`
`
`
`9
`
`8
`
`Defendants’ Proposal
`
`Evolved Wireless’s Proposal
`
`Terms/Elements for Construction
`
`(’236)
`Claims
`
`Case 1:15-cv-00546-SLR-SRF Document 57-1 Filed 05/17/16 Page 17 of 21 PageID #: 1193
`
`PETITIONERS 1048-0016
`IPR2016-00758
`
`

`

`17
`
`Indefinite.
`
`Not indefinite.
`
`Indefinite.
`
`Not indefinite.
`
`Indefinite.
`
`Not indefinite.
`
`Indefinite.
`
`Not indefinite.
`
`response message”
`signal received on the random access
`Channel (PDCCH) or a UL Grant
`a Physical Downlink Control
`either a UL Grant signal received on
`received on the specific message is
`“wherein the UL Grant signal
`identifier”
`including a user equipment
`Protocol Data Unit (MAC PDU)
`buffer is a Medium Access Control
`“wherein the data stored in the Msg3
`PDCCH”
`Grant signal received on the
`correspondence with the received UL
`new data to be transmitted in
`“wherein the HARQ entity controls
`(PDCCH)”
`Downlink Control Channel
`signal received on a Physical
`the specific message is a UL Grant
`received by the reception module on
`“wherein the UL Grant signal
`
`
`
`
`
`
`
`13
`
`12
`
`10
`
`10
`
`Defendants’ Proposal
`
`Evolved Wireless’s Proposal
`
`Terms/Elements for Construction
`
`(’236)
`Claims
`
`Case 1:15-cv-00546-SLR-SRF Document 57-1 Filed 05/17/16 Page 18 of 21 PageID #: 1194
`
`PETITIONERS 1048-0017
`IPR2016-00758
`
`

`

`18
`
`
`
`consecutive sequence”
`(CP) to a front end of said
`concatenating a single cyclic prefix
`sequence having a length (N*L) and
`times to generate a consecutive
`sequence, having a length (L), N
`sequence by repeating a specific
`Function: “generating said preamble
`
`governed by Section 112(6).
`This is a means plus function term
`
`
`
`therefore invalid as indefinite.
`corresponding structure, and
`Structure: Lacks sufficient
`
`
`
`
`
`said consecutive sequence”
`cyclic prefix (CP) to a front end of
`(N*L) and concatenate a single
`consecutive sequence having a length
`length (L), N times to generate a
`repeat a specific sequence, having a
`performing the following algorithm:
`transmitter that is capable of
`“hardware and/or software in the
`
`
`
`the function.
`name for the structure that performs
`sufficiently definite meaning as the
`would understand the term to have a
`the art reading the specification
`because a person of ordinary skill in
`Section 112(6) does not apply
`
`(CP) to a front end of said
`concatenating a single cyclic prefix
`sequence having a length (N*L) and
`times to generate a consecutive
`sequence, having a length (L), N
`sequence by repeating a specific
`Function: “generating said preamble
`
`
`
`If section 112(6) applies:
`
`
`
`consecutive sequence”
`(CP) to a front end of said
`concatenating a single cyclic prefix
`sequence having a length (N*L) and
`times to generate a consecutive
`sequence, having a length (L), N
`sequence by repeating a specific
`configured to generate said preamble
`“a preamble generation unit
`
`
`
`Defendants’ Proposal
`
`Evolved Wireless’s Proposal
`
`Terms/Elements for Construction
`
`Proposed Constructions of Claim Terms/Phrases of the ’481 Patent
`
`
`
`Case 1:15-cv-00546-SLR-SRF Document 57-1 Filed 05/17/16 Page 19 of 21 PageID #: 1195
`
`8
`
`(’481)
`Claims
`
`PETITIONERS 1048-0018
`IPR2016-00758
`
`

`

`governed by Section 112(6).
`This is a means plus function term
`
`
`
`side”
`preamble sequence to a receiving
`random access channel, said
`Function: “transmitting, on a
`
`therefore invalid as indefinite.
`corresponding structure, and
`Structure: Lacks sufficient
`
`
`
`
`
`consecutive sequence”
`(CP) to a front end of said
`concatenate a single cyclic prefix
`having a length (N*L) and
`generate a consecutive sequence
`having a length (L), N times to
`algorithm: repeat a specific sequence,
`capable of performing the following
`software in the transmitter that is
`Structure: “hardware and/or
`
`consecutive sequence”
`
`
`
`
`
`side”
`random access channel to a receiving
`the preamble sequence on the
`transmitter capable of transmitting
`“hardware and/or software in the
`
`
`
`the function.
`name for the structure that performs
`sufficiently definite meaning as the
`would understand the term to have a
`the art reading the specification
`because a person of ordinary skill in
`Section 112(6) does not apply
`
`19
`
`If 112(6) applies:
`
`
`
`
`
`receiving side”
`channel, said preamble sequence to a
`transmit, on a random access
`“a transmission unit configured to
`
`
`
`8
`
`Defendants’ Proposal
`
`Evolved Wireless’s Proposal
`
`Terms/Elements for Construction
`
`(’481)
`Claims
`
`Case 1:15-cv-00546-SLR-SRF Document 57-1 Filed 05/17/16 Page 20 of 21 PageID #: 1196
`
`PETITIONERS 1048-0019
`IPR2016-00758
`
`

`

`20
`
`receiving side”
`on the random access channel to a
`transmitting the preamble sequence
`software in the transmitter capable of
`Structure: “hardware and/or
`
`
`
`side”
`preamble sequence to a receiving
`random access channel, said
`Function: “transmitting, on a
`
`
`
`
`
`
`
`Defendants’ Proposal
`
`Evolved Wireless’s Proposal
`
`Terms/Elements for Construction
`
`(’481)
`Claims
`
`Case 1:15-cv-00546-SLR-SRF Document 57-1 Filed 05/17/16 Page 21 of 21 PageID #: 1197
`
`PETITIONERS 1048-0020
`IPR2016-00758
`
`