Case 1:15-cv-00546-SLR-SRF Document 57-1 Filed 05/17/16 Page 1 of 21 PageID #: 1177
`Case 1:15—cv—OO546—SLR—SRF Document 57-1 Filed 05/17/16 Page 1 of 21 Page|D #: 1177
`
`EXHIBIT A
`
`EXHIBIT A
`
`
`
`SAM SU NG 1046-0001
`
`SAMSUNG 1046-0001
`
`

`
`Case 1:15-cv-00546-SLR-SRF Document 57-1 Filed 05/17/16 Page 2 of 21 PageID #: 1178
`
`Proposed Constructions of Claim Terms/Phrases of the ’916 Patent
`
`Claims
`(’916)
`
`6
`
`Terms/Elements for Construction
`
`“a code sequence generator for
`generating a code sequence having a
`second length by cyclic extension of
`a code sequence having a first length,
`and performing a circular shift to the
`code sequence having the second
`length”
`
`
`
`
`Evolved Wireless’s Proposal
`
`Defendants’ Proposal
`
`This is a means plus function term
`governed by Section 112(6).
`
`
`Function: “generating a code
`sequence having a second length by
`cyclic extension of a code sequence
`having a first length, and performing
`a circular shift to the code sequence
`having the second length”
`
`
`Structure: Lacks sufficient
`corresponding structure, and
`therefore invalid as indefinite.
`
`
`“hardware and/or software in the
`apparatus that is capable of
`generating a code sequence having a
`second length by cyclic extension of
`a code sequence having a first length,
`and performing a circular shift to the
`code sequence having the second
`length”
`
`Section 112(6) does not apply
`because a person of ordinary skill in
`the art reading the specification
`would understand the term to have a
`sufficiently definite meaning as the
`name for the structure that performs
`the function.
`
`If section 112(6) applies:
`
`Function: “generating a code
`sequence having a second length by
`cyclic extension of a code sequence
`having a first length, and performing
`a circular shift to the code sequence
`having the second length”
`
`
`1
`
`SAMSUNG 1046-0002
`
`

`
`Case 1:15-cv-00546-SLR-SRF Document 57-1 Filed 05/17/16 Page 3 of 21 PageID #: 1179
`
`Claims
`(’916)
`
`Terms/Elements for Construction
`
`Evolved Wireless’s Proposal
`
`Defendants’ Proposal
`
`Structure: “hardware and/or
`software in the apparatus that is
`capable of generating a code
`sequence having a second length by
`cyclic extension of a code sequence
`having a first length, and performing
`a circular shift to the code sequence
`having the second length”
`
`“hardware and/or software in the
`apparatus that is capable of
`transmitting the circular shifted code
`sequence having the second length”
`
`Section 112(6) does not apply
`because a person of ordinary skill in
`the art reading the specification
`would understand the term to have a
`sufficiently definite meaning as the
`name for the structure that performs
`the function.
`
`If section 112(6) applies:
`
`Function: “transmitting the circular
`shifted code sequence having the
`second length”
`
`Structure: “hardware and/or
`software in the apparatus that is
`
`2
`
`This is a means plus function term
`governed by Section 112(6).
`
`Function: “transmitting the circular
`shifted code sequence having the
`second length”
`
`Structure: Lacks sufficient
`corresponding structure, and
`therefore invalid as indefinite.
`
`
`“a transmitting unit for transmitting
`the circular shifted code sequence
`having the second length”
`
`6
`
`
`
`SAMSUNG 1046-0003
`
`

`
`Case 1:15-cv-00546-SLR-SRF Document 57-1 Filed 05/17/16 Page 4 of 21 PageID #: 1180
`
`Claims
`(’916)
`
`Terms/Elements for Construction
`
`Evolved Wireless’s Proposal
`
`Defendants’ Proposal
`
`capable of transmitting the circular
`shifted code sequence having the
`second length”
`
`
`
`
`3
`
`
`
`
`
`SAMSUNG 1046-0004
`
`

`
`Case 1:15-cv-00546-SLR-SRF Document 57-1 Filed 05/17/16 Page 5 of 21 PageID #: 1181
`
`Proposed Constructions of Claim Terms/Phrases of the ’965 Patent
`
`Claims
`(’965)
`
`8
`
`Terms/Elements for Construction
`
`“a sequence selecting module
`acquiring information about
`predetermined two or more random
`access preamble sequence sets,
`selecting one random access
`preamble sequence set from among
`the predetermined random access
`preamble sequence sets considering
`at least one of a size of information
`to be transmitted by the apparatus
`and a degree of a path loss, and
`randomly selecting a
`specific sequence within the selected
`random access sequence set”
`
`
`
`
`
`Evolved Wireless’s Proposal
`
`Defendants’ Proposal
`
`Indefinite.
`
`To the extent this limitation is found
`to be a means plus function term
`governed by 112(6):
`
`Function: “acquiring information
`about predetermined two or more
`random access preamble sequence
`sets, selecting one random access
`preamble sequence set from among
`the predetermined random access
`preamble sequence sets considering
`at least one of a size of information
`to be transmitted by the apparatus
`and a degree of a path loss, and
`randomly selecting a specific
`sequence within the selected random
`access sequence set”
`
`Structure: Lacks sufficient
`corresponding structure, and
`therefore invalid as indefinite.
`
`
`Not indefinite.
`
`“hardware and/or software in the user
`equipment that is capable of
`performing the following algorithm:
`acquire information about
`predetermined two or more random
`access preamble sequence sets, select
`one random access preamble
`sequence set from among the
`predetermined random access
`preamble sequence sets considering
`at least one of a size of information
`to be transmitted by the apparatus
`and a degree of a path loss, and
`randomly select a specific sequence
`within the selected random access
`sequence set”
`
`Section 112(6) does not apply
`because a person of ordinary skill in
`the art reading the specification
`would understand the term to have a
`sufficiently definite meaning as the
`name for the structure that performs
`the function.
`
`
`4
`
`SAMSUNG 1046-0005
`
`

`
`Case 1:15-cv-00546-SLR-SRF Document 57-1 Filed 05/17/16 Page 6 of 21 PageID #: 1182
`
`Claims
`(’965)
`
`Terms/Elements for Construction
`
`Evolved Wireless’s Proposal
`
`Defendants’ Proposal
`
`If section 112(6) applies:
`
`Function: “acquiring information
`about predetermined two or more
`random access preamble sequence
`sets, selecting one random access
`preamble sequence set from among
`the predetermined random access
`preamble sequence sets considering
`at least one of a size of information
`to be transmitted by the apparatus
`and a degree of a path loss, and
`randomly selecting a specific
`sequence within the selected random
`access sequence set”
`
`Structure: “hardware and/or
`software in the user equipment that is
`capable of performing the following
`algorithm: acquire information about
`predetermined two or more random
`access preamble sequence sets, select
`one random access preamble
`sequence set from among the
`predetermined random access
`preamble sequence sets considering
`at least one of a size of information
`to be transmitted by the apparatus
`and a degree of a path loss, and
`randomly select a specific sequence
`
`5
`
`
`
`SAMSUNG 1046-0006
`
`

`
`Case 1:15-cv-00546-SLR-SRF Document 57-1 Filed 05/17/16 Page 7 of 21 PageID #: 1183
`
`Terms/Elements for Construction
`
`Evolved Wireless’s Proposal
`
`Defendants’ Proposal
`
`“an access module accessing a
`random access channel using the
`specific sequence selected by the
`sequence selecting module”
`
`
`Indefinite.
`
`To the extent this limitation is found
`to be a means plus function term
`governed by 112(6):
`
`Function: “accessing a random
`access channel using the specific
`sequence selected by the sequence
`selecting module”
`
`Structure: Lacks sufficient
`corresponding structure, and
`therefore invalid as indefinite.
`
`
`within the selected random access
`sequence set”
`Not indefinite.
`
`“hardware and/or software in the user
`equipment that is capable of
`transmitting the specific selected
`sequence on the random access
`channel to the base station.”
`
`Section 112(6) does not apply
`because a person of ordinary skill in
`the art reading the specification
`would understand the term to have a
`sufficiently definite meaning as the
`name for the structure that performs
`the function.
`
`If section 112(6) applies:
`
`Function: “accessing a random
`access channel using the specific
`sequence selected by the sequence
`selecting module”
`
`Structure: “hardware and/or
`software in the user equipment that is
`capable of transmitting the specific
`selected sequence on the random
`access channel to the base station.”
`
`6
`
`Claims
`(’965)
`
`8
`
`
`
`SAMSUNG 1046-0007
`
`

`
`Case 1:15-cv-00546-SLR-SRF Document 57-1 Filed 05/17/16 Page 8 of 21 PageID #: 1184
`
`Proposed Constructions of Claim Terms/Phrases of the ’373 Patent
`
`Terms/Elements for Construction
`
`Evolved Wireless’s Proposal
`
`Defendants’ Proposal
`
`
`
`Claims
`(’373)
`1, 4, 7, 8, 13,
`15, 17, 23-24
`
`“handover”
`
`“a process to transfer a
`telecommunication link by
`establishing radio connection with
`the target base station after radio
`connection with the source base
`station has ceased”
`
`To the extent this term requires
`construction, “handover” and
`“handover request” should both be
`construed in order to specify the
`meaning of “handover” when used as
`a noun and as an adjective.
`
`“handover” means “transfer of a
`terminal’s connection with a source
`base station to a target base station”
`
`“handover request” means “a request
`to transfer a terminal’s connection
`with a source base station to a target
`base station”
`To the extent this term requires
`construction, “target base station”
`means “base station to which a
`terminal’s connection may be
`transferred”
`No construction necessary. Evolved
`Wireless’s proposed construction
`improperly inserts the words “by the
`source base station” into this claim
`limitation.
`
`1, 3, 8, 15,
`18, 20, 23-25
`
`“target base station”
`
`“the base station to which the source
`base station determines the mobile
`terminal will be transferred”
`
`17
`
`
`
`“the measurement report is used to
`determine”
`
`“the measurement report is used by
`the source base station to determine”
`
`7
`
`SAMSUNG 1046-0008
`
`

`
`Case 1:15-cv-00546-SLR-SRF Document 57-1 Filed 05/17/16 Page 9 of 21 PageID #: 1185
`
`Terms/Elements for Construction
`
`Evolved Wireless’s Proposal
`
`Defendants’ Proposal
`
`“a radio protocol adapted to receive
`access information from a source
`base station after a handover request
`is accepted by the target base station
`and to perform a random access
`procedure with the target base station
`using the received access
`information, such that the access
`information is configured to permit
`the terminal to access the target base
`station”
`
`Indefinite.
`
`To the extent this term is found to be
`a means plus function term governed
`by Section 112(6):
`
`Function: “receiving access
`information from a source base
`station after a handover request is
`accepted by the target base station”
`
`Structure: Lacks sufficient
`corresponding structure, and
`therefore invalid as indefinite.
`
`
`Not indefinite.
`
`“hardware and/or software in the
`mobile terminal adapted to receive
`access information from a source
`base station after a handover request
`is accepted by the target base station
`and to perform a random access
`procedure with the target base station
`using the received access
`information, such that the access
`information is configured to permit
`the terminal to access the target base
`station, wherein the access
`information includes preamble
`information for the random access
`procedure, wherein the preamble
`information is a dedicated preamble
`used only for a specific terminal, and
`wherein the dedicated preamble is
`determined by the target base
`station”
`
`Section 112(6) does not apply
`because a person of ordinary skill in
`the art reading the specification
`would understand the term to have a
`sufficiently definite meaning as the
`name for the structure that performs
`the function.
`
`8
`
`Claims
`(’373)
`
`24
`
`
`
`SAMSUNG 1046-0009
`
`

`
`Case 1:15-cv-00546-SLR-SRF Document 57-1 Filed 05/17/16 Page 10 of 21 PageID #: 1186
`
`Claims
`(’373)
`
`Terms/Elements for Construction
`
`Evolved Wireless’s Proposal
`
`Defendants’ Proposal
`
`
`If section 112(6) applies:
`
`
`Function: “(1) to receive access
`information from a source base
`station after a handover request is
`accepted by the target base station,
`and (2) to perform a random access
`procedure with the target base station
`using the received access
`information, such that the access
`information is configured to permit
`the terminal to access the target base
`station, wherein the access
`information includes preamble
`information for the random access
`procedure, wherein the preamble
`information is a dedicated preamble
`used only for a specific terminal, and
`wherein the dedicated preamble is
`determined by the target base
`station”
`
`Structure: “hardware and/or
`software in the mobile terminal
`adapted to receive access information
`from a source base station and to
`perform a random access procedure
`with the target base station using the
`received access information”
`
`9
`
`
`
`SAMSUNG 1046-0010
`
`

`
`Case 1:15-cv-00546-SLR-SRF Document 57-1 Filed 05/17/16 Page 11 of 21 PageID #: 1187
`
`Claims
`(’373)
`
`24
`
`25
`
`
`
`Terms/Elements for Construction
`
`Evolved Wireless’s Proposal
`
`Defendants’ Proposal
`
`“wherein the dedicated preamble is
`determined by the target base
`station”
`“an Evolved Universal Mobile
`Telecommunication System (E-
`UMTS)”
`
`
`
`Not indefinite.
`
`Not indefinite.
`
`Indefinite.
`
`Indefinite.
`
`
`
`10
`
`SAMSUNG 1046-0011
`
`

`
`Case 1:15-cv-00546-SLR-SRF Document 57-1 Filed 05/17/16 Page 12 of 21 PageID #: 1188
`
`Proposed Constructions of Claim Terms/Phrases of the ’236 Patent
`
`Terms/Elements for Construction
`
`
`Evolved Wireless’s Proposal
`
`Defendants’ Proposal
`
`Claims
`(’236)
`
`7
`
`“a reception module adapted to
`receive an uplink grant (UL Grant)
`signal from a base station on a
`specific message”
`
`“hardware and/or software in the user
`equipment that is capable of
`receiving an uplink grant signal from
`a base station on a specific message.
`
`Section 112(6) does not apply
`because a person of ordinary skill in
`the art reading the specification
`would understand the term to have a
`sufficiently definite meaning as the
`name for the structure that performs
`the function.
`
`If section 112(6) applies:
`
`Function: “receiving an uplink grant
`(UL Grant) signal from a base station
`on a specific message”
`
`Structure: “hardware and/or
`software in the user equipment that is
`capable of receiving an uplink grant
`(UL Grant) signal from a base station
`on aspecific message”
`“hardware and/or software in the user
`equipment that is capable of
`transmitting data to the base station
`
`11
`
`This is a means plus function term
`governed by Section 112(6).
`
`
`Function: “receiving an uplink grant
`(UL Grant) signal from a base station
`on a specific message”
`
`Structure: Lacks sufficient
`corresponding structure, and
`therefore invalid as indefinite.
`
`
`This is a means plus function term
`governed by Section 112(6).
`
`
`“a transmission module
`adapted to transmit data to the base
`station using the UL Grant signal
`
`7
`
`
`
`SAMSUNG 1046-0012
`
`

`
`Case 1:15-cv-00546-SLR-SRF Document 57-1 Filed 05/17/16 Page 13 of 21 PageID #: 1189
`
`Claims
`(’236)
`
`Terms/Elements for Construction
`
`Evolved Wireless’s Proposal
`
`Defendants’ Proposal
`
`received on the specific message”
`
`“a Hybrid Automatic Repeat Request
`(HARQ) entity adapted to determine
`whether there is data stored in the
`Msg3 buffer when the reception
`module receives the UL Grant signal
`and the specific message is a random
`access response message, acquiring
`
`7
`
`
`
`using the UL Grant signal received
`on the specific message”
`
`Section 112(6) does not apply
`because a person of ordinary skill in
`the art reading the specification
`would understand the term to have a
`sufficiently definite meaning as the
`name for the structure that performs
`the function.
`
`If section 112(6) applies:
`
`Function: “transmit data to the base
`station using the UL Grant signal
`received on the specific message”
`
`Structure: “hardware and/or
`software in the user equipment that
`is capable of transmitting data to the
`base station using the UL Grant
`signal received on the specific
`message.
`Not indefinite.
`
`“hardware and/or software in the user
`equipment that is capable of
`determining whether there is data
`stored in the Msg3 buffer when the
`reception module receives the UL
`
`12
`
`Function: “transmit data to the base
`station using the UL Grant signal
`received on the specific message”
`
`Structure: Lacks sufficient
`corresponding structure, and
`therefore invalid as indefinite.
`
`
`Indefinite.
`
`
`To the extent this limitation is found
`to be a means plus function term
`governed by 112(6):
`
`Function: “determining whether
`
`SAMSUNG 1046-0013
`
`

`
`Case 1:15-cv-00546-SLR-SRF Document 57-1 Filed 05/17/16 Page 14 of 21 PageID #: 1190
`
`Claims
`(’236)
`
`Terms/Elements for Construction
`
`Evolved Wireless’s Proposal
`
`Defendants’ Proposal
`
`there is data stored in the Msg3
`buffer when the reception module
`receives the UL Grant signal and the
`specific message is a random access
`response message, acquiring the data
`stored in the Msg3 buffer if there is
`data stored in the Msg3 buffer when
`the reception module receives the UL
`Grant signal and the specific message
`is the random access response
`message, and controlling the
`transmission module to transmit the
`data stored in the Msg3 buffer to the
`base station using the UL Grant
`signal received by the reception
`module on the specific message”
`
`Structure: Lacks sufficient
`corresponding structure, and
`therefore invalid as indefinite.
`
`
`
`Grant signal and the specific message
`is a random access response message,
`acquiring the data stored in the Msg3
`buffer if there is data stored in the
`Msg3 buffer when the reception
`module receives the UL Grant signal
`and the specific message is the
`random access response message,
`and controlling the transmission
`module to transmit the data stored in
`the Msg3 buffer to the base station
`using the UL Grant signal received
`by the reception module on the
`specific message.
`
`Section 112(6) does not apply
`because a person of ordinary skill in
`the art reading the specification
`would understand the term to have a
`sufficiently definite meaning as the
`name for the structure that performs
`the function.
`
`If section 112(6) applies:
`
`Function: “determining whether
`there is data stored in the Msg3
`buffer when the reception module
`receives the UL Grant signal and the
`specific message is a random access
`
`13
`
`the data stored in the Msg3 buffer if
`there is data stored in the Msg3
`buffer when the reception module
`receives the UL Grant signal and the
`specific message is the random
`access response message, and
`controlling the transmission module
`to transmit the data stored in the
`Msg3 buffer to the base station using
`the UL Grant signal received by the
`reception module on the specific
`message”
`
`
`
`SAMSUNG 1046-0014
`
`

`
`Case 1:15-cv-00546-SLR-SRF Document 57-1 Filed 05/17/16 Page 15 of 21 PageID #: 1191
`
`Claims
`(’236)
`
`Terms/Elements for Construction
`
`Evolved Wireless’s Proposal
`
`Defendants’ Proposal
`
`response message, acquiring the data
`stored in the Msg3 buffer if there is
`data stored in the Msg3 buffer when
`the reception module receives the UL
`Grant signal and the specific message
`is the random access response
`message, and controlling the
`transmission module to transmit the
`data stored in the Msg3 buffer to the
`base station using the UL Grant
`signal received by the reception
`module on the specific message”
`
`Structure: “hardware and/or
`software in the user equipment that is
`capable of determining whether there
`is data stored in the Msg3 buffer
`when the reception module receives
`the UL Grant signal and the specific
`message is a random access response
`message, acquiring the data stored in
`the Msg3 buffer if there is data stored
`in the Msg3 buffer when the
`reception module receives the UL
`Grant signal and the specific message
`is the random access response
`message, and controlling the
`transmission module to transmit the
`data stored in the Msg3 buffer to the
`base station using the UL Grant
`
`14
`
`
`
`SAMSUNG 1046-0015
`
`

`
`Case 1:15-cv-00546-SLR-SRF Document 57-1 Filed 05/17/16 Page 16 of 21 PageID #: 1192
`
`Claims
`(’236)
`
`Terms/Elements for Construction
`
`Evolved Wireless’s Proposal
`
`Defendants’ Proposal
`
`7
`
`“a multiplexing and assembly entity
`used for transmission of new data”
`
`“wherein the HARQ entity acquires
`the new data to be transmitted from
`the multiplexing and assembly entity
`if there is no data stored in the Msg3
`buffer when the reception module
`receives the UL Grant signal on the
`specific message or the received
`
`7
`
`
`
`Indefinite.
`
`
`To the extent this limitation is found
`to be a means plus function term
`governed by Section 112(6):
`
`
`Function: “transmitting new data”
`
`Structure: Lacks sufficient
`corresponding structure, and
`therefore invalid as indefinite.
`
`
`Indefinite.
`
`signal received by the reception
`module on the specific message”
`Not indefinite.
`
`“hardware and/or software in the user
`equipment that is capable of
`transmitting new data”
`
`Section 112(6) does not apply
`because a person of ordinary skill in
`the art reading the specification
`would understand the term to have a
`sufficiently definite meaning as the
`name for the structure that performs
`the function.
`
`If section 112(6) applies:
`
`Function: “transmitting new data”
`
`Structure: “hardware and/or
`software in the user equipment that is
`capable of transmitting new data”
`Not indefinite.
`
`15
`
`SAMSUNG 1046-0016
`
`

`
`Case 1:15-cv-00546-SLR-SRF Document 57-1 Filed 05/17/16 Page 17 of 21 PageID #: 1193
`
`Claims
`(’236)
`
`Terms/Elements for Construction
`
`Evolved Wireless’s Proposal
`
`Defendants’ Proposal
`
`message is not the random access
`response message, and controls the
`transmission module to transmit the
`new data acquired from the
`multiplexing and assembly entity
`using the UL Grant signal received
`by the reception module on the
`specific message”
`“wherein the HARQ entity transfers
`the data acquired from the
`multiplexing and assembly entity or
`the Msg3 buffer to a specific HARQ
`process of the one or more HARQ
`processes and controls the specific
`HARQ process to transmit the data
`acquired from the multiplexing and
`assembly entity or the Msg3 buffer
`through the transmission module”
`“wherein, when the specific HARQ
`process transmits the data stored in
`the Msg3 buffer through the
`transmission module, the data stored
`in the Msg3 buffer is controlled to be
`copied into a specific HARQ buffer
`corresponding to the specific HARQ
`process, and the data copied into the
`specific HARQ buffer is controlled
`to be transmitted through the
`transmission module”
`
`8
`
`9
`
`
`
`Not indefinite.
`
`Indefinite.
`
`Not indefinite.
`
`Indefinite.
`
`16
`
`SAMSUNG 1046-0017
`
`

`
`Case 1:15-cv-00546-SLR-SRF Document 57-1 Filed 05/17/16 Page 18 of 21 PageID #: 1194
`
`Claims
`(’236)
`
`Terms/Elements for Construction
`
`Evolved Wireless’s Proposal
`
`Defendants’ Proposal
`
`10
`
`10
`
`12
`
`13
`
`
`
`
`
`Not indefinite.
`
`Indefinite.
`
`Not indefinite.
`
`Indefinite.
`
`Not indefinite.
`
`Indefinite.
`
`Not indefinite.
`
`Indefinite.
`
`“wherein the UL Grant signal
`received by the reception module on
`the specific message is a UL Grant
`signal received on a Physical
`Downlink Control Channel
`(PDCCH)”
`“wherein the HARQ entity controls
`new data to be transmitted in
`correspondence with the received UL
`Grant signal received on the
`PDCCH”
`“wherein the data stored in the Msg3
`buffer is a Medium Access Control
`Protocol Data Unit (MAC PDU)
`including a user equipment
`identifier”
`“wherein the UL Grant signal
`received on the specific message is
`either a UL Grant signal received on
`a Physical Downlink Control
`Channel (PDCCH) or a UL Grant
`signal received on the random access
`response message”
`
`
`17
`
`SAMSUNG 1046-0018
`
`

`
`Case 1:15-cv-00546-SLR-SRF Document 57-1 Filed 05/17/16 Page 19 of 21 PageID #: 1195
`
`Proposed Constructions of Claim Terms/Phrases of the ’481 Patent
`
`Claims
`(’481)
`
`8
`
`Terms/Elements for Construction
`
`“a preamble generation unit
`configured to generate said preamble
`sequence by repeating a specific
`sequence, having a length (L), N
`times to generate a consecutive
`sequence having a length (N*L) and
`concatenating a single cyclic prefix
`(CP) to a front end of said
`consecutive sequence”
`
`
`
`
`
`Evolved Wireless’s Proposal
`
`Defendants’ Proposal
`
`This is a means plus function term
`governed by Section 112(6).
`
`Function: “generating said preamble
`sequence by repeating a specific
`sequence, having a length (L), N
`times to generate a consecutive
`sequence having a length (N*L) and
`concatenating a single cyclic prefix
`(CP) to a front end of said
`consecutive sequence”
`
`Structure: Lacks sufficient
`corresponding structure, and
`therefore invalid as indefinite.
`
`
`“hardware and/or software in the
`transmitter that is capable of
`performing the following algorithm:
`repeat a specific sequence, having a
`length (L), N times to generate a
`consecutive sequence having a length
`(N*L) and concatenate a single
`cyclic prefix (CP) to a front end of
`said consecutive sequence”
`
`Section 112(6) does not apply
`because a person of ordinary skill in
`the art reading the specification
`would understand the term to have a
`sufficiently definite meaning as the
`name for the structure that performs
`the function.
`
`If section 112(6) applies:
`
`Function: “generating said preamble
`sequence by repeating a specific
`sequence, having a length (L), N
`times to generate a consecutive
`sequence having a length (N*L) and
`concatenating a single cyclic prefix
`(CP) to a front end of said
`
`18
`
`SAMSUNG 1046-0019
`
`

`
`Case 1:15-cv-00546-SLR-SRF Document 57-1 Filed 05/17/16 Page 20 of 21 PageID #: 1196
`
`Claims
`(’481)
`
`Terms/Elements for Construction
`
`Evolved Wireless’s Proposal
`
`Defendants’ Proposal
`
`This is a means plus function term
`governed by Section 112(6).
`
`Function: “transmitting, on a
`random access channel, said
`preamble sequence to a receiving
`side”
`
`Structure: Lacks sufficient
`corresponding structure, and
`therefore invalid as indefinite.
`
`
`consecutive sequence”
`
`Structure: “hardware and/or
`software in the transmitter that is
`capable of performing the following
`algorithm: repeat a specific sequence,
`having a length (L), N times to
`generate a consecutive sequence
`having a length (N*L) and
`concatenate a single cyclic prefix
`(CP) to a front end of said
`consecutive sequence”
`
`“hardware and/or software in the
`transmitter capable of transmitting
`the preamble sequence on the
`random access channel to a receiving
`side”
`
`
`Section 112(6) does not apply
`because a person of ordinary skill in
`the art reading the specification
`would understand the term to have a
`sufficiently definite meaning as the
`name for the structure that performs
`the function.
`
`
`
`If 112(6) applies:
`
`
`19
`
`“a transmission unit configured to
`transmit, on a random access
`channel, said preamble sequence to a
`receiving side”
`
`8
`
`
`
`SAMSUNG 1046-0020
`
`

`
`Case 1:15-cv-00546-SLR-SRF Document 57-1 Filed 05/17/16 Page 21 of 21 PageID #: 1197
`
`Claims
`(’481)
`
`Terms/Elements for Construction
`
`Evolved Wireless’s Proposal
`
`Defendants’ Proposal
`
`Function: “transmitting, on a
`random access channel, said
`preamble sequence to a receiving
`side”
`
`Structure: “hardware and/or
`software in the transmitter capable of
`transmitting the preamble sequence
`on the random access channel to a
`receiving side”
`
`
`20
`
`
`
`
`
`SAMSUNG 1046-0021