IN THE UNITED STATES DISTRICT COURT
`FOR THE EASTERN DISTRICT OF TEXAS
`MARSHALL DIVISION
`
`
`
`
`Case No. 2:15-cv-0576-RWS-RSP
`(Lead Case)
`
`
`JURY TRIAL DEMANDED
`
`CELLULAR COMMUNICATIONS
`EQUIPMENT LLC,
`
`Plaintiff,
`
`v.
`
`AT&T, INC., ET AL.,
`
`Defendants.
`
`)
`)
`)
`)
`)
`)
`)
`)
`)
`)
`)
`)
`
`
`PLAINTIFF’S P.R. 4-2 DISCLOSURES
`
`
`
` Pursuant to the Court’s Docket Control Order and Local Patent Rule 4-2, Plaintiff
`
`provides the following preliminary proposed construction for each claim term identified by the
`
`parties:
`
`U.S. Patent No. 8,457,022
`
`Claim Term
`
`Plaintiff’s Proposed Construction
`
`“detecting start of a system information
`message transmission window” / “detect start
`of a system information message transmission
`window” (claims 1 and 6)
`“the predetermined subframes” (claims 1 and
`6)
`“continuous over adjacent radio frames”
`(claims 1 and 6)
`
`signaling module
`version
`“redundancy
`configured
`to detect start of a system
`information message transmission window
`and to assign a redundancy version sequence
`
`Plain and ordinary meaning.
`
`No construction necessary.
`
` “the excluded uplink subframes and multi-
`cast subframes”
`Plain and ordinary meaning.
`
`No construction necessary.
`Not governed by 35 U.S.C. § 112(6).
`
`To the extent this limitation is determined to
`be governed by 35 U.S.C. § 112(6), the
`corresponding structure is: “software,
`
`
`
`HTC/ZTE Exhibit 1018
`
`
`FOR THE EASTERN DISTRICT OF TEXAS
`MARSHALL DIVISION
`
`
`
`
`Case No. 2:15-cv-0576-RWS-RSP
`(Lead Case)
`
`
`JURY TRIAL DEMANDED
`
`CELLULAR COMMUNICATIONS
`EQUIPMENT LLC,
`
`Plaintiff,
`
`v.
`
`AT&T, INC., ET AL.,
`
`Defendants.
`
`)
`)
`)
`)
`)
`)
`)
`)
`)
`)
`)
`)
`
`
`PLAINTIFF’S P.R. 4-2 DISCLOSURES
`
`
`
` Pursuant to the Court’s Docket Control Order and Local Patent Rule 4-2, Plaintiff
`
`provides the following preliminary proposed construction for each claim term identified by the
`
`parties:
`
`U.S. Patent No. 8,457,022
`
`Claim Term
`
`Plaintiff’s Proposed Construction
`
`“detecting start of a system information
`message transmission window” / “detect start
`of a system information message transmission
`window” (claims 1 and 6)
`“the predetermined subframes” (claims 1 and
`6)
`“continuous over adjacent radio frames”
`(claims 1 and 6)
`
`signaling module
`version
`“redundancy
`configured
`to detect start of a system
`information message transmission window
`and to assign a redundancy version sequence
`
`Plain and ordinary meaning.
`
`No construction necessary.
`
` “the excluded uplink subframes and multi-
`cast subframes”
`Plain and ordinary meaning.
`
`No construction necessary.
`Not governed by 35 U.S.C. § 112(6).
`
`To the extent this limitation is determined to
`be governed by 35 U.S.C. § 112(6), the
`corresponding structure is: “software,
`
`
`
`HTC/ZTE Exhibit 1018
`
`
`
`at the start of the transmission window” (claim
`6)
`
`hardware, firmware, or a combination
`thereof,”
`
`performing the function of: detecting start of
`a system information message transmission
`window and assigning a redundancy version
`sequence at the start of the transmission
`window.
`
`U.S. Patent No. 8,570,957
`
`Claim Term
`
`Plaintiff’s Proposed Construction
`
`“power headroom” (claims 1, 4, 7, and 10)
`
`“radio network resources” (claims 4 and 10)
`
`nominal maximum
`the
`“subtracting
`transmission power and the power that the
`apparatus would use if it did not apply
`maximum power limitations” (claims 1 and 7)
`
`“as applicable” (claims 1, 4, 7, 10)
`
`“when applicable” (claims 4, 10)
`
`Plain and ordinary meaning.
`
`No construction necessary.
`
`Plain and ordinary meaning.
`
`No construction necessary.
`
`“subtracting the power that the apparatus
`would use if it did not apply maximum power
`limitations from the nominal maximum
`transmission power”
`
`Plain and ordinary meaning.
`
`No construction necessary.
`
`Plain and ordinary meaning.
`
`No construction necessary.
`
`
`
`
`
`
`
`
`
`
`
`
`- 2 -
`
`HTC/ZTE Exhibit 1018-2
`
`
`
`U.S. Patent No. 8,867,472
`
`Claim Term
`
`Plaintiff’s Proposed Construction
`
`“aperiodic channel information” (claims 1, 14,
`15, 27, 28, 41, 44, and 56)
`
`“downlink component carrier” / “component
`carrier” (claims 1, 10, 11, 12, 15, 25, 26, 28,
`44, 54, and 55)
`
`information with
`“establish(ing) channel
`respect to the selected downlink component
`carrier” (claims 1 and 28.)
`
`selected downlink
`the
`“determin[e/ing]
`based
`on which
`component
`[carrier]
`the plurality of
`component carrier of
`component carriers carried
`the
`request”
`(claims 1 and 28)
`
`“the channel information” (claims 1, 10, 11,
`28, 26, 55)
`
`Plain and ordinary meaning.
`
`No construction necessary.
`
`Plain and ordinary meaning.
`
`No construction necessary.
`
`Plain and ordinary meaning.
`
`No construction necessary.
`
`Or, alternatively:
`
`“monitoring, evaluating, and/or collecting
`channel information with respect to the
`selected downlink component carrier”
`Plain and ordinary meaning.
`
`No construction necessary.
`
`Or, alternatively:
`
`“identify[ing] the selected downlink
`component [carrier] based on which
`component carrier of the plurality of
`component carriers carried the request”
`
`Plain and ordinary meaning.
`
`No construction necessary.
`
`Or, alternatively:
`
`“the established channel information”
`
`
`- 3 -
`
`HTC/ZTE Exhibit 1018-3
`
`
`
`“on a component carrier for which the
`aperiodic channel information is provided”
`(claims 15 and 44)
`
`“a processor configured to: determine the
`selected downlink component carrier based on
`which component carrier of the plurality of
`component carriers carried the request for
`providing the aperiodic channel information”
`(claim 1)
`
`“a processor configured to . . . establish
`channel
`information with respect
`to
`the
`selected downlink component carrier” (claim
`1)
`
`to
`is configured
`the processor
`“wherein
`provide channel information for at least one of
`the other component carriers of the plurality of
`component carriers other than the selected
`downlink component carrier” (claim 10)
`
`Plain and ordinary meaning.
`
`No construction necessary.
`
`Or, alternatively:
`
`“on a component carrier for which the
`aperiodic channel information is to be
`provided”
`Not governed by 35 U.S.C. § 112(6).
`
`To the extent this limitation is determined to
`be governed by 35 U.S.C. § 112(6), the
`corresponding structure is: “a processor,”
`
`
`performing the function of: determining the
`selected downlink component carrier based
`on which component carrier of the plurality
`of component carriers carried the request for
`providing the aperiodic channel information.
`
`Not governed by 35 U.S.C. § 112(6).
`
`To the extent this limitation is determined to
`be governed by 35 U.S.C. § 112(6), the
`corresponding structure is: “a processor,”
`
`
`performing the function of: establishing
`channel information with respect to the
`selected downlink component carrier.
`
`Not governed by 35 U.S.C. § 112(6).
`
`To the extent this limitation is determined to
`be governed by 35 U.S.C. § 112(6), the
`corresponding structure is: “a processor,”
`
`
`performing the function of: providing
`channel information for at least one of the
`other component carriers of the plurality of
`component carriers other than the selected
`downlink component carrier.
`
`
`- 4 -
`
`HTC/ZTE Exhibit 1018-4
`
`
`
`“a processor configured to generate a request
`for providing aperiodic channel information
`with respect to a selected downlink component
`carrier of a plurality of component carriers”
`(claim 15)
`
`to
`is configured
`the processor
`“wherein
`generate a request for providing channel
`information for at least one of the other
`component carriers of
`the plurality of
`component carriers other than the selected
`component carrier” (claim 25)
`
`to
`is configured
`the processor
`“wherein
`include the request for providing the aperiodic
`channel information in an uplink grant” (claim
`27)
`
`Not governed by 35 U.S.C. § 112(6).
`
`To the extent this limitation is determined to
`be governed by 35 U.S.C. § 112(6), the
`corresponding structure is: “a processor,”
`
`
`performing the function of: generating a
`request for providing aperiodic channel
`information with respect to a selected
`downlink component carrier of a plurality of
`component carriers.
`
`Not governed by 35 U.S.C. § 112(6).
`
`To the extent this limitation is determined to
`be governed by 35 U.S.C. § 112(6), the
`corresponding structure is: “a processor,”
`
`
`performing the function of: generating a
`request for providing channel information for
`at least one of the other component carriers of
`the plurality of component carriers other than
`the selected component carrier.
`
`Not governed by 35 U.S.C. § 112(6).
`
`To the extent this limitation is determined to
`be governed by 35 U.S.C. § 112(6), the
`corresponding structure is: “a processor,”
`
`
`performing the function of: including the
`request for providing the aperiodic channel
`information in an uplink grant.
`
`
`
`
`
`
`
`
`
`
`
`
`- 5 -
`
`HTC/ZTE Exhibit 1018-5
`
`
`
`U.S. Patent No. 9,078,262
`
`Claim Term
`
`Plaintiff’s Proposed Construction
`
`“aperiodic channel information” (claims 1, 2,
`10, 16, 17, 25, and 31)
`
`“downlink component carrier” / “component
`carrier” (claims 1, 13, 14, 16, 28, 29, and 31)
`
`“non-contiguous component carriers” (claims
`1, 13, 16, 28, and 31)
`
`Plain and ordinary meaning.
`
`No construction necessary.
`
`Plain and ordinary meaning.
`
`No construction necessary.
`
`Plain and ordinary meaning.
`
`No construction necessary.
`
`“the channel information” (claims 14 and 29) Plain and ordinary meaning.
`
`No construction necessary.
`
`Or, alternatively:
`
`“the established channel information”
`
`Plain and ordinary meaning.
`
`No construction necessary, subject to any
`proposed construction of constituent parts.
`
`
`“a processor configured to generate a request
`for providing aperiodic channel information
`with respect to a selected downlink component
`carrier of a plurality of non-contiguous
`component carriers; and a transmitting unit
`configured to send the request for providing
`the aperiodic channel
`information on a
`component carrier for which the aperiodic
`channel information is to be provided.” (claim
`1)
`“generating a request for providing aperiodic
`channel information with respect to a selected
`downlink component carrier of a plurality of
`non-contiguous component carriers; and
`sending the request for providing the aperiodic
`channel information on a component carrier
`for which the aperiodic channel information is
`to be provided.” (claims 16, 31)
`
`Plain and ordinary meaning.
`
`No construction necessary, subject to any
`proposed construction of constituent parts.
`
`
`- 6 -
`
`HTC/ZTE Exhibit 1018-6
`
`
`
`“a processor configured to generate a request
`for providing aperiodic channel information
`with respect to a selected downlink component
`carrier of a plurality of non-contiguous
`component carriers” (claim 1)
`
`“wherein the processor is further configured to
`include the request for providing the aperiodic
`channel information in an uplink grant.”
`(claim 10)
`
`“wherein the processor is further configured to
`generate a request for providing channel
`information for at least one of the other
`component carriers of the plurality of non-
`contiguous component carriers other than the
`selected component carrier.” (claim 13)
`
`Not governed by 35 U.S.C. § 112(6).
`
`To the extent this limitation is determined to
`be governed by 35 U.S.C. § 112(6), the
`corresponding structure is: “a processor,”
`
`
`performing the function of: generating a
`request for providing aperiodic channel
`information with respect to a selected
`downlink component carrier of a plurality of
`non-contiguous component carriers.
`
`Not governed by 35 U.S.C. § 112(6).
`
`To the extent this limitation is determined to
`be governed by 35 U.S.C. § 112(6), the
`corresponding structure is: “a processor,”
`
`
`performing the function of: including the
`request for providing the aperiodic channel
`information in an uplink grant.
`
`Not governed by 35 U.S.C. § 112(6).
`
`To the extent this limitation is determined to
`be governed by 35 U.S.C. § 112(6), the
`corresponding structure is: “a processor,”
`
`
`performing the function of: generating a
`request for providing channel information for
`at least one of the other component carriers of
`the plurality of non-contiguous component
`carriers other than the selected component
`carrier.
`
`
`
`
`
`
`
`
`
`
`
`
`- 7 -
`
`HTC/ZTE Exhibit 1018-7
`
`
`
`U.S. Patent No. 8,457,676
`
`Claim Term
`
`Plaintiff’s Proposed Construction
`
`“reaching a threshold of the at least one
`threshold of k transmission time intervals
`following a previous power control headroom
`report” (claims 1, 19, and 33)
`“an absolute difference between current and
`most recent path-loss measurements has
`reached a threshold of difference” (claims 3,
`21, and 34)
`“wherein said at least one threshold adjustable
`via
`the signal comprises adjusting
`the
`threshold integer k” (claims 1, 19, and 33)
`
`“memory including software . . . configured,
`with the at least one processor, to cause the
`apparatus to at least: determine that a set of at
`least one triggering criterion is met” (claim 19)
`
`“memory including software . . . configured,
`with the at least one processor, to cause the
`apparatus to at least . . . provide a power
`control headroom report on an uplink from
`user equipment, in response to the set having
`been met” (claim 19)
`
`Plain and ordinary meaning.
`
`No construction necessary.
`
`Plain and ordinary meaning.
`
`No construction necessary.
`
`Plain and ordinary meaning.
`
`No construction necessary.
`
`Not governed by 35 U.S.C. § 112(6).
`
`To the extent this limitation is determined to
`be governed by 35 U.S.C. § 112(6), the
`corresponding structure is: “memory
`including software and at least one
`processor,”
`
`
`performing the function of: determining that
`a set of at least one triggering criterion is met.
`
`Not governed by 35 U.S.C. § 112(6).
`
`To the extent this limitation is determined to
`be governed by 35 U.S.C. § 112(6), the
`corresponding structure is: “memory
`including software and at least one
`processor,”
`
`
`performing the function of: providing a
`power control headroom report on an uplink
`from user equipment, in response to the set
`having been met.
`
`
`
`
`
`
`- 8 -
`
`HTC/ZTE Exhibit 1018-8
`
`
`
`U.S. Patent No. 9,025,590
`
`Claim Term
`
`Plaintiff’s Proposed Construction
`
`“bitmap indicating power headroom reports
`being reported” (claims 1, 5); “a bitmap that
`indicates power headroom reports being
`reported” (claim 9)
`“bits for power headroom reports for a
`plurality of secondary cells” (claims 1, 5, and
`9)
`
`“secondary cells” (claims 1, 5, and 9)
`
`“bitmap” (claims 1, 2, 5, 6, 9, 10)
`
`
`
`“a collection of bits arranged to indicate
`which power headroom reports are being
`reported.”
`
`Plain and ordinary meaning.
`
`No construction necessary.
`
`Plain and ordinary meaning.
`
`No construction necessary.
`
`“a collection of bits”
`
`At this time, pursuant to P.R. 4-2(b), Plaintiff does not identify any extrinsic evidence that
`
`it intends to rely upon in support of the proposed claim constructions.
`
`Consistent with P.R. 4-2, Plaintiff reserves the right to supplement, revise, modify, or
`
`otherwise finalize its list of proposed terms, preliminary proposed constructions, and identified
`
`extrinsic evidence to facilitate preparation of a Claim Construction and Prehearing Statement, or
`
`in response to terms and constructions identified by Defendants.
`
`
`
`
`
`
`
`- 9 -
`
`HTC/ZTE Exhibit 1018-9
`
`
`
`
`
`Dated: July 18, 2016
`
`
`
`
`
`Respectfully submitted,
`
`T. John Ward, Jr.
`State Bar No. 00794818
`Claire Abernathy Henry
`State Bar No. 24053063
`Wesley Hill
`State Bar No. 24032294
`WARD, SMITH & HILL, PLLC
`P.O. Box 1231
`Longview, Texas 75606-1231
`(903) 757-6400 (telephone)
`(903) 757-2323 (facsimile)
`E-mail: jw@wsfirm.com
`
`claire@wsfirm.com
`
`wh@wsfirm.com
`
`Attorneys for Plaintiff
`CELLULAR COMMUNICATIONS
`EQUIPMENT LLC
`
`
`
`/s/ Terry A. Saad
`
`Jeffrey R. Bragalone (lead attorney)
`Texas Bar No. 02855775
`Monte M. Bond
`Texas Bar No. 02585625
`Terry A. Saad
`Texas Bar No. 24066015
`BRAGALONE CONROY PC
`2200 Ross Avenue
`Suite 4500W
`Dallas, TX 75201
`Tel: (214) 785-6670
`Fax: (214) 785-6680
`jbragalone@bcpc-law.com
`mbond@bcpc-law.com
`tsaad@bcpc-law.com
`
`Edward R. Nelson, III
`ed@nelbum.com
`Texas Bar No. 00797142
`Thomas C. Cecil
`tom@nelbum.com
`Texas Bar No. 24069489
`NELSON BUMGARDNER, P.C.
`3131 West 7th Street, Suite 300
`Fort Worth, Texas 76107
`Phone: (817) 377-9111
`Fax: (817) 377-3485
`
`
`
`
`
`
`
`
`
`CERTIFICATE OF SERVICE
`
`I hereby certify that a true and correct copy of the foregoing document was served on all
`
`counsel of record via email on this 18th day of July, 2016.
`
`
`/s/ Terry A. Saad
`
`
`
`- 10 -
`
`HTC/ZTE Exhibit 1018-10
`
`
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