throbber
Case 2:16-cv-00082-JRG Document 118 Filed 01/18/17 Page 1 of 4 PageID #: 2943
`
`IN THE UNITED STATES DISTRICT COURT
` FOR THE EASTERN DISTRICT OF TEXAS
` MARSHALL DIVISION
`
`
`SAINT LAWRENCE COMMUNICATIONS
`LLC,
`
`
`Plaintiff,
`
`
`
`v.
`
`
`
`Case No. 2:16-cv-00082-JRG
`
`Jury Trial Demanded
`
`
`











`
`
`APPLE INC., AT&T MOBILITY LLC,
`and CELLCO PARTNERSHIP D/B/A
`VERIZON WIRELESS,
`
`
`Defendants.
`
`
`
`
`JOINT CLAIM CONSTRUCTION CHART PURSUANT TO P.R. 4-5(D)
`
`Plaintiff Saint Lawrence Communications LLC (“St. Lawrence”) and Defendants Apple
`Inc., AT&T Mobility LLC, and Cellco Partnership d/b/a Verizon Wireless (Collectively,
`“Defendants”), hereby submit their Joint Claim Construction Chart pursuant to Local Patent Rule
`4-5(d).
`Appendix A is a chart listing the complete language of disputed claims with the disputed
`terms in bold type. The claims currently asserted by St. Lawrence are as follows:
`
`• U.S. Patent Number 6,795,805: claims 1-3, 6, 11-13, 16, 21-23, 26, 31-33, 36,
`51-53, 56, 61-63, and 66;
`
`• U.S. Patent Number 6,807,524: claims 1-21, 29-42;
`
`• U.S. Patent Number 7,151,802: claims 1-3, 8-11, 16, 25-27, 32-35, 40, 49-50,
`52-53;
`
`• U.S. Patent Number 7,191,123: claims 1-11, 13-16, 18-31, 33-36, 53-63, 65-
`79, 81-84, 102-03; and
`
`• U.S. Patent Number 7,260,521: claims 1, 2, 5-8, 10, 11, 14, 15, 17, 28, 29, 32,
`33, 35, 37, 38, 41, 42, 44, 55, 56, 59, 60, and 62.
`Appendix A contains the complete language of these asserted claims but also contains the
`
`Ex. 1018 / Page 1 of 26
`Apple v. Saint Lawrence
`
`

`

`Case 2:16-cv-00082-JRG Document 118 Filed 01/18/17 Page 2 of 4 PageID #: 2944
`
`complete language of any unasserted claims from which these asserted claims depend.
`Appendix B contains the parties’ proposed constructions for the disputed terms.
`
`Respectfully submitted,
`
`/s/ Demetrios Anaipakos
`Demetrios Anaipakos
`Texas Bar No. 00793258
`danaipakos@azalaw.com
`Amir Alavi
`Texas Bar No. 00793239
`aalavi@azalaw.com
`Brian E. Simmons
`Texas Bar No. 24004922
`bsimmons@azalaw.com
`Masood Anjom
`Texas Bar No. 24055107
`manjom@azalaw.com
`Michael McBride
`Texas Bar No. 24065700
`mmcbride@azalaw.com
`Kyril Talanov
`Texas Bar No. 24075139
`ktalanov@azalaw.com
`Jamie Aycock
`Texas Bar No. 24050241
`jaycock@azalaw.com
`Scott W. Clark
`Texas Bar No. 24007003
`sclark@azalaw.com
`Alisa A. Lipski
`Texas Bar No. 24041345
`alipski@azalaw.com
`Weining Bai
`Texas Bar No. 24101477
`wbai@azalaw.com
`Justin Chen
`Texas Bar No. 24074024
`jchen@azalaw.com
`AHMAD, ZAVITSANOS, ANAIPAKOS, ALAVI
`& MENSING P.C.
`1221 McKinney Street, Suite 2500
`Houston, TX 77010
`Telephone: 713-655-1101
`Facsimile: 713-655-0062
`
`
`Dated: January 18, 2017
`
`
`
`
`
`/s/ Melissa Smith
`Melissa Smith
`Gilliam & Smith LLP
`303 South Washington Avenue
`Marshall, TX 75670
`melissa@gillamsmithlaw.com
`(903) 934-9257
`
`Douglas E. Lumish
`Doug.Lumish@lw.com
`Jeffrey G. Homrig
`Jeff.Homrig@lw.com
`S. Giri Pathmanaban
`Giri.Pathmanaban@lw.com
`Lisa Nguyen
`lisa.nguyen@lw.com
`Yasamin Parsafar
`yasamin.parsafar@lw.com
`LATHAM & WATKINS LLP
`140 Scott Drive
`Menlo Park, CA 94025
`(650) 328-4600
`(650) 463-2600
`
`Allison K. Harms, Pro Hac Vice
`Allison.Harms@lw.com
`Blake R. Davis
`blake.davis@lw.com
`LATHAM & WATKINS LLP
`505 Montgomery St., Suite 2000
`San Francisco, CA 94111
`(415) 391-0600
`(415) 395-8095
`
`Cassius K. Sims
`NY State Bar No. 4910469
`Cassius.Sims@lw.com
`LATHAM & WATKINS LLP
`885 Third Avenue
`
`
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`2
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`Ex. 1018 / Page 2 of 26
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`

`

`Case 2:16-cv-00082-JRG Document 118 Filed 01/18/17 Page 3 of 4 PageID #: 2945
`
`
`Andrea L. Fair
`State Bar No. 24078488
`andrea@wsfirm.com
`Claire Abernathy Henry
`State Bar No. 24053063
`claire@wsfirm.com
`Wesley Hill
`State Bar No. 24032294
`wh@wsfirm.com
`WARD, SMITH & HILL, PLLC
`P.O. Box 1231
`Longview, Texas 75606-1231
`(903) 757-6400 (telephone)
`(903) 757-2323 (facsimile)
`
`ATTORNEYS FOR PLAINTIFF SAINT
`LAWRENCE COMMUNICATIONS
`LLC
`
`/s/ Kevin P. Anderson
`Michael E Jones
`Potter Minton, a Professional Corporation
`110 N College Avenue
`Suite 500
`Tyler, TX 75702
`903-597-8311
`Fax: 903-593-0846
`mikejones@potterminton.com
`
`Kevin P. Anderson
`kanderson@wileyrein.com
`Floyd B. Chapman
`fchapman@wileyrein.com
`WILEY REIN LLP
`1776 K Street, NW
`Washington, D.C. 20006
`Tel: 202.719.7000
`Fax: 202.719.7049
`
`ATTORNEYS FOR DEFENDANT
`CELLCO PARTNERSHIP d/b/a
`VERIZON WIRELESS.
`
`New York, NY 10022
`(212) 906-1200
`(212) 751-4864
`
`James R. Bender
`DC State Bar No. 1004382
`james.bender@lw.com
`LATHAM & WATKINS LLP
`555 Eleventh St. NW Washington, D.C. 20004-
`1304
`Telephone: (202) 637-2200
`Facsimile: (202) 637-2201
`
`ATTORNEYS FOR DEFENDANT APPLE
`INC.
`
`
`
`
`/s/ Brett Christopher Govett
`Brett Christopher Govett
`Norton Rose Fulbright US LLP
`2200 Ross Avenue
`Suite 2800
`Dallas, TX 75201
`214/855-8118
`Fax: 12148558200
`brett.govett@nortonrosefulbright.com
`
`Daniel S Leventhal
`Norton Rose Fulbright US LLP - Houston
`Fulbright Tower
`1301 McKinney, Suite 5100
`Houston, TX 77010-3095
`713-651-5151
`Fax: 713-651-5246
`daniel.leventhal@nortonrosefulbright.com
`
`Talbot R. Hansum
`State Bar No. 24084586
`James Warriner
`State Bar No. 24070813
`Norton Rose Fulbright US LLP
`98 San Jacinto Boulevard, Suite 1100
`Austin, TX 78701
`
`
`
`3
`
`Ex. 1018 / Page 3 of 26
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`

`

`Case 2:16-cv-00082-JRG Document 118 Filed 01/18/17 Page 4 of 4 PageID #: 2946
`
`Tel: 512.536.3083
`Fax: 512.536.4598
`talbot.hansum@nortonrosefulbright.com
`jim.warriner@nortonrosefulbright.com
`
`ATTORNEYS FOR DEFENDANT AT&T
`MOBILITY LLC
`
`
`CERTIFICATE OF SERVICE
`The undersigned hereby certifies that all counsel of record who are deemed to have
`
`
`
`consented to electronic service are being served with a copy of this document via the Court’s
`
`CM/ECF system per Local Rule CV-5(a)(3) on January 18, 2017.
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`/s/ Melissa R. Smith
`Melissa R. Smith
`
`
`
`
`
`
`
`4
`
`
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`
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`
`
`Ex. 1018 / Page 4 of 26
`
`

`

`Case 2:16-cv-00082-JRG Document 118-1 Filed 01/18/17 Page 1 of 18 PageID #: 2947
`APPENDIX A
`
`
`
`U.S. Patent Number 6,795,805
`
`1. A device for enhancing periodicity of an excitation signal produced in relation to a pitch
`codevector and an innovative codevector for supplying a signal synthesis filter in view of
`synthesizing a wideband speech signal, said periodicity enhancing device comprising:
`a) a factor generator for calculating a periodicity factor related to the wideband speech signal;
`and
`b) an innovation filter for filtering the innovative codevector in relation to said periodicity factor
`to thereby reduce energy of a low frequency portion of the innovative codevector and enhance
`periodicity of a low frequency portion of the excitation signal.
`
`11. A method for enhancing periodicity of an excitation signal produced in relation to a
`pitch codevector and an innovative codevector for supplying a signal synthesis filter in view
`of synthesizing a wideband speech signal, said periodicity enhancing method comprising:
`a) calculating a periodicity factor related to the wideband speech signal; and
`b) filtering the innovative codevector in relation to said periodicity factor to thereby reduce
`energy of a low frequency portion of the innovative codevector and enhance periodicity of a low
`frequency portion of the excitation signal.
`
`21. A decoder for producing a synthesized wideband speech signal, comprising:
`a) a signal fragmenting device for receiving an encoded wideband speech signal and extracting
`from said encoded wideband speech signal at least pitch codebook parameters, innovative
`codebook parameters, and synthesis filter coefficients;
`b) an pitch codebook responsive to said pitch codebook parameters for producing a pitch
`codevector;
`c) an innovative codebook responsive to said innovative codebook parameters for producing an
`innovative codevector;
`d) a periodicity enhancing device as recited in claim 1 comprising said factor generator for
`calculating a periodicity factor related to the wideband speech signal, and said innovation filter
`for filtering the innovative codevector;
`e) a combiner circuit for combining said pitch codevector and said innovative codevector filtered
`by said innovation filter to thereby produce said periodicity enhanced excitation signal; and
`f) a signal synthesis filter for filtering said periodicity enhanced excitation signal in relation to
`said synthesis filter coefficients to thereby produce said synthesized wideband speech signal.
`
`22. A decoder for producing a synthesized wideband speech signal as defined in claim 21,
`wherein said factor generator comprises a means for calculating a periodicity factor in response
`to the pitch codevector and the innovative codevector.
`23. A decoder for producing a synthesized wideband speech signal as defined in claim 21,
`wherein said innovation filter has a transfer function of the form:
`
`
`26. A decoder for producing a synthesized wideband speech signal as defined in claim 23,
`
`𝐹𝐹(𝑧𝑧)=−∝𝑧𝑧+1−∝𝑧𝑧−1
`where ∝ is a periodicity factor derived from a level of periodicity of the excitation signal.
`wherein said factor generator comprises a means for calculating said periodicity factor ∝ using
`
`the relation:
`
`
`
`1
`
`Ex. 1018 / Page 5 of 26
`
`

`

`Case 2:16-cv-00082-JRG Document 118-1 Filed 01/18/17 Page 2 of 18 PageID #: 2948
`APPENDIX A
`
`
`
`∝=0.125 (1+𝑟𝑟𝑣𝑣), where
`𝑟𝑟𝑣𝑣=(𝐸𝐸𝑣𝑣−𝐸𝐸𝑐𝑐)/(𝐸𝐸𝑣𝑣+ 𝐸𝐸𝑐𝑐)
`
`where Ev is the energy of the pitch codevector and Ec is the energy of the innovative codevector.
`
`31. In a decoder for producing a synthesized wideband speech signal, comprising:
`a) a signal fragmenting device for receiving an encoded wideband speech signal and extracting
`from said encoded wideband speech signal at least pitch codebook parameters, innovative
`codebook parameters, and synthesis filter coefficients;
`b) an pitch codebook responsive to said pitch codebook parameters for producing a pitch
`codevector;
`c) an innovative codebook responsive to said innovative codebook parameters for producing an
`innovative codevector;
`d) a combiner circuit for combining said pitch codevector and innovative codevector to thereby
`produce an excitation signal; and
`e) a signal synthesis filter for filtering said excitation signal in relation to said synthesis filter
`coefficients to thereby produce said synthesized wideband speech signal;
`the improvement comprising of a periodicity enhancing device as recited in claim 1 comprising
`said factor generator for calculating a periodicity factor related to the wideband speech signal,
`and said innovation filter for filtering the innovative codevector.
`
`32. A decoder for producing a synthesized wideband speech signal as defined in claim 31,
`wherein said factor generator comprises a means for calculating a periodicity factor in response
`to the pitch codevector and the innovative codevector.
`
`33. A decoder for producing a synthesized wideband speech signal as defined in claim 31,
`wherein said innovation filter has a transfer function of the form:
` F(z)=−αz+1−αz −1
`where α is a periodicity factor derived from a level of periodicity of the excitation signal.
`
`36. A decoder for producing a synthesized wideband speech signal as defined in claim 33,
`wherein said factor generator comprises a means for calculating said periodicity factor α using
`the relation:
`α=0.125 (1+r v), where
`r v=(E v −E c)/(E v +E c)
`where Ev is the energy of the pitch codevector and Ec is the energy of the innovative codevector.
`
`51. A cellular mobile transmitter/receiver unit comprising:
`a) a transmitter including an encoder for encoding a wideband speech signal and a transmission
`circuit for transmitting the encoded wideband speech signal; and
`b) a receiver including a receiving circuit for receiving a transmitted encoded wideband speech
`signal and a decoder as recited in claim 21 for decoding the received encoded wideband speech
`signal.
`
`61. A cellular network element comprising:
`a) a transmitter including an encoder for encoding a wideband speech signal and a transmission
`circuit for transmitting the encoded wideband speech signal; and
`
`
`
`2
`
`Ex. 1018 / Page 6 of 26
`
`

`

`Case 2:16-cv-00082-JRG Document 118-1 Filed 01/18/17 Page 3 of 18 PageID #: 2949
`APPENDIX A
`
`
`b) a receiver including a receiving circuit for receiving a transmitted encoded wideband speech
`signal and a decoder as recited in claim 21 for decoding the received encoded wideband speech
`signal.
`
`
`
`
`
`
`3
`
`Ex. 1018 / Page 7 of 26
`
`

`

`Case 2:16-cv-00082-JRG Document 118-1 Filed 01/18/17 Page 4 of 18 PageID #: 2950
`APPENDIX A
`
`
`
`U.S. Patent Number 6,807,524
`
`A perceptual weighting device for producing a perceptually weighted signal in response
`1.
`to a wideband speech signal in order to reduce a difference between the wideband speech
`signal and a subsequently synthesized wideband speech signal, said perceptual weighting
`device comprising:
`a) a signal preemphasis filter responsive to the wideband speech signal for enhancing a high
`frequency content of the wideband speech signal to thereby produce a preemphasised signal;
`b) a synthesis filter calculator responsive to said preemphasised signal for producing synthesis
`filter coefficients; and
`c) a perceptual weighting filter, responsive to said preemphasised signal and said synthesis filter
`coefficients, for filtering said preemphasised signal in relation to said synthesis filter coefficients
`to thereby produce said perceptually weighted signal, said perceptual weighting filter having a
`transfer function with fixed denominator whereby weighting of said wideband speech signal in
`a formant region is substantially decoupled from a spectral tilt of said wideband speech signal.
`
`7. A perceptual weighting device as defined in claim 6, wherein γ2 is set equal to μ.
`
`8. A method for producing a perceptually weighted signal in response to a wideband speech
`signal in order to reduce a difference between the weighted wideband speech signal and a
`subsequently synthesized weighted wideband speech signal, said method comprising:
`a) filtering the wideband speech signal to produce a preemphasised signal with enhanced high
`frequency content;
`b) calculating, from said preemphasised signal, synthesis filter coefficients; and
`c) filtering said preemphasised signal in relation to said synthesis filter coefficients to thereby
`produce a perceptually weighted speech signal, wherein said filtering comprises processing the
`preemphasis signal through a perceptual weighting filter having a transfer function with fixed
`denominator whereby weighting of said wideband speech signal in a formant region is
`substantially decoupled from a spectral tilt of said wideband speech signal.
`
`9. A method for producing a perceptually weighted signal as defined in claim 8, wherein filtering
`the wideband speech signal comprises filtering through a transfer function of the form:
`P(z)=1−μz−1
`wherein μ is a preemphasis factor having a value located between 0 and 1.
`
`14. A method for producing a perceptually weighted signal as defined in claim 13, wherein γ2 is
`set equal to μ.
`
`15. An encoder for encoding a wideband speech signal, comprising:
`a) a perceptual weighting device as recited in claim 1;
`b) a pitch codebook search device responsive to said perceptually weighted signal for producing
`pitch codebook parameters and an innovative search target vector;
`c) an innovative codebook search device, responsive to said synthesis filter coefficients and to
`said innovative search target vector, for producing innovative codebook parameters; and
`d) a signal forming device for producing an encoded wideband speech signal comprising said
`pitch codebook parameters, said innovative codebook parameters, and said synthesis filter
`coefficients.
`
`
`
`4
`
`Ex. 1018 / Page 8 of 26
`
`

`

`Case 2:16-cv-00082-JRG Document 118-1 Filed 01/18/17 Page 5 of 18 PageID #: 2951
`APPENDIX A
`
`
`
`21. An encoder as defined in claim 20, wherein μ is set equal to γ2.
`
`29. A cellular mobile transmitter/receiver unit comprising:
`a) a transmitter including an encoder for encoding a wideband speech signal as recited in claim
`15 and a transmission circuit for transmitting the encoded wideband speech signal; and
`b) a receiver including a receiving circuit for receiving a transmitted encoded wideband speech
`signal and a decoder for decoding the received encoded wideband speech signal.
`
`35. A cellular mobile transmitter/receiver unit as defined in claim 34, wherein γ2 is set equal to
`μ.
`
`36. A cellular network element comprising:
`a) a transmitter including an encoder for encoding a wideband speech signal as defined in claim
`15 and a transmission circuit for transmitting the encoded wideband speech signal; and
`b) a receiver including a receiving circuit for receiving a transmitted encoded wideband speech
`signal and a decoder for decoding the received encoded wideband speech signal.
`
`42. A cellular network element as defined in claim 41, wherein μ is set equal to y2.
`
`
`
`
`
`5
`
`Ex. 1018 / Page 9 of 26
`
`

`

`Case 2:16-cv-00082-JRG Document 118-1 Filed 01/18/17 Page 6 of 18 PageID #: 2952
`APPENDIX A
`
`
`
`U.S. Patent Number 7,151,802
`
`1. A decoder for producing a synthesized wideband signal, comprising:
`a) a signal fragmenting device for receiving an encoded version of a wideband signal previously
`down-sampled during encoding and extracting from said encoded wideband signal version at
`least pitch codebook parameters, innovative codebook parameters, and linear prediction filter
`coefficients;
`b) a pitch code book responsive to said pitch codebook parameters for producing a pitch
`codevector;
`c) an innovative codebook responsive to said innovative codebook parameters for producing an
`innovative codevector;
`d) a combiner circuit for combining said pitch codevector and said innovative codevector to
`thereby produce an excitation signal;
`e) a signal synthesis device including a linear prediction filter for filtering said excitation signal
`in relation to said linear prediction filter coefficients to thereby produce a synthesized wideband
`signal, and an oversampler responsive to said synthesized wideband signal for producing an
`over-sampled signal version of the synthesized wideband signal; and
`f) a high-frequency content recovering device comprising:
`i) a random noise generator for producing a noise sequence having a given spectrum;
`ii) a spectral shaping unit for shaping the spectrum of the noise sequence in relation to
`linear prediction filter coefficients related to said down-sampled wideband signal; and
`iii) a signal injection circuit for injecting said spectrally-shaped noise sequence in said
`over-sampled synthesized signal version to thereby produce said full-spectrum
`synthesized wideband signal.
`
`
`2. A decoder for producing a synthesized wideband signal as defined in claim 1, wherein said
`random noise generator comprises a random white noise generator for producing a white noise
`sequence whereby said spectral shaping unit produces a spectrally-shaped white noise sequence.
`
`3. A decoder for producing a synthesized wideband signal as defined in claim 2, wherein said
`spectral shaping unit comprises:
`a) a gain adjustment module, responsive to said white noise sequence and a set of gain adjusting
`parameters, for producing a scaled white noise sequence;
`b) a spectral shaper for filtering said scaled white noise sequence in relation to a bandwidth
`expanded version of the linear prediction filter coefficients to produce a filtered scaled white
`noise sequence characterized by a frequency bandwidth generally higher than a frequency
`bandwidth of said over-sampled synthesized signal version; and
`c) a band-pass filter responsive to said filtered scaled white noise sequence for producing a band-
`pass filtered scaled white noise sequence to be subsequently injected in said over-sampled
`synthesized signal version as said spectrally-shaped white noise sequence.
`
`8. A decoder for producing a synthesized wideband signal as defined in claim 3, wherein said
`band-pass filter comprises a frequency bandwidth located between 5.6 kHz and 7.2 kHz.
`
`9. A decoder for producing a synthesized wideband signal, comprising:
`a) a signal fragmenting device for receiving an encoded version of a wideband signal previously
`down-sampled during encoding and extracting from said encoded wideband signal version at
`
`
`
`6
`
`Ex. 1018 / Page 10 of 26
`
`

`

`Case 2:16-cv-00082-JRG Document 118-1 Filed 01/18/17 Page 7 of 18 PageID #: 2953
`APPENDIX A
`
`
`least pitch codebook parameters, innovative codebook parameters, and linear prediction filter
`coefficients;
`b) a pitch codebook responsive to said pitch codebook parameters for producing a pitch
`codevector;
`c) an innovative codebook responsive to said innovative codebook parameters for producing an
`innovative codevector;
`d) a combiner circuit for combining said pitch codevector and said innovative codevector to
`thereby produce an excitation signal; and
`e) a signal synthesis device including a linear prediction filter for filtering said excitation signal
`in relation to said linear prediction filter coefficients to thereby produce a synthesized wideband
`signal, and an oversampler responsive to said synthesized wideband signal for producing an
`over-sampled signal version of the synthesized wideband signal;
`the improvement a high-frequency content recovering device comprising:
`i) a random noise generator for producing a noise sequence having a given spectrum;
`ii) a spectral shaping unit for shaping the spectrum of the noise sequence in relation to linear
`prediction filter coefficients related to said down-sampled wideband signal; and
`iii) a signal injection circuit for injecting said spectrally-shaped noise sequence in said over-
`sampled synthesized signal version to thereby produce said full-spectrum synthesized wideband
`signal.
`
`10. A decoder for producing a synthesized wideband signal as defined in claim 9, wherein said
`random noise generator comprises a random white noise generator for producing a white noise
`sequence whereby said spectral shaping unit produces a spectrally-shaped white noise sequence.
`
`11. A decoder for producing a synthesized wideband signal as defined in claim 10, wherein
`said spectral shaping unit comprises:
`a) a gain adjustment module, responsive to said white noise sequence and a set of gain adjusting
`parameters, for producing a scaled white noise sequence;
`b) a spectral shaper for filtering said scaled white noise sequence in relation to a bandwidth
`expanded version of the linear prediction filter coefficients to produce a filtered scaled white
`noise sequence characterized by a frequency bandwidth generally higher than a frequency
`bandwidth of said over-sampled synthesized signal version; and
`c) a band-pass filter responsive to said filtered scaled white noise sequence for producing a band-
`pass filtered scaled white noise sequence to be subsequently injected in said over-sampled
`synthesized signal version as said spectrally-shaped white noise sequence.
`16. A decoder for producing a synthesized wideband signal as defined in claim 11, wherein
`said band-pass filter comprises a frequency bandwidth located between 5.6 kHz and 7.2 kHz.
`
`25. A mobile transmitter/receiver unit comprising:
`a receiver including a receiving circuit for receiving a transmitted encoded wideband signal and
`a decoder for decoding the received encoded wideband signal, said decoder comprising:
`a signal fragmenting device for receiving an encoded version of a wideband
`i)
`signal previously downsampled during encoding and extracting from said
`encoded wideband signal version at least pitch codebook parameters, innovative
`codebook parameters, and linear prediction filter coefficients;
`
`
`
`7
`
`Ex. 1018 / Page 11 of 26
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`

`

`Case 2:16-cv-00082-JRG Document 118-1 Filed 01/18/17 Page 8 of 18 PageID #: 2954
`APPENDIX A
`
`
`
`ii)
`
`iii)
`
`iv)
`
`v)
`
`vi)
`
`a pitch codebook responsive to said pitch codebook parameters for producing a
`pitch codevector;
`an innovative codebook responsive to said innovative codebook parameters for
`producing an innovative codevector;
`a combiner circuit for combining said pitch codevector and said innovative
`codevector to thereby produce an excitation signal;
`a signal synthesis device including a linear prediction filter for filtering said
`excitation signal in relation to said linear prediction filter coefficients to thereby
`produce a synthesized wideband signal, and an oversampler responsive to said
`synthesized wideband signal for producing an over-sampled signal version of
`the synthesized wideband signal; and
`a high-frequency content recovering device comprising:
`(1) a random noise generator for producing a noise sequence having a given
`spectrum;
`(2) a spectral shaping unit for shaping the spectrum of the noise sequence in
`relation to linear prediction filter coefficients related to said downsampled
`wideband signal; and
`(3) a signal injection circuit for injecting said spectrally-shaped noise sequence in
`said over-sampled synthesized signal version to thereby produce said full-
`spectrum synthesized wideband signal.
`
`
`33. A communication network element comprising:
`a receiver including a receiving circuit for receiving a transmitted encoded wideband signal and
`a decoder as recited in claim 1 for decoding the received encoded wideband signal.
`
`49. A decoder for producing a synthesized wideband signal as defined in claim 1, wherein said
`spectral shaping unit comprises a spectral shaper for filtering the noise sequence in relation to a
`bandwidth expanded version of the linear prediction filter coefficients to produce a filtered noise
`sequence characterized by a frequency bandwidth generally higher than a frequency bandwidth
`of the over-sampled synthesized signal version.
`
`50. A decoder for producing a synthesized wideband signal as defined in claim 9, wherein said
`spectral shaping unit comprises a spectral shaper for filtering the noise sequence in relation to a
`bandwidth expanded version of the linear prediction filter coefficients to produce a filtered noise
`sequence characterized by a frequency bandwidth generally higher than a frequency bandwidth
`of the over-sampled synthesized signal version.
`
`
`
`
`8
`
`Ex. 1018 / Page 12 of 26
`
`

`

`Case 2:16-cv-00082-JRG Document 118-1 Filed 01/18/17 Page 9 of 18 PageID #: 2955
`APPENDIX A
`
`
`
`U.S. Patent Number 7,191,123
`
`1. A method for producing a gain-smoothed codevector during decoding of an encoded
`wideband signal from a set of wideband signal encoding parameters, said method comprising:
`finding a codevector in relation to at least one first wideband signal encoding parameter of said
`set;
`calculating a first factor representative of voicing in the wideband signal in response to at least
`one second wideband signal encoding parameter of said set;
`calculating a second factor representative of stability of said wideband signal in response to at
`least one third wideband signal encoding parameter of said set;
`calculating a smoothing gain based on said first and second factors; and
`amplifying the found codevector with said smoothing gain to thereby produce said gain-
`smoothed codevector.
`
`2. A gain-smoothed codevector producing method as claimed in claim 1, wherein:
`finding a codevector comprises finding an innovative codevector in an innovative codebook in
`relation to said at least one first wideband signal encoding parameter; and the smoothing gain
`calculation comprises calculating the smoothing gain also in relation to an innovative codebook
`gain forming a fourth wideband signal encoding parameter of said set.
`
`3. A gain-smoothed codevector producing method as claimed in claim 1, wherein:
`finding a codevector comprises finding a codevector in a codebook in relation to said at least one
`first wideband signal encoding parameter; and
`said at least one first wideband signal encoding parameter comprises an innovative codebook
`index.
`
`4. A gain-smoothed codevector producing method as claimed in claim 1, wherein:
`finding a codevector comprises finding an innovative codevector in an innovative codebook in
`relation to said at least one first wideband signal encoding parameter; and
`said at least one second wideband signal encoding parameter comprises the following
`parameters:
`a pitch gain computed during encoding of the wideband signal;
`a pitch delay computed during encoding of the wideband signal;
`an index j of a low-pass filter selected during encoding of the wideband signal and applied to a
`pitch codevector computed during encoding of the wideband signal; and
`an innovative codebook index computed during encoding of the wideband signal.
`
`5. A gain-smoothed codevector producing method as claimed in claim 1, wherein said at least
`one third wideband signal encoding parameter comprises coefficients of a linear prediction filter
`calculated during encoding of the wideband signal.
`
`6. A gain-smoothed codevector producing method as claimed in claim 1, wherein:
`finding a codevector comprises finding an innovative codevector in an innovative codebook in
`relation to an index k of said innovative codebook, said index k forming said at least one first
`wideband signal encoding parameter; and
`
`
`
`9
`
`Ex. 1018 / Page 13 of 26
`
`

`

`Case 2:16-cv-00082-JRG Document 118-1 Filed 01/18/17 Page 10 of 18 PageID #: 2956
`APPENDIX A
`
`
`calculating a first factor comprises computing a voicing factor rv by means of the following
`relation:
`rv=(Ev−Ec)/(Ev+Ec)
`where:
`Ev is the energy of a scaled adaptive codevector bvT;
`Ec is the energy of a scaled innovative codevector gck;
`b is a pitch gain computed during encoding of the wideband signal;
`T is a pitch delay computed during encoding of the wideband signal;
`vT is an adaptive codebook vector at pitch delay T;
`g is an innovative codebook gain computed during encoding of the wideband signal;
`k is an index of the innovative codebook computed during encoding of the wideband signal; and
`ck is the innovative codevector of said innovative codebook at index k.
`
`10. A gain-smoothed codevector producing method as claimed in claim 1, wherein calculating a
`second factor comprises determining a distance measure giving a similarity between adjacent,
`successive linear prediction filters computed during encoding of the wideband signal.
`
`11. A gain-smoothed codevector producing method as claimed in claim 10, wherein:
`the wideband signal is sampled prior to encoding, and is processed by frames during encoding
`and decoding; and
`determining a distance measure comprises calculating an Immitance Spectral Pair distance
`measure between the Immitance Spectral Pairs in a present frame n of the wideband signal and
`the Immitance Spectral Pairs of a past frame n−1 of the wideband signal through the following
`relation:
`
`D s = ∑ i = 1 p - 1 ⁢ ⁢ ( isp i ( n ) - ispSUBi( n - 1 ) ) 2
`
`where p is the order of the linear prediction filters.
`
`14. A gain-smoothed codevector producing method as claimed in claim 13, wherein the factor
`Sm has a value approaching 1 for an unvoiced and stable wideband signal, and a value
`approaching 0 for a pure voiced wideband signal or an unstable wideband signal.
`
`15. A gain-smoothed codevector producing method as claimed in claim 1, wherein:
`finding a codevector comprises finding an innovative codevector in an innovative codebook in
`relation to said at least one first wideband signal encoding parameter;
`the wideband signal is sampled prior to encoding, and is processed by frames and subframes
`during encoding and decoding; and
`calculating a smoothing gain comprises computing an initial modified gain g0 by comparing an
`innovative codebook gain g computed during encoding of the wideband signal to a threshold
`given by the initial modified gain from the past subframe g−1 as follows:
`
`if g < g − 1 then g0 = g × 1.19 bounded by g0 ≦ g − 1 and if g ≧ g − 1 then g0 = g/1.19 bounded
`by g0 ≧ g − 1.
`
`
`18. A method for producing a gain-smoothed codevector during decoding of an encoded
`wideband signal from a set of wideband signal encoding parameters, said method comprising:
`finding a codevector in relation to at least one first wideband signal encoding parameter of said
`set;
`
`
`
`10
`
`Ex. 1018 / Page 14 of 26
`
`

`

`Case 2:16-cv-00082-JRG Document 118-1 Filed 01/18/17 Page 11 of 18 PageID #: 2957
`APPENDIX A
`
`
`calculating a factor representative of voicing

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