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`M. ELIZABETH DAY (SBN 177125)
`eday@feinday.com
`DAVID ALBERTI (SBN 220265)
`dalberti@feinday.com
`SAL LIM (SBN 211836)
`slim@feinday.com
`MARC BELLOLI (SBN 244290)
`mbelloli@feinday.com
`FEINBERG DAY ALBERTI LIM &
`BELLOLI LLP
`1600 El Camino Real, Suite 280
`Menlo Park, CA 94025
`Tel: 650.618.4360
`Fax: 650.618.4368
`
`Attorneys for Uniloc 2017 LLC.
`
`UNITED STATES DISTRICT COURT
`CENTRAL DISTRICT OF CALIFORNIA
`
`UNILOC 2017 LLC,
`
`Plaintiff,
`
`v.
`
`MICROSOFT CORPORATION,
`Defendant.
`
`CASE NO. 8:18-cv-02053-AG-JDE
`DISCLOSURE OF ASSERTED CLAIMS
`AND INFRINGEMENT
`CONTENTIONS; DOCUMENT
`PRODUCTION ACCOMPANYING
`DISCLOSURE
`
`-1-
`DISCLOSURE OF ASSERTED CLAIMS AND INFRINGEMENT CONTENTIONS
`CASE NO. 8:18-cv-02053-AG-JDE
`
`Page 1 of 27
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`In accordance with Standing Patent Rule 2.1 of the Court’s Standing Patent
`Rules, Plaintiff Uniloc 2017 LLC (“Uniloc”) hereby provides its Disclosure of
`Asserted Claims and Infringement Contentions and Document Production
`Accompanying Disclosure, as follows:
`Disclosure Under Standing Patent Rule 2.1.1 and 2.1.2
`Uniloc alleges that Microsoft Corporation (“Microsoft”) directly and
`indirectly infringes U.S. Patent Nos. 7,016,676 (the “’676 Patent), 7,075,917 (the
`“’917 Patent”), 8,706,636 (the “’636 patent”) and 8,606,856 (the “’856 Patent”)
`(collectively “the Asserted Patents”) under 35 U.S.C. § § 271(a)-(c).
`Uniloc is asserting the following claims against the following Microsoft
`products/services: claims 1, 2 and 5 of the ’676 Patent against Microsoft Surface
`products containing a combined Bluetooth/Wi-Fi chip solution, such as the Marvell
`Avastar Family devices; claim 10 of the ’917 Patent against Microsoft products and
`services, including without limitation hotspots, modems and terminals that support
`HSPA/HSPA+/HSUPA/HSUPA+ (collectively “HSPA”) standardized in UMTS 3
`GPP Release 6 and above, including compatible Microsoft Surface products, such
`as the Microsoft Surface Pro with LTE and the Surface Go with LTE Advanced,
`and Microsoft Lumia products, such as the Microsoft Lumia 535 products, Lumia
`635 products, Lumia 640 LTE products, Lumia 640 XL products, Lumia 950
`products, and Lumia 950 XL products; claims 1, 4, 7, 8, 9, 18, 21, 24, 25, 26, 36,
`38, 39, 42, 45 and 48 of the ’636 Patent against Microsoft Office Products that
`allow for subscription sharing, and related, software, servers, user/client devices,
`systems and methods (including, but are not limited to, activation and installation
`software for all versions of Microsoft Office 365); and claims 1, 2, 4, 7, 9, 10, 12,
`15, 17, 18, 20 and 23 of the ’856 patent against Microsoft Office Products that
`allow for subscription sharing, and related, software, servers, user/client devices,
`systems and methods (including, but are not limited to, activation and installation
`software for all versions of Microsoft Office 365).
`-2-
`INFRINGEMENT CONTENTIONS
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`A further description of the infringing Microsoft products/services is
`provided in charts attached hereto as Exhibits A-D and incorporated by reference.
`Disclosure Under Standing Patent Rule 2.1.3
`Each accused apparatus, product, device, process, method, act, or other
`instrumentality (“Accused Product”) of Microsoft of which Uniloc is aware
`currently is identified, separately for each asserted claim, in charts attached hereto
`as Exhibits A-D and incorporated by reference.
`This disclosure is based on the present state of the Uniloc’s knowledge,
`without the benefit of any discovery from Microsoft or any other third-parties.
`Uniloc accordingly reserves the right to support its infringement contentions with
`additional allegations of infringement of other Products and of other claims, and
`with additional facts and products, particularly those for which information is not
`publicly available. Uniloc also reserves the right to modify the positions taken in
`these disclosures, based on later obtained materials, and/or based on information
`currently available, which Uniloc has not yet identified as significant.
`Each element of each claim as set forth in Exhibits A-D is literally present in
`the Accused Products. Uniloc will serve an interrogatory on Microsoft seeking its
`non-infringement contentions. Uniloc intends to supplement its infringement
`contentions to allege infringement under the doctrine of equivalents to the extent
`Microsoft provides information regarding those claim elements it contends it does
`not literally infringe. In addition, to the extent that the Court construes claims
`differently, Uniloc reserves the right to specifically identify equivalents to those
`construed claims which are practiced by Microsoft directly or indirectly.
`Disclosure Under Standing Patent Rule 2.1.4
`Uniloc contends the Asserted Claims of the Asserted Patents are entitled to
`the following priority dates:
`The ’676 patent: August 8, 2000
`The ’917 patent: October 11, 2000
`-3-
`INFRINGEMENT CONTENTIONS
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`The ’636 patent: December 10, 2001
`The ’856 patent: December 10, 2001
`Disclosure Under Standing Patent Rule 2.1.5
`Uniloc is not relying on the assertion that its own apparatuses, products,
`devices, processes, methods, acts, or other instrumentalities practice the claimed
`inventions.
`Disclosure Under Standing Patent Rule 2.1.6
`Uniloc alleges that Microsoft willfully infringes the Asserted Patents as
`follows:
` Microsoft’s acts of infringement of the Asserted Patents have been willful
`and intentional under the standard announced in Halo Elecs., Inc. v. Pulse Elecs.,
`Inc., 136 S.Ct. 1923, 195 L.Ed 2d 278 (2016). Since at least July 24, 2018,
`Microsoft has willfully infringed the ’676 patent and since at least August 10, 2018
`Microsoft has willfully infringed the ’917 patent, the ’636 patent and the ’856
`patent by refusing to take a license and continuing to make, use, test, sell, license,
`import, and/or offer for sale/license the Accused Products. Microsoft has been
`aware that it infringes the Asserted Patents since at least July 24 ,2018 and August
`10, 2018 and instead of taking a license, Microsoft has opted to make the business
`decision to “efficiently infringe” the Asserted Patents. In doing so, Microsoft has
`willfully infringed the Asserted Patents.
`Uniloc reserves the right to modify the positions taken in these disclosures,
`based on later obtained materials and/or based on information currently available
`that the Uniloc has not yet identified as significant.
`Document Production Under Standing Patent Rule 2.2
`Uniloc objects to the requirements of this production to the extent that it calls
`for the production of documents protected by the attorney-client privilege. Further,
`in producing these documents, Uniloc does not admit or concede the relevancy,
`materiality, authenticity, or admissibility as evidence of any of these documents.
`-4-
`INFRINGEMENT CONTENTIONS
`
`Page 4 of 27
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`

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`All objections to the use, at trial or otherwise, of any document produced are hereby
`expressly reserved. Uniloc’s discovery and investigation in connection with this
`lawsuit is ongoing. As a result, Uniloc produces these documents without prejudice
`as to the right to produce additional documents after considering documents
`obtained or reviewed through further discovery or investigation. Subject to and
`without waiving its objections, Uniloc produces responsive documents as follows:
`Standing Patent Rule 2.2.1: UNI-MS-2053_0000198-1526
`Standing Patent Rule 2.2.2: UNI-MS-2053_0000001-197; UNI-MS-
`2053_0001527-4040
`Standing Patent Rule 2.2.3: None.
`
`Dated: January 4, 2019
`
`FEINBERG DAY ALBERTI LIM & BELLOLI
`LLP
`
`By: /s/ M. Elizabeth Day
`M. Elizabeth Day
`Attorneys for Plaintiff
`Uniloc 2017 LLC
`
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`-5-
`INFRINGEMENT CONTENTIONS
`
`Page 5 of 27
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`
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`
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`
`
`
`Exhibit A
`
`Exhibit A
`
`
`
`
`
`
`Page 6 of 27
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`Page 6 of 27
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`

`

`connection with the provision of its expert reports.
`(e.g., to allege infringement under the doctrine of equivalents), in view of the Court’s final claim construction in this action, and in
`these contentions, including as discovery in the case progresses, in view of any non-infringement arguments Microsoft may make
`supplement these contentions once such information is made available to Plaintiff. Furthermore, Plaintiff reserves the right to revise
`accurately describe all infringing features and functionality of the Accused Products and, accordingly, Plaintiff reserves the right to
`not publicly available in their entirety. An analysis of Microsoft’s documentation and/or source code may be necessary to fully and
`software in the Accused Products. The precise designs, processes, and algorithms used in them are held secret, at least in part, and are
`The asserted claims include elements that are implemented, at least in part, by proprietary and specialized electronics, firmware and
`
`
`
`Microsoft dated July 24, 2018.
`substantial noninfringing use. Microsoft is on notice of its infringement of the ’676 patent by virtue of a letter from Uniloc to
`or especially adapted for use in infringement of the ’676 patent, not a staple article, and not a commodity of commerce suitable for
`’676 patent, and constitute a material part of the invention. Microsoft knows portions of the Accused Products to be especially made
`distributing, and/or importing the Accused Products which devices are used in practicing the processes, or using the systems, of the
`Plaintiff further accuses Microsoft of indirectly infringing the ’676 Patent by offering to commercially distribute, commercially
`
`
`
`https://support.microsoft.com.
`training videos, demonstrations, brochures and user guides, such as those located at: www.microsoft.com and
`limitation by instructing the users to operate the Accused Products. Microsoft intentionally instructs its customers to infringe through
`Microsoft instructs and/or controls and directs third parties to use the Accused Products in an infringing manner, including without
`and others the Accused Products to utilize in an infringing manner. Microsoft intends to cause infringement by such third parties as
`Plaintiff also accuses Microsoft of indirectly infringing the ’676 Patent by providing to third parties including users, customers, agents
`
`Products”) of directly infringing U.S. Patent No. 7,016,676 (the “’676 Patent”).
`Microsoft Surface products containing a combined Bluetooth/Wi-Fi chip solution, such as the Marvell Avastar Family (the “Accused
`Plaintiff accuses Microsoft Corporation (“Microsoft”) of making, using, selling, licensing, offering for sale/license and/or importing
`
`Microsoft’s Infringement of US Patent No. 7,016,676
`
`Page 7 of 27
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`

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`electronic devices. Although devices including these two technologies can use separate ICs on
`Wi-Fi and Bluetooth are two of the most widely used wireless technologies in consumer
`
`The Increasing Popularity of Wi-Fi and Bluetooth--Together
`
`
`
`today.
`family of multi-functional radios (MFRs) have over competing devices available in the market
`effective consumer devices. Finally, it expands on the advantages that Marvell’s Avastar®
`original equipment manufacturers (OEMs) overcome potential issues and rapidly develop cost-
`challenges of competing wireless signals, as well as innovative design techniques to help
`integrated circuit (IC) for use in today’s popular handheld devices. It explains the potential
`This white paper discusses the emergence of Wi-Fi and Bluetooth technologies on a single
`
`
`
`answer is yes.
`people continue to ask “Can these Wi-Fi and Bluetooth coexist in a single device?” The
`As these two wireless technologies continue to permeate the consumer electronics market,
`
`
`
`disrupting the “conversation.”
`handheld type—the signals transmitted can cause interference with each other, thereby
`“Similarly, when Wi-Fi and Bluetooth® are put into the same device—particularly a smaller
`
`
`
`is used by a first (Bluetooth) and second (Wi-Fi) interface standard.
`interface control method that provides for alternate use of the 2.4 GHz frequency band, which
`as the chips from the Marvell Avastar Family of products. The Accused Products perform an
`The Accused Products include chips with integrated Bluetooth and Wi-Fi functionality, such
`
`Accused Products
`
`
`
`comprising:
`standard, the radio system
`first and a second radio interface
`provided for alternate use by a
`common frequency band that is
`system which has at least one
`protocol method for a radio
`1 (pre). 1. An interface-control
`
`’676 Patent Claim
`
`Page 8 of 27
`
`

`

`combined Bluetooth and Wi-Fi radio (e.g., the Marvell Avastar 88W8897).
`The Accused Products, such as the Microsoft Surface Pro 4, include a Marvell Avastar family
`
`Semiconductor (March 2010)
`Ronak Choski, Yes! Wi-Fi and Bluetooth Can Coexist in Handheld Devices, Marvell
`
`ensuring optimal performance.”
`difficult challenge to accommodate the requirements of both Wi-Fi and Bluetooth links while
`access time is slotted. Also, the advent of 802.11n technology in handheld platforms poses the
`Access / Collision Avoidance (CSMA/CA) mechanism. With Bluetooth devices, the medium
`on an asynchronous protocol and access the wireless medium using the Carrier Sense Multiple
`(ISM) band, but are disparate from each other in almost every manner. Wi-Fi devices operate
`These technologies operate in the 2.4GHz Industrial, Scientific and Medical Device band
`
`
`
`locate Wi-Fi and Bluetooth devices on one IC, thereby reducing cost, size and time-to-market.
`an embedded platform, with the latest advances in technology innovation, it is possible to co-
`
`Accused Products
`
`’676 Patent Claim
`
`Page 9 of 27
`
`

`

`https://www.ifixit.com/Teardown/Microsoft+Surface+Pro+4+Teardown/51568
`
`
`
`
`
`Accused Products
`
`’676 Patent Claim
`
`Page 10 of 27
`
`

`

`mouse/8qc5p0d8ddjt?activetab=pivot:techspecstab
`https://www.microsoft.com/en-us/p/surface-precision-
`
`
`
`etc.
`Examples of Bluetooth stations include Bluetooth peripherals such as mice, pens, keyboard,
`
`operate using a first interface standard (Bluetooth) and/or second (Wi-Fi) interface standard.
`The Accused Products with integrated Bluetooth / Wi-Fi chips communicate with stations that
`
`Accused Products
`
`
`
`radio interface standard, and
`interface standard and/or a second
`accordance with a first radio
`1a. stations which operate in
`
`’676 Patent Claim
`
`Page 11 of 27
`
`

`

`pen/8zl5c82qmg6b/7X3T?activetab=pivot:techspecstab
`https://www.microsoft.com/en-us/p/surface-
`
`
`
`
`
`Accused Products
`
`’676 Patent Claim
`
`Page 12 of 27
`
`

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`mouse/8p5sv2rx3rn5/GGLX?cid=msft_web_collection&activetab=pivot:techspecstab
`https://www.microsoft.com/en-us/p/surface-arc-
`
`
`
`Accused Products
`
`’676 Patent Claim
`
`Page 13 of 27
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`

`

`
`
`dial/925r551sktgn/d5ft?cid=msft_web_collection&activetab=pivot:techspecstab
`https://www.microsoft.com/en-us/p/surface-
`
`
`
`Accused Products
`
`’676 Patent Claim
`
`Page 14 of 27
`
`

`

`network
`https://support.microsoft.com/en-us/help/4023494/surface-connect-surface-to-a-wireless-
`
`
`
`Examples of Wi-Fi stations include Wi-Fi modems, routers, access points (APs) and the like.
`
`Accused Products
`
`’676 Patent Claim
`
`Page 15 of 27
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`

`

`throughput and Bluetooth audio quality through packet arbitration. (See Figure 2 below.)
`example, are designed to optimize medium access time for maximum yield of Wi-Fi
`designed into this block. Marvell Wi-Fi/Bluetooth multi-function radio MFR devices, for
`In an integrated Wi-Fi and Bluetooth SoC, however, there can be additional “handshakes”
`
`followed between the SoCs through hardware signaling.
`separate Wi-Fi and Bluetooth SoCs), a unique set of protocols (e.g., 2-wire, 3-wire, 4-wire) is
`programmed priority of packet transmissions and receptions. In a discrete solution (i.e.,
`that controls access of Wi-Fi and Bluetooth devices to the antenna. It does this through pre-
`“Packet Traffic Arbiter (PTA). PTA is a dedicated hardware System-on-Chip (SoC) block
`
`
`
`frequency band.
`within the Marvell Avastar family radio) that controls the alternate use of the 2.4 GHz
`The Accused Products with integrated Bluetooth / Wi-Fi chips include a control station (e.g.,
`
`frequency band,
`controls the alternate use of the
`1b. a control station which
`
`Accused Products
`
`’676 Patent Claim
`
`Page 16 of 27
`
`

`

`the downlink traffic from the access point.
`to Wi-Fi link loss, depending on the type of access point. Therefore, it is important to control
`over-the-air collisions. This results either in very low Wi-Fi throughput or eventually leading
`on the client Wi-Fi device. Downlink frames from an access point can arrive anytime, creating
`traffic from the access point. Access points are usually unaware of ongoing Bluetooth traffic
`One of the primary challenges with Wi-Fi and Bluetooth coexistence is controlling downlink
`
`“PS-Poll and WMM Trigger Frames.
`
`
`
`Accused Products
`
`’676 Patent Claim
`
`Page 17 of 27
`
`

`

`white-paper-2010-03.pdf, pp. 4-5.
`https://www.marvell.com/docs/wireless/assets/marvell-wireless-wifi-bluetooth-coexistence-
`
`
`
`
`
`quite challenging when a discrete set of Wi-Fi and Bluetooth SoCs are used.”
`downlink Wi-Fi traffic is also sustained—thereby minimizing over-the-air collisions. This is
`frames, as shown in the figure below, so that the audio quality does not suffer and the
`In an integrated Wi-Fi/ Bluetooth SoC, it is possible to line up these frames with the Bluetooth
`
`aggressively rate-dropping access point.
`enhancements are particularly helpful when the client Wi-Fi device associates with an
`whereas the latter is used when the Wi-Fi device operates in WMM Power Save mode. These
`although in different modes of operation. The former is used in IEEE Power Save mode,
`packet at a time, whereas the latter can be used to download multiple frames at a time,
`MultiMedia (WMM) Trigger frames. (See Figure 3) The former polls the access point one data
`This can be accomplished either by using PowerSave-Poll (PS-Poll) frames or Wi-Fi
`
`Accused Products
`
`’676 Patent Claim
`
`Page 18 of 27
`
`

`

`white-paper-2010-03.pdf, p.6.
`https://www.marvell.com/docs/wireless/assets/marvell-wireless-wifi-bluetooth-coexistence-
`
`• Wi-Fi and Bluetooth link-aware performance”
`
`access point and paired with their individual headsets)
`WiFi+Bluetooth enabled smartphones in a small conference room connected to the same
`• Scheme to sustain the overall network throughput in a multiple-client scenario (e.g., multiple
`
`simultaneously with Wi-Fi traffic
`and Personal Area Network (PAN)-over-Asynchronous Connectionless Link (ACL)
`• Coexistence for a multi-profile usage scenarios, for example, running HFP (i.e., SCO/eSCO)
`
`• Partition airtime between Bluetooth and Wi-Fi traffic to yield best performance possible
`
`• Interception of Bluetooth page/inquiry to yield for WLAN traffic
`
`• Dynamic Bluetooth-aware Wi-Fi rate adaptation scheme
`
`• Usage of larger Wi-Fi time window whenever available, especially during eSCO
`
`mentioned in the section above
`• Alignment of PS-Poll / Trigger frames with SCO / eSCO slots to optimize Rx traffic, as
`
`Among these coexistence technologies are:
`
`simultaneously delivers maximum Wi-Fi throughput with optimal Bluetooth voice quality.
`technologies to offer world-class performance, leading to an overall user experience that
`Marvell’s Avastar family of wireless connectivity solutions has mastered the coexistence
`As Marvell has integrated the Wi-Fi and Bluetooth devices on a single silicon die, the
`
` “Solutions Catering to Offer Best-in-Class Overall User Experience
`
`Accused Products
`
`’676 Patent Claim
`
`Page 19 of 27
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`

`

`is quite challenging when a discrete set of Wi-Fi and Bluetooth SoCs are used.”
`the downlink Wi-Fi traffic is also sustained—thereby minimizing over-the-air collisions. This
`Bluetooth frames, as shown in the figure below, so that the audio quality does not suffer and
`“In an integrated Wi-Fi/ Bluetooth SoC, it is possible to line up these frames with the
`
`PS-Poll and WMM Trigger Frames
`
`requesting access.
`station provides access to the frequency band during times that the Bluetooth stations are not
`Bluetooth stations are not requesting access to the frequency band. For example, the control
`frequency band available to WiFi stations communicating with Microsoft Surface only when
`The Marvell Avastar radio employs a coexistence strategy that makes the shared 2.4 GHz
`
`request access to the frequency band.
`when stations working in accordance with the first radio interface standard (Bluetooth) do not
`access by the stations working in accordance with the second radio interface standard (WiFi)
`The controller in the Marvell Avastar family radio renders the frequency band available for
`
`(Bluetooth).
`frequency band for stations working in accordance with the first radio interface standard
`within the Marvell Avastar family radio) that controls the access to the common 2.4 GHz
`The Accused Products with integrated Bluetooth / Wi-Fi chips include a control station (e.g.,
`
`Accused Products
`
`frequency band.
`not request access to the
`first radio interface standard do
`working in accordance with the
`interface standard if stations
`accordance with the second radio
`access by the stations working in
`frequency band available for
`standard and—renders the
`with the first radio interface
`stations working in accordance
`common frequency band for
`controls the access to the
`1c. wherein the control station
`
`’676 Patent Claim
`
`Page 20 of 27
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`

`

`• Dynamic Bluetooth-aware Wi-Fi rate adaptation scheme
`
`• Usage of larger Wi-Fi time window whenever available, especially during eSCO
`
`mentioned in the section above
`• Alignment of PS-Poll / Trigger frames with SCO / eSCO slots to optimize Rx traffic, as
`
`Among these coexistence technologies are:
`
`simultaneously delivers maximum Wi-Fi throughput with optimal Bluetooth voice quality.
`technologies to offer world-class performance, leading to an overall user experience that
`Marvell’s Avastar family of wireless connectivity solutions has mastered the coexistence
`As Marvell has integrated the Wi-Fi and Bluetooth devices on a single silicon die, the
`
` “Solutions Catering to Offer Best-in-Class Overall User Experience
`
`white-paper-2010-03.pdf, pp. 4-5.
`https://www.marvell.com/docs/wireless/assets/marvell-wireless-wifi-bluetooth-coexistence-
`
`
`
`Accused Products
`
`’676 Patent Claim
`
`Page 21 of 27
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`

`

`operating in unlicensed frequency bands.
`IEEE 802.15.2 Recommended Practice: Coexistence of WPAN with other wireless devices
`
`transmit ACL packets if in the previous time slot the WPAN slave received an ACL packet.”
`transmissions are controlled by the WPAN master. In particular, WPAN slaves may only
`“In particular, if the WPAN device conforms to IEEE 802.15.1, then all ACL data
`
`controls when the slaves are given access to communicate.
`communication. Therefore, by controlling when the control station communicates to slaves,
`Bluetooth slave stations can only communicate ACL data packets in response to a Master
`
`
`
`white-paper-2010-03.pdf, p. 6.
`https://www.marvell.com/docs/wireless/assets/marvell-wireless-wifi-bluetooth-coexistence-
`
`• Wi-Fi and Bluetooth link-aware performance”
`
`access point and paired with their individual headsets)
`WiFi+Bluetooth enabled smartphones in a small conference room connected to the same
`• Scheme to sustain the overall network throughput in a multiple-client scenario (e.g., multiple
`
`(ACL) simultaneously with Wi-Fi traffic
`SCO/eSCO) and Personal Area Network (PAN)-over-Asynchronous Connectionless Link
`• Coexistence for a multi-profile usage scenarios, for example, running HFP (i.e.,
`
`• Partition airtime between Bluetooth and Wi-Fi traffic to yield best performance possible
`
`• Interception of Bluetooth page/inquiry to yield for WLAN traffic
`
`Accused Products
`
`’676 Patent Claim
`
`Page 22 of 27
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`

`

`white-paper-2010-03.pdf, p. 5.
`https://www.marvell.com/docs/wireless/assets/marvell-wireless-wifi-bluetooth-coexistence-
`
`
`
`
`
`shown below.
`yield best performance possible.” One example of the duration of the partitioned airtime is
`For example, the control station “[p]artition(s) airtime between Bluetooth and Wi-Fi traffic to
`
`standard (WiFi) are allowed to utilize the frequency band.
`respective duration in which the stations working in accordance with the second radio interface
`The Accused Products include a controller in the Marvell Avastar family radio determines the
`
`Accused Products
`
`
`
`frequency band.
`are allowed to utilize the
`second radio interface standard
`working in accordance with the
`duration in which the stations
`station determines the respective
`in claim 1, herein the control
`2. The method as claimed
`
`’676 Patent Claim
`
`Page 23 of 27
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`

`• Partition airtime between Bluetooth and Wi-Fi traffic to yield best performance possible
`
`• Interception of Bluetooth page/inquiry to yield for WLAN traffic
`
`• Dynamic Bluetooth-aware Wi-Fi rate adaptation scheme
`
`• Usage of larger Wi-Fi time window whenever available, especially during eSCO
`
`mentioned in the section above
`• Alignment of PS-Poll / Trigger frames with SCO / eSCO slots to optimize Rx traffic, as
`
`Among these coexistence technologies are:
`
`simultaneously delivers maximum Wi-Fi throughput with optimal Bluetooth voice quality.
`technologies to offer world-class performance, leading to an overall user experience that
`Marvell’s Avastar family of wireless connectivity solutions has mastered the coexistence
`As Marvell has integrated the Wi-Fi and Bluetooth devices on a single silicon die, the
`
` “Solutions Catering to Offer Best-in-Class Overall User Experience
`
`requests.
`transmitted on as interfered and hops to other page/inquiry channels for further page/inquiry
`cause the Bluetooth devices to interpret the radio channel that the page/inquiry packet is
`"[i]nterception of Bluetooth page/inquiry to yield for WLAN traffic." Such interception will
`The Marvell Avastar radio employs a Bluetooth and WiFi coexistence strategy that includes
`
`its own operation.
`(Bluetooth) to interpret the radio channel as interfered and to seize another radio channel for
`functions which cause radio systems in accordance with the first radio interface standard
`The Accused Products include a controller in the Marvell Avastar family radio carries out
`
`Accused Products
`
`own operation.
`seize another radio channel for its
`radio channel as interfered and to
`interface standard to interpret the
`accordance with the first radio
`which cause radio systems in
`station also carries out functions
`in claim 1, wherein the control
`5. The method as claimed
`
`’676 Patent Claim
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`Page 24 of 27
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`

`

`
`
`white-paper-2010-03.pdf, p. 6.
`https://www.marvell.com/docs/wireless/assets/marvell-wireless-wifi-bluetooth-coexistence-
`
`• Wi-Fi and Bluetooth link-aware performance”
`
`access point and paired with their individual headsets)
`WiFi+Bluetooth enabled smartphones in a small conference room connected to the same
`• Scheme to sustain the overall network throughput in a multiple-client scenario (e.g., multiple
`
`simultaneously with Wi-Fi traffic
`and Personal Area Network (PAN)-over-Asynchronous Connectionless Link (ACL)
`• Coexistence for a multi-profile usage scenarios, for example, running HFP (i.e., SCO/eSCO)
`
`Accused Products
`
`’676 Patent Claim
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`Page 25 of 27
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`

`

`Bluetooth devices, 3) flexibility of allowing simultaneous transmit and receive activities on
`front-end components and isolation thereof, 2) transmit power level of the Wi-Fi and
`The specifics of how many channels are required to be blocked should be governed by: 1) RF
`
`of channels that should not be included in the hopping pattern.
`center frequency. Hence, the Bluetooth device is programmed with a static (or adoptive) mask
`Bluetooth device can be programmed to not use the frequencies around the Wi-Fi channel’s
`Bluetooth coexistence perspective, this feature is very helpful. Based on the Wi-Fi channel, the
`(programmable) set of frequencies as part of its hopping sequence. From a Wi-Fi and
`spectrum as a key enhancement. This enables the Bluetooth device to use only a certain
`specification, all Bluetooth devices offered Adaptive Frequency-hopping (AFH) spread
`Adaptive Frequency Hopping (AFH). Starting from version 1.2 of the Bluetooth
`
`Fi channel's center frequency, as shown below.
`channels that can be used by the Bluetooth devices to exclude the frequencies around the Wi-
`The Bluetooth and WiFi coexistence strategy also includes programming the set of frequency
`
`Source: Bluetooth Core Specification, v5.0, published on Dec. 6, 2016, pages 203, 204.
`
`
`
`Accused Products
`
`’676 Patent Claim
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`Page 26 of 27
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`

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`white-paper-2010-03.pdf, p. 5.
`https://www.marvell.com/docs/wireless/assets/marvell-wireless-wifi-bluetooth-coexistence-
`
`
`
`
`
`
`
`wide.
`frequency and are approximately 23 MHz wide, while Bluetooth channels are only 1 MHz
`a total of 13 Wi-Fi and 79 Bluetooth channels in this band. Wi-Fi channels have a center
`Figure 4 below depicts the channel map allocated for Wi-Fi and Bluetooth devices. There are
`
`and Bluetooth devices.
`Wi-Fi and Bluetooth devices and 4) maximum adjacent channel rejection (ACR) of the Wi-Fi
`
`Accused Products
`
`’676 Patent Claim
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`Page 27 of 27
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