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`APPENDIX A
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`ZTE, Exhibit 1019-0001
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`APPENDIX A
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`ZTE, Exhibit 1019-0001
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`range”
`within a predetermined
`not detected to be
`external object is or is
`“a signal that an
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`APPENDIX A: JOINT CLAIM CONSTRUCTION WORKSHEET
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`of the existence of a
`(3) “a signal indicative
`proximate.”
`external object is
`represents that the
`means “the signal
`of the external object”
`indicates the proximity
`(2) “the signal
`external object.”
`proximity of an
`represents the
`“a signal that
`external object” means
`of proximity of an
`(1) “a signal indicative
`proposes:
`warranted, BNR
`specific construction is
`determines that a
`the extent the Court
`In the alternative, to
`
`meaning.
`Plain and ordinary
`
`
`
`
`
`indicates the
`and (ii) the signal
`telephone call is active
`determines that a
`microprocessor
`display if (i) the
`(c) reduce power to the
`sensor; and
`from the proximity
`(b) receive the signal
`active;
`a telephone call is
`(a) determine whether
`adapted to:
`a microprocessor
`external object; and
`proximity of an
`signal indicative of
`adapted to generate a
`a proximity sensor
`a display;
`comprising:
`1. A mobile station,
`
`’889 Patent:
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`
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`Plaintiff’s Proposed
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`Construction
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`Agreed Proposed
`
`Construction
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`’889 & ’554 Patent
`
`Terms
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`Appendix A: Joint Claim Construction Worksheet
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`ZTE, Exhibit 1019-0002
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`proximate.”
`an external object is
`signal to represent that
`proximate” means “a
`external object is
`condition being that an
`first condition, the first
`
`wireless telephone call
`initiating an outgoing
`mobile station
`concurrently with the
`substantially
`object is proximate
`whether an external
`begins detecting
`the proximity sensor
`is active; and
`wireless telephone call
`determines that the
`the microprocessor
`external object only if
`proximity of the
`signal indicates the
`display while the
`reduces power to the
`the microprocessor
`call;
`wireless telephone
`the telephone call is a
`wherein:
`external object;
`proximity of the
`
`Plaintiff’s Proposed
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`Construction
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`Agreed Proposed
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`Construction
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`’889 & ’554 Patent
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`Terms
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`Appendix A: Joint Claim Construction Worksheet
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`ZTE, Exhibit 1019-0003
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`external object.
`proximity of the
`indicates the
`and (ii) the signal
`telephone call is active
`determines that a
`microprocessor
`display only if (i) the
`reduces power to the
`microprocessor
`of claim 1, wherein the
`2. The mobile station
`
`telephone call.
`incoming wireless
`or receiving an
`
`
`
`
`
`signal indicative of
`adapted to generate a
`a proximity sensor
`a display;
`comprising:
`1. A mobile station,
`
`
`
`’554 Patent:
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`Plaintiff’s Proposed
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`Construction
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`Agreed Proposed
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`Construction
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`’889 & ’554 Patent
`
`Terms
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`Appendix A: Joint Claim Construction Worksheet
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`ZTE, Exhibit 1019-0004
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`condition exists,
`(a) that the second
`determination in step
`(b) in response to a
`call;
`answer an incoming
`outgoing call or to
`an action to initiate an
`station has performed
`user of the mobile
`condition being that a
`condition, the second
`different from the first
`independent and
`a second condition
`sensor, the existence of
`using the proximity
`(a) determine, without
`adapted to:
`a microprocessor
`proximate; and
`an external object is
`condition being that
`condition, the first
`the existence of a first
`
`Plaintiff’s Proposed
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`Construction
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`Agreed Proposed
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`Construction
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`’889 & ’554 Patent
`
`Terms
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`Appendix A: Joint Claim Construction Worksheet
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`ZTE, Exhibit 1019-0005
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`adapted to:
`a microprocessor
`proximate; and
`an external object is
`condition being that
`condition, the first
`the existence of a first
`signal indicative of
`adapted to generate a
`a proximity sensor
`a display;
`comprising:
`14. A mobile station,
`
`condition exists.
`indicates that the first
`proximity sensor
`from the activated
`display if the signal
`(d) reduce power to the
`proximity sensor; and
`from the activated
`(c) receive the signal
`sensor;
`activate the proximity
`
`
`
`Plaintiff’s Proposed
`
`Construction
`
`Agreed Proposed
`
`Construction
`
`’889 & ’554 Patent
`
`Terms
`
`Appendix A: Joint Claim Construction Worksheet
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`ZTE, Exhibit 1019-0006
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`
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`proximity sensor; and
`from the activated
`(c) receive the signal
`sensor;
`activate the proximity
`condition exists,
`(a) that the second
`determination in step
`(b) in response to a
`call;
`answer an incoming
`outgoing call or to
`an action to initiate an
`station has performed
`user of the mobile
`condition being that a
`condition, the second
`from the first
`condition different
`existence of a second
`proximate, the
`the external object is
`determination whether
`independently of the
`(a) determine,
`
`Plaintiff’s Proposed
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`Construction
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`Agreed Proposed
`
`Construction
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`’889 & ’554 Patent
`
`Terms
`
`Appendix A: Joint Claim Construction Worksheet
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`ZTE, Exhibit 1019-0007
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`condition exists.
`indicates that the first
`proximity sensor
`from the activated
`display if the signal
`(d) reduce power to the
`
`
`
`Plaintiff’s Proposed
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`Construction
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`Agreed Proposed
`
`Construction
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`’889 & ’554 Patent
`
`Terms
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`Appendix A: Joint Claim Construction Worksheet
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`ZTE, Exhibit 1019-0008
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`history.
`the prosecution
`the specification and
`invention in light of
`the scope of the
`reasonable certainty
`understand with
`the art would
`as a person skilled in
`term is not indefinite
`BNR contends that this
`
`3GPP) utilizing an
`example, IEEE or
`Organization (for,
`Standard Setting
`standard issued by a
`construction: “a
`alternative
`proposes the following
`warranted, BNR
`construction is
`that a specific
`the Court determines
`However, to the extent
`
`
`
`
`
`carried by a greater
`training sequence is
`optimal extended long
`wherein at least the
`to-average ratio, and
`with a minimal peak-
`long training sequence
`an optimal extended
`generator and provides
`from the signal
`long training sequence
`processes the extended
`Fourier Transformer
`wherein the Inverse
`the signal generator,
`operatively coupled to
`Transformer
`an Inverse Fourier
`and
`long training sequence;
`generates an extended
`a signal generator that
`device, comprising:
`communications
`1. A wireless
`
`Plaintiff’s Proposed
`
`Construction
`
`Agreed Proposed
`
`Construction
`
`’842 Patent Terms
`
`Appendix A: Joint Claim Construction Worksheet
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`ZTE, Exhibit 1019-0009
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`
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`Indefinite.
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`history.
`the prosecution
`the specification and
`invention in light of
`the scope of the
`reasonable certainty
`understand with
`the art would
`as a person skilled in
`term is not indefinite
`BNR contends that this
`
`warranted, BNR
`construction is
`that a specific
`the Court determines
`However, to the extent
`
`
`
`scheme.”
`Division Multiplexing
`Orthogonal Frequency
`
`
`
`
`
`generator and provides
`from the signal
`long training sequence
`processes the extended
`Fourier Transformer
`wherein the Inverse
`the signal generator,
`operatively coupled to
`Transformer
`an Inverse Fourier
`sequence; and
`long training
`generates an extended
`a signal generator that
`device, comprising:
`communications
`1. A wireless
`
`Multiplexing scheme.
`Frequency Division
`Orthogonal
`configuration for an
`wireless networking
`than a standard
`number of subcarriers
`
`
`
`Plaintiff’s Proposed
`
`Construction
`
`Agreed Proposed
`
`Construction
`
`’842 Patent Terms
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`Appendix A: Joint Claim Construction Worksheet
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`ZTE, Exhibit 1019-0010
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`
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`the time domain”
`frequency domain into
`values from the
`transforms a series of
`function that
`a defined mathematical
`software that performs
`“a circuit and/or
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`Court’s Construction
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`Construction
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`Proposed
`Defendants’
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`proposes: “circuit
`warranted, BNR
`specific construction is
`determines that a
`the extent the Court
`In the alternative, to
`
`meaning.
`Plain and ordinary
`
`
`
`same standard.”
`earlier version of the
`subcarriers than an
`uses more active
`training sequence that
`construction: “a
`alternative
`proposes the following
`
`
`
`
`
`Transformer
`an Inverse Fourier
`and
`long training sequence;
`generates an extended
`a signal generator that
`device, comprising:
`communications
`1. A wireless
`
`scheme.
`Division Multiplexing
`Orthogonal Frequency
`configuration for an
`wireless networking
`than a standard
`number of subcarriers
`carried by a greater
`training sequence is
`optimal extended long
`wherein at least the
`to-average ratio, and
`with a minimal peak-
`long training sequence
`an optimal extended
`
`
`
`Plaintiff’s Proposed
`
`Construction
`
`Agreed Proposed
`
`Construction
`
`’842 Patent Terms
`
`Appendix A: Joint Claim Construction Worksheet
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`ZTE, Exhibit 1019-0011
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`
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`transform.”
`inverse Fourier
`least performs an
`and/or software that at
`
`scheme.
`Division Multiplexing
`Orthogonal Frequency
`configuration for an
`wireless networking
`than a standard
`number of subcarriers
`carried by a greater
`training sequence is
`optimal extended long
`wherein at least the
`to-average ratio, and
`with a minimal peak-
`long training sequence
`an optimal extended
`generator and provides
`from the signal
`long training sequence
`processes the extended
`Fourier Transformer
`wherein the Inverse
`the signal generator,
`operatively coupled to
`
`
`
`Plaintiff’s Proposed
`
`Construction
`
`Agreed Proposed
`
`Construction
`
`’842 Patent Terms
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`Appendix A: Joint Claim Construction Worksheet
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`ZTE, Exhibit 1019-0012
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`
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`Indefinite.
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`history.
`the prosecution
`the specification and
`invention in light of
`the scope of the
`reasonable certainty
`understand with
`the art would
`as a person skilled in
`term is not indefinite
`BNR contends that this
`
`Standard Setting
`standard issued by a
`an earlier version of a
`network device using
`wireless local area
`construction: “a
`alternative
`proposes the following
`warranted, BNR
`construction is
`that a specific
`the Court determines
`However, to the extent
`
`
`
`
`
`standard.
`networking protocol
`with a legacy wireless
`device in accordance
`local area network
`by a legacy wireless
`training sequence used
`longer than a long
`training sequence is
`optimal extended long
`claim 1, wherein the
`device according to
`communications
`14. The wireless
`
`
`
`Plaintiff’s Proposed
`
`Construction
`
`Agreed Proposed
`
`Construction
`
`’842 Patent Terms
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`Appendix A: Joint Claim Construction Worksheet
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`ZTE, Exhibit 1019-0013
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`3GPP).
`(for, example, IEEE or
`Organization (SSO)
`
`
`
`
`
`
`
`Plaintiff’s Proposed
`
`Construction
`
`Agreed Proposed
`
`Construction
`
`’842 Patent Terms
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`Appendix A: Joint Claim Construction Worksheet
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`ZTE, Exhibit 1019-0014
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`
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`angles”
`a reduced set of
`matrix (V) to produce
`beamforming unitary
`transmitter
`“factor the estimated
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`Construction
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`Proposed
`Defendants’
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`APPENDIX A: JOINT CLAIM CONSTRUCTION WORKSHEET
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`quantized coefficients”
`a reduced number of
`matrix (V) to produce
`beamforming unitary
`estimated transmitter
`proposes: “factor the
`warranted, BNR
`specific construction is
`determines that a
`the extent the Court
`In the alternative, to
`
`
`
`meaning.
`Plain and ordinary
`
`
`
`
`
`and a receiver
`the channel response
`matrix (V) based upon
`beamforming unitary
`transmitter
`determine an estimated
`sequence;
`the preamble
`response based upon
`estimate a channel
`the baseband signal;
`sequence carried by
`receive a preamble
`module operable to:
`a baseband processing
`signal; and
`signal to a baseband
`and to convert the RF
`to receive an RF signal
`components operable
`Frequency (RF)
`a plurality of Radio
`comprising:
`communication device
`9. A wireless
`
`Plaintiff’s Proposed
`
`Construction
`
`Agreed Proposed
`
`Construction
`
`’862 Patent Terms
`
`Appendix A: Joint Claim Construction Worksheet
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`ZTE, Exhibit 1019-0015
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`
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`Construction
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`Agreed Proposed
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`Construction
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`’862 Patent Terms
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`Appendix A: Joint Claim Construction Worksheet
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`preamble sequence
`Function: “receive a
`
`
`
`element.
`This is a 112 ¶ 6 claim
`
`Instead, a baseband
`not a nonce word.
`processing module” is
`element – “baseband
`Not a 112 ¶ 6 claim
`
`
`
`device.
`transmitting wireless
`information to the
`beamforming
`transmitter
`wirelessly send the
`components to
`plurality of RF
`employed by the
`form a baseband signal
`information; and
`beamforming
`the transmitter
`matrix (V) to produce
`beamforming unitary
`estimated transmitter
`decompose the
`matrix (U);
`beamforming unitary
`
`
`
`Frequency (RF)
`a plurality of Radio
`comprising:
`communication device
`9. A wireless
`
`ZTE, Exhibit 1019-0016
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`
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`plurality of RF
`employed by the
`a baseband signal
`information; and form
`beamforming
`the transmitter
`matrix (V) to produce
`beamforming unitary
`transmitter
`the estimated
`matrix (U); decompose
`beamforming unitary
`and a receiver
`the channel response
`matrix (V) based upon
`beamforming unitary
`transmitter
`an estimated
`sequence; determine
`the preamble
`response based upon
`estimate a channel
`baseband signal;
`carried by the
`
`Construction
`
`Proposed
`Defendants’
`
`structure:
`corresponding
`is indefinite for lack of
`disagrees that the term
`and Structure, and
`the following Function
`112 ¶ 6, BNR proposes
`claim is governed by
`determines that this
`the extent the Court
`In the alternative, to
`
`Function:
`
`
`
`hardware.
`communication
`or the like in RF
`FGPA, logic circuits,
`implemented in ASIC,
`baseband processor
`would know this is a
`structure. A POSA
`itself sufficient
`processing module is
`
`
`
`matrix (U);
`beamforming unitary
`receiver
`response and a
`upon the channel
`matrix (V) based
`beamforming unitary
`estimated transmitter
`determine an
`sequence;
`the preamble
`response based upon
`estimate a channel
`the baseband signal;
`sequence carried by
`receive a preamble
`operable to:
`processing module
`a baseband
`signal; and
`signal to a baseband
`and to convert the RF
`to receive an RF signal
`components operable
`
`Plaintiff’s Proposed
`
`Construction
`
`Agreed Proposed
`
`Construction
`
`’862 Patent Terms
`
`Appendix A: Joint Claim Construction Worksheet
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`ZTE, Exhibit 1019-0017
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`
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`specification.
`structure in the patent
`corresponding
`for lack of
`Structure: Indefinite
`
`device”
`transmitting wireless
`information to the
`beamforming
`transmitter
`wirelessly send the
`components to
`
`Construction
`
`Proposed
`Defendants’
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`plurality of RF
`employed by the
`a baseband signal
`information; and form
`beamforming
`the transmitter
`matrix (V) to produce
`beamforming unitary
`estimated transmitter
`decompose the
`matrix (U);
`beamforming unitary
`and a receiver
`the channel response
`matrix (V) based upon
`beamforming unitary
`transmitter
`determine an estimated
`sequence;
`the preamble
`response based upon
`estimate a channel
`the baseband signal;
`sequence carried by
`“receive a preamble
`
`device.
`transmitting wireless
`information to the
`beamforming
`transmitter
`wirelessly send the
`components to
`the plurality of RF
`signal employed by
`form a baseband
`information; and
`beamforming
`the transmitter
`matrix (V) to produce
`beamforming unitary
`estimated transmitter
`decompose the
`
`
`
`Plaintiff’s Proposed
`
`Construction
`
`Agreed Proposed
`
`Construction
`
`’862 Patent Terms
`
`Appendix A: Joint Claim Construction Worksheet
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`ZTE, Exhibit 1019-0018
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`
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`
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`element.
`This is a 112 ¶ 6 claim
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`Court’s Construction
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`Construction
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`Proposed
`Defendants’
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`equivalents:
`specification, or their
`the patent
`following portions of
`in at least the
`alleged function exists
`structure for the
`Corresponding
`Structure:
`
`device”
`transmitting wireless
`information to the
`beamforming
`transmitter
`wirelessly send the
`components to
`
`
`
`
`
`13:54–15:67.
`9:30; 9:31–13:35;
`6:12, 6:37–7:20; 7:51–
`Figs. 2-5, Col. 5:49–
`
`element – “baseband
`Not a 112 ¶ 6 claim
`
`
`
`
`
`communication device
`10. The wireless
`
`Plaintiff’s Proposed
`
`Construction
`
`Agreed Proposed
`
`Construction
`
`’862 Patent Terms
`
`Appendix A: Joint Claim Construction Worksheet
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`ZTE, Exhibit 1019-0019
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`
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`
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`specification.
`structure in the patent
`corresponding
`for lack of
`Structure: Indefinite
`
`coordinates”
`matrix (V) to polar
`beamforming unitary
`transmitter
`convert the estimated
`coordinates; and
`matrix (V) in Cartesian
`beamforming unitary
`transmitter
`produce the estimated
`operable to . . .
`processing module
`Function: “a baseband
`
`Construction
`
`Proposed
`Defendants’
`
`structure:
`corresponding
`is indefinite for lack of
`disagrees that the term
`and Structure, and
`the following Function
`112 ¶ 6, BNR proposes
`claim is governed by
`determines that this
`the extent the Court
`In the alternative, to
`
`hardware.
`communication
`or the like in RF
`FGPA, logic circuits,
`implemented in ASIC,
`baseband processor
`would know this is a
`structure. A POSA
`itself sufficient
`processing module is
`Instead, a baseband
`not a nonce word.
`processing module” is
`
`
`
`coordinates.
`matrix (V) to polar
`beamforming unitary
`transmitter
`convert the estimated
`coordinates; and
`Cartesian
`matrix (V) in
`beamforming unitary
`estimated transmitter
`produce the
`to:
`module is operable
`baseband processing
`matrix (U), the
`beamforming unitary
`and a receiver
`the channel response
`matrix (V) based upon
`beamforming unitary
`estimated transmitter
`determining an
`of claim 9, wherein in
`
`
`
`Plaintiff’s Proposed
`
`Construction
`
`Agreed Proposed
`
`Construction
`
`’862 Patent Terms
`
`Appendix A: Joint Claim Construction Worksheet
`
`ZTE, Exhibit 1019-0020
`
`
`
`Case 3:18-cv-01786-CAB-BLM Document 79-1 Filed 04/19/19 PageID.1911 Page 21 of 58
`
`Court’s Construction
`
`Construction
`
`Proposed
`Defendants’
`
`20
`
`APPENDIX A: JOINT CLAIM CONSTRUCTION WORKSHEET
`
`coordinates”
`matrix (V) to polar
`beamforming unitary
`transmitter
`convert the estimated
`coordinates; and
`matrix (V) in Cartesian
`beamforming unitary
`transmitter
`produce the estimated
`operable to . . .
`processing module
`“a baseband
`Function:
`
`
`
`equivalents:
`specification, or their
`the patent
`following portions of
`in at least the
`alleged function exists
`structure for the
`Corresponding
`Structure:
`
`
`
`Plaintiff’s Proposed
`
`Construction
`
`Agreed Proposed
`
`Construction
`
`’862 Patent Terms
`
`Appendix A: Joint Claim Construction Worksheet
`
`ZTE, Exhibit 1019-0021
`
`
`
`Case 3:18-cv-01786-CAB-BLM Document 79-1 Filed 04/19/19 PageID.1912 Page 22 of 58
`
`21
`
`APPENDIX A: JOINT CLAIM CONSTRUCTION WORKSHEET
`
`Court’s Construction
`
`Construction
`
`Proposed
`Defendants’
`
`13:54–15:67.
`9:30; 9:31–13:35;
`6:12, 6:37–7:20; 7:51–
`Figs. 2-5, Col. 5:49–
`
`
`
`
`
`
`
`
`
`Plaintiff’s Proposed
`
`Construction
`
`Agreed Proposed
`
`Construction
`
`’862 Patent Terms
`
`Appendix A: Joint Claim Construction Worksheet
`
`ZTE, Exhibit 1019-0022
`
`
`
`Case 3:18-cv-01786-CAB-BLM Document 79-1 Filed 04/19/19 PageID.1913 Page 23 of 58
`
`
`
`Court’s Construction
`
`22
`
`APPENDIX A: JOINT CLAIM CONSTRUCTION WORKSHEET
`
`
`
`the true values of H(t)”
`contains estimates of
`frequencies, where Hest
`of different
`“matrix Hest for tones
`
`Construction
`
`Proposed
`Defendants’
`
`of H(t)”
`estimates of the values
`decomposition of the
`on an SVD
`matrices that is based
`proposes: “one or more
`warranted, BNR
`specific construction is
`determines that a
`the extent the Court
`In the alternative, to
`
`meaning.
`Plain and ordinary
`
`
`
`Plaintiff’s Proposed
`
`Construction
`
`Agreed Proposed
`
`Construction
`
`Appendix A: Joint Claim Construction Worksheet
`
`
`
`to said base station, via
`feedback information
`coefficients as
`transmitting said
`signals; and
`on said received
`decomposition (SVD)
`value matrix
`performing a singular
`derived from
`comprise coefficients
`estimate matrices
`plurality of channel
`channels, wherein said
`more downlink RF
`base station, via one or
`mobile terminal from a
`signals received by a
`matrices based on
`of channel estimate
`computing a plurality
`method comprising:
`communication, the
`1. A method for
`
`’450 Patent Terms
`
`
`
`ZTE, Exhibit 1019-0023
`
`
`
`Case 3:18-cv-01786-CAB-BLM Document 79-1 Filed 04/19/19 PageID.1914 Page 24 of 58
`
`Court’s Construction
`
`Construction
`
`Proposed
`Defendants’
`
`23
`
`APPENDIX A: JOINT CLAIM CONSTRUCTION WORKSHEET
`
`frequencies.
`more distinct
`corresponds to one or
`plurality of tones
`wherein each of said
`plurality of tones,
`corresponding one of a
`matrices for a
`of channel estimate
`each of said plurality
`comprising computing
`according to claim 1,
`2. The method
`
`to each of said
`matrix, corresponding
`and a singular value
`singular vector matrix
`one or both of, a right
`comprising computing
`according to claim 2,
`3. The method
`
`
`
`channels.
`one or more uplink RF
`
`
`
`Plaintiff’s Proposed
`
`Construction
`
`Agreed Proposed
`
`Construction
`
`’450 Patent Terms
`
`Appendix A: Joint Claim Construction Worksheet
`
`ZTE, Exhibit 1019-0024
`
`
`
`Case 3:18-cv-01786-CAB-BLM Document 79-1 Filed 04/19/19 PageID.1915 Page 25 of 58
`
`Court’s Construction
`
`Construction
`
`Proposed
`Defendants’
`
`24
`
`APPENDIX A: JOINT CLAIM CONSTRUCTION WORKSHEET
`
`on said received
`decomposition (SVD)
`singular value matrix
`from performing a
`coefficients derived
`matrices comprise
`channel estimate
`said plurality of
`RF channels, wherein
`one or more downlink
`from a base station, via
`said mobile terminal
`signals received by
`matrices based on
`channel estimate
`compute a plurality of
`are operable to
`a mobile terminal that
`one or more circuits of
`system comprising:
`communication, the
`11. A system for
`
`estimate matrices.
`plurality of channel
`
`
`
`Plaintiff’s Proposed
`
`Construction
`
`Agreed Proposed
`
`Construction
`
`’450 Patent Terms
`
`Appendix A: Joint Claim Construction Worksheet
`
`ZTE, Exhibit 1019-0025
`
`
`
`Case 3:18-cv-01786-CAB-BLM Document 79-1 Filed 04/19/19 PageID.1916 Page 26 of 58
`
`Court’s Construction
`
`Construction
`
`Proposed
`Defendants’
`
`25
`
`APPENDIX A: JOINT CLAIM CONSTRUCTION WORKSHEET
`
`channels.
`one or more uplink RF
`to said base station, via
`feedback information
`said coefficients as
`operable to transmit
`or more circuits are
`signals; and said one
`
`
`
`frequencies.
`more distinct
`corresponds to one or
`plurality of tones
`wherein each of said
`plurality of tones,
`corresponding one of a
`matrices for a
`of channel estimate
`each of said plurality
`operable to compute
`more circuits are
`wherein said one or
`according to claim 11,
`12. The system
`
`
`
`Plaintiff’s Proposed
`
`Construction
`
`Agreed Proposed
`
`Construction
`
`’450 Patent Terms
`
`Appendix A: Joint Claim Construction Worksheet
`
`ZTE, Exhibit 1019-0026
`
`
`
`Case 3:18-cv-01786-CAB-BLM Document 79-1 Filed 04/19/19 PageID.1917 Page 27 of 58
`
`Court’s Construction
`
`Construction
`
`Proposed
`Defendants’
`
`26
`
`APPENDIX A: JOINT CLAIM CONSTRUCTION WORKSHEET
`
`estimate matrices.
`plurality of channel
`to each of said
`matrix, corresponding
`and a singular value
`singular vector matrix
`one or both of, a right
`operable to compute
`more circuits are
`wherein said one or
`according to claim 12,
`13. The system
`
`matrix based on the
`channels; deriving a
`more downlink RF
`station, via one or
`terminal from a base
`received by a mobile
`based on signals
`of channel estimates
`computing a plurality
`method comprising:
`communication, the
`21. A method for
`
`
`
`Plaintiff’s Proposed
`
`Construction
`
`Agreed Proposed
`
`Construction
`
`’450 Patent Terms
`
`Appendix A: Joint Claim Construction Worksheet
`
`ZTE, Exhibit 1019-0027
`
`
`
`Case 3:18-cv-01786-CAB-BLM Document 79-1 Filed 04/19/19 PageID.1918 Page 28 of 58
`
`Court’s Construction
`
`Construction
`
`Proposed
`Defendants’
`
`27
`
`APPENDIX A: JOINT CLAIM CONSTRUCTION WORKSHEET
`
`channels.
`one or more uplink RF
`to said base station, via
`feedback information
`coefficients as
`transmitting the
`channel estimates; and
`on said plurality of
`decomposition (SVD)
`value matrix
`performing a singular
`coefficients from
`matrix comprises
`estimates, wherein the
`plurality of channel
`
`based on signals
`channel estimates
`compute a plurality of
`are operable to
`a mobile terminal that
`one or more circuits of
`system comprising:
`communication, the
`22. A system for
`
`
`
`Plaintiff’s Proposed
`
`Construction
`
`Agreed Proposed
`
`Construction
`
`’450 Patent Terms
`
`Appendix A: Joint Claim Construction Worksheet
`
`ZTE, Exhibit 1019-0028
`
`
`
`Case 3:18-cv-01786-CAB-BLM Document 79-1 Filed 04/19/19 PageID.1919 Page 29 of 58
`
`Court’s Construction
`
`Construction
`
`Proposed
`Defendants’
`
`28
`
`APPENDIX A: JOINT CLAIM CONSTRUCTION WORKSHEET
`
`channels.
`one or more uplink RF
`to said base station, via
`feedback information
`coefficients as
`transmit said
`circuits are operable to
`said one or more
`channel estimates; and
`on said plurality of
`decomposition (SVD)
`singular value matrix
`from performing a
`coefficients derived
`said matrix comprises
`estimates, wherein
`plurality of channel
`matrix based on said
`operable to derive a
`more circuits are
`channels; said one or
`more downlink RF
`base station, via one or
`mobile terminal from a
`received by said
`
`Plaintiff’s Proposed
`
`Construction
`
`Agreed Proposed
`
`Construction
`
`’450 Patent Terms
`
`Appendix A: Joint Claim Construction Worksheet
`
`ZTE, Exhibit 1019-0029
`
`
`
`Case 3:18-cv-01786-CAB-BLM Document 79-1 Filed 04/19/19 PageID.1920 Page 30 of 58
`
`
`
`
`
`Hest=USVH”
`U, S, or VH, where
`“values in the matrices
`
`Court’s Construction
`
`Construction
`
`Proposed
`Defendants’
`
`29
`
`APPENDIX A: JOINT CLAIM CONSTRUCTION WORKSHEET
`
`value decomposition”
`derived from a singular
`proposes: “values
`warranted, BNR
`specific construction is
`determines that a
`the extent the Court
`In the alternative, to
`
`meaning.
`Plain and ordinary
`
`
`
`
`
`to said base station, via
`feedback information
`coefficients as
`transmitting said
`signals; and
`on said received
`decomposition (SVD)
`singular value matrix
`performing a
`derived from
`comprise coefficients
`estimate matrices
`plurality of channel
`channels, wherein said
`more downlink RF
`base station, via one or
`mobile terminal from a
`signals received by a
`matrices based on
`of channel estimate
`computing a plurality
`method comprising:
`communication, the
`1. A method for
`
`
`
`Plaintiff’s Proposed
`
`Construction
`
`Agreed Proposed
`
`Construction
`
`’450 Patent Terms
`
`Appendix A: Joint Claim Construction Worksheet
`
`ZTE, Exhibit 1019-0030
`
`
`
`Case 3:18-cv-01786-CAB-BLM Document 79-1 Filed 04/19/19 PageID.1921 Page 31 of 58
`
`Court’s Construction
`
`Construction
`
`Proposed
`Defendants’
`
`30
`
`APPENDIX A: JOINT CLAIM CONSTRUCTION WORKSHEET
`
`on said received
`decomposition (SVD)
`singular value matrix
`from performing a
`coefficients derived
`matrices comprise
`channel estimate
`said plurality of
`RF channels, wherein
`one or more downlink
`from a base station, via
`said mobile terminal
`signals received by
`matrices based on
`channel estimate
`compute a plurality of
`are operable to
`a mobile terminal that
`one or more circuits of
`system comprising:
`communication, the
`11. A system for
`
`channels.
`one or more uplink RF
`
`
`
`Plaintiff’s Proposed
`
`Construction
`
`Agreed Proposed
`
`Construction
`
`’450 Patent Terms
`
`Appendix A: Joint Claim Construction Worksheet
`
`ZTE, Exhibit 1019-0031
`
`
`
`Case 3:18-cv-01786-CAB-BLM Document 79-1 Filed 04/19/19 PageID.1922 Page 32 of 58
`
`Court’s Construction
`
`Construction
`
`Proposed
`Defendants’
`
`31
`
`APPENDIX A: JOINT CLAIM CONSTRUCTION WORKSHEET
`
`channels.
`one or more uplink RF
`to said base station, via
`feedback information
`said coefficients as
`operable to transmit
`or more circuits are
`signals; and said one
`
`coefficients from
`matrix comprises
`estimates, wherein the
`plurality of channel
`matrix based on the
`channels; deriving a
`more downlink RF
`station, via one or
`terminal from a base
`received by a mobile
`based on signals
`of channel estimates
`computing a plurality
`method comprising:
`communication, the
`21. A method for
`
`
`
`Plaintiff’s Proposed
`
`Construction
`
`Agreed Proposed
`
`Construction
`
`’450 Patent Terms
`
`Appendix A: Joint Claim Construction Worksheet
`
`ZTE, Exhibit 1019-0032
`
`
`
`Case 3:18-cv-01786-CAB-BLM Document 79-1 Filed 04/19/19 PageID.1923 Page 33 of 58
`
`Court’s Construction
`
`Construction
`
`Proposed
`Defendants’
`
`32
`
`APPENDIX A: JOINT CLAIM CONSTRUCTION WORKSHEET
`
`more downlink RF
`base station, via one or
`mobile terminal from a
`received by said
`based on signals
`channel estimates
`compute a plurality of
`are operable to
`a mobile terminal that
`one or more circuits of
`system comprising:
`communication, the
`22. A system for
`
`channels.
`one or more uplink RF
`to said base station, via
`feedback information
`coefficients as
`transmitting the
`channel estimates; and
`on said plurality of
`decomposition (SVD)
`singular value matrix
`performing a
`
`
`
`Plaintiff’s Proposed
`
`Construction
`
`Agreed Proposed
`
`Construction
`
`’450 Patent Terms
`
`Appendix A: Joint Claim Construction Worksheet
`
`ZTE, Exhibit 1019-0033
`
`
`
`Case 3:18-cv-01786-CAB-BLM Document 79-1 Filed 04/19/19 PageID.1924 Page 34 of 58
`
`Court’s Construction
`
`Construction
`
`Proposed
`Defendants’
`
`33
`
`APPENDIX A: JOINT CLAIM CONSTRUCTION WORKSHEET
`
`
`
`
`
`channels.
`one or
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