`
`EXHIBIT 4
`U.S. Patent No. 8,411,557
`
`These infringement contentions are prepared with public information and have not been prepared with the benefit of discovery. Plaintiffs
`reserve the right to amend these contentions, including adding and/or amending a doctrine of equivalents analysis for any claim element of
`any asserted claim, as discovery progresses. Plaintiffs further reserve the right to update, amend, or supplement these contentions and/or to
`add Accused Instrumentalities, standard, or chipset information, based on information received by Plaintiffs or otherwise produced by Apple,
`Qualcomm, Intel, or any other entity, in this litigation. Such information may include, but is not limited to, data sheets, design specifications,
`source code, testing information, reference designs, implementation and utilization information, and/or schematics. Plaintiffs’ citation of
`portions of the 3GPP LTE standard herein should not be interpreted to limit Plaintiffs’ infringement proof in expert reports or at
`trial in any way. Plaintiffs’ citation of portions of the 3GPP LTE standard herein provides detailed notice of Plaintiffs’ theory of
`infringement, but Plaintiffs intend to rely on additional evidence including, but not limited to, data sheets, design specifications, source code,
`testing information, reference designs, implementation and utilization information, and/or schematics as proof of infringement in expert
`reports and at trial. Reference should also be made to the cover pleading and Appendix A hereto.
`
`Claim
`No.
`1
`
`Claim 1
`
`ACCUSED INSTRUMENTALITIES
`
`A mobile station apparatus
`comprising:
`
`The Accused Instrumentalities1 include a mobile station for use in a mobile communications
`system.
`
`For example, and without limitation, each of the Accused Instrumentalities is compliant with or is
`configured and designed to comply with and/or support the 3GPP Long Term Evolution (“LTE”)
`Standard. Under the 3GPP LTE Standard, User Equipment (UE) comprises a mobile station
`apparatus for use in mobile communications. The LTE Standard covers the operation of mobile
`stations (such as Apple’s Accused Instrumentalities) in LTE connectivity and communication.
`
`As further examples, and without limitation:
`
`1 Throughout this chart, non-limiting examples from the iPhone XS are used to illustrate the application of the claims to the Accused
`Instrumentalities based on their LTE support. Appendix A to these contentions lists in a non-limiting manner similar LTE support
`documentation illustrating how the other Accused Instrumentalities infringe in the same manner.
`
`IPR2020-00466
`APPLE v. OPTIS
`APPLE 1046
`
`

`

`U.S. Patent No. 8,411,557
`
`Claim
`No.
`
`Claim 1
`
`ACCUSED INSTRUMENTALITIES
`
`
`(Source: https://www.apple.com/iphone/)
`
`2
`
`
`
`

`

`U.S. Patent No. 8,411,557
`
`Claim
`No.
`
`Claim 1
`
`ACCUSED INSTRUMENTALITIES
`
`
`(Source: https://www.apple.com/iphone-xs/specs/)
`
`
`
`1 Scope
`The present document describes a general description of the physical layer of the E-UTRA radio interface. The present
`document also describes the document structure of the 3GPP physical layer specifications, i.e. TS 36.200 series. The TS
`36.200 series specifies the Uu point for the 3G LTE mobile system, and defines the minimum level of specifications
`required for basic connections in terms of mutual connectivity and compatibility.
`
`3
`
`

`

`U.S. Patent No. 8,411,557
`
`Claim
`No.
`
`Claim 1
`
`1.1
`
`a receiving unit configured
`to receive control
`information;
`
`
`
`ACCUSED INSTRUMENTALITIES
`
`(Source: 3GPP TS 36.201 V8.3.0 (2009-03) at § 1) and all subsequent versions.
`
`4 General description of LTE Layer 1
`4.1 Relation to other layers
`4.1.1 General Protocol Architecture
`The radio interface described in this specification covers the interface between the User Equipment (UE) and the
`network. The radio interface is composed of the Layer 1, 2 and 3. The TS 36.200 series describes the Layer 1 (Physical
`Layer) specifications. Layers 2 and 3 are described in the 36.300 series.
`(Source: 3GPP TS 36.201 V8.3.0 (2009-03) at § 4.1.1) and all subsequent versions.
`
`See also 1.1-1.4.
`
`PanOptis reserves the right to add additional information and infringement theories once discovery
`begins in this case, particularly once Apple produces its technical documents (including, but not
`limited to, source code).
`The Accused Instrumentalities include a receiving unit configured to receive control information.
`
`For example, and without limitation, because each of the Accused Instrumentalities is compliant
`with or is configured and designed to comply with and/or support the LTE Standard, they
`necessarily include a receiving unit configured to receive control information.
`
`As further example and without limitation, the LTE Standard requires that a receiving unit be
`configured to receive control information:
`
`5 MAC procedures
`
`4
`
`

`

`U.S. Patent No. 8,411,557
`
`Claim
`No.
`
`Claim 1
`
`ACCUSED INSTRUMENTALITIES
`
`5.1 Random Access procedure
`5.1.1 Random Access Procedure initialization
`The Random Access procedure described in this subclause is initiated by a PDCCH order or by the MAC sublayer
`itself. If a UE receives a PDCCH transmission consistent with a PDCCH order [5] masked with its C-RNTI, it shall
`initiate a Random Access procedure. The PDCCH order or RRC optionally indicate ra-PreambleIndex and ra-PRACH-
`MaskIndex.
`
`Before the procedure can be initiated, the following information is assumed to be available [8]:
`
`-
`
`-
`
`the available set of PRACH resources for the transmission of the Random Access Preamble, prach-ConfigIndex.
`
`the groups of Random Access Preambles and the set of available Random Access Preambles in each group:
`
` The preambles that are contained in Random Access Preambles group A and Random Access Preambles group B
`are calculated from the parameters numberOfRA-Preambles and sizeOfRA-PreamblesGroupA:
`
`
`
`If sizeOfRA-PreamblesGroupA is equal to numberOfRA-Preambles then there is no Random Access Preambles
`group B. The preambles in Random Access Preamble group A are the preambles 0 to sizeOfRA-
`PreamblesGroupA – 1 and, if it exists, the preambles in Random Access Preamble group B are the preambles
`sizeOfRA-PreamblesGroupA to numberOfRA-Preambles – 1 from the set of 64 preambles as defined in [7].
`
`-
`
`if Random Access Preambles group B exists, the thresholds, messagePowerOffsetGroupB and
`messageSizeGroupA, the configured UE transmitted power, PCMAX [10], and the offset between the preamble and
`Msg3, deltaPreambleMsg3, that are required for selecting one of the two groups of Random Access Preambles.
`(Source: 3GPP TS 36.321 V8.7.0 (2009-09) at § 5.1.1) and all subsequent versions.
`
`5 Procedures
`5.1 General
`5.1.1 Introduction
`The procedural requirements are structured according to the main functional areas: system information (5.2), connection
`
`5
`
`

`

`U.S. Patent No. 8,411,557
`
`Claim
`No.
`
`Claim 1
`
`ACCUSED INSTRUMENTALITIES
`
`control (5.3), inter-RAT mobility (5.4) and measurements (5.5). In addition there is a sub-clause other (5.6) that covers
`e.g. NAS dedicated information transfer, UE capability transfer. Finally, sub-clause 5.7 specifies the generic error
`handling.
`5.1.2 General requirements
`The UE shall:
`
`1> process the received messages in order of reception by RRC, i.e. the processing of a message shall be completed
`before starting the processing of a subsequent message;
`(Source: 3GPP TS 36.331 V8.7.0 (2009-09) at § 5.1.2) and all subsequent versions.
`
`Actions upon reception of SystemInformationBlockType2
`5.2.2.9
`Upon receiving SystemInformationBlockType2, the UE shall:
`
`1> if upper layers indicate that a (UE specific) paging cycle is configured:
`
`2> Apply the shortest of the (UE specific) paging cycle and the defaultPagingCycle included in the
`radioResourceConfigCommon;
`
`1> else:
`
`2> Apply the defaultPagingCycle included in the radioResourceConfigCommon;
`
`1> if the mbsfn-SubframeConfigList is included:
`
`2> consider that no other DL assignments occur in the MBSFN subframes indicated in the IE mbsfn-
`SubframeConfigList:
`
`1> apply the configuration included in the radioResourceConfigCommon;
`
`1> apply the specified PCCH configuration defined in 9.1.1.3;
`
`1> not apply the timeAlignmentTimerCommon;
`(Source: 3GPP TS 36.331 V8.7.0 (2009-09) at § 5.2.2.9) and all subsequent versions.
`
`6
`
`

`

`U.S. Patent No. 8,411,557
`
`Claim
`No.
`
`Claim 1
`
`ACCUSED INSTRUMENTALITIES
`
`6.3 RRC information elements
`6.3.1 System information blocks
`–
`SystemInformationBlockType2
`The IE SystemInformationBlockType2 contains radio resource configuration information that is common for all UEs.
`
`NOTE: UE timers and constants related to functionality for which parameters are provided in another SIB are
`included in the corresponding SIB.
`SystemInformationBlockType2 information element
`
`-- ASN1START
`
`SEQUENCE {
`SystemInformationBlockType2 ::=
`
`SEQUENCE {
`
`ac-BarringInfo
`
`
`
`
`
`BOOLEAN,
`
`
`ac-BarringForEmergency
`
`
`
`
`ac-BarringForMO-Signalling
`
`AC-BarringConfig
`
`
`
`
`ac-BarringForMO-Data
`
`
`
`AC-BarringConfig
`
`
`
`}
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`radioResourceConfigCommon
`
`
`RadioResourceConfigCommonSIB,
`
`ue-TimersAndConstants
`
`
`
`UE-TimersAndConstants,
`(Source: 3GPP TS 36.331 V8.7.0 (2009-09) at § 6.3.1) and all subsequent versions.
`
`OPTIONAL,
`OPTIONAL
`OPTIONAL,
`
`
`
`
`
`-- Need OP
`-- Need OP
`-- Need OP
`
`Radio resource control information elements
`
`6.3.2
`[…]
`PRACH-Config
`–
`The IE PRACH-ConfigSIB and IE PRACH-Config are used to specify the PRACH configuration in the system
`information and in the mobility control information, respectively.
`PRACH-Config information elements
`
`-- ASN1START
`
`PRACH-ConfigSIB ::=
`
`rootSequenceIndex
`
`
`
`
`SEQUENCE {
`
`
`
`
`INTEGER (0..837),
`
`7
`
`

`

`U.S. Patent No. 8,411,557
`
`Claim
`No.
`
`Claim 1
`
`ACCUSED INSTRUMENTALITIES
`
`prach-ConfigInfo
`
`
`
`
`
`
`
`
`}
`
`
`PRACH-Config ::=
`
`rootSequenceIndex
`
`prach-ConfigInfo
`}
`
`
`
`PRACH-ConfigInfo ::=
`
`
`
`prach-ConfigIndex
`
`
`
`highSpeedFlag
`
`
`zeroCorrelationZoneConfig
`
`prach-FreqOffset
`
`
`}
`
`-- ASN1STOP
`
`
`
`
`
`
`
`
`
`
`
`
`PRACH-ConfigInfo
`
`SEQUENCE {
`
`
`INTEGER (0..837),
`
`
`PRACH-ConfigInfo
`
`
`
`
`
`
`
`SEQUENCE {
`
`INTEGER (0..63),
`
`BOOLEAN,
`
`INTEGER (0..15),
`
`INTEGER (0..94)
`
`
`
`
`
`
`
`
`
`OPTIONAL
`
`-- Need ON
`
`PRACH-Config field descriptions
`
`rootSequenceIndex
`Parameter: RACH_ROOT_SEQUENCE, see TS 36.211 [21, 5.7.1].
`prach-ConfigIndex
`Parameter: prach-ConfigurationIndex, see TS 36.211 [21, 5.7.1].
`highSpeedFlag
`Parameter: High-speed-flag, see TS 36.211, [21, 5.7.2].TRUE corresponds to Restricted set and FALSE to
`Unrestricted set.
`zeroCorrelationZoneConfig
`Parameter: NCS configuration, see TS 36.211, [21, 5.7.2: table 5.7.2-2] for preamble format 0..3 and TS 36.211, [21,
`5.7.2: table 5.7.2-3] for preamble format 4.
`prach-FreqOffset
`Parameter: prach-FrequencyOffset, see TS 36.211, [21, 5.7.1]. For TDD the value range is dependent on the value of
`prach-ConfigIndex.
`
`[…]
`RadioResourceConfigCommon
`–
`The IE RadioResourceConfigCommonSIB and IE RadioResourceConfigCommon are used to specify common radio
`resource configurations in the system information and in the mobility control information, respectively, e.g., the random
`access parameters and the static physical layer parameters.
`RadioResourceConfigCommon information element
`
`8
`
`

`

`U.S. Patent No. 8,411,557
`
`Claim
`No.
`
`Claim 1
`
`ACCUSED INSTRUMENTALITIES
`
`-- ASN1START
`
`RadioResourceConfigCommonSIB ::=
`
`rach-ConfigCommon
`
`
`
`
`SEQUENCE {
`
`RACH-ConfigCommon,
`
`[…]
`RACH-ConfigCommon
`–
`The IE RACH-ConfigCommon is used to specify the generic random access parameters.
`RACH-ConfigCommon information element
`
`-- ASN1START
`
`SEQUENCE {
`
`RACH-ConfigCommon ::=
`
`
`
`
`
`preambleInfo
`
`
`
`numberOfRA-Preambles
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`preamblesGroupAConfig
`
`
`
`
`
`sizeOfRA-PreamblesGroupA
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`messageSizeGroupA
`
`
`
`
`
`messagePowerOffsetGroupB
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`...
`
`
`}
`
`
`OPTIONAL
`
`
`
`},
`
`[…]
`
`SEQUENCE {
`
`ENUMERATED {
`
`
`n4, n8, n12, n16 ,n20, n24, n28,
`
`
`n32, n36, n40, n44, n48, n52, n56,
`
`
`n60, n64},
`
`SEQUENCE {
`
`
`ENUMERATED {
`
`
`
`n4, n8, n12, n16 ,n20, n24, n28,
`
`
`
`n32, n36, n40, n44, n48, n52, n56,
`
`
`
`n60},
`
`
`ENUMERATED {b56, b144, b208, b256},
`
`
`ENUMERATED {
`
`
`
`minusinfinity, dB0, dB5, dB8, dB10, dB12,
`
`
`
`dB15, dB18},
`
`
`
`
`
`
`
`
`
`
`-- Need OP
`
`
`
`
`
`RACH-ConfigCommon field descriptions
`
`numberOfRA-Preambles
`Number of non-dedicated random access preambles in TS 36.321 [6]. Value is an integer. Value n4 corresponds to 4,
`n8 corresponds to 8 and so on.
`preamblesGroupAConfig
`Provides the configuration for preamble grouping in TS 36.321 [6]. If the field is not signalled, the size of the random
`access preambles group A [6] is equal to numberOfRA-Preambles.
`
`9
`
`

`

`U.S. Patent No. 8,411,557
`
`Claim
`No.
`
`Claim 1
`
`1.2
`
`a selecting unit configured
`to randomly select a
`sequence from a plurality of
`sequences contained in one
`group of a plurality of
`groups, into which a
`predetermined number of
`sequences that are
`generated from a plurality
`of base sequences are
`grouped and which are
`respectively associated with
`
`ACCUSED INSTRUMENTALITIES
`
`sizeOfRA-PreamblesGroupA
`Size of the random access preambles group A in TS 36.321 [6]. Value is an integer. Value n4 corresponds to 4, n8
`corresponds to 8 and so on.
`messageSizeGroupA
`Threshold for preamble selection in TS 36.321 [6]. Value in bits. Value b56 corresponds to 56 bits, b144 corresponds
`to 144 bits and so on.
`messagePowerOffsetGroupB
`Threshold for preamble selection in TS 36.321 [6]. Value in dB. Value minusinfinity corresponds to –infinity. Value dB0
`corresponds to 0 dB, dB5 corresponds to 5 dB and so on.
`(Source: 3GPP TS 36.331 V8.7.0 (2009-09) at § 6.3.2) and all subsequent versions.
`
`The Accused Instrumentalities receive, among other things, the number of preambles in the groups,
`the message size threshold for group A, and the size of the message 3 to send and the pathloss,
`which are “used to determine which group a preamble is selected from.”
`
`(Source: 3GPP TS 36.300 V8.8.0 (2009-03) at § 10.1.5.1) and all subsequent versions.
`
`PanOptis reserves the right to add additional information and infringement theories once discovery
`begins in this case, particularly once Apple produces its technical documents (including, but not
`limited to, source code).
`The Accused Instrumentalities include a selecting unit configured to randomly select a sequence
`from a plurality of sequences contained in one group of a plurality of groups, into which a
`predetermined number of sequences that are generated from a plurality of base sequences are
`grouped and which are respectively associated with different amounts of data or reception qualities,
`wherein the predetermined number of sequences are grouped by partitioning the predetermined
`number of sequences, in which sequences generated from the same base sequence and having
`different cyclic shifts are arranged in an increasing order of the cyclic shifts.
`
`For example and without limitation, because each of the Accused Instrumentalities is compliant
`with or is configured and designed to comply with and/or support the LTE Standard, they
`necessarily include a selecting unit configured to randomly select a sequence from a plurality of
`sequences contained in one group of a plurality of groups, into which a predetermined number of
`
`10
`
`

`

`U.S. Patent No. 8,411,557
`
`Claim
`No.
`
`Claim 1
`
`ACCUSED INSTRUMENTALITIES
`
`different amounts of data or
`reception qualities, wherein
`the predetermined number
`of sequences are grouped by
`partitioning the
`predetermined number of
`sequences, in which
`sequences generated from
`the same base sequence and
`having different cyclic
`shifts are arranged in an
`increasing order of the
`cyclic shifts; and
`
`
`
`sequences that are generated from a plurality of base sequences are grouped and which are
`respectively associated with different amounts of data or reception qualities, wherein the
`predetermined number of sequences are grouped by partitioning the predetermined number of
`sequences, in which sequences generated from the same base sequence and having different cyclic
`shifts are arranged in an increasing order of the cyclic shifts.
`
`As further example and without limitation, the LTE Standard requires a selecting unit configured to
`randomly select a sequence from a plurality of sequences contained in one group of a plurality of
`groups, into which a predetermined number of sequences that are generated from a plurality of base
`sequences are grouped and which are respectively associated with different amounts of data or
`reception qualities:
`
`Contention based random access procedure
`10.1.5.1
`The contention based random access procedure is outlined on Figure 10.1.5.1-1 below:
`
`
`
`11
`
`

`

`U.S. Patent No. 8,411,557
`
`Claim
`No.
`
`Claim 1
`
`ACCUSED INSTRUMENTALITIES
`
`Figure 10.1.5.1-1: Contention based Random Access Procedure
`
`The four steps of the contention based random access procedures are:
`
`1) Random Access Preamble on RACH in uplink:
`
`- There are two possible groups defined and one is optional. If both groups are configured the size of message
`3 and the pathloss are used to determine which group a preamble is selected from. The group to which a
`preamble belongs provides an indication of the size of the message 3 and the radio conditions at the UE. The
`preamble group information along with the necessary thresholds are broadcast on system information.
`(Source: 3GPP TS 36.300 V8.8.0 (2009-03) at § 10.1.5.1) and all subsequent versions.
`5.1
`Random Access procedure
`5.1.1
`Random Access Procedure initialization
`The Random Access procedure described in this subclause is initiated by a PDCCH order or by the MAC sublayer
`itself. If a UE receives a PDCCH transmission consistent with a PDCCH order [5] masked with its C-RNTI, it shall
`initiate a Random Access procedure. The PDCCH order or RRC optionally indicate ra-PreambleIndex and ra-PRACH-
`MaskIndex.
`
`Before the procedure can be initiated, the following information is assumed to be available [8]:
`
`-
`
`-
`
`the available set of PRACH resources for the transmission of the Random Access Preamble, prach-ConfigIndex.
`
`the groups of Random Access Preambles and the set of available Random Access Preambles in each group:
`
` The preambles that are contained in Random Access Preambles group A and Random Access Preambles group B
`are calculated from the parameters numberOfRA-Preambles and sizeOfRA-PreamblesGroupA:
`
`
`
`If sizeOfRA-PreamblesGroupA is equal to numberOfRA-Preambles then there is no Random Access Preambles
`group B. The preambles in Random Access Preamble group A are the preambles 0 to sizeOfRA-
`PreamblesGroupA – 1 and, if it exists, the preambles in Random Access Preamble group B are the preambles
`sizeOfRA-PreamblesGroupA to numberOfRA-Preambles – 1 from the set of 64 preambles as defined in [7].
`
`-
`
`if Random Access Preambles group B exists, the thresholds, messagePowerOffsetGroupB and
`messageSizeGroupA, the configured UE transmitted power, PCMAX [10], and the offset between the preamble and
`
`12
`
`

`

`U.S. Patent No. 8,411,557
`
`Claim
`No.
`
`Claim 1
`
`ACCUSED INSTRUMENTALITIES
`
`Msg3, deltaPreambleMsg3, that are required for selecting one of the two groups of Random Access Preambles.
`
`the RA response window size ra-ResponseWindowSize.
`-
`(Source: 3GPP TS 36.321 V8.7.0 (2009-09) at § 5.1.1) and all subsequent versions.
`
`5.1.2
`
`Random Access Resource selection
`
`The Random Access Resource selection procedure shall be performed as follows:
`
`-
`
`If ra-PreambleIndex (Random Access Preamble) and ra-PRACH-MaskIndex (PRACH Mask Index) have been
`explicitly signalled and ra-PreambleIndex is not 000000:
`
`-
`
`the Random Access Preamble and the PRACH Mask Index are those explicitly signalled.
`
`- else the Random Access Preamble shall be selected by the UE as follows:
`
`-
`
`If Msg3 has not yet been transmitted, the UE shall:
`
`-
`
`if Random Access Preambles group B exists and if the potential message size (data available for
`transmission plus MAC header and, where required, MAC control elements) is greater than
`messageSizeGroupA and if the pathloss is less than PCMAX – preambleInitialReceivedTargetPower –
`deltaPreambleMsg3 – messagePowerOffsetGroupB, then:
`
`-
`
`select the Random Access Preambles group B;
`
`- else:
`
`-
`
`select the Random Access Preambles group A.
`
`- else, if Msg3 is being retransmitted, the UE shall:
`
`-
`
`select the same group of Random Access Preambles as was used for the preamble transmission attempt
`corresponding to the first transmission of Msg3.
`
`-
`
`randomly select a Random Access Preamble within the selected group. The random function shall be such
`that each of the allowed selections can be chosen with equal probability;
`(Source: 3GPP TS 36.321 V8.7.0 (2009-09) at § 5.1.2) and all subsequent versions.
`
`13
`
`

`

`U.S. Patent No. 8,411,557
`
`Claim
`No.
`
`Claim 1
`
`ACCUSED INSTRUMENTALITIES
`
`For further example, in the Accused Instrumentalities, the amounts of data or reception qualities
`that are associated with group A are different than the respective amounts of data or reception
`qualities that are associated with the other groups, e.g., group B. For example, group A has a
`different message 3 size associated with it than the other groups, e.g., group B.
`
`As further example and without limitation, the LTE Standard requires a plurality of groups, into
`which a predetermined number of sequences that are generated from a plurality of base sequences
`are grouped and which are respectively associated with different amounts of data or reception
`qualities, wherein the predetermined number of sequences are grouped by partitioning the
`predetermined number of sequences, in which sequences generated from the same base sequence
`and having different cyclic shifts are arranged in an increasing order of the cyclic shifts.
`
`5.7.2 Preamble sequence generation
`The random access preambles are generated from Zadoff-Chu sequences with zero correlation zone, generated from one
`or several root Zadoff-Chu sequences. The network configures the set of preamble sequences the UE is allowed to use.
`
`There are 64 preambles available in each cell. The set of 64 preamble sequences in a cell is found by including first, in
`the order of increasing cyclic shift, all the available cyclic shifts of a root Zadoff-Chu sequence with the logical index
`RACH_ROOT_SEQUENCE, where RACH_ROOT_SEQUENCE is broadcasted as part of the System Information.
`Additional preamble sequences, in case 64 preambles cannot be generated from a single root Zadoff-Chu sequence, are
`obtained from the root sequences with the consecutive logical indexes until all the 64 sequences are found. The logical
`root sequence order is cyclic: the logical index 0 is consecutive to 837. The relation between a logical root sequence
`index and physical root sequence index u is given by Tables 5.7.2-4 and 5.7.2-5 for preamble formats 0 – 3 and 4,
`respectively.
`(Source: 3GPP TS 36.211 V8.2.0 (2008-03) at § 5.7.2) and all subsequent versions.
`
`Radio resource control information elements
`
`6.3.2
`[…]
`RACH-ConfigCommon
`–
`The IE RACH-ConfigCommon is used to specify the generic random access parameters.
`
`14
`
`

`

`U.S. Patent No. 8,411,557
`
`Claim
`No.
`
`Claim 1
`
`ACCUSED INSTRUMENTALITIES
`
`RACH-ConfigCommon information element
`
`-- ASN1START
`
`SEQUENCE {
`
`RACH-ConfigCommon ::=
`
`
`
`
`
`preambleInfo
`
`
`
`numberOfRA-Preambles
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`preamblesGroupAConfig
`
`
`
`
`
`sizeOfRA-PreamblesGroupA
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`messageSizeGroupA
`
`
`
`
`
`messagePowerOffsetGroupB
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`...
`
`
`}
`
`
`OPTIONAL
`
`
`
`},
`[…]
`
`SEQUENCE {
`
`ENUMERATED {
`
`
`n4, n8, n12, n16 ,n20, n24, n28,
`
`
`n32, n36, n40, n44, n48, n52, n56,
`
`
`n60, n64},
`
`SEQUENCE {
`
`
`ENUMERATED {
`
`
`
`n4, n8, n12, n16 ,n20, n24, n28,
`
`
`
`n32, n36, n40, n44, n48, n52, n56,
`
`
`
`n60},
`
`
`ENUMERATED {b56, b144, b208, b256},
`
`
`ENUMERATED {
`
`
`
`minusinfinity, dB0, dB5, dB8, dB10, dB12,
`
`
`
`dB15, dB18},
`
`
`
`
`
`
`
`
`
`
`-- Need OP
`
`
`
`
`
`RACH-ConfigCommon field descriptions
`
`numberOfRA-Preambles
`Number of non-dedicated random access preambles in TS 36.321 [6]. Value is an integer. Value n4 corresponds to 4,
`n8 corresponds to 8 and so on.
`preamblesGroupAConfig
`Provides the configuration for preamble grouping in TS 36.321 [6]. If the field is not signalled, the size of the random
`access preambles group A [6] is equal to numberOfRA-Preambles.
`sizeOfRA-PreamblesGroupA
`Size of the random access preambles group A in TS 36.321 [6]. Value is an integer. Value n4 corresponds to 4, n8
`corresponds to 8 and so on.
`messageSizeGroupA
`Threshold for preamble selection in TS 36.321 [6]. Value in bits. Value b56 corresponds to 56 bits, b144 corresponds
`to 144 bits and so on.
`messagePowerOffsetGroupB
`Threshold for preamble selection in TS 36.321 [6]. Value in dB. Value minusinfinity corresponds to –infinity. Value dB0
`corresponds to 0 dB, dB5 corresponds to 5 dB and so on.
`(Source: 3GPP TS 36.331 V8.7.0 (2009-09) at § 6.3.2) and all subsequent versions.
`
`15
`
`

`

`U.S. Patent No. 8,411,557
`
`Claim
`No.
`
`Claim 1
`
`1.3
`
`a transmitting unit
`configured to transmit the
`selected sequence,
`
`
`
`ACCUSED INSTRUMENTALITIES
`
`In the Accused Instrumentalities, base Zadoff Chu sequences are cyclically shifted by a set amount
`to derive additional sequences defined by cyclic shift values, the resulting sequences are then
`arranged in increasing order and joined with the other base sequences and their respective
`sequences defined by cyclic shift values. The base code sequences in U.S. Patent No. 8,411,557 are
`used to derive multiple sequences based on cyclic shifts, which are arranged in a structure such as
`shown in figures 4, 5, 6, 8, and 9, in increasing order, the same way as the accused instrumentalities.
`The sequences are partitioned into groups, such that at least one group contains all of the sequences
`derived from at least one base sequence, in the structures shown, e.g, at U.S. Patent No. 8,411,557
`Figure 9 and the accompanying text.
`
`To the extent that Apple claims that these elements are not met literally, the Accused
`Instrumentalities perform substantially the same function of associating reception qualities or
`amounts of data with groups comprised of sequences associated with cyclic shift values, in
`substantially the same way, by associating each group of sequences with differing reception
`qualities or amounts of data, to achieve substantially the same result, which is that the sequences in
`each group are associated with reception qualities or amounts of data, so that when a sequence is
`randomly selected from a group, it is known to be associated with certain reception qualities or
`amounts of data by virtue of which group it was selected from.
`
`PanOptis reserves the right to add additional information and infringement theories once discovery
`begins in this case, particularly once Apple produces its technical documents (including, but not
`limited to, source code).
`The Accused Instrumentalities include a transmitting unit configured to transmit the selected
`sequence.
`
`For example, and without limitation, because each of the Accused Instrumentalities is compliant
`with or is configured and designed to comply with and/or support the LTE Standard, they
`necessarily include a transmitting unit configured to transmit the selected sequence.
`
`
`16
`
`

`

`U.S. Patent No. 8,411,557
`
`Claim
`No.
`
`Claim 1
`
`ACCUSED INSTRUMENTALITIES
`
`As further example and without limitation, the LTE Standard requires that a transmitting unit be
`configured to transmit the selected sequence:
`
`5.1.3 Random Access Preamble transmission
`The random-access procedure shall be performed as follows:
`
`-
`
`set PREAMBLE_RECEIVED_TARGET_POWER to preambleInitialReceivedTargetPower +
`DELTA_PREAMBLE + (PREAMBLE_TRANSMISSION_COUNTER – 1) * powerRampingStep;
`
`-
`
`instruct the physical layer to transmit a preamble using the selected PRACH, corresponding RA-RNTI, preamble
`index and PREAMBLE_RECEIVED_TARGET_POWER.
`(Source: 3GPP TS 36.321 V8.7.0 (2009-09) at § 5.1.3) and all subsequent versions.
`
`Contention based random access procedure
`10.1.5.1
`The contention based random access procedure is outlined on Figure 10.1.5.1-1 below:
`
`17
`
`

`

`U.S. Patent No. 8,411,557
`
`Claim
`No.
`
`Claim 1
`
`ACCUSED INSTRUMENTALITIES
`
`
`Figure 10.1.5.1-1: Contention based Random Access Procedure
`
`The four steps of the contention based random access procedures are:
`
`1) Random Access Preamble on RACH in uplink:
`
`- There are two possible groups defined and one is optional. If both groups are configured the size of message
`3 and the pathloss are used to determine which group a preamble is selected from. The group to which a
`preamble belongs provides an indication of the size of the message 3 and the radio conditions at the UE. The
`preamble group information along with the necessary thresholds are broadcast on system information.
`(Source: 3GPP TS 36.300 V8.8.0 (2009-03) at § 10.1.5.1) and all subsequent versions.
`6.1 Physical non-synchronized random access procedure
`From the physical layer perspective, the L1 random access procedure encompasses the transmission of random access
`preamble and random access response. The remaining messages are scheduled for transmission by the higher layer on
`the shared data channel and are not considered part of the L1 random access procedure. A random access channel
`
`18
`
`

`

`U.S. Patent No. 8,411,557
`
`Claim
`No.
`
`Claim 1
`
`ACCUSED INSTRUMENTALITIES
`
`occupies 6 resource blocks in a subframe or set of consecutive subframes reserved for random access preamble
`transmissions. The eNodeB is not prohibited from scheduling data in the resource blocks reserved for random access
`channel preamble transmission.
`
`The following steps are required for the L1 random access procedure:
`
`1. Layer 1 procedure is triggered upon request of a preamble transmission by higher layers.
`
`2. A preamble index, a target preamble received power (PREAMBLE_RECEIVED_TARGET_POWER), a
`corresponding RA-RNTI and a PRACH resource are indicated by higher layers as part of the request.
`
`3. A preamble transmission power PPRACH is determined as
`PPRACH = min{ CMAXP
`, PREAMBLE_RECEIVED_TARGET_POWER + PL}_[dBm], where CMAXP
` is the
`configured UE transmitted power defined in [6] and PL is the downlink pathloss estimate calculated in the UE.
`
`4. A preamble sequence is selected from the preamble sequence set using the preamble index.
`
`5. A single preamble is transmitted using the selected preamble sequence with transmission power PPRACH on the
`indicated PRACH resource.
`
`6. Detection of a PDCCH with the indicated RA-RNTI is attempted during a window controlled by higher layers
`(see [8], clause 5.1.4). If detected, the corresponding PDSCH transport block is passed to higher layers. The
`higher layers parse the transport block and indicate the 20-bit UL-SCH grant to the physical layer, which is
`processed according to section 6.2.
`(Source: 3GPP TS 36.213 V8.6.0 (2009-03) at § 6.1) and all subsequent versions.
`5.8 Modulation and upconversion
`Modulation and upconversion to the carrier frequency of the complex-valued SC-FDMA baseband signal for each
`antenna port is shown in Figure 5.8-1. The filtering required prior to transmission is defined by the requirements in [6].
`
`
`19
`
`

`

`U.S. Patent No. 8,411,557
`
`Claim
`No.
`
`Claim 1
`
`ACCUSED INSTRUMENTALITIES
`
`
`(cid:11) (cid:12)tf02
`cos (cid:83)
`
`Re
`
`(cid:96))(
`(cid:94)
`tsl
`
`(cid:96))(
`(cid:94)
`Im tsl
`
`)(tsl
`
`(cid:16)
`
`
`(cid:11) (cid:12)tf02
`sin (cid:83)
`
`Figure 5.8-1: Uplink modulation.
`
`
`
`(Source: 3GPP TS 36.211 V8.2.0 (2008-03) at § 5.8) and all subsequent versions.
`
`PanOptis reserves the right to add additional information and infringement theories once discovery
`begins in this case, particularly once Apple produces its technical documents (including, but not
`limited to, source code).
`The Accused Instrumentalities comprise the configuration wherein a position at which the
`predetermined number of sequences are partitioned is determined based on the control information,
`and a number of sequences c