BNR’S INFRINGEMENT CONTENTIONS
`
`Asserted Claims
`
`Samsung Galaxy $101
`
`Exhibit C - Infringement of US. Patent No. 8,416,862
`
`9. A wireless communication device
`comprising:
`
`To the extent that the preamble is found to be limiting, the Samsung Galaxy S l 0 is a wireless
`communication device.
`
`
`
`1Device images presented in Exhibit C are images of LG’s Samsung Galaxy 810. The features presented in those images are
`substantially similar in all material reSpects to the analogous features of the other devices accused of infringing the United States Patent No.
`
`
`
`Asserted Claims
`
`Samsung Galaxy $101
`
`Exhibit C - Infringement of US. Patent No. 8,416,862
`
`9. A wireless communication device
`comprising:
`
`To the extent that the preamble is found to be limiting, the Samsung Galaxy S l 0 is a wireless
`communication device.
`
`
`
`1Device images presented in Exhibit C are images of LG’s Samsung Galaxy 810. The features presented in those images are
`substantially similar in all material reSpects to the analogous features of the other devices accused of infringing the United States Patent No.
`
`
`
`BNR’S INFRINGEMENT CONTENTIONS
`
`[i] a plurality of Radio Frequency
`(RF) components operable to receive
`an RF signal and to convert the RF
`signal to a baseband signal; and
`
`Exhibit C - Infringement of US. Patent No. 8,416,862
`
`The Samsung Galaxy $10 includes a plurality of Radio Frequency (RF) components operable to
`receive an RF signal and to convert the RF signal to a baseband signal.
`
`The Samsung Galaxy $10 complies with the 802.1 lac standard (“Part 1 1: Wireless LAN Medium,
`Access Control (MAC) and Physical Layer (PHY) Specifications”).
`
`g9?3uzbaxaar’#specs, last accessed January 14, 2020.
`
`
`Connecfivfly
`
`wrn
`
`802.11 a.--'b,-"g.-"n..-"acfax 2116450112,
`
`HE80, M|M0,1OZd-QAM
`
`See http_s:fi’www.samsungcomi’usr’mobilefphonesfgalaxy-sfgalaxy-s l 0- l28gb-unlocked-sm-
`g973uzbaxaaf#specs, last accessed January 14, 2020.
`
`As shown below, the Samsung Galaxy SlO supports beamformee capabilities and therefore must
`comply with the beamforming sections of the 802.1 lac, which includes beamforming related
`features of Clause 19 and Clause 21.
`
`Connectivity
`
`Wi-Fi
`
`802.11 a.--'b.-"g.-'n,-"ac.-"ax 2.46-SGH2.
`
`HE80. MIMO, 1024-QAM
`
`See https:h’www.samsungcoms’usfmobilefphonesi’galaxy-si’galaxy-s10-lZSgb-unlocked-sm-
`
`
`
`BNR’S INFRINGEMENT CONTENTIONS
`
`Exhibit C — Infringement of US. Patent No. 8,416,862
`
`[ii] a baseband processing module
`operable to:
`
`The Samsung Galaxy $10 includes a baseband processing module.
`
`HE80,MIMO,1024-QAM
`
`Connectivity
`
`wi-Fi fl
`
`802.11 arbr'gi’nr'acfax 2.21956 Hz,
`
`[ii][a] receive a preamble sequence
`carried by the baseband signal
`
`The baseband processing module in the Samsung Galaxy $10 is operable to receive a preamble
`sequence carried by the baseband signal. First, the Samsung Galaxy SlO complies with the
`802.1 lac standard (“Part 11: Wireless LAN Medium, Access Control (MAC) and Physical Layer
`(PHY) Specifications”).
`
`The Samsung Galaxy SlO complies with the 802.1 lac standard (“Part 11: Wireless LAN Medium,
`Access Control (MAC) and Physical Layer (PHY) Specifications”).
`
`
`
`BNR’S INFRINGEMENT CONTENTIONS
`
`Exhibit C - Infringement of US. Patent No. 8,416,862
`
`See httpsn’fwww.samsung.comfusr’mobilefphonesr’galaxy-sr’galaxy-sl0-128gb-unlocked-sm-
`g973uzbaxaaf#specs, last accessed January 14, 2020.
`
`As shown below, the Samsung Galaxy SlO supports beamformee capabilities and therefore must
`comply with the beamforming sections of the 802.1 lac, which includes beamforming related
`features of Clause 19 and Clause 2].
`
`Connectivity
`
`Wi-Fi
`
`802.113. b-"g.-'n.-’ac.-'ax 2.36-56Hz,
`
`HESO,t-.-‘lltv10,10221-Q.:\t-J.
`
`See httpsn’fwww.samsung.comfusr’mobilefphonesr’galaxy-sr’galaxy-sl0-128gb-unlocked-sm-
`g973uzbaxaaf#specs, last accessed January 14, 2020.
`
`Any device that complies with the 802.1 lac standard must be capable of receiving a preamble
`sequence carried by the baseband signal.
`
`21.3.8 VHT preamble
`21.3.8.1 Introduction
`
`A VHT preamble is defined to carry the required information to operate in either single user
`or multi-user mode. To maintain compatibility with non-VHT STAs, specific non-VHT
`fields are defined that can be received by non-VHT STAs compliant with Clause 17 or
`Clause 19. The non-VHT fields are followed by VHT fields specific to VHT STAs.
`
`See 802.11-2016 (p. 2538).
`
`21.3.ll.2 Beamforming Feedback Matrix V
`Upon receipt of a VHT NDP sounding PPDU, the beamformee shall remove the space-time
`stream CSD in Table 21-l1 from the measured channel before computing a set of matrices
`
`
`
`
`
`
`
`
`
`BNR’S INFRINGEMENT CONTENTIONS
`
`Exhibit C - Infringement of U.S. Patent No. 8,416,862
`
`beamformee u for subcarrier It shall be compressed in the form of angles using the method
`described in 19.3. 12.3.6. The angles, effigy) and tb(k,u), are quantized according to Table 9-
`68. The number of bits for quantization is chosen by the beamformee, based on the
`indication from the beamformer as to whether the feedback is requested for SU-MIMO
`beamforming or DLMU-MIMO beamforming. The compressed beamforming feedback
`using 19.3.12.3.6 is the only Clause 21 beamforming feedback format defined.
`
`See 802.11-2016 (p. 2579).
`
`21.3.12 VHT preamble format for sounding PPDUs
`NDP is the only VHT sounding format.
`
`The format ofa VHT NDP PPDU is shown in Figure 21-28.
`
`8us
`
`Bus
`
`4us
`
`Bus
`
`4us zlusperVI-l'l'i'l'Fsynbol
`
`4us
`
`m L
`
`—
`
`VHT—
`
`VHT-
`m a...
`
`m...
`
`Figure 21-28—VHT NDP format
`
`[ii][b] estimate a channel response
`based upon the preamble sequence
`
`When the Samsung Galaxy 510 receives a preamble sequence, the baseband processing module is
`operable to estimate a channel response based upon the preamble sequence.
`
`See 80211-2016 0. 2580 .
`
`21.3.8 VHT preamble
`21.3.8.1 Introduction
`
`A VHT preamble is defined to carry the required information to operate in either single user
`or multi-user mode. To maintain compatibility with non-VHT STAs, specific non-VHT
`fields are defined that can be received by non-VHT STAs compliant with Clause 1? or
`Clause 19. The non-VHT fields are followed by VHT fields specific to VHT STAs.
`
`
`
`BNR’S INFRINGEMENT CONTENTIONS
`
`Exhibit C - Infringement of U.S. Patent No. 8,416,862
`
`21.3.11.2 Beamforming Feedback Matrix V
`Upon receipt of a VHT NDP sounding PPDU, the beamformee shall remove the space-time
`stream CSD in Table 21-11 from the measured channel before computing a set of matrices
`for feedback to the beamformer. The beamforming feedback matrix, Va", found by the
`beamformee u for subcarrier It shall be compressed in the form of angles using the method
`described in 19.3.12.3.6. The angles, 9015,11) and tb(k,u), are quantized according to Table 9-
`68. The number of bits for quantization is chosen by the beamformee, based on the
`indication from the beamformer as to whether the feedback is requested for SU-MIMO
`beamforming or DLMU-MIMO beamforming. The compressed beamforming feedback
`using 19.3.l2.3.6 is the only Clause 21 beamforming feedback format defined.
`
`Sbe802Jl-2016(p.2579)
`
`19.3.12 Beamforming
`
`19.3.12.3.6 Compressed beamforming feedback matrix
`
`In compressed beamforming feedback matrix, the beamformee shall remove the space-time
`stream CSD in Table 19-10 from the measured channel before computing a set of matrices for
`feedback to the beamformer. The beamforming feedback matrices, Vflc), found by the
`beamformee are compressed in the form of angles, which are sent to the beamformer. The
`beamfonner might use these angles to decompress the matrices and determine the steering
`matrices Qt.
`
`See 8
`
`02Jl-2016(p.2398)
`
`21.3.8 VHT preamble
`21.3.8.1 Introduction
`
`A VHT preamble is defined to carry the required information to operate in either single user
`or multi-user mode. To maintain compatibility with non-VHT STAs, specific non-VHT
`
`
`
`
`
`
`
`BNR’S INFRINGEMENT CONTENTIONS
`
`Exhibit C — Infringement of U.S. Patent No. 8,416,862
`
`See 802.11-2016 (p. 2538).
`
`21.3.12 VHT preamble format for sounding PPDUs
`NDP is the only VHT sounding format.
`
`The format ofa VHT NDP PPDU is shown in Figure 21-28.
`
`Bus
`
`Bus
`
`4ps
`
`Bus
`
`4us 4psperVHT-LTFsynbol
`
`WEE—HIM
`L-
`VHT-
`
`Figure 21 ~28—VHT NDP format
`
`See 802.11-2016 (p. 2400).
`
`See 802.11-2016 (p. 2580).
`
`19.3.13 HT Preamble format for sounding PPDUs
`
`193.13.] General
`
`The MIMO channel measurement takes place in every PPDU as a result of transmitting the
`HT-LTFS as part of the PHY preamble. The number of HT-LTFS transmitted shall be
`determined by the number of space-time streams transmitted unless additional dimensions are
`optionally sounded using HT-ELTFs and these are transmitted using the same spatial
`transformation that is used for the Data field of the HT PPDU. The use of the same spatial
`transformation enables the computation of the spatial equalization at the receiver
`
`
`
`BNR’S INFRINGEMENT CONTENTIONS
`
`Exhibit C — Infringement of U.S. Patent No. 8,416,862
`
`[ii][c] determine an estimated
`transmitter beamforming unitary
`matrix (V) based upon the channel
`response and a receiver beamforming
`unitary matrix (U);
`
`The baseband processing module of the Samsung Galaxy $10 is operable to determine an estimated
`transmitter beamforming unitary matrix (V) based upon the channel response and a receiver
`beamforming unitary matrix (U).
`
`21.1.] Introduction to the VHT PHY
`Clause 21 specifies the PHY entity for a very high throughput (VHT) orthogonal frequency
`division multiplexing (OFDM) system.
`In addition to the requirements in Clause 21, a VHT STA shall be capable of transmitting and
`receiving PDUs that are compliant with the mandatory PHY specifications defined in Clause
`19.
`
`A VHT STA may support the following features:
`
`— Responding to transmit beamforming sounding (by providing compressed beamforming
`feedback)
`
`19.3.12.3.6 Compressed beamforming feedback matrix
`
`See 80211-2016 (p. 2497).
`
`19.3.12 Beamforming
`19.3.12.l General
`
`Beamforming is a technique in which the beamformer utilizes the knowledge of the MIMO
`channel to generate a steering matrix Q}; that improves reception in the beamformee.
`
`The beamfonning steering matrix that is computed (or updated) from a new channel
`measurement replaces the existing Q}: for the next beamformed data transmission. There are
`several methods of beamforming, differing in the way the beamformer acquires the
`knowledge of the channel matrices Hk and on whether the beamformer generates Qk or the
`beamformee provides feedback information for the beamformer to generate Qk.
`
`See 80211-2016 (p. 2392-93).
`
`
`
`BNR’S INFRINGEMENT CONTENTIONS
`
`Exhibit C - Infringement of US. Patent No. 8,416,862
`
`In compressed beamforming feedback matrix, the beamformee shall remove the space-time
`stream CSD in Table 19-10 from the measured channel before computing a set of matrices for
`feedback to the beamformer. The beamforming feedback matrices, Wk), found by the
`beamformee are compressed in the form of angles, which are sent to the beamformer. The
`beamfonner might use these angles to decompress the matrices and determine the steering
`matrices Qk.
`
`See 802.11-2016 (p. 2398).
`
`Eqn. 19-29 relates matrix V to beamforming information. The estimated transmitter beamforming
`matrix can be constructed using captured beamforming information and Equation (19-79).
`
`On information and belief, the Samsung Galaxy 810 uses singular value decomposition to
`determine the estimated transmitter beamforming unitary matrix:
`
`13 Transmit Beamforming
`The 802.1 In standard does not dictate a specific approach for determining the transmitter
`weighting matrix. However, the most common approach is using singular value decomposition
`to calculate the transmitter weights.
`
`See Eldad Perahia & Robert Stacey, Next Generation Wireless LANs: 802.11n and 802.1 lac, 2d ed
`(USA: Cambridge University Press, 2013) (p. 366)
`
`13.2 Transmit Beamforming with SVD
`The motivation behind using the matrix V calculated by SVD is that it results in maximum
`likelihood performance with a linear receiver, greatly simplifying receiver design...
`
`See Eldad Perahia & Robert Stacey, Next Generation Wireless LANs: 802.1111 and 802.1 lac, 2d ed
`(USA: Cambridge University Press, 2013) (p. 369)
`
`
`
`
`
`
`
`BNR’S INFRINGEMENT CONTENTIONS
`
`Exhibit C - Infringement of U.S. Patent No. 8,416,862
`
`[ii][d] decompose the estimated
`transmitter beamforming unitary
`matrix (V) to produce the transmitter
`beamforming information; and
`
`The baseband processing module of the Samsung Galaxy S 10 is operable to decompose the
`estimated transmitter beamforming unitary matrix to produce the transmitter beamforming
`information.
`
`21.3.11.2 Beamforming Feedback Matrix V
`Upon receipt of a VHT NDP sounding PPDU, the beamformee shall remove the space-time
`stream CSD in Table 21-11 from the measured channel before computing a set of matrices
`for feedback to the beamformer. The beamforming feedback matrix, Va”, found by the
`beamformee u for subcarrier It shall be compressed in the form of angles using the method
`described in 19.3.12.3.6. The angles, ¢(k,u) and tpflcu), are quantized according to Table 9~
`68. The number of bits for quantization is chosen by the beamformee, based on the
`indication from the beamformer as to whether the feedback is requested for SU-MIMO
`beamforming or DLMU-MIMO beamforming. The compressed beamforming feedback
`using l9.3.12.3.6 is the only Clause 21 beamforming feedback format defined.
`
`matrix becomes a unitary matrix.
`
`See 802.11-2016 (p. 2579).
`
`l9.3.12.3.6 Compressed beamforming feedback matrix
`
`In compressed beamforming feedback matrix, the beamformee shall remove the space-time
`stream CSD in Table 19-10 from the measured channel before computing a set of matrices for
`feedback to the beamformer. The beamforming feedback matrices, V(k), found by the
`beamformee are compressed in the form of angles, which are sent to the beamformer. The
`beamformer might use these angles to decompress the matrices and determine the steering
`matrices Qk.
`
`The matrix Vper tone shall be compressed as follows: The Mac Nc beamforming feedback
`orthonormal column matrix Vfound by the beamformee shall be represented as shown in
`Equation (19-79). When the number of rows and columns is equal, the orthonormal column
`
`
`
`BNR’S INFRINGEMENT CONTENTIONS
`
`Exhibit C - Infringement of U.S. Patent No. 8,416,862
`
` 0
`
`I
`
`(“U31 511111131 0 0
`
`x 4011121 “W11 0 0
`010
`
`x
`
`I
`
`1'
`
`town 0 511114131 0
`I)
`l
`0
`I)"
`—5innr310cosur310
`o
`o
`o
`1
`
`rosy“ O 0 stunt,“
`0
`ll]
`I]
`0
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`0
`-sinmi°°cosmi
`
`1'
`
`D
`
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`
`1000
`
`I
`
`0 -5‘l|1Wfl C03|¥33 0
`1
`
`‘mecflsmwu K
`0
`l
`0
`
`0-smw430cosufl
`
`[ii][e] form a baseband signal
`employed by the plurality of RF
`components to wirelessly send the
`transmitter beamforming information
`to the transmitting wireless device.
`
`See 802.11-2016 (p. 2398-99).
`
`The baseband processing module of the Samsung Galaxy $10 is operable to form a baseband signal
`employed by the plurality of RF components to wirelessly send the transmitter beamforming
`information to the transmitting wireless device.
`
`19.3.12.3.6 Compressed beamforming feedback matrix
`
`In compressed beamforming feedback matrix, the beamformee shall remove the space-time
`stream CSD in Table 19-10 from the measured channel before computing a set of matrices for
`feedback to the beamformer. The beamfonning feedback matrices, Wk), found by the
`beamformee are compressed in the form of angles, which are sent to the beamformer. The
`beamformer might use these angles to decompress the matrices and determine the steering
`matrices Qk.
`
`The matrix Vper tone shall be compressed as follows: The er Ne beamforming feedback
`orthonormal column matrix Vfound b the beamformee shall be re resented as shown in
`
`
`
`
`
`BNR’S INFRINGEMENT CONTENTIONS
`
`Exhibit C - Infringement of U.S. Patent No. 8,416,862
`
`Equation (19-79). When the number of rows and columns is equal, the orthonormal column
`matrix becomes a unitary matrix.
`
`See 802.11-2016 (p. 2398).
`
`
`10. The wireless communication
`
`See claim 9.
`
`device of claim 9,
`
`See claim 9[i]-[ii][c].
`
`[i] wherein in determining an
`estimated transmitter beamforming
`unitary matrix (V) based upon the
`channel reSponse and a receiver
`beamforming unitary matrix (U), the
`baseband processing module is
`operable to:
`
`[ii] produce the estimated transmitter
`beamforming unitary matrix (V) in
`Cartesian coordinates; and
`
`(17—20)
`
`The baseband processing module of the Samsung Galaxy 810 is operable to produce the estimated
`transmitter beamforming unitary matrix (V) in Cartesian coordinates.
`
`17.3.5.8 Subcarrier modulation mapping
`
`The OFDM subcarriers shall be modulated by using BPSK, QPSK, lé-QAM, or 64-QAM,
`depending on the RATE requested. The encoded and interleaved binary serial input data shall
`be divided into groups of NBPSC (1, 2, 4, or 6) bits and converted into complex numbers
`representing BPSK, QPSK, lé-QAM, or 64-QAM constellation points. The conversion shall
`be performed according to Gray-coded constellation mappings, illustrated in Figure 1’1-10,
`with the input bit, Bo, being the earliest in the stream. The output values, d, are formed by
`multiplying the resulting (1+jQ) value by a normalization factor KMOD, as described in
`Equation (17-20).
`
`d = (I +jQ) x KMOD
`
`
`
`BNR’S INFRINGEMENT CONTENTIONS
`
`Exhibit C - Infringement of US. Patent No. 8,416,862
`
`
`
`[iii] convert the estimated transmitter
`beamforming unitary matrix (V) to
`polar coordinates.
`
`The baseband processing module of the Samsung Galaxy $10 is operable to convert the estimated
`transmitter beamforming unitary matrix (V) to polar coordinates.
`
`19.3.12.3.6 Compressed beamforming feedback matrix
`
`In compressed beamforming feedback matrix, the beamformee shall remove the space-time
`stream CSD in Table 19-10 from the measured channel before computing a set of matrices for
`feedback to the beamformer. The beamforming feedback matrices, Wk), found by the
`beamformee are compressed in the form of angles, which are sent to the beamformer. The
`beamformer might use these angles to decompress the matrices and determine the steering
`matrices Qk.
`
`The matrix Vper tone shall be compressed as follows: The er Ne beamforming feedback
`orthonormal column matrix Vfound by the beamformee shall be represented as shown in
`Equation (19-79). When the number of rows and columns is equal, the orthonormal column
`matrix becomes a unitary matrix.
`
`See 802.1 1-2016 (p. 2398).
`
`1 l. The wireless communications
`
`See claim 9.
`
`device according to claim 9,
`
`wherein the channel response (H),
`estimated transmitter beamforming
`unitary matrix (V), and the receiver
`beamforming unitary matrix (U) are
`related by the equation:
`
`H=UDV*
`
`The channel response (H), estimated transmitter beamforming unitary matrix (V), and the receiver
`beamforming unitary matrix (U) of the Samsung Galaxy 810 are related by the equation:
`H=UDV*
`where, D is a diagonal matrix.
`
`On information and belief, the Samsung Galaxy 810 uses singular value decomposition:
`
`where, D is a dia_onal matrix.
`
`13 Transmit Beamformin_
`
`
`
`
`
`BNR’S INFRINGEMENT CONTENTIONS
`
`Exhibit C - Infringement of US. Patent No. 8,416,862
`
`The 802.1ln standard does not dictate a specific approach for determining the transmitter
`weighting matrix. However, the most common approach is using singular value decomposition
`to calculate the transmitter weights.
`
`See Eldad Perahia & Robert Stacey, Next Generation Wireless LANs: 802.11n and 802.1 lac, 2d ed
`(USA: Cambridge University Press, 2013) (p. 366)
`
`13.2 Transmit Beamforming with SVD
`The motivation behind using the matrix V calculated by SVD is that it results in maximum
`likelihood performance with a linear receiver, greatly simplifying receiver design...
`
`See Eldad Perahia & Robert Stacey, Next Generation Wireless LANs: 802.1 In and 802.1 lac, 2d
`ed (USA: Cambridge University Press, 2013) (p. 369)
`
`12. The wireless communications
`
`See claim 9.
`
`device according to claim 9,
`
`wherein in determining the estimated
`transmitter beamforming unitary
`matrix (V) based upon the channel
`response and the receiver
`beamforming unitary matrix (U), the
`baseband processing module
`performs Singular Value
`Decomposition (SVD) operations.
`
`When the Samsung Galaxy $10 determines the estimated transmitter beamforming unitary matrix
`(V) based upon the channel response and the receiver beamforming unitary matrix (U), the
`baseband processing module of the Samsung Galaxy 510 performs Singular Value Decomposition
`(SVD) operations.
`
`On information and belief, the Samsung Galaxy 810 uses singular value decomposition:
`
`l3 Transmit Beamforming
`The 802.1 In standard does not dictate a specific approach for determining the transmitter
`weighting matrix. However, the most common approach is using singular value decomposition
`to calculate the transmitter weights.
`
`See Eldad Perahia & Robert Stacey, Next Generation Wireless LANs: 802.11n and 802.1 lac, 2d ed
`(USA: Cambridge University Press, 2013) (p. 366)
`
`
`
`
`
`BNR’S INFRINGEMENT CONTENTIONS
`
`Exhibit C — Infringement of U.S. Patent No. 8,416,862
`
`
`The motivation behind using the matrix V calculated by SVD is that it results in maximum
`likelihood performance with a linear receiver, greatly simplifying receiver design...
`
`See Eldad Perahia & Robert Stacey, Next Generation Wireless LANs: 802.11n and 802.1 lac, 2d
`ed (USA: Cambridge University Press, 2013) (p. 369)
`
`
`
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