`
`Douglas G. Muehlhauser (SBN 179495)
`doug.muehlhauser@knobbe.com
`Payson LeMeilleur (SBN 205690)
`payson.lemeilleur@knobbe.com
`KNOBBE, MARTENS, OLSON & BEAR, LLP
`2040 Main Street, Fourteenth Floor
`Irvine, CA 92614
`Telephone: 949-760-0404
`Facsimile: 949-760-9502
`
`Attorneys for Plaintiff
`ONE-E-WAY, INC.
`
`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE CENTRAL DISTRICT OF CALIFORNIA
`WESTERN DIVISION
` Case No. 2:20-CV-06339-JSK-PD
`ONE-E-WAY, INC., a California
`corporation,
`ONE-E-WAY’S DISCLOSURE
`OF ASSERTED CLAIMS AND
`INFRINGEMENT
`CONTENTIONS AND
`ACCOMPANYING
`DOCUMENTS PURSUANT TO
`S.P.R. 2.1 AND 2.2
`
`v.
`APPLE INC., a California corporation,
`Defendant.
`
`Plaintiff,
`
`
`
`
`
`Hon. John A. Kronstadt
`
`
`
`1 2 3 4 5 6 7 8 9
`
`10
`11
`12
`13
`14
`15
`16
`17
`18
`19
`20
`21
`22
`23
`24
`25
`26
`27
`28
`
`Petitioner's Exhibit 1032
`Page 001
`
`

`

`
`
`Pursuant to this Court’s Standing Patent Rules (“S.P.R.”) 2.1 and 2.2 (Dkt.
`No. 10), Plaintiff One-E-Way, Inc. (“Plaintiff” or “One-E-Way”) hereby provides
`its disclosure of asserted claims and infringement contentions and accompanying
`document production. In view of the limited discovery available to One-E-Way at
`this early stage of the proceeding, One-E-Way reserves the right to amend this
`disclosure in view of any relevant evidence subsequently obtained through
`discovery.
`I. DISCLOSURE OF ASSERTED CLAIMS AND INFRINGEMENT
`CONTENTIONS – S.P.R. 2.1
`A. Asserted Claims – S.P.R. 2.1.1
`Based on currently available information, Plaintiff One-E-Way contends that
`Defendant Apple Inc. (“Defendant” or “Apple”) infringes the following claims of
`U.S. Patent Nos. 8,131,391 (“the ’391 patent”), 10,129,627 (“the ’627 patent”) and
`10,468,047 (“the ’047 patent”) (collectively, “the Asserted Patents”):
`
`
`Asserted Patent
`’391
`’627
`’047
`
`Asserted Claims
`1, 3-6, 10
`1-6, 10-12
`1-6, 8-15, 17-20
`
`
`Each claim in the table above is alleged to be infringed under 35 U.S.C.
`§ 271(a) and (b). These claims are collectively referred to as the “Asserted Claims.”
`One-E-Way reserves the right to amend or supplement this disclosure as information
`becomes available.
`B. Accused Instrumentalities – S.P.R. 2.1.2
`One-E-Way hereby identifies the following Apple products as products that
`practice the Asserted Claims. For all products identified herein, One-E-Way also
`identifies any prior or subsequent commercial iteration of the product if that product
`-1-
`
`1 2 3 4 5 6 7 8 9
`
`10
`11
`12
`13
`14
`15
`16
`17
`18
`19
`20
`21
`22
`23
`24
`25
`26
`27
`28
`
`Petitioner's Exhibit 1032
`Page 002
`
`

`

`
`
`was/is capable of wirelessly transmitting or receiving audio data using Bluetooth
`connectivity in the manner set forth in the S.P.R. 2.1.3 disclosure.
`Apple
`AirPods, AirPods Pro, HomePod, iPhone, iPad, iPod, and Apple Watch.1
`
`Beats
`
`Powerbeats Wireless Earphones, Powerbeats Pro Wireless Earphones,
`Powerbeats3 Wireless Earphones, Beats Solo Pro Wireless Noise Cancelling
`Headphones, Beats Solo3 Wireless Headphones, Beats Studio3 Wireless
`Headphones, BeatsX Wireless Earphones, and Beats Pill+ Portable Speaker.
`C. Claim Charts – S.P.R. 2.1.3
`Attached as Exhibits A-C are claim charts showing where each limitation of
`each of the Asserted Claims is literally present within the accused devices.
`D.
`Priority Date of the Patents-in-Suit – S.P.R. 2.1.4
`Each Asserted Patent claims a priority date of December 21, 2001, the date of
`U.S. Patent Application No. 10/027,391, which is the common original parent
`application to the Asserted Patents.
`The sole named inventor on the Asserted Patents, and the 10/027,391 original
`parent application, is C. Earl Woolfork. Mr. Woolfork conceived of the inventions
`of the Asserted Claims by at least June 25, 1999. The Asserted Claims were
`constructively reduced to practice by at least December 21, 2001, the date upon
`which the 10/027,391 original parent application was filed. Mr. Woolfork was
`diligent towards reducing the Asserted Claims to practice from at least June 25,
`1999, until December 21, 2001, and the Asserted Claims are entitled to priority of
`invention as of at least June 25, 1999.
`/ / /
`
`
`1 Although apparently not yet commercially available, One-E-Way also identifies Apple’s
`AirPods Studio Headphones.
`
`-2-
`
`1 2 3 4 5 6 7 8 9
`
`10
`11
`12
`13
`14
`15
`16
`17
`18
`19
`20
`21
`22
`23
`24
`25
`26
`27
`28
`
`Petitioner's Exhibit 1032
`Page 003
`
`

`

`
`
`E.
`
`A.
`
`Practicing the Claimed Invention – S.P.R. 2.1.5
`One-E-Way does not intend to rely on its own products practicing any of the
`Asserted Claims to prove infringement.
`F. Willful Infringement – S.P.R. 2.1.6
`Based on the limited discovery available to One-E-Way at this early stage of
`the proceedings, One-E-Way does not allege willful infringement at this time.
`II. ACCOMPANYING DOCUMENT PRODUCTION – S.P.R. 2.2
`File Histories of the Asserted Patents – S.P.R. 2.2.1
`One-E-Way has produced the file histories of the Asserted Patents, along with
`the file histories of the other patents in the chain of priority of the Asserted Patents,
`at OEW_APPLE-0000086-0008878.
`B. Documents Evidencing Ownership – S.P.R. 2.2.2
`One-E-Way has produced documents evidencing ownership of the Asserted
`Patents at OEW_APPLE-0008879-8940.
`C. Documents Supporting Practicing the Claimed Invention – S.P.R. 2.2.3
`For the reasons stated in Section I.E above, One-E-Way has not produced any
`documents pursuant to S.P.R. 2.2.3.
`
`
`KNOBBE, MARTENS, OLSON & BEAR, LLP
`
`Dated: September 15, 2020 /s/ Douglas G. Muehlhauser
`Douglas G. Muehlhauser
`Payson LeMeilleur
`
`Attorneys for Plaintiff
`ONE-E-WAY, INC.
`
`
`
`-3-
`
`1 2 3 4 5 6 7 8 9
`
`10
`11
`12
`13
`14
`15
`16
`17
`18
`19
`20
`21
`22
`23
`24
`25
`26
`27
`28
`
`Petitioner's Exhibit 1032
`Page 004
`
`

`

`Exhibit A
`
`One-E-Way’s S.P.R. 2.1.3 Asserted Claim Chart For The ’391 Patent
`
`One-E-Way hereby provides its S.P.R. 2.1.3 Asserted Claim Chart for One-E-Way’s U.S.
`
`Patent No. 8,131,391. The claims of the ’391 patent identified herein are claims 1, 3-6 and 10.
`
`As used herein, “Accused Receiver Device” includes any of the following individual
`
`devices: Apple’s AirPods, AirPods Pro and HomePod, and Apple’s Powerbeats Wireless
`
`Earphones, Powerbeats Pro Wireless Earphones, Powerbeats3 Wireless Earphones, Beats Solo Pro
`
`Wireless Noise Cancelling Headphones, Beats Solo3 Wireless Headphones, Beats Studio3 Wireless
`
`Headphones, BeatsX Wireless Earphones, and Beats Pill+ Portable Speaker.1 Although not
`
`commercially available yet, One-E-Way expects, upon information and belief, that Apple’s
`
`AirPods Studio Headphones will satisfy the same claims, in the same manner, as the Accused
`
`Receiver Devices discussed below.
`
`As used herein, “Accused Transmitter Device” includes any of the following individual
`
`devices: Apple’s iPhone, iPad, iPod and Apple Watch.
`
`The following chart provides exemplary evidence of infringement. Additionally, for
`
`simplicity, One-E-Way relies on citations to Bluetooth specification 5.0. However, because of the
`
`backwards-compatibility of Bluetooth back to Bluetooth version 2.1, each citation to Bluetooth
`
`5.0 should be understood to also refer to the corresponding sections in each Bluetooth specification
`
`from version 2.1 onward, such as Bluetooth specification 4.0, 4.1 and 4.2. One-E-Way also notes
`
`that Apple has yet to provide discovery, as the case is in the beginning stages. One-E-Way reserves
`
`the right to identify additional information learned through discovery that further confirms these
`
`infringement contentions.
`
`
`
`
`
`1 For Claims 1, 3, 6 and 10, the term “Accused Receiver Device” does not include the Apple HomePod or
`Beats Pill+ Portable Speaker.
`
`1
`
`Petitioner's Exhibit 1032
`Page 005
`
`

`

`
`
`U.S. Patent 8,131,391
`1. A wireless digital
`audio headphone
`comprising:
`
`a portable digital
`audio headphone
`receiver configured
`to receive a unique
`user code bit
`sequence and a
`original audio
`signal
`representation in
`the form of packets,
`said digital audio
`headphone
`receiver, capable of
`mobile operation
`and configured for
`direct digital
`wireless spread
`
`Exhibit A
`
`Accused Transmitter and Receiver Devices
`Each Accused Receiver Device includes a wireless headphone having
`one or more speakers. These include over-head-type headphones, in-
`ear earbud-type headphones and behind-neck-type headphones.
`
`For example, Apple promotes its AirPods and AirPods Pro as
`headphones.
`
`https://www.apple.com/airpods/
`https://www.apple.com/newsroom/2016/09/apple-reinvents-the-wireless-
`headphones-with-airpods/
`https://www.apple.com/shop/product/MWNX2/powerbeats-high-
`performance-wireless-earphones-red
`
`Each Accused Receiver Device is operative to communicate
`wirelessly.
`See also:
`1 GENERAL DESCRIPTION
`Bluetooth wireless technology is a short-range communications
`system intended to replace the cable(s) connecting portable and/or
`fixed electronic devices. The key features of Bluetooth wireless
`technology are robustness, low power consumption, and low cost.
`Many features of the core specification are optional, allowing product
`differentiation.
`(BT Specification 5.0, Vol. 1, Part A, Section 1.)
`
`Each Accused Receiver Device is a product that wirelessly receives
`audio data using Bluetooth connectivity.
`
`Each Accused Receiver Device is a digital audio spread spectrum
`receiver. For example:
`
`The Basic Rate / Enhanced Data Rate (BR/EDR) radio (physical layer
`or PHY) operates in the unlicensed ISM band at 2.4 GHz. The system
`employs a frequency hopping transceiver to combat interference and
`fading and provides many FHSS [frequency hopping spread
`spectrum] carriers.
`(BT Specification 5.0, Vol. 1, Part A, Section 1.1.)
`
`Each Accused Receiver Device is configured to receive a unique user
`code. For example:
`1.3 ACCESS CODES
`
`2
`
`Petitioner's Exhibit 1032
`Page 006
`
`

`

`Exhibit A
`
`Accused Transmitter and Receiver Devices
`In the Bluetooth system all transmissions over the physical channel
`begin with an access code. Three different access codes are defined,
`see also Section 6.3.1:
`
`
`• device access code (DAC)
`• channel access code (CAC)
`• inquiry access code (IAC)
`
`All access codes are derived from the LAP of a device address or an
`inquiry address. The device access code is used during page, page
`scan and page response substates and shall be derived from the paged
`device’s BD_ADDR. The channel access code is used in the
`CONNECTION state, . . ..
`
`The access code also indicates to the receiver the arrival of a packet.
`It is used for timing synchronization and offset compensation. The
`receiver correlates against the entire synchronization word in the
`access code, providing very robust signaling.
`(BT Specification 5.0, Vol. 2, Part B, Section 1.3.)
`
`See also, for example:
`Each Bluetooth device shall be allocated a unique 48-bit Bluetooth
`device address (BD_ADDR). The address shall be a 48-bit extended
`unique identifier (EUI-48) created in accordance with section 8.2
`(“Universal addresses”) of the IEEE 802-2014 standard
`(http://standards.ieee.org/findstds/standard/802-2014.html).
`
`Creation of a valid EUI-48 requires one of the following MAC
`Address Block types to be obtained from the IEEE Registration
`Authority:
`
` •
`
` MAC Address Block Large (MA-L)
`• MAC Address Block Medium (MA-M)
`• MAC Address Block Small (MA-S)
`
`(BT Specification 5.0, Vol. 2, Part B, Section 1.2.)
`
`See also, for example, BT Specification 5.0, Vol. 1, Part A, Sections
`1.2, 1.3, 3.2.1 and 3.3; Vol. 2, Part B, Sections 2, 4.2, 6.4.
`
`Each Accused Receiver Device relies on packet-based
`communication.
`For example:
`
`3
`
`U.S. Patent 8,131,391
`spectrum
`communication
`with a mobile
`digital audio
`transmitter;
`
`Petitioner's Exhibit 1032
`Page 007
`
`

`

`Exhibit A
`
`Accused Transmitter and Receiver Devices
`The physical channel is sub-divided into time units known as slots.
`Data is transmitted between Bluetooth devices in packets that are
`positioned in these slots. When circumstances permit, a number of
`consecutive slots may be allocated to a single packet.
`(BT Specification 5.0, Vol. 1, Part A, Section 1.1; see also Section
`3.2.1 (“BR/EDR Generic Packet Structure”).)
`See also:
`2.3 PACKET FORMAT
`Each PDU is assigned either a 7 or a 15 bit opcode used to uniquely
`identify different types of PDUs, see Table 5.1. The first 7 bits of the
`opcode and a transaction ID are located in the first byte of the
`payload body. If the initial 7 bits of the opcode have one of the
`special escape values 124-127 then an additional byte of opcode is
`located in the second byte of the payload and the combination
`uniquely identifies the PDU.
`(BT Specification 5.0, Vol. 2, Part C, Section 2.3.)
`
`Each Accused Receiver Device is capable of portable operation and,
`through Bluetooth connectivity, is designed to work with a portable
`transmitter implementing Bluetooth connectivity.
`
`See also, for example:
`
` GENERAL DESCRIPTION
`Bluetooth wireless technology is a short-range communications
`system intended to replace the cable(s) connecting portable and/or
`fixed electronic devices.
`(BT Specification 5.0, Vol. 1, Part A, Section 1.)
`
`Each Accused Receiver Device has a direct conversion module. For
`example, Apple promotes the low power consumption characteristics
`of the accused devices.
`https://www.apple.com/newsroom/2016/09/apple-reinvents-the-wireless-
`headphones-with-airpods/
`https://gizbuyerguide.com/fixing-muffled-airpods-a-step-by-step-guide/
`https://www.crutchfield.com/S-oMrYi3E9DOy/p_472ARPDS2/Apple-
`AirPods-2nd-Generation.html
`https://www.beatsbydre.com/products
`
` 1
`
` 1
`
` GENERAL DESCRIPTION
`
`4
`
`U.S. Patent 8,131,391
`
`a direct conversion
`module configured
`to capture packets
`and the correct bit
`sequence within the
`packets aided by
`lowering signal
`detection error
`through reduced
`intersymbol
`interference coding
`of said audio
`representation
`signal respective to
`
`Petitioner's Exhibit 1032
`Page 008
`
`

`

`U.S. Patent 8,131,391
`said headphone
`receiver and said
`mobile digital
`audio transmitter,
`said packets
`embedded in the
`received spread
`spectrum signal, the
`captured packets
`corresponding to
`the unique user
`code;
`
`Exhibit A
`
`Accused Transmitter and Receiver Devices
`Bluetooth wireless technology is a short-range communications
`system intended to replace the cable(s) connecting portable and/or
`fixed electronic devices. The key features of Bluetooth wireless
`technology are robustness, low power consumption, and low cost.
`Many features of the core specification are optional, allowing product
`differentiation.
`(BT Specification 5.0, Vol. 1, Part A, Section 1.)
`
`Each Accused Receiver Device relies on packet-based
`communication.
`For example:
`The physical channel is sub-divided into time units known as slots.
`Data is transmitted between Bluetooth devices in packets that are
`positioned in these slots. When circumstances permit, a number of
`consecutive slots may be allocated to a single packet.
`(BT Specification 5.0, Vol. 1, Part A, Section 1.1; see also Section
`3.2.1 (“BR/EDR Generic Packet Structure”).)
`See also:
`2.3 PACKET FORMAT
`Each PDU is assigned either a 7 or a 15 bit opcode used to uniquely
`identify different types of PDUs, see Table 5.1. The first 7 bits of the
`opcode and a transaction ID are located in the first byte of the
`payload body. If the initial 7 bits of the opcode have one of the
`special escape values 124-127 then an additional byte of opcode is
`located in the second byte of the payload and the combination
`uniquely identifies the PDU.
`(BT Specification 5.0, Vol. 2, Part C, Section 2.3.)
`Each Accused Receiver Device decodes transmissions encoded to
`reduce intersymbol interference. For example:
`The modulation shall employ square-root raised cosine pulse shaping
`to generate the equivalent lowpass information-bearing signal v(t).
`The output of the transmitter shall be a bandpass signal that can be
`represented as
`
` (EQ 1)
`(BT Specification 5.0, Vol. 2, Part A, Section 3.2.1.1; see also BT
`Specification 5.0, Vol. 2, Part A, Section 3.2.1.3, Appendix C; Root
`Raised Cosine (RRC) Filters and Pulse Shaping in Communication
`Systems, NASA, Erkin Cubukcu (May 18, 2012), available at
`http://ntrs.nasa.gov/archive/nasa/casi.ntrs.nasa.gov/20120008631.pdf;
`
`5
`
`Petitioner's Exhibit 1032
`Page 009
`
`

`

`Exhibit A
`
`Accused Transmitter and Receiver Devices
`Inter Symbol Interference (ISI) and raised cosine filtering, available
`at http://complextoreal.com/wp-content/uploads/2013/01/isi.pdf)
`
`Each Accused Receiver Device is configured to receive a unique user
`code. For example:
`1.3 ACCESS CODES
`In the Bluetooth system all transmissions over the physical channel
`begin with an access code. Three different access codes are defined,
`see also Section 6.3.1:
`
`
`• device access code (DAC)
`• channel access code (CAC)
`• inquiry access code (IAC)
`
`All access codes are derived from the LAP of a device address or an
`inquiry address. The device access code is used during page, page
`scan and page response substates and shall be derived from the paged
`device’s BD_ADDR. The channel access code is used in the
`CONNECTION state, . . ..
`
`The access code also indicates to the receiver the arrival of a packet.
`It is used for timing synchronization and offset compensation. The
`receiver correlates against the entire synchronization word in the
`access code, providing very robust signaling.
`(BT Specification 5.0, Vol. 2, Part B, Section 1.3.)
`
`See also, for example:
`Each Bluetooth device shall be allocated a unique 48-bit Bluetooth
`device address (BD_ADDR). The address shall be a 48-bit extended
`unique identifier (EUI-48) created in accordance with section 8.2
`(“Universal addresses”) of the IEEE 802-2014 standard
`(http://standards.ieee.org/findstds/standard/802-2014.html).
`
`Creation of a valid EUI-48 requires one of the following MAC
`Address Block types to be obtained from the IEEE Registration
`Authority:
`
` •
`
` MAC Address Block Large (MA-L)
`• MAC Address Block Medium (MA-M)
`• MAC Address Block Small (MA-S)
`
`(BT Specification 5.0, Vol. 2, Part B, Section 1.2.)
`
`
`6
`
`U.S. Patent 8,131,391
`
`Petitioner's Exhibit 1032
`Page 010
`
`

`

`U.S. Patent 8,131,391
`
`a digital demodulator
`configured for
`independent
`CDMA
`communication
`operation;
`
`Exhibit A
`
`Accused Transmitter and Receiver Devices
`See also, for example, BT Specification 5.0, Vol. 1, Part A, Sections
`1.2, 1.3, 3.2.1 and 3.3; Vol. 2, Part B, Sections 2, 4.2, 6.4.
`
`Each Accused Receiver Device uses a digital demodulator configured
`for independent code division multiple access (CDMA)
`communication.
`Bluetooth is based on FH-CDMA (Frequency Hopping Code
`Division Multiple Access). See Performance Analysis of Bluetooth
`Network in the Presence of WI-FI System, by Shehu Hassan Ayagi,
`Computer Engineering and Intelligent Systems, Vol. 5, No. 9, 2014;
`see also Bluetooth Communication with Arduino by Dr. Xiaohai Li,
`available at
`http://citytechrobotics.org/EMT2461/Bluetooth%20with%20Arduino-
`2014.pdf. See also Wireless Communication Systems: From RF
`Subsystems to 4G Enabling Technologies by Ke-Lin Du, M. N. S.
`Swam, Cambridge University Press 2010, at 283 (“FH-CDMA is the
`core multiple-access technology in Bluetooth. . . .”).
`
`See also:
`
`The Basic Rate / Enhanced Data Rate (BR/EDR) radio (physical layer
`or PHY) operates in the unlicensed ISM band at 2.4 GHz. The system
`employs a frequency hopping transceiver to combat interference and
`fading and provides many FHSS [frequency hopping spread
`spectrum] carriers.
`
`(BT Specification 5.0, Vol. 1, Part A, Section 1.1.)
`
`Devices in a piconet use a specific frequency hopping pattern, which
`is algorithmically determined by certain fields in the Bluetooth
`address and clock of the master. The basic hopping pattern is a
`pseudo-random ordering of the 79 frequencies in the ISM band. The
`hopping pattern may be adapted to exclude a portion of the
`frequencies that are used by interfering devices. The adaptive
`hopping technique improves Bluetooth co-existence with static (non-
`hopping) ISM systems when these are co-located.
`
`The physical channel is sub-divided into time units known as slots.
`Data is transmitted between Bluetooth devices in packets, that are
`positioned in these slots. When circumstances permit, a number of
`consecutive slots may be allocated to a single packet. Frequency
`hopping takes place between the transmission or reception of packets.
`Bluetooth technology provides the effect of full duplex transmission
`through the use of a Time-Division Duplex (TDD) scheme.
`
`7
`
`Petitioner's Exhibit 1032
`Page 011
`
`

`

`U.S. Patent 8,131,391
`
`a decoder operative to
`decode reduced
`intersymbol
`interference coding
`of original audio
`signal
`representation;
`
`a digital-to-analog
`converter (DAC)
`generating an audio
`output of said
`original audio
`signal
`representation; and
`
`Exhibit A
`
`Accused Transmitter and Receiver Devices
`
`
`(BT Specification 5.0, Vol. 1, Part A, Sections 1.1, 1.4 (BR/EDR
`Piconet Physical Channel), 3.3.1.1.2.)
`
`
`Each Accused Receiver Device decodes transmissions encoded to
`reduce intersymbol interference. For example:
`The modulation shall employ square-root raised cosine pulse shaping
`to generate the equivalent lowpass information-bearing signal v(t).
`The output of the transmitter shall be a bandpass signal that can be
`represented as
`
` (EQ 1)
`
`
`(BT Specification 5.0, Vol. 2, Part A, Section 3.2.1.1; see also BT
`Specification 5.0, Vol. 2, Part A, Section 3.2.1.3, Appendix C; Root
`Raised Cosine (RRC) Filters and Pulse Shaping in Communication
`Systems, NASA, Erkin Cubukcu (May 18, 2012), available at
`http://ntrs.nasa.gov/archive/nasa/casi.ntrs.nasa.gov/20120008631.pdf;
`Inter Symbol Interference (ISI) and raised cosine filtering, available
`at http://complextoreal.com/wp-content/uploads/2013/01/isi.pdf)
`
`Each Accused Receiver Device generates audio output by converting
`the received digital signal representation to analog audio.
`
`For example:
`
`LOUDSPEAKER PATH
`RLR measurement model
`
`
`
`
`
`(BT Specification 5.0, Vol. 2, Part B, Appendix A, A.5.)
`
`Each Accused Receiver Device has a speaker to reproduce audio
`output.
`
`See also:
`
`a module adapted to
`reproduce said
`generated audio
`output in response
`
`8
`
`Petitioner's Exhibit 1032
`Page 012
`
`

`

`U.S. Patent 8,131,391
`to the unique user
`code bit sequence
`being recognized,
`said audio having
`been wirelessly
`transmitted and
`reproduced
`virtually free from
`interference from
`device transmitted
`signals operating in
`the wireless
`headphone
`spectrum.
`
`Exhibit A
`
`Accused Transmitter and Receiver Devices
`
`
`LOUDSPEAKER PATH
`RLR measurement model
`
`
`
`
`
`(BT Specification 5.0, Vol. 2, Part B, Appendix A, A.5.)
`
`Apple promotes the high quality and clear sound of each of the
`Accused Receiver Devices. For example:
`
`https://www.apple.com/airpods-2nd-generation/
`https://www.apple.com/newsroom/2019/10/apple-reveals-new-airpods-pro-
`available-october-30/
`
`https://www.apple.com/newsroom/2016/09/apple-reinvents-the-wireless-
`headphones-with-airpods/
`https://www.apple.com/shop/product/MV7N2AM/A/airpods-with-charging-case
`https://www.apple.com/homepod/
`https://www.beatsbydre.com/speakers/beats-pill-plus
`https://www.beatsbydre.com/earphones/beats-x
`https://www.beatsbydre.com/headphones/solo3-wireless
`https://www.apple.com/shop/product/MXY92LL/A/powerbeats-pro-totally-
`wireless-earphones-spring-yellow
`https://www.apple.com/shop/product/MWNX2LL/A/powerbeats-high-
`performance-wireless-earphones-red
`https://www.apple.com/shop/product/MRJA2LL/A/beats-solo-pro-wireless-noise-
`cancelling-headphones-more-matte-collection-dark-blue
`https://www.apple.com/shop/product/MXJA2LL/A/beats-studio3-wireless-
`headphones-the-beats-skyline-collection-midnight-black
`https://www.apple.com/shop/product/MWUJ2LL/A/beats-studio3-wireless-
`headphones-beats-camo-collection-sand-dune
`https://gizbuyerguide.com/fixing-muffled-airpods-a-step-by-step-guide/
`
`https://www.crutchfield.com/S-oMrYi3E9DOy/p_472ARPDS2/Apple-AirPods-
`2nd-Generation.html
`
`
`9
`
`Petitioner's Exhibit 1032
`Page 013
`
`

`

`U.S. Patent 8,131,391
`
`3. A portable wireless
`digital audio
`system for digital
`transmission of an
`original audio
`signal
`representation from
`a portable audio
`player to a portable
`digital audio
`headphone
`receiver, said
`portable wireless
`digital audio
`system comprising:
`
`Exhibit A
`
`Accused Transmitter and Receiver Devices
`
`See also:
`
`The Basic Rate / Enhanced Data Rate (BR/EDR) radio (physical layer
`or PHY) operates in the unlicensed ISM band at 2.4 GHz. The system
`employs a frequency hopping transceiver to combat interference and
`fading and provides many FHSS [frequency hopping spread
`spectrum] carriers.
`
`(BT Specification 5.0, Vol. 1, Part A, Section 1.1.)
`
`See also BT Specification 5.0, Vol. 1, Part A, Section 3.1.3, 3.3.1;
`BT Specification 5.0, Vol. 2, Part A, Section 4.1.2.)
`
`Each Accused Receiver Device includes a wireless headphone having
`one or more speakers. These include over-head-type headphones, in-
`ear earbud-type headphones and behind-neck-type headphones.
`
`For example, Apple promotes its AirPods and AirPods Pro as
`headphones.
`
`https://www.apple.com/airpods/
`https://www.apple.com/newsroom/2016/09/apple-reinvents-the-wireless-
`headphones-with-airpods/
`https://www.apple.com/shop/product/MWNX2/powerbeats-high-
`performance-wireless-earphones-red
`
`Each Accused Receiver Device is operative to communicate
`wirelessly.
`See also:
`1 GENERAL DESCRIPTION
`Bluetooth wireless technology is a short-range communications
`system intended to replace the cable(s) connecting portable and/or
`fixed electronic devices. The key features of Bluetooth wireless
`technology are robustness, low power consumption, and low cost.
`Many features of the core specification are optional, allowing product
`differentiation.
`(BT Specification 5.0, Vol. 1, Part A, Section 1.)
`
`Each Accused Receiver Device is capable of portable operation and,
`through Bluetooth connectivity, is designed to work with a portable
`transmitter implementing Bluetooth connectivity
`
`See also, for example:
`
`10
`
`Petitioner's Exhibit 1032
`Page 014
`
`

`

`Exhibit A
`
`Accused Transmitter and Receiver Devices
`
` 1
`
` GENERAL DESCRIPTION
`Bluetooth wireless technology is a short-range communications
`system intended to replace the cable(s) connecting portable and/or
`fixed electronic devices.
`(BT Specification 5.0, Vol. 1, Part A, Section 1.)
`
`Each Accused Transmitter Device is a product that wirelessly
`transmits audio data using Bluetooth connectivity.
`
`Each Accused Transmitter Device is a digital audio spread spectrum
`transmitter. For example:
`
`The Basic Rate / Enhanced Data Rate (BR/EDR) radio (physical layer
`or PHY) operates in the unlicensed ISM band at 2.4 GHz. The system
`employs a frequency hopping transceiver to combat interference and
`fading and provides many FHSS [frequency hopping spread
`spectrum] carriers.
`(BT Specification 5.0, Vol. 1, Part A, Section 1.1)
`
`Apple promotes each Accused Transmitter Device as providing
`audio, including music.
`
`See also:
`This profile defines the requirements for Bluetooth devices necessary
`for support of the high quality audio distribution. The requirements
`are expressed in terms of end-user services, and by defining the
`features and procedures that are required for interoperability between
`Bluetooth devices in the Audio Distribution usage model.
`(Advanced Audio Distribution v1.3.2, Abstract)
`
`Each Accused Transmitter Device is a product that wirelessly
`transmits audio data using Bluetooth connectivity.
`
`Each Accused Transmitter Device is a digital audio spread spectrum
`transmitter. For example:
`
`The Basic Rate / Enhanced Data Rate (BR/EDR) radio (physical layer
`or PHY) operates in the unlicensed ISM band at 2.4 GHz. The system
`employs a frequency hopping transceiver to combat interference and
`fading and provides many FHSS [frequency hopping spread
`spectrum] carriers.
`(BT Specification 5.0, Vol. 1, Part A, Section 1.1)
`
`
`U.S. Patent 8,131,391
`
`a digital audio
`transmitter
`operatively coupled
`to said portable
`audio player and
`transmitting a
`unique user code
`bit sequence with
`said original audio
`signal
`representation in
`packet format,
`wherein said digital
`audio transmitter
`
`11
`
`Petitioner's Exhibit 1032
`Page 015
`
`

`

`Exhibit A
`
`Accused Transmitter and Receiver Devices
`Each Accused Transmitter Device is configured to transmit a unique
`user code. For example:
`1.3 ACCESS CODES
`In the Bluetooth system all transmissions over the physical channel
`begin with an access code. Three different access codes are defined,
`see also Section 6.3.1:
`
`
`• device access code (DAC)
`• channel access code (CAC)
`• inquiry access code (IAC)
`
`All access codes are derived from the LAP of a device address or an
`inquiry address. The device access code is used during page, page
`scan and page response substates and shall be derived from the paged
`device’s BD_ADDR. The channel access code is used in the
`CONNECTION state, . . ..
`
`The access code also indicates to the receiver the arrival of a packet.
`It is used for timing synchronization and offset compensation. The
`receiver correlates against the entire synchronization word in the
`access code, providing very robust signaling.
`(BT Specification 5.0, Vol. 2, Part B, Section 1.3.)
`
`See also, for example:
`Each Bluetooth device shall be allocated a unique 48-bit Bluetooth
`device address (BD_ADDR). The address shall be a 48-bit extended
`unique identifier (EUI-48) created in accordance with section 8.2
`(“Universal addresses”) of the IEEE 802-2014 standard
`(http://standards.ieee.org/findstds/standard/802-2014.html).
`
`Creation of a valid EUI-48 requires one of the following MAC
`Address Block types to be obtained from the IEEE Registration
`Authority:
`
` •
`
` MAC Address Block Large (MA-L)
`• MAC Address Block Medium (MA-M)
`• MAC Address Block Small (MA-S)
`
`(BT Specification 5.0, Vol. 2, Part B, Section 1.2.)
`
`See also, for example, BT Specification 5.0, Vol. 1, Part A, Sections
`1.2, 1.3, 3.2.1 and 3.3; Vol. 2, Part B, Sections 2, 4.2, 6.4.
`
`
`
`12
`
`U.S. Patent 8,131,391
`operatively coupled
`to said audio player
`is capable of
`mobile operation,
`said digital audio
`transmitter
`comprising:
`
`Petitioner's Exhibit 1032
`Page 016
`
`

`

`Exhibit A
`
`Accused Transmitter and Receiver Devices
`Each Accused Transmitter Device relies on packet-based
`communication.
`For example:
`The physical channel is sub-divided into time units known as slots.
`Data is transmitted between Bluetooth devices in packets that are
`positioned in these slots. When circumstances permit, a number of
`consecutive slots may be allocated to a single packet.
`(BT Specification 5.0, Vol. 1, Part A, Section 1.1; see also Section
`3.2.1 (“BR/EDR Generic Packet Structure”).)
`See also:
`2.3 PACKET FORMAT
`Each PDU is assigned either a 7 or a 15 bit opcode used to uniquely
`identify different types of PDUs, see Table 5.1. The first 7 bits of the
`opcode and a transaction ID are located in the first byte of the
`payload body. If the initial 7 bits of the opcode have one of the
`special escape values 124-127 then an additional byte of opcode is
`located in the second byte of the payload and the combination
`uniquely identifies the PDU.
`(BT Specification 5.0, Vol. 2, Part C, Section 2.3.)
`
`Each Accused Transmitter Device is capable of mobile operation and,
`through Bluetooth connectivity, is designed to work with a portable
`receiver implementing Bluetooth connectivity.
`
`See also, for example:
`
` 1
`
` GENERAL DESCRIPTION
`Bluetooth wireless technology is a short-range communications
`system intended to replace the cable(s) connecting portable and/or
`fixed electronic devices.
`(BT Specification 5.0, Vol. 1, Part A, Section 1.)
`
`Each Accused Transmitter Device encodes transmissions to reduce
`intersymbol interference. For example:
`The modulation shall employ square-root raised cosine pulse shaping
`to generate the equivalent lowpass information-bearing signal v(t).
`The output of the transmitter shall be a bandpass signal that can be
`represented as
`
`U.S. Patent 8,131,391
`
`a encoder operative to
`encode said
`original audio
`signal
`representation to
`reduce intersymbol
`interference;
`
` (EQ 1)
`
`13
`
`Petitioner's Exhibit 1032
`Page 017
`
`

`

`U.S. Patent 8,131,391
`
`a digital modulator
`module configured
`for independent
`CDMA
`communication
`operation;
`
`Exhibit A
`
`Accused Transmitter and Receiver Devices
`
`
`(