UNITED STATES DISTRICT COURT
`FOR THE WESTERN DISTRICT OF TEXAS
`WACO DIVISION
`
`XR COMMUNICATIONS, LLC, dba
`VIVATO TECHNOLOGIES,
`
`Plaintiff,
`
`v.
`
`Defendant.
`
`HP INC.,
`
`Case No.
`
`JURY TRIAL DEMANDED
`
`COMPLAINT FOR PATENT INFRINGEMENT AGAINST
`HP INC.
`
`This is an action for patent infringement arising under the Patent Laws of the United States
`
`of America, 35 U.S.C. § 1 et seq., in which Plaintiff XR Communications LLC d/b/a Vivato
`
`Technologies (“Plaintiff” or “Vivato”) makes the following allegations against Defendant HP Inc.
`
`(“Defendant”):
`
`INTRODUCTION
`
`1.
`
`This complaint arises from Defendant’s unlawful infringement of the following
`
`United States patent owned by Vivato, which generally relates to wireless communications
`
`technology: United States Patent No. 10,715,235 (the “’235 Patent”) (the “Asserted Patent”).
`
`2.
`
`Countless electronic devices today connect to the Internet wirelessly. Beyond just
`
`connecting our devices together, wireless networks have become an inseparable part of our lives
`
`in our homes, our offices, and our neighborhood coffee shops. In even our most crowded spaces,
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`today’s wireless technology allows all of us to communicate with each other, on our own devices,
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`at virtually the same time. Our connected world would be unrecognizable without the ubiquity of
`
`1
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`6:21-cv-694
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`Exhibit 1018
`Page 01 of 25
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`sophisticated wireless networking technology.
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`3.
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`Just a few decades ago, wireless technology of this kind could only be found in
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`science fiction. The underlying science behind wireless communications can be traced back to the
`
`development of “wireless telegraphy” in the nineteenth century. Guglielmo Marconi is credited
`
`with developing the first practical radio, and in 1896, Guglielmo Marconi was awarded British
`
`patent 12039, Improvements in transmitting electrical impulses and signals and in apparatus
`
`there-for, the first patent to issue for a Herzian wave-based wireless telegraphic system. Marconi
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`would go on to win the Nobel Prize in Physics in 1909 for his contributions to the field.
`
`4.
`
`One of Marconi’s preeminent contemporaries was Dr. Karl Ferdinand Braun, who
`
`shared the 1909 Nobel Prize in Physics with Marconi. In his Nobel lecture dated December 11,
`
`1909, Braun explained that he was inspired to work on wireless technology by Marconi’s own
`
`experiments. Braun had observed that the signal strength in Marconi’s radio was limited beyond a
`
`certain distance, and wondered why increasing the voltage on Marconi’s radio did not result in a
`
`stronger transmission at greater distances. Braun thus dedicated himself to developing wireless
`
`devices with a stronger, more effective transmission capability.
`
`5.
`
`In 1905, Braun invented the first phased array antenna. This phased array antenna
`
`featured three antennas carefully positioned relative to one another with a specific phase
`
`relationship so that the radio waves output from each antenna could add together to increase
`
`radiation in a desired direction. This design allowed Braun’s phased array antenna to transmit a
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`directed signal.
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`6.
`
`Building on the fundamental breakthrough that radio transmissions can be directed
`
`according to a specific radiation pattern through the use of a phased array antenna, directed
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`wireless communication technology has developed many applications over the years. Braun’s
`
`
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`2
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`invention of the phased array antenna led to the development of radar, smart antennas, and,
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`eventually, to a technology known as “MIMO,” or “multiple-input, multiple-output,” which would
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`ultimately allow a single radio channel to receive and transmit multiple data signals
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`simultaneously. Along the way, engineers have worked tirelessly to overcome limitations and
`
`roadblocks directed wireless communication technology.
`
`7.
`
`At the beginning of the twenty-first century, the vast majority of wireless networks
`
`still did not yet take advantage of directed wireless communications. Instead, “omnidirectional”
`
`access points were ubiquitous. Omnidirectional access points transmit radio waves uniformly
`
`around the access point in every direction and do not steer the signal in particular directions.
`
`Omnidirectional antennas access points do typically achieve 360 degrees of coverage around the
`
`access point, but with a reduced coverage distance. Omnidirectional access points also lack
`
`sophisticated approaches to overcome certain types of interference in the environment. As only
`
`one example, the presence of solid obstructions, such as a concrete wall, ceiling, or pillar, can limit
`
`signal penetration. As another example, interference arises when radio waves are reflected,
`
`refracted, or diffracted based on obstacles present between the transmitter and receiver. The
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`multiple paths that radio waves can travel between the transmitter and receiver often result in signal
`
`interference that decreases performance, and omnidirectional access points lack advanced
`
`solutions to overcome these “multipath” effects.
`
`8.
`
`Moving from omnidirectional networks to modern networks has required an
`
`additional series of advancements that harness the capabilities of directed wireless technology.
`
`These advancements range from conceiving various ways to steer and modify radiation patterns,
`
`to enhancing the transmission signal power in a desired direction, to suppressing radiation in
`
`undesired directions, to minimizing signal “noise,” and then applying these new approaches into
`
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`3
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`Exhibit 1018
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`communications networks with multiple, heterogenous transmitters and receivers.
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`9.
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`Harnessing the capabilities of directed wireless technology resulted in a significant
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`leap forward in the signal strength, reliability, concurrent users, and/or data transmission capability
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`of a wireless network. One of the fundamental building blocks of this latest transition was the
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`development of improvements to MIMO and “beamforming,” which are the subject matter of
`
`patents in this infringement action. The patents in this action resulted from the investment of tens
`
`of millions of dollars and years of tireless effort by a group of engineers who built a technology
`
`company slightly ahead of its time. Their patented innovations laid the groundwork for today’s
`
`networks, and are infringed by Defendant’s accused products.
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`
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`4
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`Exhibit 1018
`Page 04 of 25
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`PARTIES
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`10.
`
`Plaintiff XR Communications, LLC, d/b/a Vivato Technologies (“Vivato” or
`
`“Plaintiff”) is a limited liability company organized and existing under the laws of the State of
`
`Delaware with its principal place of business at 2809 Ocean Front Walk, Venice, California 90291.
`
`Vivato is the sole owner by assignment of all right, title, and interest in each Asserted Patent.
`
`11.
`
`Vivato was founded in 2000 as a $80+ million venture-backed company with
`
`several key innovators in the wireless communication field including Siavash Alamouti, Ken Biba,
`
`William Crilly, James Brennan, Edward Casas, and Vahid Tarokh, among many others. At that
`
`time, and as remains the case today, “Wi-Fi” or “802.11” had become the ubiquitous means of
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`wireless connection to the Internet, integrated into hundreds of millions of mobile devices globally.
`
`Vivato was founded to leverage its talent to generate intellectual property and deliver Wi-Fi/802.11
`
`wireless connectivity solutions to service the growing demand for bandwidth.
`
`12.
`
`Vivato has accomplished significant innovations in the field of wireless
`
`communications technology. One area of focus at Vivato was the development of advanced
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`wireless systems with sophisticated antenna designs to improve wireless speed, coverage, and
`
`reliability. Vivato also focused on designing wireless systems that maximize the efficient use of
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`spectrum and wireless resources for large numbers of connected mobile devices.
`
`13.
`
`Among many fundamental breakthroughs achieved by Vivato are inventions that
`
`allow for intelligent and adaptive beamforming based on up-to-date information about the wireless
`
`medium. Through these and many other inventions, Vivato’s engineers pioneered a wireless
`
`technology that provides for simultaneous transmission and reception, a significant leap forward
`
`over conventional wireless technology.
`
`14.
`
`Over the years, Vivato has developed proven technology, with over 400
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`
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`5
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`Exhibit 1018
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`deployments globally, including private, public and government, and it has become a recognized
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`provider of extended range Wi-Fi network infrastructure solutions. Vivato's wireless base stations
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`integrate beamforming phased array antenna design with packet steering technology to deliver
`
`high-bandwidth extended range connections to serve multiple users and multiple devices.
`
`15.
`
`Vivato’s patent portfolio includes over 17 issued patents and pending patent
`
`applications. The patents at issue in this case are directed to specific aspects of wireless
`
`communication, including adaptively steered antenna technology and beam switching technology.
`
`16.
`
`Defendant HP Inc. is a Delaware corporation with a principal place of business at
`
`1501 Page Mill Road, Palo Alto, California 94304.
`
`17.
`
`Defendant maintains a regular and established place of business at 3800 Quick Hill
`
`Road #100, Austin, Texas 78728, and it advertises positions on its website available in Austin.
`
`Defendant distributes, markets, and sells electronic devices in the United States. Defendant is
`
`authorized to do business in Texas and may be served through its registered agent CT Corporation
`
`System, 1999 Bryan Street, Suite 900, Dallas, Texas 75201.
`
`18.
`
`Defendant offers for sale, sells, designs and manufactures and/or has manufactured
`
`on their behalf abroad certain Accused Products that are then sold for importation into the United
`
`States, imported into the United States, and/or sold, offered for sale, and/or used within the United
`
`States after importation. By registering to conduct business in Texas and by having facilities where
`
`it regularly conducts business in this District, Defendant has a permanent and continuous presence
`
`in Texas and a regular and established place of business in the Western District of Texas.
`
`JURISDICTION AND VENUE
`
`19.
`
`This action arises under the patent laws of the United States, Title 35 of the United
`
`States Code § 1, et seq, including 35 U.S.C. §§ 271, 281, 283, 284, and 285. This Court has original
`
`
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`6
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`Exhibit 1018
`Page 06 of 25
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`subject matter jurisdiction pursuant to 28 U.S.C. §§ 1331 and 1338(a).
`
`20.
`
`This Court has personal jurisdiction over Defendant in this action because
`
`Defendant has committed acts within this District giving rise to this action, and has established
`
`minimum contacts with this forum such that the exercise of jurisdiction over Defendant would not
`
`offend traditional notions of fair play and substantial justice. Defendant, directly and/or through
`
`subsidiaries or intermediaries, have committed and continue to commit acts of infringement in this
`
`District by, among other things, importing, offering to sell, and selling products that infringe the
`
`asserted patents, and inducing others to infringe the asserted patents in this District. Defendant is
`
`directly and through intermediaries making, using, selling, offering for sale, distributing,
`
`advertising, promoting, and otherwise commercializing their infringing products in this District.
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`Defendant regularly conducts and solicits business in, engage in other persistent courses of conduct
`
`in, and/or derive substantial revenue from goods and services provided to the residents of this
`
`District and the State of Texas. Defendant is subject to jurisdiction pursuant to due process and/or
`
`the Texas Long Arm Statute due to its substantial business in this State and District including at
`
`least its infringing activities, regularly doing or soliciting business at its Austin facilities, and
`
`engaging in persistent conduct and deriving substantial revenues from goods and services provided
`
`to residents in the State of Texas including the Western District of Texas.
`
`21.
`
`Venue is proper in this District pursuant to 28 U.S.C. § 1391(b), (c), (d), and
`
`1400(b) because Defendant has a permanent and continuous presence in, have committed acts of
`
`infringement in, and maintain regular and established places of business in this district. Defendant
`
`has committed acts of direct and indirect infringement in this judicial district including using and
`
`purposefully transacting business involving the Accused Products in this judicial district such as
`
`by sales to one or more customers in the State of Texas including in the Western District of Texas,
`
`
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`7
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`Exhibit 1018
`Page 07 of 25
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`and maintaining regular and established places of business in this district. For example, Defendant
`
`maintains a regular and established place of business at 3800 Quick Hill Road #100, Austin, Texas
`
`78728.
`
`COUNT I
`
`INFRINGEMENT OF U.S. PATENT NO. 10,715,235
`
`22.
`
`Vivato realleges and incorporates by reference the foregoing paragraphs as if fully
`
`set forth herein.
`
`23.
`
`On July 14, 2020, United States Patent No. 10,715,235 duly and legally issued for
`
`inventions entitled “Directed Wireless Communication.” Vivato owns the ’235 Patent and holds
`
`the right to sue and recover damages for infringement thereof. A copy of the ’235 Patent is attached
`
`hereto as Exhibit A.
`
`24.
`
`Defendant has directly infringed and continues to directly infringe numerous claims
`
`of the ’235 Patent, including at least claim 8, by manufacturing, using, selling, offering to sell,
`
`and/or importing into the United States certain products supporting MIMO and/or MU-MIMO
`
`technologies (e.g., Defendant’s Laptop computers, including all variations and configurations
`
`thereof, such as: Envy Series, 1 Envy x360 Series, Pavilion Series, Pavilion Gaming Series,
`
`Pavilion x360 Convertible Series, Spectre x360 Convertible Series, Omen Series, Chromebook
`
`x360 Series, Chromebook 11a Series, Chromebook 14b Series, Chromebook Clamshell Series,
`
`Chromebook x360 Series, ProBook Series, Elite DragonFly Series, Elite Folio Series, ZBook
`
`Series, Elite x2 Series, and EliteBook Series; Defendant’s Desktop computers, including all
`
`variations and configurations thereof, such as: Pavilion Gaming Series, All-in-One Series, Envy
`
`Series, Pavilion Series, OMEN Series, ProDesk Series, EliteOne Series, z2 Mini Workstation
`
`
`1 HP Envy 15 Webpage: https://www.hp.com/us-en/laptops/envy/envy-15-laptop.html
`
`
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`8
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`Exhibit 1018
`Page 08 of 25
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`Series, ProOne Series, EliteDesk Series, Elite Slice Series, Chromebox Series, Z2 Small Form
`
`Factor Workstation Series, and Z2 Tower Workstation Series) (collectively, the “’235 Accused
`
`Products”). Defendant is liable for infringement of the ’235 Patent pursuant to 35 U.S.C. § 271(a).
`
`25.
`
`The ’235 Accused Products satisfy all claim limitations of numerous claims of
`
`the ’235 Patent, including Claim 8. The following paragraphs compare limitations of Claim 8 to
`
`an exemplary Accused Product, the Envy 15 Laptop. See, e.g., HP Envy Laptop Webpage,2 HP
`
`Envy Laptop Datasheet.3 Like the Envy 15 Laptop, each Accused Product supports MU-MIMO
`
`technology. For example, the Envy 15 Laptop includes “Wi-Fi 6 and Bluetooth 5.0 for super-fast
`
`connectivity.” See HP Envy 15 Webpage. The HP Envy 15 supports “Intel® Wi-Fi 6 AX 201
`
`(2x2)” connectivity, see HP Envy Laptop Webpage, with “MU-MIMO supported.” See HP Envy
`
`Laptop Datasheet.
`
`26.
`
`Each ’235 Accused Product performs a method for use in a wireless
`
`communications system, the method comprising receiving a first signal transmission from a remote
`
`station via a first antenna element of an antenna and a second signal transmission from the remote
`
`station via a second antenna element of the antenna simultaneously, wherein the first signal
`
`transmission and the second signal transmission comprise electromagnetic signals comprising one
`
`or more transmission peaks and one or more transmission nulls. For example, as with each ’235
`
`
`2 HP Envy Laptop Webpage, available at: https://www.hp.com/us-en/shop/pdp/hp-envy-laptop-
`15-
`ep0098nr?bvroute=Review%2F234385063&bvstate=pg:2/ct:r&cq_src=google_ads&cq_cmp=12
`690817676&cq_con=123460399194&cq_term=&cq_med=&cq_plac=&cq_net=g&cq_pos=&cq
`_plt=gp&DSA&jumpid=ps_con_nb_ns&utm_medium=ps&utm_source=ga&utm_campaign=HP
`-Store_US_BRA_PS_CPS_OPEX_Google_All_SEM_All_Notebooks-
`DSA&utm_term=&matchtype=b&adid=512564949515&addisttype=g&gclid=CjwKCAjww-
`CGBhALEiwAQzWxOqjxfsR309dR8iCpGVQeiIgUvelkug-
`SAjy99RX2DTwm6UftDCee9xoC0L8QAvD_BwE&gclsrc=aw.ds
`3 HP Envy Laptop Datasheet: https://www8.hp.com/h20195/v2/GetPDF.aspx/c06931364.pdf
`
`
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`9
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`Exhibit 1018
`Page 09 of 25
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`Accused Product, the Envy 15 Laptop receives a first signal transmission from a remote station,
`
`such as a Wi-Fi Access Point, via a first antenna element of an antenna and a second signal
`
`transmission from the remote station via a second antenna element of the antenna simultaneously,
`
`such as when the Envy 15 Laptop receives first and second signals with its first and second antenna
`
`elements that contain training fields of a null data packet used for MU-MIMO sounding and
`
`channel estimation procedures. For example, the Envy 15 Laptop includes “Wi-Fi 6 and Bluetooth
`
`5.0 for super-fast connectivity.” See HP Envy 15 Webpage. The HP Envy 15 supports “Intel® Wi-
`
`Fi 6 AX 201 (2x2)” connectivity, see HP Envy Laptop Webpage, with “MU-MIMO supported.”
`
`See HP Envy Laptop Datasheet. See, e.g., IEEE 802.11ax Standard, Section 27.3.1.1 (“The
`
`transmission within an RU in a PPDU may be single stream to one user, spatially multiplexed to
`
`one user (SU-MIMO), or spatially multiplexed to multiple users (MU-MIMO).”); Section 27.3.2.5
`
`(“The number of users in the MU-MIMO group is indicated in the Number Of HE-SIG-B Symbols
`
`Or MU-MIMO Users field in HE-SIG-A. The allocated spatial streams for each user and the total
`
`number of spatial streams are indicated in the Spatial Configuration field of User field in HE-SIG-
`
`B containing the STA-ID of the designated MU-MIMO STA as defined in Table 27-29 (Spatial
`
`Configuration subfield encoding)…[i]f there is only one User field (see Table 27-27 (User field
`
`format for a non-MU-MIMO allocation)) for an RU in the HE-SIG-B content channel, then the
`
`number of spatial streams for the user in the RU is indicated by the NSTS field in the User field.
`
`If there is more than one User field (see Table 27-28 (User field for an MU-MIMO allocation)) for
`
`an RU in the HE-SIG-B content channel, then the number of allocated spatial streams for each
`
`user in the RU is indicated by the Spatial Configuration field of the User field in HE-SIG-B.”);
`
`Section 27.3.2.6 (“UL MU transmissions are preceded by a Trigger frame or frame carrying a TRS
`
`Control subfield from the AP. The Trigger frame or frame carrying the TRS Control subfield
`
`
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`10
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`Exhibit 1018
`Page 10 of 25
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`indicates the parameters, such as the duration of the HE TB PPDU, RU allocation, target RSSI and
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`MCS (see 9.3.1.22 (Trigger frame format), 9.2.4.6a.1 (TRS Control) and 26.5.3.3 (Non-AP STA
`
`behavior for UL MU operation)), required to transmit an HE TB PPDU”); Section 27.3.10.8 (HE-
`
`SIG-B) (“The HE-SIG-B field provides the OFDMA and DL MU-MIMO resource allocation
`
`information to allow the STAs to look up the corresponding resources to be used in the data portion
`
`of the frame.”); Section 27.3.15 (“SU-MIMO and DL-MU-MIMO beamforming are techniques
`
`used by a STA with multiple antennas (the beamformer) to steer signals using knowledge of the
`
`channel to improve throughput. With SU-MIMO beamforming all space-time streams in the
`
`transmitted signal are intended for reception at a single STA in an RU. With DL MU-MIMO
`
`beamforming, disjoint subsets of the space-time streams are intended for reception at different
`
`STAs in an RU of size greater than or equal to 106-tones”); Section 27.3.10.8.5 (HE-SIG-B per
`
`user content) (“The User Specific field consists of multiple User fields. The User fields follow the
`
`Common field of HE-SIG-B. The RU Allocation field in the Common field and the position of the
`
`User field in the User Specific field together identify the RU used to transmit a STA’s data…”).
`
`See, e.g., IEEE 802.11ac Standard Clause 9.31.5.1 (“Transmit beamforming and DL-MU-MIMO
`
`require knowledge of the channel state to compute a steering matrix that is applied to the
`
`transmitted signal to optimize reception at one or more receivers. The STA transmitting using the
`
`steering matrix is called the VHT beamformer and a STA for which reception is optimized is called
`
`a VHT beamformee. An explicit feedback mechanism is used where the VHT beamformee directly
`
`measures the channel from the training symbols transmitted by the VHT beamformer and sends
`
`back a transformed estimate of the channel state to the VHT beamformer. The VHT beamformer
`
`then uses this estimate, perhaps combining estimates from multiple VHT beamformees, to derive
`
`the steering matrix.”); See, e.g., 802.11ac Standard Clause 9.31.5.2 (“A VHT beamformer shall
`
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`Exhibit 1018
`Page 11 of 25
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`initiate a sounding feedback sequence by transmitting a VHT NDP Announcement frame followed
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`by a VHT NDP after a SIFS. The VHT beamformer shall include in the VHT NDP Announcement
`
`frame one STA Info field for each VHT beamformee that is expected to prepare VHT Compressed
`
`Beamforming feedback and shall identify the VHT beamformee by including the VHT
`
`beamformee’s AID in the AID subfield of the STA Info field. The VHT NDP Announcement
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`frame shall include at least one STA Info field.”); id. (“A non-AP VHT beamformee that receives
`
`a VHT NDP Announcement frame… shall transmit its VHT Compressed Beamforming feedback
`
`a SIFS after receiving a Beamforming Report Poll with RA matching its MAC address and a non-
`
`bandwidth signaling TA obtained from the TA field matching the MAC address of the VHT
`
`beamformer.”); id. Clause 8.5.23.2 (defining format and subfields within the VHT Compressed
`
`Beamforming frame); id. Clause 8.4.1.48 (including Tables 8-53(d)-(h)) (“Each SNR value per
`
`tone in stream i (before being averaged) corresponds to the SNR associated with the column i of
`
`the beamforming feedback matrix V determined at the beamformee”); id. Clause 8.4.1.49
`
`(including Table 8-53i – MU Exclusive Beamforming Report information); id. Clauses 8.4.1.24,
`
`9.31.5.1, 9.31.5.2; id. Clauses 22.3.4.6(d), 22.3.4.7(e), 22.3.4.8(l), 22.3.4.9.1(m), 22.3.4.9.2(m),
`
`22.3.4.10.4(a) (“Spatial mapping: Apply the Q matrix as described in 22.3.10.11.1.”); id. Clause
`
`22.3.10.11.1; IEEE 802.11-2012 Standard Clause 20.3.12.3.6; 802.11ac Standard Clauses
`
`8.4.1.24, 9.31.5.1, 9.31.5.2; id. Clause 22.3.11.1:
`
`
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`12
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`Exhibit 1018
`Page 12 of 25
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`; id. Clause 22.3.11.2:
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`
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`27.
`
`Each ’235 Accused Product performs a method for use in a wireless
`
`communications system, the method comprising determining first signal information for the first
`
`signal transmission and determining second signal information for the second signal transmission,
`
`wherein the second signal information is different than the first signal information. For example,
`
`as with each ’235 Accused Product, the Envy 15 Laptop determines different signal information
`
`for the first signal transmission than it does for the second signal transmission, by using the training
`
`fields of a null data packet for MU-MIMO sounding and channel estimation to determine the
`
`parameters in the beamforming feedback matrix. For example, the Envy 15 Laptop includes “Wi-
`
`Fi 6 and Bluetooth 5.0 for super-fast connectivity.” See HP Envy 15 Webpage. The HP Envy 15
`
`supports “Intel® Wi-Fi 6 AX 201 (2x2)” connectivity, see HP Envy Laptop Webpage, with “MU-
`
`MIMO supported.” See HP Envy Laptop Datasheet. See, e.g., IEEE 802.11ax Standard, Section
`
`26.7 (HE sounding protocol) (“Transmit beamforming and DL MU-MIMO require knowledge of
`
`the channel state to compute a steering matrix that is applied to the transmit signal to optimize
`
`reception at one or more receivers. HE STAs use the HE sounding protocol to determine the
`
`
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`13
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`Exhibit 1018
`Page 13 of 25
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`channel state information. The HE sounding protocol provides explicit feedback mechanisms,
`
`defined as HE non-trigger-based (non-TB) sounding and HE trigger-based (TB) sounding, where
`
`the HE beamformee measures the channel using a training signal (i.e., an HE sounding NDP)
`
`transmitted by the HE beamformer and sends back a transformed estimate of the channel state.
`
`The HE beamformer uses this estimate to derive the steering matrix. The HE beamformee returns
`
`an estimate of the channel state in an HE compressed beamforming/CQI report carried in one or
`
`more HE Compressed Beamforming/CQI frames.”); Section 26.7.3 (“An HE beamformee that
`
`receives an HE NDP Announcement frame from an HE beamformer with which it is associated
`
`and that contains the HE beamformee’s MAC address in the RA field and also receives an HE
`
`sounding NDP a SIFS after the HE NDP Announcement frame shall transmit its HE compressed
`
`beamforming/CQI report a SIFS after the HE sounding NDP. The TXVECTOR parameter
`
`CH_BANDWIDTH for the PPDU containing the HE compressed beamforming/CQI report shall
`
`be set to indicate a bandwidth not wider than that indicated by the RXVECTOR parameter
`
`CH_BANDWIDTH of the HE sounding NDP. An HE beamformee that receives an HE NDP
`
`Announcement frame as part of an HE TB sounding sequence with a STA Info field addressed to
`
`it soliciting SU or MU feedback shall generate an HE compressed beamforming/CQI report using
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`the feedback type, Ng and codebook size indicated in the STA Info field. If the HE beamformee
`
`then receives a BFRP Trigger frame with a User Info field addressed to it, the HE beamformee
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`transmits an HE TB PPDU containing the HE compressed beamforming/CQI report following the
`
`rules defined in 26.5.3.3 (Non-AP STA behavior for UL MU operation).”); Section 26.5.3 (UL
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`MU operation) (“UL MU operation allows an AP to solicit simultaneous immediate response
`
`frames from one or more non-AP HE STAs”); Section 27.3.10.10 (HE-LTF) (“The HE-LTF field
`
`provides a means for the receiver to estimate the MIMO channel between the set of constellation
`
`
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`14
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`Exhibit 1018
`Page 14 of 25
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`mapper outputs (or, if STBC is applied, the STBC encoder outputs) and the receive chains. In an
`
`HE SU PPDU and HE ER SU PPDU, the transmitter provides training for NSTS space-time
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`streams (spatial mapper inputs) used for the transmission of the PSDU. In an HE MU PPDU, the
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`transmitter provides training for NSTS,r,total space-time streams used for the transmission of the
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`PSDU(s) in the r-th RU. In an HE TB PPDU, the transmitter of user u in the r-th RU provides
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`training for NSTS,r,u space-time streams used for the transmission of the PSDU. For each tone in
`
`the r-th RU, the MIMO channel that can be estimated is an NRX x NSTS,r,total matrix. An HE
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`transmission has a preamble that contains HE-LTF symbols, where the data tones of each HE-LTF
`
`symbol are multiplied by entries belonging to a matrix PHE-LTF, to enable channel estimation at
`
`the receiver…. In an HE SU PPDU, HE MU PPDU and HE ER SU PPDU, the combination of
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`HE-LTF type and GI duration is indicated in HE-SIG-A field. In an HE TB PPDU, the combination
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`of HE-LTF type and GI duration is indicated in the Trigger frame that triggers transmission of the
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`PPDU. If an HE PPDU is an HE sounding NDP, the combinations of HE-LTF types and GI
`
`durations are listed in 27.3.18 (Transmit specification). If an HE PPDU is an HE TB feedback
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`NDP, the combination of HE-LTF types and GI durations are listed in 27.3.4 (HE PPDU
`
`formats.”); Section 27.3.15.1 (SU-MIMO and DL-MIMO beamforming) (“The DL MU-MIMO
`
`steering matrix Qk = [Qk,0, Qk,1,…,Qk,Nuser,r-1] can be detected by the beamformer using the
`
`beamforming feedback for subcarrier k from beamformee u, where u = 0,1,…Nuser,r -1. The
`
`feedback report format is described in 9.4.1.65 (HE Compressed Beamforming Report field) and
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`9.4.1.66 (HE MU Exclusive Beamforming Report field). The steering matrix that is computed (or
`
`updated) using new beamforming feedback from some or all of participating beamformees might
`
`replace the existing steering matrix Qk for the next DL MU-MIMO data transmission. For SU-
`
`MIMO beamforming, the steering matrix Qk can be determined from the beamforming feedback
`
`
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`15
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`Exhibit 1018
`Page 15 of 25
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`matrix Vk that is sent back to the beamformer by the beamformee using the compressed
`
`beamforming feedback matrix format as defined in 19.3.12.3.6 (Compressed beamforming
`
`feedback matrix). The feedback report format is described in 9.4.1.65 (HE Compressed
`
`Beamforming Report field.”). See, e.g., IEEE 802.11ac Standard Clause 9.31.5.1 (“Transmit
`
`beamforming and DL-MU-MIMO require knowledge of the channel state to compute a steering
`
`matrix that is applied to the transmitted signal to optimize reception at one or more receivers. The
`
`STA transmitting using the steering matrix is called the VHT beamformer and a STA for which
`
`reception is optimized is called a VHT beamformee. An explicit feedback mechanism is used
`
`where the VHT beamformee directly measures the channel from the training symbols transmitted
`
`by the VHT beamformer and sends back a transformed estimate of the channel state to the VHT
`
`beamformer. The VHT beamformer then uses this estimate, perhaps combining estimates from
`
`multiple VHT beamformees, to derive the steering matrix.”); See, e.g., 802.11ac Standard Clause
`
`9.31.5.2 (“A VHT beamformer shall initiate a sounding feedback sequence by transmitting a VHT
`
`NDP Announcement frame followed by a VHT NDP after a SIFS. The VHT beamformer shall
`
`include in the VHT NDP Announcement frame one STA Info field for each VHT beamformee that
`
`is expected to prepare VHT Compressed Beamforming feedback and shall identify the VHT
`
`beamformee by including the VHT beamformee’s AID in the AID subfield of the STA Info field.
`
`The VHT NDP Announcement frame shall include at least one STA Info field.”); id. (“A non-AP
`
`VHT beamformee that receives a VHT NDP Announcement frame… shall transmit its VHT
`
`Compressed Beamforming feedback a SIFS after receiving a Beamforming Report Poll with RA
`
`matching its MAC address and a non-bandwidth signaling TA obtained from the TA field
`
`matching the MAC address of the VHT beamformer.”); id. Clause 8.5.23.2 (defining format and
`
`subfields within the VHT Compressed Beamforming frame); id. Clause 8.4.1.48 (including Tables
`
`
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`16
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`Exhibit 1018
`Page 16 of 25
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`8-53(d)-(h)) (“Each SNR value per tone in stream i (before being averaged) corresponds to the
`
`SNR associated with the column i of the beamforming feedback matrix V determined at the
`
`beamformee”); id. Clause 8.4.1.49 (including Table 8-53i – MU Exclusive Beamforming Report
`
`information); id. Clauses 8.4.1.24, 9.31.5.1, 9.31.5.2; id. Clauses 22.3.4.6(d), 22.3.4.7(e),
`
`22.3.4.8(l), 22.3.4.9.1(m), 22.3.4.9.2(m), 22.3.4.10.4(a) (“Spatial mapping: Apply the Q matrix as
`
`described in 22.3.10.11.1.”); id. Clause 22.3.10.11.1; IEEE 802.11-2012 Standard Clause
`
`20.3.12.3.6; 802.11ac Standard Clauses 8.4.1.24, 9.31.5.1, 9.31.5.2; id. Clause 22.3.11.1:
`
`; id. Clause 22.3.11.2:
`
`
`
`
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`28.
`
`Each ’235 Accused Product performs a method for use in a wireless
`
`communications system, the method comprising determining a set of weighting values based on
`
`the first signal information and the second signal information, wherein the set of weighting values
`
`
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`17
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`Exhibit 1018
`Page 17 of 25
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`
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`is configured to be used by the remote station to construct one or more beam-formed transmission
`
`signals, and transmitting to the remote station a third signal comprising content based on the set of
`
`weighting values. For example, as with each ’235 Accused Product, the Envy 15 Laptop
`
`determines a set of weighting values based on the first signal information and the second signal
`
`information, wherein the set of weighting values is configured to be used by the remote station to
`
`construct one or more beam-formed transmission signals, and transmits to the remote station a
`
`third signal comprising content based on the set of weighting values, by determining the
`
`parameters of the beamforming feedback matrix, which include weighting values