Case 2:22-md-03034-TGB ECF No. 114-2, PageID.8779 Filed 01/18/23 Page 1 of 8
`
`Exhibit B
`
`Neo Wireless LLC, Exhibit 2005
`Page 2005 - 1
`IPR2023-00079, Mercedes-Benz USA, LLC v. Neo Wireless LLC
`
`
`
`Exhibit B
`
`Neo Wireless LLC, Exhibit 2005
`Page 2005 - 1
`IPR2023-00079, Mercedes-Benz USA, LLC v. Neo Wireless LLC
`
`
`
`Case 2:22-md-03034-TGB ECF No. 114-2, PageID.8780 Filed 01/18/23 Page 2 of 8
`
`#
`
`Proposed By
`
`Claim Term
`
`1 Defendants
`
`“configured to”
`
`
`Defendants’
`Proposed
`Construction
`“designed to”
`
`Disputed Claim Terms12
`Claims
`Plaintiff’s Proposed
`Construction
`
`’366 Patent,
`Claims 1 & 5;
`’908 Patent,
`Claims 1–3 & 9;
`’450 Patent,
`Claim 7;
`’941 Patent,
`Claims 13 & 14;
`’302 Patent,
`Claim 23; ’512
`Patent, Claim 15
`
`
`Plain and ordinary
`meaning. No
`construction necessary.
`
`Alternatively, if a
`construction is
`necessary:
`An apparatus/element is
`“configured to”
`perform a function if it
`includes hardware
`and/or software
`enabling the
`
`1 Volkswagen Grp. of Am., Inc. and Volkswagen Grp. of Am. Chattanooga Operations, LLC, do not take a
`position on the proposed constructions for any of the Disputed Claim Terms. That said, Volkswagen Grp. of Am.,
`Inc. and Volkswagen Grp. of Am. Chattanooga Operations, LLC understand that they will be bound by any claim
`construction ruling set forth by the Court.
`2 Neo Wireless objects to the Volkswagen Defendants’ decision to take no position on any claim terms
`(contravening the parties’ agreed Discovery Plan, which Volkswagen signed). This is an attempt by the
`Volkswagen Defendants, in the IPRs that they alone filed, to adopt broad interpretations to support their invalidity
`positions; while accepting the benefit of the other Defendants’ narrow, incompatible interpretations in this Court to
`support their non-infringement positions. Neo is continuing to meet and confer with Volkswagen about this issue.
`
`Neo Wireless LLC, Exhibit 2005
`Page 2005 - 2
`IPR2023-00079, Mercedes-Benz USA, LLC v. Neo Wireless LLC
`
`
`
`Case 2:22-md-03034-TGB ECF No. 114-2, PageID.8781 Filed 01/18/23 Page 3 of 8
`
`2 Defendants
`
`’366 Patent,
`Claims 1 & 17
`
`“the ranging signal
`exhibits a low peak-
`to-average power
`ratio in the time
`domain”
`
`
`3 Defendants
`
`4
`
`Jointly Proposed
`
`’366 Patent,
`Claims 1 & 17
`
`’908 Patent,
`Claim 4
`
`“a ranging sequence
`selected from a set
`of ranging
`sequences”
`
`“wherein the
`portion of the
`frequency band
`used for
`transmission of the
`
`apparatus/element to
`perform the function.
`Plain and ordinary
`meaning. No
`construction
`necessary.
`
`Alternatively, to the
`extent construction is
`deemed necessary,
`“exhibits a low peak-to-
`average power ratio in
`the time domain”
`means “exhibits a peak-
`to-average power ratio
`in the time domain of
`9dBs or less.”
`
`Plain and ordinary
`meaning. No
`construction necessary.
`
`“wherein the portion of
`the frequency band
`used for transmission of
`the random access
`signal does not overlap
`
`Indefinite.
`
`“a ranging sequence
`selected by said
`apparatus from a set
`of ranging sequences”
`
`“wherein the portion
`of the frequency band
`used for transmission
`of the random access
`signal does not
`
`Neo Wireless LLC, Exhibit 2005
`Page 2005 - 3
`IPR2023-00079, Mercedes-Benz USA, LLC v. Neo Wireless LLC
`
`
`
`Case 2:22-md-03034-TGB ECF No. 114-2, PageID.8782 Filed 01/18/23 Page 4 of 8
`
`random access
`signal does not
`include control
`channels”
`
`“associated with”
`
`5 Defendants
`
`6 Defendants
`
`“random access
`signal”
`
`’908 Patent,
`Claims 1–2 & 9
`
`
`’908 Patent,
`Claims 1–2, 4,
`& 6–9
`
`7 Defendants
`
`“time-frequency
`resource unit”
`
`’450 Patent,
`Claims 7 & 11
`
`with the portions of the
`frequency band used
`for control channels”
`
`
`include channels
`carrying control
`information”
`
`Plain and ordinary
`meaning. No
`construction necessary.
`
`Plain and ordinary
`meaning. No
`construction necessary.
`
`Plain and ordinary
`meaning. No
`construction necessary.
`
`
`“identifying”
`
`“direct sequence
`spread spectrum
`signal”
`
`“a combination of
`time and frequency
`units designed
`according to the
`application
`requirements of the
`application that is
`being grouped”
`
`
`
`
`
`
`
`
`Neo Wireless LLC, Exhibit 2005
`Page 2005 - 4
`IPR2023-00079, Mercedes-Benz USA, LLC v. Neo Wireless LLC
`
`
`
`Case 2:22-md-03034-TGB ECF No. 114-2, PageID.8783 Filed 01/18/23 Page 5 of 8
`
`8
`
`Jointly Proposed
`
`’941 Patent,
`Claims 8 & 13
`
`“the antenna
`transmission
`scheme comprising
`a transmission
`diversity scheme or
`a multiple-input
`multiple-output
`(MIMO) scheme”
`
`
`“the antenna
`transmission scheme is
`capable of comprising
`either a MIMO scheme
`or a transmission
`diversity scheme other
`than MIMO. To avoid
`any doubt, this requires
`supporting both MIMO
`and non-MIMO
`transmission diversity
`systems.”
`
`
`
`
`
`“the mobile-station
`specific transmission
`parameters
`alternatively indicate
`an antenna
`transmission scheme
`that comprises a
`MIMO scheme or an
`antenna transmission
`scheme comprising a
`transmission diversity
`scheme other than
`MIMO, wherein the
`antenna transmission
`scheme is capable of
`comprising either a
`MIMO scheme or a
`transmission diversity
`scheme other than
`MIMO. To avoid any
`doubt, this requires
`supporting both
`MIMO and non-
`MIMO transmission
`diversity systems.”
`
`
`Neo Wireless LLC, Exhibit 2005
`Page 2005 - 5
`IPR2023-00079, Mercedes-Benz USA, LLC v. Neo Wireless LLC
`
`
`
`Case 2:22-md-03034-TGB ECF No. 114-2, PageID.8784 Filed 01/18/23 Page 6 of 8
`
`9
`
`Jointly Proposed
`
`’941 Patent,
`Claims 8 & 13
`
`“the mobile station-
`specific
`transmission
`parameters indicate
`… a corresponding
`subchannel
`configuration … the
`corresponding
`subchannel
`configuration
`characterized by
`distributed
`subcarriers or
`localized subcarriers
`in the frequency
`domain”
`
`
`“the mobile station-
`specific transmission
`parameter
`alternatively indicates
`either distributed
`subcarriers or
`localized subcarriers
`in the frequency
`domain as subchannel
`configurations”
`
`
`
`“the mobile station-
`specific transmission
`parameters indicate …
`a corresponding
`subchannel
`configuration . . the
`corresponding
`subchannel
`configuration
`characterized by
`distributed subcarriers
`or localized subcarriers
`in the frequency
`domain, wherein the
`subchannel
`configuration is capable
`of comprising either
`localized or distributed
`subcarriers. To avoid
`any doubt, this requires
`supporting both
`localized and
`distributed subchannel
`configurations.”
`
`
`
`Neo Wireless LLC, Exhibit 2005
`Page 2005 - 6
`IPR2023-00079, Mercedes-Benz USA, LLC v. Neo Wireless LLC
`
`
`
`Case 2:22-md-03034-TGB ECF No. 114-2, PageID.8785 Filed 01/18/23 Page 7 of 8
`
`’302 Patent,
`Claims 23–24,
`26, & 28
`
`’302 Patent,
`Claim 23
`
`10 Defendants
`
`“probing signal”
`
`11 Jointly Proposed
`
`12 Defendants
`
`“the probing signal
`is configured to
`occupy a portion of
`spectrum in the
`uplink frequency
`band not designated
`for transmission of
`uplink control
`signals in the
`system”
`
`
`“a receiver
`configured to
`receive a request for
`a probing signal
`from a base station
`in the system”
`
`’302 Patent,
`Claim 23
`
`Plain and ordinary
`meaning. No
`construction necessary.
`
`Plain and ordinary
`meaning. No
`construction necessary.
`
`“direct sequence
`spread spectrum
`signal”
`
`“the probing signal is
`configured to reside
`within a portion of
`spectrum in the uplink
`frequency band not
`designated for
`transmission of uplink
`control signals in the
`system.”
`
`“the probing signal is
`configured to occupy
`a portion of spectrum
`in the uplink
`frequency band not
`designated for
`transmission of uplink
`control signals in the
`Orthogonal Frequency
`Division Multiplexing
`(OFDM)
`communication
`system”
`
`“a receiver configured
`to receive a request
`for a probing signal
`from a base station in
`the Orthogonal
`Frequency Division
`Multiplexing (OFDM)
`communication
`system”
`
`
`Neo Wireless LLC, Exhibit 2005
`Page 2005 - 7
`IPR2023-00079, Mercedes-Benz USA, LLC v. Neo Wireless LLC
`
`
`
`Case 2:22-md-03034-TGB ECF No. 114-2, PageID.8786 Filed 01/18/23 Page 8 of 8
`
`13 Defendants
`
`14 Plaintiff
`
`15 Defendants
`
`“the probing signal
`is configured to
`overlap, in the time
`domain, with uplink
`signals transmitted
`over an uplink
`frequency band by
`other mobile
`devices in the
`system”
`
`
`“wherein the first
`plurality of
`subcarriers and the
`second plurality of
`subcarriers are
`received in at least
`one of the time
`slots”
`
`“second pilots of a
`second type”
`
`’302 Patent,
`Claim 23
`
`Plain and ordinary
`meaning. No
`construction necessary.
`
`’512 Patent,
`Claims 15 & 23
`
`“wherein the first
`plurality of subcarriers
`and the second plurality
`of subcarriers are
`received in at least one
`of the same time slots”
`
`“the probing signal is
`configured to overlap,
`in the time domain,
`with uplink signals
`transmitted over an
`uplink frequency band
`by other mobile
`devices in the
`Orthogonal Frequency
`Division Multiplexing
`(OFDM)
`communication
`system”
`
`Plain and ordinary
`meaning.
`
`’512 Patent,
`Claims 15 & 23
`
`Plain and ordinary
`meaning. No
`construction necessary.
`
`“pilots possessing a
`set of characteristics
`common to all base
`stations of the
`system”
`
`Neo Wireless LLC, Exhibit 2005
`Page 2005 - 8
`IPR2023-00079, Mercedes-Benz USA, LLC v. Neo Wireless LLC
`
`
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