`Case 1:23-cv-00633 Document 1-4 Filed 06/02/23 Page 1 of 23
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`EXHIBIT D
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`EXHIBIT D
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`Case 1:23-cv-00633 Document 1-4 Filed 06/02/23 Page 2 of 23
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`NXP– INFRINGEMENT CLAIM CHART – U.S. PATENT NO. RE 48,629
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`Bell Northern Research (“BNR”) provides evidence of infringement of exemplary claims 1, 8, 9, 10, 11, 13, 14, 19, 20 and 27 of U.S. Patent No. RE
`48,629 (hereinafter “the ’629 patent”) by the NXP 88W8997 2.4/5 GHz Dual-Band 2x2 Wi-Fi 5 (802.11ac) + Bluetooth 5.3 system-on-chip
`(“88W8997”) produced by NXP. These claim charts demonstrate infringement by comparing each element of the asserted claims to corresponding
`components, aspects, and/or features of the Accused Products. These claim charts are not intended to constitute an expert report on infringement. These
`claim charts include information provided by way of example, and not by way of limitation.
`
`The information in this chart is exemplary, based only upon information from available resources, and is only intended to evidence BNR’s present
`theory (or theories) of infringement as of the date of service. BNR provides these infringement contentions before obtaining discovery from Respondent.
`BNR expects that Respondent and/or third parties will produce additional information regarding the Respondent’s products and processes beyond that
`which is presently publicly available. Accordingly, BNR reserves the right to supplement this infringement analysis once such information is made
`available to BNR. Furthermore, BNR reserves the right to revise this infringement analysis, as appropriate, upon issuance of a court order construing
`any terms recited in the asserted claims.
`
`The Accused Processes, identified below, are performed using one or more one or more wireless communications device and comprise the claimed
`methods described below. The Accused Products include NXP products that practice 802.11ac and/or 802.11ax. These include, but are not limited to
`the NXP 88Q9098, 88Q9098S, 88W8801, 88W8887, 88W8897, 88W8897P, 88W8964, 88W8977, 88W8987, 88W8987S, 88W9054, 88W9098,
`AW690, CW641, IW416, IW612, and IW620 products. One such device, the 88W8997 is charted below.
`
`Unless otherwise noted, BNR contends that NXP and customers of NXP directly infringe under 35 U.S.C. § 271(a) the ’914 patent by using the systems
`claimed below within the United States. In particular, on information and belief, NXP at least infringes § 271(a) via testing of its Accused Products
`within the United States and NXP’s customers and their end users infringe § 271(a) by testing and using products containing the Accused Products to
`communicate over wireless networks using the 802.11ac standard or subsequent backwards-compatible standards, which testing and use practice the
`systems in accordance with the 802.11ac standard as set forth below.
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`In addition, BNR contends that NXP induces its customers and their end users to infringe pursuant to 35 U.S.C. § 271(b). BNR also contends that
`NXP contributes to infringement by offering to sell within the United States, selling within the United States, and importing into the United States an
`apparatus for use in practicing the ’914 Patented Processes under 35 U.S.C. § 271(c). The Accused Products form a material part of the invention
`(lacking only external antennas), and the Accused Processes are especially adapted for use infringement of the’914 patent by practicing 802.11ac or
`subsequent backwards-compatible wireless networking standards and are not stable articles of commerce suitable for substantial non-infringing use.
`
`Unless otherwise noted, BNR believes and contends that each element of each claim asserted herein is literally met through NXP’s testing of the
`Accused Products. However, to the extent that NXP attempts to allege that any asserted claim element is not literally met, BNR believes and contends
`that such elements are met under the doctrine of equivalents. More specifically, in its investigation and analysis of the Accused Products, BNR did not
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`NXP– INFRINGEMENT CLAIM CHART – U.S. PATENT NO. RE 48,629
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`identify any substantial differences between the elements of the patent claims and the corresponding features of the Accused Products, as set forth
`herein. In each instance, the identified step of the Accused Processes is performed by the Accused Products for at least substantially the same function
`in substantially the same way to achieve substantially the same result as the corresponding claim element.
`
`To the extent the chart of an asserted claim relies on evidence about certain specifically-identified Accused Products, BNR asserts that, on information
`and belief, any similarly-functioning instrumentalities also infringe the charted claims. BNR reserves the right to amend this infringement analysis
`based on other products made, used, sold, imported, or offered for sale by NXP. BNR further reserves the right to amend this infringement analysis
`by adding, subtracting, or otherwise modifying content in the Exemplary Evidence column of each chart.
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`NXP – INFRINGEMENT CLAIM CHART – U.S. PATENT NO. RE 48,629
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`
`Accused Instrumentalities
`Upon information and belief, NXP is the direct infringer practicing the claim recited here by, for example,
`NXP’s 88W8997 wireless communications device that is compatible with the 802.11n standard (IEEE Std.
`802.11-2016).
`
`
`
`
`Claim #
`1. A wireless
`communications
`device, comprising:
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`NXP – INFRINGEMENT CLAIM CHART – U.S. PATENT NO. RE 48,629
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`https://www.nxp.com/docs/en/fact-sheet/88W8997-FACT-SHEET.pdf
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`NXP – INFRINGEMENT CLAIM CHART – U.S. PATENT NO. RE 48,629
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`https://www.nxp.com/assets/block-diagram/en/88W8997.pdf
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`NXP – INFRINGEMENT CLAIM CHART – U.S. PATENT NO. RE 48,629
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`
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`Source: https://standards.ieee.org/standard/802_11-2016.html
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`NXP’s 88W8997 includes, for example, a signal generator that generates an extended long training
`sequence in compliance with the 802.11n standard.
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`[i] a signal generator
`that generates an
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`extended long training
`sequence; and
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`NXP – INFRINGEMENT CLAIM CHART – U.S. PATENT NO. RE 48,629
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`
`See, e.g.:
`
`
`20.3.9.4.6 HT-LTF definition
`
`The HT-LTF provides a means for the receiver to estimate the MIMO channel between the set of
`QAM mapper outputs (or, if STBC is applied, the STBC encoder outputs) and the receive chains. If
`the transmitter is providing training for exactly the space-time streams (spatial mapper inputs) used
`for the transmission of the PSDU, the number of training symbols, NLTF, is equal to the number of
`space-time streams, NSTS, except that for three space-time streams, four training symbols are required.
`If the transmitter is providing training for more space-time streams (spatial mapper inputs) than the
`number used for the transmission of the PSDU, the number of training symbols is greater than the
`number of space-time streams. This latter case happens in a sounding PPDU.
`
`The HT-LTF portion has one or two parts. The first part consists of one, two, or four HT-LTFs that
`are necessary for demodulation of the HT-Data portion of the PPDU. These HT-LTFs are referred to
`as HT-DLTFs. The optional second part consists of zero, one, two, or four HT-LTFs that may be used
`to sound extra spatial dimensions of the MIMO channel that are not utilized by the HT-Data portion
`of the PPDU. These HT-LTFs are referred to as HT-ELTFs. If a receiver has not advertised its ability
`to receive HT-ELTFs, it shall either issue a PHY-RXEND.indicate(UnsupportedRate) primitive upon
`reception of a frame that includes HT-ELTFs or decode that frame. (When an HT packet includes
`one or more HT-ELTFs, it is optional for a receiver that has not advertised its capability to receive
`HT-ELTFs to decode the data portion of the PPDU.)
`
`...
`
`The HT-LTF sequence shown in Equation (20-23) is transmitted in the case of 20 MHz operation.
`
`
`HT-LTF-28,28 = {1, 1, 1, 1, –1, –1, 1, 1, –1, 1, –1, 1, 1, 1, 1, 1, 1, –1, –1, 1, 1, –1, 1, –1, 1, 1, 1,
`1, 0, 1, –1, –1, 1, 1, –1, 1, –1, 1, –1, –1, –1, –1, –1, 1, 1, –1, –1, 1, –1, 1, –1, 1, 1, 1, 1, –1, –
`1}
` (20-23)
`
`NOTE—This sequence is an extension of the L-LTF where the four extra subcarriers are filled with
`+1 for negative frequencies and –1 for positive frequencies.
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`[ii] an Inverse Fourier
`Transformer
`operatively coupled to
`the signal generator,
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`NXP – INFRINGEMENT CLAIM CHART – U.S. PATENT NO. RE 48,629
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`802.11n-2009, Section 20.3.9.4.6; see also, e.g., 802.11-2016, Section 19.3.9.4.6
`
`The High Throughput Long Training Field (HT-LTF), Extension HT-LTF (HT-ELTF), and Data HT-LTF
`generated by the signal generator are extended long training sequences because they use a greater number
`of active OFDM subcarriers (56) when compared to the long training field used in legacy wireless
`networks such as 802.11a/g. (See ’629 patent at 2:24-26.)
`
`NXP’s 88W8997 includes, for example, an Inverse Fourier Transformer operatively coupled to the signal
`generator in compliance with the 802.11n standard.
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`19.3.4 Overview of the PPDU encoding process
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`The encoding process is composed of the steps described below. The following overview is intended to
`facilitate an understanding of the details of the convergence procedure:
`…
`b) Construct the PHY preamble SIGNAL fields from the appropriate fields of the TXVECTOR by adding
`tail bits, applying convolutional coding, formatting into one or more OFDM symbols, applying cyclic
`shifts, applying spatial processing, calculating an inverse Fourier transform for each OFDM symbol and
`transmit chain, and prepending a cyclic prefix or GI to each OFDM symbol in transmit chain. The number
`and placement of the PHY preamble SIGNAL fields depend on the frame format being used.
`
`
`Source: IEEE Std. 802.11-2016 (p. 2349)
`
`
`The generation of HT-DLTFs is shown in Figure 20-9. The generation of HT-ELTFs is shown in
`Figure 20-10. In these figures, and in the following text, the following notational conventions are
`used:
`— [X] m , n indicates the element in row m and column n of matrix X
`— [X] N indicates a matrix consisting of the first N columns of matrix X
`— [X] M , N indicates a matrix consisting of columns M through N of matrix X
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`NXP – INFRINGEMENT CLAIM CHART – U.S. PATENT NO. RE 48,629
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`where
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`...
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`M ≤ N
`X is either Qk or PHTLTF
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`NXP – INFRINGEMENT CLAIM CHART – U.S. PATENT NO. RE 48,629
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`802.11n-2009, Section 20.3.9.4.6; see also, e.g., 802.11-2016, Section 19.3.9.4.6
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`See 802.11-2016 at p. 2372.
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`NXP’s 88W8997 includes, for example, an Inverse Fourtier Transformer that processes the extended long
`training sequence from the signal generator and provides an optimal extended long training sequence with
`a minimal peak-to-average ratio in compliance with the 802.11n standard.
`
`
`See, e.g.:
`The generation of HT-DLTFs is shown in Figure 20-9. The generation of HT-ELTFs is shown in
`Figure 20-10. In these figures, and in the following text, the following notational conventions are
`used:
`— [X] m , n indicates the element in row m and column n of matrix X
`— [X] N indicates a matrix consisting of the first N columns of matrix X
`— [X] M , N indicates a matrix consisting of columns M through N of matrix X
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`[iii] wherein the
`Inverse Fourier
`Transformer
`processes the
`extended long training
`sequence from the
`signal generator and
`provides an optimal
`extended long training
`sequence with a
`minimal peak-to-
`average ratio, and
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`NXP – INFRINGEMENT CLAIM CHART – U.S. PATENT NO. RE 48,629
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`where
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`...
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`M ≤ N
`X is either Qk or PHTLTF
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`NXP – INFRINGEMENT CLAIM CHART – U.S. PATENT NO. RE 48,629
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`802.11n-2009, Section 20.3.9.4.6; see also, e.g., 802.11-2016, Section 19.3.9.4.6
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`See 802.11-2016 at p. 2372
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`On information the extended long training sequence taught by the 802.11n-2009 and 802.11-2016
`standards is optimal because it has a peak-to-average ratio of 3.6 dB. This peak-to-average ratio
`corresponds to the “minimal” peak-to-average power ratio of 3.6 dB as taught by the specification of the
`’629 patent. (’629 patent at 5:30-35.)
`
`
`NXP’s 88W8997 includes, for example, at least an optimal extended long training sequence that is carried
`by a greater number of subcarriers than a standard wireless networking configuration for an Orthogonal
`Frequency Division Multiplexing scheme in compliance with the 802.11n standard.
`
`
`See, e.g.:
`
`
`20.3.9.4.6 HT-LTF definition
`...
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`[iv] wherein at least
`the optimal extended
`long training
`sequence is carried by
`a greater number of
`subcarriers than a
`standard wireless
`networking
`configuration for an
`Orthogonal Frequency
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`Division Multiplexing
`scheme,
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`[v] wherein the
`optimal extended long
`training sequence is
`carried by exactly 56
`active sub-carriers,
`and
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`NXP – INFRINGEMENT CLAIM CHART – U.S. PATENT NO. RE 48,629
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`The HT-LTF sequence shown in Equation (20-23) is transmitted in the case of 20 MHz operation.
`
`
`HT-LTF-28,28 = {1, 1, 1, 1, –1, –1, 1, 1, –1, 1, –1, 1, 1, 1, 1, 1, 1, –1, –1, 1, 1, –1, 1, –1, 1, 1, 1,
`1, 0, 1, –1, –1, 1, 1, –1, 1, –1, 1, –1, –1, –1, –1, –1, 1, 1, –1, –1, 1, –1, 1, –1, 1, 1, 1, 1, –1, –
`1}
` (20-23)
`
`NOTE—This sequence is an extension of the L-LTF where the four extra subcarriers are filled with
`+1 for negative frequencies and –1 for positive frequencies.
`
`802.11n-2009, Section 20.3.9.4.6; see also, e.g., 802.11-2016, Section 19.3.9.4.6
`
`The optimal extended long training sequence shown above uses 56 active OFDM subcarriers. This is a
`greater number of subcarriers than the 52 active subcarriers used by legacy (i.e., standard) wireless
`networking schemes such as 802.11a/g. (See ’629 patent at 2:24-26.)
`
`
`NXP’s 88W8997 includes, for example, an optimal extended long training sequence that is carried by
`exactly 56 active sub-carriers in compliance with the 802.11n standard.
`
`See, e.g.:
`20.3.9.4.6 HT-LTF definition
`...
`The HT-LTF sequence shown in Equation (20-23) is transmitted in the case of 20 MHz operation.
`
`
`HT-LTF-28,28 = {1, 1, 1, 1, –1, –1, 1, 1, –1, 1, –1, 1, 1, 1, 1, 1, 1, –1, –1, 1, 1, –1, 1, –1, 1, 1, 1,
`1, 0, 1, –1, –1, 1, 1, –1, 1, –1, 1, –1, –1, –1, –1, –1, 1, 1, –1, –1, 1, –1, 1, –1, 1, 1, 1, 1, –1, –
`1}
` (20-23)
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`802.11n-2009, Section 20.3.9.4.6; see also, e.g., 802.11-2016, Section 19.3.9.4.6
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`NXP – INFRINGEMENT CLAIM CHART – U.S. PATENT NO. RE 48,629
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`NXP’s 88W8997 includes, for example and in compliance with the 802.11n standard, an optimal extended
`long training sequence that is represented by encodings for indexed sub-carriers -28 to +28, excluding
`indexed sub-carrier 0 which is set to zero, as follows:
`
`
`
`
`
`See, e.g.:
`20.3.9.4.6 HT-LTF definition
`...
`The HT-LTF sequence shown in Equation (20-23) is transmitted in the case of 20 MHz operation.
`
`
`HT-LTF-28,28 = {1, 1, 1, 1, –1, –1, 1, 1, –1, 1, –1, 1, 1, 1, 1, 1, 1, –1, –1, 1, 1, –1, 1, –1, 1, 1, 1,
`1, 0, 1, –1, –1, 1, 1, –1, 1, –1, 1, –1, –1, –1, –1, –1, 1, 1, –1, –1, 1, –1, 1, –1, 1, 1, 1, 1, –1, –
`1}
` (20-23)
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`802.11n-2009, Section 20.3.9.4.6; see also, e.g., 802.11-2016, Section 19.3.9.4.6
`
`
`See claim 1.
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`[vi] wherein the
`optimal extended long
`training sequence is
`represented by
`encodings for indexed
`sub-carriers -28 to
`+28, excluding
`indexed sub-carrier 0
`which is set to zero,
`as follows:
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`8. The wireless
`communications
`device according to
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`NXP – INFRINGEMENT CLAIM CHART – U.S. PATENT NO. RE 48,629
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`NXP’s 88W8997 includes binary phase shift key encoding that is used for each sub-carrier above the +26
`indexed sub-carrier and below the -26 indexed sub-carrier.
`
`For example, because the subcarriers used by the HT-LTF, HT-DLTF, and HT-ELTS sequences are all
`encoded as +1 or -1, the subcarriers are BPSK encoded. This includes each sub-carrier above the +26
`indexed sub-carrier and below the -26 indexed sub-carrier.
`
`See claim 1[iv].
`
`See claim 1.
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`NXP’s 88W8997 includes an Inverse Fourier Transformer that comprises an Inverse Fast Fourier
`Transformer or an Inverse Discrete Fourier Transformer.
`
`See claim 1[iii].
`
`
`
`
`
`
`See claim 1.
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`For example, NXP intends that the 88W8997 be deployed within one or more of the following: a personal
`digital assistant, a laptop computer, a personal computer, a processor, or a cellular phone, and operated
`within the claimed system.
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`claim 1, wherein a
`binary phase shift key
`encoding is used for
`each sub-carrier
`above the +26
`indexed sub-carrier
`and below the -26
`indexed sub-carrier.
`
`9. The wireless
`communications
`device according to
`claim 1, wherein the
`Inverse Fourier
`Transformer
`comprises an Inverse
`Fast Fourier
`Transformer or an
`Inverse Discrete
`Fourier Transformer.
`
`10. The wireless
`communications
`device according to
`claim 1, wherein the
`wireless
`communications
`device comprises one
`or more of the
`following: a personal
`digital assistant, a
`laptop computer, a
`personal computer, a
`
`
`
`
`
`
`
`processor, and a
`cellular phone.
`11. The wireless
`communications
`device according to
`claim 1, wherein the
`wireless
`communications
`device comprises a
`wireless mobile
`communications
`device.
`13. The wireless
`communications
`device according to
`claim 1, wherein the
`wireless
`communications
`device is backwards
`compatible with
`legacy wireless local
`area network devices.
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`NXP – INFRINGEMENT CLAIM CHART – U.S. PATENT NO. RE 48,629
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`
`See claim 1.
`
`For example, NXP intends that the 88W8997 be deployed within a wireless mobile communications device
`and operated within the claimed system.
`
`
`
`See claim 1.
`
`NXP’s 88W8997 is, for example, a wireless communications device that is backwards compatible with
`legacy wireless local area network devices such as 802.11a and 802.11g compliant legacy devices.
`
`See, e.g.:
`
`
`19.1.1 Introduction to the HT PHY
`
`Clause 19 specifies the PHY entity for a high-throughput (HT) orthogonal frequency division
`multiplexing (OFDM) system.
`
`In addition to the requirements found in Clause 19, an HT STA shall be capable of transmitting and
`receiving frames that are compliant with the mandatory PHY specifications defined as follows:
`— In Clause 17 when the HT STA is operating in a 20 MHz channel width in the 5 GHz band
`— In Clause 16 and Clause 18 when the HT STA is operating in a 20 MHz channel width in the
`2.4 GHz band
`
`
`802.11-2016 Section 19.1.1
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`NXP – INFRINGEMENT CLAIM CHART – U.S. PATENT NO. RE 48,629
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`See Claim [1], which describes the infringing nature of NXP’s 88W8997, which is compliant with the
`802.11n standard and newer versions of 802.11 that are backwards compatible with legacy wireless local
`area network devices.
`
`
`See claim 1.
`
`NXP’s 88W8997 includes, for example, an optimal extended long training sequence that is longer than a
`long training training sequence used by a legacy wireless local area network device in accordiance with a
`legacy wireless networking protocol standard.
`
`See claim 1[iv].
`
`See claim 1.
`
`NXP’s 88W8997 includes, for example, an extended long training sequence or an optimal extended long
`training sequence that is encoded using binary phase shift key encoding on each of the 56 active
`subcarriers.
`
`See claim 1[ii], [vi].
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`14. The wireless
`communications
`device according to
`claim 1, wherein the
`optimal extended long
`training sequence is
`longer than a long
`training sequence
`used by a legacy
`wireless local area
`network device in
`accordance with a
`legacy wireless
`networking protocol
`standard.
`19. The wireless
`communications
`device according to
`claim 1, wherein the
`extended long training
`sequence or the
`optimal extended long
`training sequence is
`encoded using binary
`phase shift key
`encoding on each of
`the 56 active
`subcarriers.
`
`
`
`
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`NXP – INFRINGEMENT CLAIM CHART – U.S. PATENT NO. RE 48,629
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`See claim 1.
`
`NXP’s 88W8997 includes, for example, a symbol mapper operatively coupled to the signal generator,
`wherein the symbol mapper receives coded bits and generates symbols for each of 64 subcarriers of an
`Orthogonal Frequency Division Multiplexing sequence.
`
`See, e.g.:
`
`
`20.3.3 Transmitter block diagram
`***
`f) Constellation mapper maps the sequence of bits in each spatial stream to constellation points
`(complex numbers).
`***
`
`20. The wireless
`communications
`device according to
`claim 1, comprising: a
`symbol mapper
`operatively coupled to
`the signal generator,
`wherein the symbol
`mapper receives
`coded bits and
`generates symbols for
`each of 64 subcarriers
`of an Orthogonal
`Frequency Division
`Multiplexing
`sequence.
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`20.3.4 Overview of the PPDU encoding process
`***
`p) Map each of the complex numbers in each of the NST subcarriers in each of the OFDM symbols in
`each of the NSTS space-time streams to the NTX transmit chain inputs. For direct-mapped operation,
`NTX = NSTS , and there is a one-to-one correspondence between space-time streams and transmit chains.
`In this case, the OFDM symbols associated with each space-time stream are also associated with the
`corresponding transmit chain. Otherwise, a spatial mapping matrix associated with each OFDM
`subcarrier, as indicated by the EXPANSION_MAT parameter of the TXVECTOR, is used to perform
`a linear transformation on the vector of NSTS complex numbers associated with each subcarrier in each
`OFDM symbol. This spatial mapping matrix maps the vector of NSTS complex numbers in each
`subcarrier into a vector of NTX complex numbers in each subcarrier. The sequence of NST complex
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`NXP – INFRINGEMENT CLAIM CHART – U.S. PATENT NO. RE 48,629
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`numbers associated with each transmit chain (where each of the NST complex numbers is taken from
`the same position in the NTX vector of complex numbers across the NST subcarriers associated with an
`OFDM symbol) constitutes an OFDM symbol associated with the corresponding transmit chain. For
`details, see 20.3.11.10. Spatial mapping matrices may include cyclic shifts, as described in
`20.3.11.10.1.
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`802.11n-2009, Sections 20.3.3 & 20.3.4; see also, e.g., 802.11-2016, Sections 19.3.3 & 19.3.4
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`See claim 1.
`NXP’s 88W8997 includes, for example, an output of the Inverse Fourier Transformer that is
`operatively coupled to a time-domain windower.
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`See, e.g.:
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`20.3.3 Transmitter block diagram
`***
`f) Constellation mapper maps the sequence of bits in each spatial stream to constellation points
`(complex numbers).
`***
`
`27. The wireless
`communications
`device according to
`claim 1, wherein an
`output of the Inverse
`Fourier Transformer
`is operatively coupled
`to a time-domain
`windower.
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`20.3.4 Overview of the PPDU encoding process
`***
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`r) For each group of 𝑁𝑁𝑆𝑆𝑆𝑆 subcarriers and each of the𝑁𝑁𝑆𝑆𝑇𝑇 transmit chains, convert the subcarriers to
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`time domain using IDFT. Prepend to the Fourier-transformed waveform a circular extension of itself,
`thus forming a GI, and truncate the resulting periodic waveform to a single OFDM symbol length by
`applying time domain windowing. Determine the length of the GI according to the GI_TYPE
`parameter of the TXVECTOR. Refer to 20.3.11.10 and 20.3.11.11 for details. When beamforming is
`not used, it is sometimes possible to implement the cyclic shifts in the time domain.
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`NXP – INFRINGEMENT CLAIM CHART – U.S. PATENT NO. RE 48,629
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`802.11n-2009, Sections 20.3.3 & 20.3.4; see also, e.g., 802.11-2016, Sections 19.3.3 & 19.3.4
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`
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`Caveat: The notes and/or cited excerpts utilized herein are set forth for illustrative purposes only and are not meant to be limiting in any
`manner. For example, the notes and/or cited excerpts, may or may not be supplemented or substituted with different excerpt(s) of the
`relevant reference(s), as appropriate. Further, to the extent any error(s) and/or omission(s) exist herein, all rights are reserved to correct
`the same.
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