throbber
Case 1:23-cv-00633 Document 1-4 Filed 06/02/23 Page 1 of 23
`Case 1:23-cv-00633 Document 1-4 Filed 06/02/23 Page 1 of 23
`
`EXHIBIT D
`
`EXHIBIT D
`
`

`

`Case 1:23-cv-00633 Document 1-4 Filed 06/02/23 Page 2 of 23
`
`NXP– INFRINGEMENT CLAIM CHART – U.S. PATENT NO. RE 48,629
`
`
`
`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.
`
`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
`
`
`
`
` 1 of 22
`
`
`

`

`Case 1:23-cv-00633 Document 1-4 Filed 06/02/23 Page 3 of 23
`
`NXP– INFRINGEMENT CLAIM CHART – U.S. PATENT NO. RE 48,629
`
`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.
`
`
`
`
`
`
`
`
`
` 2 of 22
`
`
`

`

`Case 1:23-cv-00633 Document 1-4 Filed 06/02/23 Page 4 of 23
`
`NXP – INFRINGEMENT CLAIM CHART – U.S. PATENT NO. RE 48,629
`
`
`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:
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
` 3 of 22
`
`
`

`

`Case 1:23-cv-00633 Document 1-4 Filed 06/02/23 Page 5 of 23
`
`NXP – INFRINGEMENT CLAIM CHART – U.S. PATENT NO. RE 48,629
`
`
`https://www.nxp.com/docs/en/fact-sheet/88W8997-FACT-SHEET.pdf
`
`
`
`
`
`
`
`
` 4 of 22
`
`
`

`

`Case 1:23-cv-00633 Document 1-4 Filed 06/02/23 Page 6 of 23
`
`NXP – INFRINGEMENT CLAIM CHART – U.S. PATENT NO. RE 48,629
`
`
`
`https://www.nxp.com/assets/block-diagram/en/88W8997.pdf
`
`
`
`
`
`
`
`
` 5 of 22
`
`
`

`

`Case 1:23-cv-00633 Document 1-4 Filed 06/02/23 Page 7 of 23
`
`NXP – INFRINGEMENT CLAIM CHART – U.S. PATENT NO. RE 48,629
`
`
`
`Source: https://standards.ieee.org/standard/802_11-2016.html
`
`NXP’s 88W8997 includes, for example, a signal generator that generates an extended long training
`sequence in compliance with the 802.11n standard.
`
`
`
`
` 6 of 22
`
`
`[i] a signal generator
`that generates an
`
`
`
`
`
`

`

`extended long training
`sequence; and
`
`Case 1:23-cv-00633 Document 1-4 Filed 06/02/23 Page 8 of 23
`
`NXP – INFRINGEMENT CLAIM CHART – U.S. PATENT NO. RE 48,629
`
`
`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.
`
`
`
`
`
` 7 of 22
`
`
`

`

`[ii] an Inverse Fourier
`Transformer
`operatively coupled to
`the signal generator,
`
`Case 1:23-cv-00633 Document 1-4 Filed 06/02/23 Page 9 of 23
`
`NXP – INFRINGEMENT CLAIM CHART – U.S. PATENT NO. RE 48,629
`
`
`
`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.
`
`19.3.4 Overview of the PPDU encoding process
`
`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
`
`
`
`
`
` 8 of 22
`
`
`

`

`Case 1:23-cv-00633 Document 1-4 Filed 06/02/23 Page 10 of 23
`
`NXP – INFRINGEMENT CLAIM CHART – U.S. PATENT NO. RE 48,629
`
`
`where
`
`...
`
`M ≤ N
`X is either Qk or PHTLTF
`
`
`
`
`
`
`
` 9 of 22
`
`
`
`
`
`
`

`

`Case 1:23-cv-00633 Document 1-4 Filed 06/02/23 Page 11 of 23
`
`NXP – INFRINGEMENT CLAIM CHART – U.S. PATENT NO. RE 48,629
`
`
`
`802.11n-2009, Section 20.3.9.4.6; see also, e.g., 802.11-2016, Section 19.3.9.4.6
`
`
`
`
`
`See 802.11-2016 at p. 2372.
`
`
`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
`
` 10 of 22
`
`
`[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
`
`
`
`
`
`

`

`Case 1:23-cv-00633 Document 1-4 Filed 06/02/23 Page 12 of 23
`
`NXP – INFRINGEMENT CLAIM CHART – U.S. PATENT NO. RE 48,629
`
`
`where
`
`...
`
`M ≤ N
`X is either Qk or PHTLTF
`
`
`
`
`
`
`
`
`
` 11 of 22
`
`
`

`

`Case 1:23-cv-00633 Document 1-4 Filed 06/02/23 Page 13 of 23
`
`NXP – INFRINGEMENT CLAIM CHART – U.S. PATENT NO. RE 48,629
`
`802.11n-2009, Section 20.3.9.4.6; see also, e.g., 802.11-2016, Section 19.3.9.4.6
`
`
`
`
`
`See 802.11-2016 at p. 2372
`
`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
`...
`
` 12 of 22
`
`
`[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
`
`
`
`
`
`

`

`Division Multiplexing
`scheme,
`
`[v] wherein the
`optimal extended long
`training sequence is
`carried by exactly 56
`active sub-carriers,
`and
`
`Case 1:23-cv-00633 Document 1-4 Filed 06/02/23 Page 14 of 23
`
`NXP – INFRINGEMENT CLAIM CHART – U.S. PATENT NO. RE 48,629
`
`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)
`
`802.11n-2009, Section 20.3.9.4.6; see also, e.g., 802.11-2016, Section 19.3.9.4.6
`
`
`
`
`
`
`
` 13 of 22
`
`
`

`

`Case 1:23-cv-00633 Document 1-4 Filed 06/02/23 Page 15 of 23
`
`NXP – INFRINGEMENT CLAIM CHART – U.S. PATENT NO. RE 48,629
`
`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)
`
`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.
`
`
` 14 of 22
`
`
`[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:
`
`
`
`
`
`
`
`8. The wireless
`communications
`device according to
`
`
`
`
`
`

`

`Case 1:23-cv-00633 Document 1-4 Filed 06/02/23 Page 16 of 23
`
`NXP – INFRINGEMENT CLAIM CHART – U.S. PATENT NO. RE 48,629
`
`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.
`
`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.
`
`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.
`
`
`
` 15 of 22
`
`
`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.
`
`Case 1:23-cv-00633 Document 1-4 Filed 06/02/23 Page 17 of 23
`
`NXP – INFRINGEMENT CLAIM CHART – U.S. PATENT NO. RE 48,629
`
`
`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
`
`
`
`
`
`
` 16 of 22
`
`
`

`

`Case 1:23-cv-00633 Document 1-4 Filed 06/02/23 Page 18 of 23
`
`NXP – INFRINGEMENT CLAIM CHART – U.S. PATENT NO. RE 48,629
`
`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].
`
` 17 of 22
`
`
`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.
`
`
`
`
`
`

`

`Case 1:23-cv-00633 Document 1-4 Filed 06/02/23 Page 19 of 23
`
`NXP – INFRINGEMENT CLAIM CHART – U.S. PATENT NO. RE 48,629
`
`
`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.
`
`
`
`
`
` 18 of 22
`
`
`

`

`Case 1:23-cv-00633 Document 1-4 Filed 06/02/23 Page 20 of 23
`
`NXP – INFRINGEMENT CLAIM CHART – U.S. PATENT NO. RE 48,629
`
`
`
`
`
`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
`
`
`
`
`
` 19 of 22
`
`
`

`

`Case 1:23-cv-00633 Document 1-4 Filed 06/02/23 Page 21 of 23
`
`NXP – INFRINGEMENT CLAIM CHART – U.S. PATENT NO. RE 48,629
`
`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.
`
`802.11n-2009, Sections 20.3.3 & 20.3.4; see also, e.g., 802.11-2016, Sections 19.3.3 & 19.3.4
`
`
`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.
`
`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).
`***
`
`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.
`
`
`
`
`
` 20 of 22
`
`
`

`

`Case 1:23-cv-00633 Document 1-4 Filed 06/02/23 Page 22 of 23
`
`NXP – INFRINGEMENT CLAIM CHART – U.S. PATENT NO. RE 48,629
`
`
`
`20.3.4 Overview of the PPDU encoding process
`***
`
`
`
`r) For each group of 𝑁𝑁𝑆𝑆𝑆𝑆 subcarriers and each of the𝑁𝑁𝑆𝑆𝑇𝑇 transmit chains, convert the subcarriers to
`
`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.
`
` 21 of 22
`
`
`
`
`
`
`
`
`

`

`Case 1:23-cv-00633 Document 1-4 Filed 06/02/23 Page 23 of 23
`
`NXP – INFRINGEMENT CLAIM CHART – U.S. PATENT NO. RE 48,629
`
`
`802.11n-2009, Sections 20.3.3 & 20.3.4; see also, e.g., 802.11-2016, Sections 19.3.3 & 19.3.4
`
`
`
`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.
`
`
`
`
`
` 22 of 22
`
`
`

This document is available on Docket Alarm but you must sign up to view it.


Or .

Accessing this document will incur an additional charge of $.

After purchase, you can access this document again without charge.

Accept $ Charge
throbber

Still Working On It

This document is taking longer than usual to download. This can happen if we need to contact the court directly to obtain the document and their servers are running slowly.

Give it another minute or two to complete, and then try the refresh button.

throbber

A few More Minutes ... Still Working

It can take up to 5 minutes for us to download a document if the court servers are running slowly.

Thank you for your continued patience.

This document could not be displayed.

We could not find this document within its docket. Please go back to the docket page and check the link. If that does not work, go back to the docket and refresh it to pull the newest information.

Your account does not support viewing this document.

You need a Paid Account to view this document. Click here to change your account type.

Your account does not support viewing this document.

Set your membership status to view this document.

With a Docket Alarm membership, you'll get a whole lot more, including:

  • Up-to-date information for this case.
  • Email alerts whenever there is an update.
  • Full text search for other cases.
  • Get email alerts whenever a new case matches your search.

Become a Member

One Moment Please

The filing “” is large (MB) and is being downloaded.

Please refresh this page in a few minutes to see if the filing has been downloaded. The filing will also be emailed to you when the download completes.

Your document is on its way!

If you do not receive the document in five minutes, contact support at support@docketalarm.com.

Sealed Document

We are unable to display this document, it may be under a court ordered seal.

If you have proper credentials to access the file, you may proceed directly to the court's system using your government issued username and password.


Access Government Site

We are redirecting you
to a mobile optimized page.





Document Unreadable or Corrupt

Refresh this Document
Go to the Docket

We are unable to display this document.

Refresh this Document
Go to the Docket