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`Case 1:23-cv-00633 Document 1-5 Filed 06/02/23 Page 1 of 33
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`EXHIBIT E
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`Case 1:23-cv-00633 Document 1-5 Filed 06/02/23 Page 2 of 33
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`NXP – INFRINGEMENT CLAIM CHART – U.S. PATENT NO. 8,416,862
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`Bell Northern Research (“BNR”) provides evidence of infringement of exemplary claims 1, 2, 3, and 4 of U.S. Patent No. 8,416,862 (“the ’862 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 ’862 patent by using the methods
`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
`methods 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 ’862 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’862 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
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`NXP – INFRINGEMENT CLAIM CHART – U.S. PATENT NO. 8,416,862
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`that such elements are met under the doctrine of equivalents. More specifically, in its investigation and analysis of the Accused Products, BNR did not
`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. 8,416,862
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`
`Accused Instrumentalities
`Upon information and belief, NXP is the direct infringer practicing the claim recited here by, for example,
`NXP 88W8997 device that provides for feeding back transmitter beamforming information from a receiving
`wireless communication device to a transmitting wireless communication device, and is compatible with the
`802.11ac standard (IEEE Std. 802.11-2016).
`
`
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`
`
`Claim #
`1. A method for
`feeding back
`transmitter
`beamforming
`information from a
`receiving wireless
`communication
`device to a
`transmitting
`wireless
`communication
`device, the method
`comprising:
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`NXP – INFRINGEMENT CLAIM CHART – U.S. PATENT NO. 8,416,862
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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. 8,416,862
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`https://www.nxp.com/assets/block-diagram/en/88W8997.pdf
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`Source: https://standards.ieee.org/standard/802_11-2016.html
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`NXP – INFRINGEMENT CLAIM CHART – U.S. PATENT NO. 8,416,862
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`The IEEE 802.11ac physical layer is referred to as Very-High Throughput (VHT). Beamforming is an
`optional feature of 802.11ac. If a product implements beamforming, then beamforming must be
`performed according to the standard.
`
`A VHT STA may support the following features:
`…
`— Beamforming sounding (by sending a VHT NDP)
`— Responding to transmit beamforming sounding (by providing compressed beamforming
`feedback)
`
`See IEEE 802.11-2016 at p. 2497.
`
`The IEEE 802.11 standard refers to the claimed receiving wireless device as a VHT beamformee and to the
`claimed transmitting wireless device as a VHT beamformer. The standard requires an explicit feedback
`mechanism according to which the beamformee sends back a transformed estimate of the channel to the
`beamformer.
`
`“very high throughput (VHT) beamformee: A VHT station (STA) that receives a VHT physical layer
`(PHY) protocol data unit (PPDU) that was transmitted using a beamforming steering matrix and that supports
`the VHT transmit beamforming feedback mechanism.”
`See IEEE 802.11-2016 at p. 169.
`
`
`10.34.5 VHT sounding protocol
`
`10.34.5.1 General
`
`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.
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`
`See IEEE 802.11-2016 at p. 1488.
`
`
`
`21.3.11 SU-MIMO and DL-MU-MIMO Beamforming
`
`21.3.11.1 General
`
`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. With DL-MU-MIMO beamforming, disjoint subsets of the space-time streams are
`intended for reception at different STAs. For SU-MIMO beamforming, the steering matrix Qk can be
`determined from the beamforming feedback 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.
`The feedback report format is described in 9.4.1.49.
`
`See IEEE 802.11-2016 at p. 2578.
`
`The 88W8997, for example, includes the receiving wireless communication device receiving a preamble
`sequence from the transmitting wireless device in compliance with the 802.11ac standard.
`
`The receiving wireless communication device receives from the transmitting wireless device a Null Data
`Packet (NDP). The format of a NDP shows that the NDP comprises a preamble sequence.
`
`
`10.34.5.2 Rules for VHT sounding protocol sequences
`
` 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.
`
`
`See IEEE 802.11-2016 at p. 1488.
`
`[i] the receiving
`wireless
`communication
`device receiving a
`preamble sequence
`from the
`transmitting
`wireless device;
`
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`21.3.12 VHT preamble format for sounding PPDUs
`
`NDP is the only VHT sounding format.
`
`The format of a VHT NDP PPDU is shown in Figure 21-28.
`
`
`
`
`
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`NOTE—The number of VHT-LTF symbols in the NDP is determined by the SU NSTS field in VHT-
`SIG-A.
`The VHT NDP PPDU has the following properties:
`— Uses the VHT PPDU format but without the Data field.
`— Is a VHT SU PPDU as indicated by the VHT-SIG-A field.
`— Has the data bits of the VHT-SIG-B field set to a fixed bit pattern (see 21.3.8.3.6).
`
`See IEEE 802.11-2016 at p. 2580.
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`See IEEE 802.11-2016 at p. 2514.
`
`
`NXP’s 88W8997, for example, includes the receiving wireless device estimating a channel response based
`upon the preamble sequence in compliance with the 802.11ac standard.
`
`
`10.34.5 VHT sounding protocol
`
`10.34.5.1 General
`
`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
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`[ii] the receiving
`wireless device
`estimating a
`channel response
`based upon the
`preamble
`sequence;
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`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.
`
`
`See IEEE 802.11-2016 at p. 1488.
`
`
`
`
`
`
`See IEEE 802.11-2016 at p. 2501
`
`The 88W8997, for example, includes the receiving wireless device determining an estimated transmitter
`beamforming unitary matrix (V) based upon the channel response and a receiver beamforming unitary matrix
`(U) in compliance with the 802.11ac standard. For example, The 88W8997 calculates a beamforming unitary
`matrix V based on a singular value decomposition of the channel response H=UDV*, where D is a diagonal
`matrix and U is a receiver unitary matrix.
`
`The receiving wireless device determines the transmitter beamforming unitary matrix V based upon the channel
`response and a receiver beamforming unitary matrix U. The standard describes that the matrix V is orthonormal
`and when the number of rows and columns is equal it becomes unitary. The matrix V described in the standard
`is the matrix V that is recited in the claim.
`
`The matrix V is determined based upon the channel response and the receiver beamforming matrix U. See, e.g.:
`
`
`
`21.3.11.2 Beamforming Feedback Matrix V
`
`Upon receipt of a VHT NDP sounding PPDU, the beamformee shall remove the space-time stream
`CSD in Table 21-11 from the measured channel before computing a set of matrices for feedback to the
`beamformer. The beamforming feedback matrix, Vk,u, found by the beamformee u for subcarrier k
`shall be compressed in the form of angles using the method described in 19.3.12.3.6.
`
`[iii] the receiving
`wireless device
`determining an
`estimated
`transmitter
`beamforming
`unitary matrix (V)
`based upon the
`channel response
`and a receiver
`beamforming
`unitary matrix (U);
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`NXP – INFRINGEMENT CLAIM CHART – U.S. PATENT NO. 8,416,862
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`
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`See IEEE 802.11-2016 at p. 2579.
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`
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`The beamforming feedback matrices, V(k) , found by the beamformee are compressed in the form of angles,
`which are sent to the beamformer. The beamformer might use these angles to decompress the matrices and
`determine the steering matrices.
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`
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`19.3.12.3.5 Noncompressed beamforming feedback matrix
`
`In noncompressed beamforming feedback matrix, the beamformee shall remove the space-time stream
`CSD in Table 19-10 from the measured channel before computing a set of matrices for feedback to the
`beamformer. The beamforming feedback matrices, V(k), found by the beamformee are sent to the
`beamformer in the order of real and imaginary components per tone as specified in 9.4.1.29. The
`beamformer might use these matrices to determine the steering matrices, Qk.
`
`19.3.12.3.6 Compressed beamforming feedback matrix
`
`In compressed beamforming feedback matrix, the beamformee shall remove the space-time stream
`CSD in Table 19-10 from the measured channel before computing a set of matrices for feedback to the
`beamformer. The beamforming feedback matrices, V(k), found by the beamformee are compressed in
`the form of angles, which are sent to the beamformer. The beamformer might use these angles to
`decompress the matrices and determine the steering matrices Qk
`
`The matrix per tone shall be compressed as follows: The beamforming feedback orthonormal
`column matrix found by the beamformee shall be represented as shown in Equation (19-79). When the
`number of rows and columns is equal, the orthonormal column matrix becomes a unitary matrix.
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`The matrix
`
`is an Nr X Nr diagonal matrix.
`
`
`
`The compressed beamforming feedback using 19.3.12.3.6 is the only Clause 21 beamforming
`feedback format defined.
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`[iv] the receiving
`wireless device
`decomposing the
`estimated
`transmitter
`beamforming
`unitary matrix (V)
`to produce the
`transmitter
`beamforming
`information; and
`
`
`See IEEE 802.11-2016 at pp. 2397-2400.
`
`The 88W8997, for example, includes the receiving wireless device decomposing the estimated transmitter
`beamforming unitary matrix (V) to produce the transmitter beamforming information in compliance with the
`802.11ac standard. For example, The 88W8997 determines beamforming feedback matrices and compresses
`those into the form of angles.
`
`See, e.g.:
`
`
`19.3.12.3.6 Compressed beamforming feedback matrix
`
`In compressed beamforming feedback matrix, the beamformee shall remove the space-time stream
`CSD in Table 19-10 from the measured channel before computing a set of matrices for feedback to the
`beamformer. The beamforming feedback matrices, V(k), found by the beamformee are compressed in
`the form of angles, which are sent to the beamformer. The beamformer might use these angles to
`decompress the matrices and determine the steering matrices Qk
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`The matrix per tone shall be compressed as follows: The beamforming feedback orthonormal
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`NXP – INFRINGEMENT CLAIM CHART – U.S. PATENT NO. 8,416,862
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`column matrix found by the beamformee shall be represented as shown in Equation (19-79). When the
`number of rows and columns is equal, the orthonormal column matrix becomes a unitary matrix.
`
`
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`See 802.11-2016 at p. 2398.
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`The standard specifically refers to the representation of V as decomposition:
`
`
`
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`“The angles found from the decomposition process above, e.g., the values of ψi,j and φk,l, are
`quantized as described in 9.6.12.8.”
`
`
`See 802.11-2016 at p. 2400. (emphasis added).
`
`The 88W8997, for example, includes the receiving wireless device wirelessly sending the transmitter
`beamforming information to the transmitting wireless device in compliance with the 802.11ac standard. For
`example, The 88W8997 sends the compressed beamformed matrices to the beamformer.
`
`See, e.g.:
`
`According to the IEEE 802.11 standard, the transmitter beamforming information is sent back, i.e. it is sent
`by the receiving wireless device to the transmitting wireless device.
`
`
`“the Compressed Beamforming Feedback Matrix subfield is sent back to the beamformer.”
`
`
`(emphasis added) See IEEE 802.11-2016 at p. 768.
`
`
`[v] the receiving
`wireless device
`wirelessly sending
`the transmitter
`beamforming
`information to the
`transmitting
`wireless device.
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`NXP – INFRINGEMENT CLAIM CHART – U.S. PATENT NO. 8,416,862
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`“For SU-MIMO beamforming, the steering matrix Qk can be determined from the beamforming
`feedback 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. (emphasis added) The feedback report
`format is described in 9.4.1.49.”
`
`See IEEE 802.11-2016 at p. 2578.
`
` The standard further states that “The compressed beamforming feedback using 19.3.12.3.6 is the only Clause
`21 beamforming feedback format defined.”
` See IEEE 802.11-2016 at p. 2579.
`
`
`See claim 1.
`
`The 88W8997 baseband processing module, for example, is operable to produce the estimated transmitter
`beamforming unitary matrix (V) in Cartesian coordinates in compliance with the 802.11ac standard.
`
`Specifically, the matrix V is a matrix of complex numbers and, on information and belief, is first produced in
`Cartesian coordinates. The 802.11 standard further requires that this matrix is compressed. See IEEE 802.11-
`2016 at pp. 2397-2400.
`
`The 88W8997 includes a receiving wireless device converting the estimated transmitter beamforming unitary
`matrix (V) to polar coordinates. For example, The 88W8997 includes converting the unitary matrix V in polar
`coordinates.
`
`
`17.3.5.8 Subcarrier modulation mapping
`
`The OFDM subcarriers shall be modulated by using BPSK, QPSK, 16-QAM, or 64-QAM, depending on the
`RATE requested. The encoded and interleaved binary serial input data shall be divided into groups of NBPSC
`(1, 2, 4, or 6) bits and converted into complex numbers representing BPSK, QPSK, 16-QAM, or 64-QAM
`constellation points. The conversion shall be performed according to Gray-coded constellation mappings,
`
`2. The method of
`claim 1
`the
`wherein
`receiving wireless
`device determining
`an
`estimated
`transmitter
`beamforming
`unitary matrix (V)
`based upon
`the
`channel
`response
`and
`a
`receiver
`beamforming
`unitary matrix (U)
`comprises:
`the
`receiving
`wireless
`device
`producing
`the
`estimated
`transmitter
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`beamforming
`unitary matrix (V)
`in
`Cartesian
`coordinates; and
`the
`receiving
`wireless
`device
`converting
`the
`estimated
`transmitter
`beamforming
`unitary matrix (V)
`to
`polar
`coordinates.
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`NXP – INFRINGEMENT CLAIM CHART – U.S. PATENT NO. 8,416,862
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`illustrated in Figure 17-10, with the input bit, B0, being the earliest in the stream. The output values, d, are
`formed by multiplying the resulting (I+jQ) value by a normalization factor KMOD, as described in Equation
`(17-20).
` d = (I + jQ) x KMOD (17-20)
`
`Source: IEEE Std. 802.11-2016 (p. 2298)
`
`The 88W8997 baseband processing module, for example, is operable to convert the estimated
`transmitter beamforming unitary matrix (V) to polar coordinates in compliance with the 802.11ac standard.
`
`19.3.12.3.6 Compressed beamforming feedback matrix
`
`In compressed beamforming feedback matrix, the beamformee shall remove the space-time stream CSD in
`Table 19-10 from the measured channel before computing a set of matrices for feedback to the beamformer.
`The beamforming feedback matrices, V(k), found by the beamformee are compressed in the form of angles,
`which are sent to the beamformer. The beamformer might use these angles to decompress the matrices and
`determine the steering matrices Qk.
`
`The matrix V per tone shall be compressed as follows: The Nr x Nc beamforming feedback orthonormal
`column matrix V found by the beamformee shall be represented as shown in Equation (19-79). When the
`number of rows and columns is equal, the orthonormal column matrix becomes a unitary matrix.
`
`
`
`Source: IEEE Std. 802.11-2016 (p. 2398)
`
`See claim 1.
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`3. The method of
`claim 1
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`NXP – INFRINGEMENT CLAIM CHART – U.S. PATENT NO. 8,416,862
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`The channel response (H), estimated transmitter beamforming unitary matrix (V), and the receiver
`beamforming unitary matrix (U) of The 88W8997 are related by the equation:
`H=UDV*
`
`Where, D is a diagonal matrix.
`
`On information and belief, the 88W8997 uses singular value decomposition:
`
`13 Transmit Beamforming
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`The 802.11n standard does not dictate a specific approach for determining the transmitter weighting matrix.
`However, the most common approach is using singular value decomposition to calculate the transmitter
`weights.
`
`See Eldad Perahia & Robert Stacey, Next Generation Wireless LANs: 802.11n and 802.11ac, 2d ed (USA:
`Cambridge University Press, 2013) (p. 366)
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`13.2 Transmit Beamforming with SVD
`
`The motivation behind using the matrix V calculated by SVD is that it results in maximum likelihood
`performance with a linear receiver, greatly simplifying receiver design…
`
`See Eldad Perahia & Robert Stacey, Next Generation Wireless LANs: 802.11n and 802.11ac, 2d ed (USA:
`Cambridge University Press, 2013) (p. 369)
`
`
`The claimed "transmitter beamforming unitary matrix V" is the matrix V in the standard. Section 19.3.12.3.6
`refers to the matrix V as "The beamforming feedback orthonormal column matrix" and explains that "when
`the number of rows and columns is equal, the orthonormal column matrix becomes a unitary matrix". This is
`the same "transmitter beamforming unitary matrix V" that is in Claim 3.
`
`See claim 3.
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`the
`wherein
`response
`channel
`estimated
`(H),
`transmitter
`beamforming
`unitary matrix (V),
`and
`the
`receiver
`beamforming
`unitary matrix (U)
`are related by the
`equation:
`
`H=UDV*
`
`is a
`where, D
`diagonal matrix.
`
`
`4. The method of
`claim 3,
`
`
`
`
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`

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`Case 1:23-cv-00633 Document 1-5 Filed 06/02/23 Page 19 of 33
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`NXP – INFRINGEMENT CLAIM CHART – U.S. PATENT NO. 8,416,862
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`When the 88W8997 determines the estimated transmitter beamforming unitary matrix (V) based upon the
`channel response and the receiver beamforming unitary matrix (U), the baseband processing module of the
`88W8997 performs a Singular Value Decomposition (SVD) operation.
`On information and belief, the 88W8997 uses singular value decomposition:
`
`13 Transmit Beamforming
`
`The 802.11n standard does not dictate a specific approach for determining the transmitter weighting matrix.
`However, the most common approach is using singular value decomposition to calculate the transmitter
`weights.
`
`See Eldad Perahia & Robert Stacey, Next Generation Wireless LANs: 802.11n and 802.11ac, 2d ed (USA:
`Cambridge University Press, 2013) (p. 366)
`
`13.2 Transmit Beamforming with SVD
`
`The motivation behind using the matrix V calculated by SVD is that it results in maximum likelihood
`performance with a linear receiver, greatly simplifying receiver design…
`
`See Eldad Perahia & Robert Stacey, Next Generation Wireless LANs: 802.11n and 802.11ac, 2d ed (USA:
`Cambridge University Press, 2013) (p. 369)
`Upon information and belief, NXP is the direct infringer practicing the claim recited here by, for example,
`NXP 88W8997 device that is compatible with the 802.11ac standard (IEEE Std. 802.11-2016).
`
`
`the
`wherein
`receiving wireless
`device determining
`an
`estimated
`transmitter
`beamforming
`unitary matrix (V)
`based upon
`the
`channel
`response
`and
`a
`receiver
`beamforming
`unitary matrix (U)
`comprises
`a
`performing
`Value
`Singular
`Decomposition
`(SVD) operation.
`
`9. A wireless
`communication
`device comprising:
`
`
`
`
`
`
`
`
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` 18 of 32
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`Case 1:23-cv-00633 Document 1-5 Filed 06/02/23 Page 20 of 33
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`NXP – INFRINGEMENT CLAIM CHART – U.S. PATENT NO. 8,416,862
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`Case 1:23-cv-00633 Document 1-5 Filed 06/02/23 Page 21 of 33
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`NXP – INFRINGEMENT CLAIM CHART – U.S. PATENT NO. 8,416,862
`
`
`https://www.nxp.com/docs/en/fact-sheet/88W8997-FACT-SHEET.pdf
`
`
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`Case 1:23-cv-00633 Document 1-5 Filed 06/02/23 Page 22 of 33
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`NXP – INFRINGEMENT CLAIM CHART – U.S. PATENT NO. 8,416,862
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`
`
`https://www.nxp.com/assets/block-diagram/en/88W8997.pdf
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`
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`Case 1:23-cv-00633 Document 1-5 Filed 06/02/23 Page 23 of 33
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`NXP – INFRINGEMENT CLAIM CHART – U.S. PATENT NO. 8,416,862
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`
`
`
`Source: https://standards.ieee.org/standard/802_11-2016.html
`
`The 88W8997, for example, includes a plurality of Radio Frequency (RF) components operable to receive an
`RF signal and to convert the RF signal to a baseband signal.
`
`
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`[i] a plurality of
`Radio Frequency
`
`
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`Case 1:23-cv-00633 Document 1-5 Filed 06/02/23 Page 24 of 33
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`NXP – INFRINGEMENT CLAIM CHART – U.S. PATENT NO. 8,416,862
`
`
`(RF) components
`operable to receive
`an RF signal and
`to convert the RF
`signal to a
`baseband signal;
`and
`
`
`
`
`
`
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`Case 1:23-cv-00633 Document 1-5 Filed 06/02/23 Page 25 of 33
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`NXP – INFRINGEMENT CLAIM CHART – U.S. PATENT NO. 8,416,862
`
`
`https://www.nxp.com/docs/en/fact-sheet/88W8997-FACT-SHEET.pdf
`
`
`
`
`
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`Case 1:23-cv-00633 Document 1-5 Filed 06/02/23 Page 26 of 33
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`NXP – INFRINGEMENT CLAIM CHART – U.S. PATENT NO. 8,416,862
`
`
`
`https://www.nxp.com/assets/block-diagram/en/88W8997.pdf
`
`
`For example, NXP intends that the 88W8997 be deployed with a plurality of Radio Frequency (RF)
`components operable to receive an RF signal and to convert the RF signal to a baseband signal, and operated
`within the claimed system.
`
`
`
`
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`Case 1:23-cv-00633 Document 1-5 Filed 06/02/23 Page 27 of 33
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`NXP – INFRINGEMENT CLAIM CHART – U.S. PATENT NO. 8,416,862
`
`The 88W8997, for example, includes a baseband processing module.
`
`
`[ii] a baseband
`processing module
`operable to:
`
`
`
`
`
`
`
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`Case 1:23-cv-00633 Document 1-5 Filed 06/02/23 Page 28 of 33
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`NXP – INFRINGEMENT CLAIM CHART – U.S. PATENT NO. 8,416,862
`
`
`https://www.nxp.com/docs/en/fact-sheet/88W8997-FACT-SHEET.pdf
`
`
`
`
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`Case 1:23-cv-00633 Document 1-5 Filed 06/02/23 Page 29 of 33
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`NXP – INFRINGEMENT CLAIM CHART – U.S. PATENT NO. 8,416,862
`
`
`
`https://www.nxp.com/assets/block-diagram/en/88W8997.pdf
`
`For example, NXP intends that the 88W8997 be deployed with a baseband processing module, and operated
`within the claimed system.
`
`The 88W8997, for example, includes a baseband processing module operable to receive a preamble sequence
`carried by the baseband signal.
`
`
`
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`[iii] receive a
`preamble sequence
`
`
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`

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`Case 1:23-cv-00633 Document 1-5 Filed 06/02/23 Page 30 of 33
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`NXP – INFRINGEMENT CLAIM CHART – U.S. PATENT NO. 8,416,862
`
`
`See Claim 1[i].
`
`The 88W8997, for example, includes a baseband processing module operable to estimate a channel response
`based upon the preamble sequence.
`
`See Claim 1[ii].
`
`The 88W8997, for example, includes a baseband processing module operable to determine an estimated
`transmitter beamforming unitary matrix (V) based upon the channel response and a receiver beamforming
`unitary matrix (U).
`
`See Claim 1[iii].
`
`
`The 88W8997, for example, includes a baseband processing module operable to decompose the estimated
`transmitter beamforming unitary matrix (V) to produce the transmitter beamforming information.
`
`See Claim 1[iv].
`
`
`The 88W8997, for example, includes a baseband processing module operable to form a baseband signal
`employed by the plurality of RF components to wirelessly send the transmitter beamforming information to
`the transmitting wireless device.
`
`See Claim 1[v].
`
`
` 29 of 32
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`
`carried by the
`baseband signal;
`[iv] estimate a
`channel response
`based upon the
`preamble
`sequence;
`[v] determine an
`estimated
`transmitter
`beamforming
`unitary matrix (V)
`based upon the
`channel response
`and a receiver
`beamforming
`unitary matrix (U);
`[vi] decompose the
`estimated
`transmitter
`beamforming
`unitary matrix (V)
`to produce the
`transmitter
`beamforming
`information; and
`[vii] form a
`baseband signal
`employed by the
`plurality of RF
`components to
`wirelessly send the
`transmitter
`
`
`
`
`
`

`

`Case 1:23-cv-00633 Document 1-5 Filed 06/02/23 Page 31 of 33
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`NXP – INFRINGEMENT CLAIM CHART – U.S. PATENT NO. 8,416,862
`
`
`See claim 9[i]-[vi].
`
`
`
`See claim 2[i].
`
`See claim 2[i].
`
`beamforming
`information to the
`transmitting
`wireless device.
`10. The wireless
`communication
`device of claim 9,
`wherein in
`determining an
`estimated
`transmitter
`beamforming
`unitary matrix (V)
`based upon the
`channel response
`and a receiver
`beamforming
`unitary matrix (U),
`the baseband
`processing module
`is operable to
`[i] produce the
`estimated
`transmitter
`beamforming
`unitary matrix (V)
`in Cartesian
`coordinates; and
`[ii] convert the
`estimated
`transmitter
`beamforming
`unitary matrix (V)
`
`
`
`
`
` 30 of 32
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`Case 1:23-cv-00633 Document 1-5 Filed 06/02/23 Page 32 of 33
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`NXP – INFRINGEMENT CLAIM CHART – U.S. PATENT NO. 8,416,862
`
`
`See claim 9.
`
`See claim 3.
`
`
`See claim 9.
`
`See claims 3 and 4.
`
`
`to polar
`coordinates.
`11. The wireless
`communication
`device of claim 9,
`wherein the
`channel response
`(H), estimated
`transmitter
`beamforming
`unitary matrix (V),
`and the receiver
`beamforming
`unitary matrix (U)
`are related by the
`equation:
`
`H=UDV*
`where, D is a
`diagonal matrix.
`12. The wireless
`communication
`device of claim 9,
`wherein in
`determining the
`estimated
`transmitter
`beamforming
`unitary matrix (V)
`based upon the
`channel response
`and the receiver
`beamforming
`
`