Case 1:23-cv-00633 Document 1-6 Filed 06/02/23 Page 1 of 30
`Case 1:23-cv-00633 Document 1-6 Filed 06/02/23 Page 1 of 30
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`EXHIBIT F
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`EXHIBIT F
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`

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`Case 1:23-cv-00633 Document 1-6 Filed 06/02/23 Page 2 of 30
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`NXP – INFRINGEMENT CLAIM CHART – U.S. PATENT NO. 7,564,914
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`
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`Bell Northern Research (“BNR”) provides evidence of infringement of exemplary claims 13–14, 17, and 21–22 of U.S. Patent No.
`7,564,914 (“the ’914 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 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 ’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.
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`Case 1:23-cv-00633 Document 1-6 Filed 06/02/23 Page 3 of 30
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`NXP – INFRINGEMENT CLAIM CHART – U.S. PATENT NO. 7,564,914
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`
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`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 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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`Case 1:23-cv-00633 Document 1-6 Filed 06/02/23 Page 4 of 30
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`U.S. Patent No. 7,564,914
`
`for
`[pre] 13. A method
`communicating information in a
`communication
`system,
`the
`method comprising:
`
`NXP – INFRINGEMENT CLAIM CHART – U.S. PATENT NO. 7,564,914
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`
`Exemplary Evidence of Plaintiff’s Theory(ies) of Infringement for the Accused Instrumentalities
`Claim 13
`To the extent that the preamble is a limitation, NXP makes, uses, sells, offers for sale, imports, or
`otherwise performs a method for communicating information in a communication system.
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`Case 1:23-cv-00633 Document 1-6 Filed 06/02/23 Page 5 of 30
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`U.S. Patent No. 7,564,914
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`NXP – INFRINGEMENT CLAIM CHART – U.S. PATENT NO. 7,564,914
`
`
`Exemplary Evidence of Plaintiff’s Theory(ies) of Infringement for the Accused Instrumentalities
`
`https://www.nxp.com/docs/en/fact-sheet/88W8997-FACT-SHEET.pdf
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`Case 1:23-cv-00633 Document 1-6 Filed 06/02/23 Page 6 of 30
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`U.S. Patent No. 7,564,914
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`NXP – INFRINGEMENT CLAIM CHART – U.S. PATENT NO. 7,564,914
`
`
`Exemplary Evidence of Plaintiff’s Theory(ies) of Infringement for the Accused Instrumentalities
`
`https://www.nxp.com/assets/block-diagram/en/88W8997.pdf
`
`For example, NXP’s Accused Instrumentalities are devices that implement the 802.11ac standard, and
`newer versions of 802.11 that are backwards compatible. See, e.g., the NXP website links corresponding
`to NXP’s Accused Instrumentalities above. On information and belief, NXP’s Accused Instrumentalities
`are 802.11ac-complaint devices that use beamforming in a wireless communication system. See, e.g.:
`
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`Case 1:23-cv-00633 Document 1-6 Filed 06/02/23 Page 7 of 30
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`U.S. Patent No. 7,564,914
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`NXP – INFRINGEMENT CLAIM CHART – U.S. PATENT NO. 7,564,914
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`Exemplary Evidence of Plaintiff’s Theory(ies) of Infringement for the Accused Instrumentalities
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`U.S. Patent No. 7,564,914
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`Case 1:23-cv-00633 Document 1-6 Filed 06/02/23 Page 8 of 30
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`NXP – INFRINGEMENT CLAIM CHART – U.S. PATENT NO. 7,564,914
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`Exemplary Evidence of Plaintiff’s Theory(ies) of Infringement for the Accused Instrumentalities
`Source: https://standards.ieee.org/standard/802_11-2016.html
`
`
`
`22.1.1 Introduction to the VHT PHY
`
`Clause 22 specifies the PHY entity for a very high throughput (VHT) orthogonal frequency
`division multiplexing (OFDM) system.
`
`In addition to the requirements in Clause 22, a VHT STA shall be capable of transmitting and
`receiving PPDUs that are compliant with the mandatory PHY specifications defined in Clause
`20.
`
`The VHT PHY is based on the HT PHY defined in Clause 20, which in turn is based on the
`OFDM PHY defined in Clause 18. The VHT PHY extends the maximum number of space-time
`streams supported to eight and provides support for downlink multi-user (MU) transmissions. A
`downlink MU transmission supports up to four users with up to four space-time streams per user
`with the total number of space-time streams not exceeding eight.
`
`NOTE—A VHT SU PPDU includes individually addressed and group addressed transmissions.
`The VHT PHY provides support for 20 MHz, 40 MHz, 80 MHz, and 160 MHz contiguous
`channel widths and support for 80+80 MHz noncontiguous channel width.
`
`The VHT PHY data subcarriers are modulated using binary phase shift keying (BPSK),
`quadrature phase shift keying (QPSK), 16-quadrature amplitude modulation (16-QAM), 64-
`QAM, and 256-QAM. Forward error correction (FEC) coding (convolutional or LDPC coding)
`is used with coding rates of 1/2, 2/3, 3/4, and 5/6.
`
`...
`
`
`A VHT STA may support the following features:
`— HT-greenfield format (transmit and receive)
`— 2 or more spatial streams (transmit and receive)
`
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`Case 1:23-cv-00633 Document 1-6 Filed 06/02/23 Page 9 of 30
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`NXP – INFRINGEMENT CLAIM CHART – U.S. PATENT NO. 7,564,914
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`Exemplary Evidence of Plaintiff’s Theory(ies) of Infringement for the Accused Instrumentalities
`— 400 ns short guard interval (transmit and receive)
`— Beamforming sounding (by sending a VHT NDP)
`— Responding
`to
`transmit beamforming sounding (by providing compressed
`beamforming feedback)
`— STBC (transmit and receive)
`— LDPC (transmit and receive)
`— VHT MU PPDUs (transmit and receive)
`— Support for 160 MHz channel width
`— Support for 80+80 MHz channel width
`— VHT-MCSs 8 and 9 (transmit and receive)
`
`20.3.12 Beamforming
`
`20.3.12.1 General
`
`Beamforming is a technique in which the beamformer utilizes the knowledge of the MIMO
`channel to generate a steering matrix Qk that improves reception in the beamformee.
`
` …
`
`
`
`
`The beamforming steering matrix that is computed (or updated) from a new channel measurement
`replaces the existing Qk for the next beamformed data transmission. There are several methods
`of beamforming, differing in the way the beamformer acquires the knowledge of the channel
`matrices Hk and on whether the beamformer generates Qk or the beamformee provides feedback
`information for the beamformer to generate Qk.
`
`20.3.12.3.6 Compressed beamforming feedback matrix
`
`
`
`In compressed beamforming feedback matrix, the beamformee shall remove the space-time
`stream CSD in Table 20-10 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
`
`U.S. Patent No. 7,564,914
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`Case 1:23-cv-00633 Document 1-6 Filed 06/02/23 Page 10 of 30
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`U.S. Patent No. 7,564,914
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`[a] receiving data via a plurality
`of RF channels utilizing a
`plurality of receiving antennas;
`
`
`
`
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`NXP – INFRINGEMENT CLAIM CHART – U.S. PATENT NO. 7,564,914
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`Exemplary Evidence of Plaintiff’s Theory(ies) of Infringement for the Accused Instrumentalities
`beamformer can use these angles to decompress the matrices and determine the steering matrices
`Qk.
`
`The matrix V per tone shall be compressed as follows: The unitary Nr × Nc beamforming feedback
`matrix found by the beamformee shall be represented as shown in Equation (20-79). When the
`number of rows and columns is equal, the orthonormal column matrix becomes a unitary matrix.
`
`
`
`802.11ac-2013, Section 22.1.1 & 802.11-2012, Sections 20.3.12.1 & 20.3.12.3.6; see also, e.g.,
`802.11-2016, Sections 21.1.1 & 19.3.12.1 & 19.3.12.3.6
`
`
`NXP’s Accused Instrumentalities receive data via a plurality of RF channels utilizing a plurality of
`receiving antennas.
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`Case 1:23-cv-00633 Document 1-6 Filed 06/02/23 Page 11 of 30
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`NXP – INFRINGEMENT CLAIM CHART – U.S. PATENT NO. 7,564,914
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`Exemplary Evidence of Plaintiff’s Theory(ies) of Infringement for the Accused Instrumentalities
`
`
`U.S. Patent No. 7,564,914
`
`https://www.nxp.com/docs/en/fact-sheet/88W8997-FACT-SHEET.pdf
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`Case 1:23-cv-00633 Document 1-6 Filed 06/02/23 Page 12 of 30
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`U.S. Patent No. 7,564,914
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`NXP – INFRINGEMENT CLAIM CHART – U.S. PATENT NO. 7,564,914
`
`
`Exemplary Evidence of Plaintiff’s Theory(ies) of Infringement for the Accused Instrumentalities
`
`https://www.nxp.com/assets/block-diagram/en/88W8997.pdf
`
`For example, NXP’s Accused Instrumentalities are devices that implement the 802.11ac standard, and
`newer versions of 802.11 that are backwards compatible, and which receive data from a beamformer
`over a number of RF channels and using a number of antennas. See, e.g.:
`
`
`22.1.1 Introduction to the VHT PHY
`
`
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`U.S. Patent No. 7,564,914
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`Case 1:23-cv-00633 Document 1-6 Filed 06/02/23 Page 13 of 30
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`NXP – INFRINGEMENT CLAIM CHART – U.S. PATENT NO. 7,564,914
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`
`Exemplary Evidence of Plaintiff’s Theory(ies) of Infringement for the Accused Instrumentalities
`Clause 22 specifies the PHY entity for a very high throughput (VHT) orthogonal frequency
`division multiplexing (OFDM) system.
`
`In addition to the requirements in Clause 22, a VHT STA shall be capable of transmitting and
`receiving PPDUs that are compliant with the mandatory PHY specifications defined in Clause
`20.
`
`The VHT PHY is based on the HT PHY defined in Clause 20, which in turn is based on the
`OFDM PHY defined in Clause 18. The VHT PHY extends the maximum number of space-time
`streams supported to eight and provides support for downlink multi-user (MU) transmissions. A
`downlink MU transmission supports up to four users with up to four space-time streams per user
`with the total number of space-time streams not exceeding eight.
`
`NOTE—A VHT SU PPDU includes individually addressed and group addressed transmissions.
`The VHT PHY provides support for 20 MHz, 40 MHz, 80 MHz, and 160 MHz contiguous
`channel widths and support for 80+80 MHz noncontiguous channel width.
`
`The VHT PHY data subcarriers are modulated using binary phase shift keying (BPSK),
`quadrature phase shift keying (QPSK), 16-quadrature amplitude modulation (16-QAM), 64-
`QAM, and 256-QAM. Forward error correction (FEC) coding (convolutional or LDPC coding)
`is used with coding rates of 1/2, 2/3, 3/4, and 5/6.
`
`...
`
`
`A VHT STA may support the following features:
`— HT-greenfield format (transmit and receive)
`— 2 or more spatial streams (transmit and receive)
`— 400 ns short guard interval (transmit and receive)
`— Beamforming sounding (by sending a VHT NDP)
`— Responding
`to
`transmit beamforming sounding (by providing compressed
`beamforming feedback)
`— STBC (transmit and receive)
`
`
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`Case 1:23-cv-00633 Document 1-6 Filed 06/02/23 Page 14 of 30
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`NXP – INFRINGEMENT CLAIM CHART – U.S. PATENT NO. 7,564,914
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`
`Exemplary Evidence of Plaintiff’s Theory(ies) of Infringement for the Accused Instrumentalities
`— LDPC (transmit and receive)
`— VHT MU PPDUs (transmit and receive)
`— Support for 160 MHz channel width
`— Support for 80+80 MHz channel width
`— VHT-MCSs 8 and 9 (transmit and receive)
`
`9.31.5 VHT sounding protocol
`
`9.31.5.1 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. The VHT beamformer then uses this estimate, perhaps
`combining estimates from multiple VHT beamformees, to derive the steering matrix.
`
`9.31.5.2 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.
`The VHT NDP Announcement frame shall include at least one STA Info field.
`
`20.3.12 Beamforming
`
`20.3.12.1 General
`
`
`U.S. Patent No. 7,564,914
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`Case 1:23-cv-00633 Document 1-6 Filed 06/02/23 Page 15 of 30
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`U.S. Patent No. 7,564,914
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`feedback
`transmitting
`[b]
`information via at least one of
`said plurality of RF channels;
`
`NXP – INFRINGEMENT CLAIM CHART – U.S. PATENT NO. 7,564,914
`
`
`Exemplary Evidence of Plaintiff’s Theory(ies) of Infringement for the Accused Instrumentalities
`Beamforming is a technique in which the beamformer utilizes the knowledge of the MIMO
`channel to generate a steering matrix Qk that improves reception in the beamformee.
`
`
`The equivalent complex baseband MIMO channel model is one in which, when a vector 𝑥𝑥𝑘𝑘=
`�𝑥𝑥1,𝑥𝑥2,…𝑥𝑥𝑁𝑁𝑇𝑇𝑇𝑇�𝑇𝑇is transmitted in subcarrier k, the received vector 𝑦𝑦𝑘𝑘=�𝑦𝑦1,𝑦𝑦2,…𝑦𝑦𝑁𝑁𝑅𝑅𝑇𝑇�𝑇𝑇 is
`
`modeled as shown in Equation (20-62).
`
`***
`
`
`802.11ac-2013, Sections 22.1.1 & 9.31.5 & 9.31.5.2 & 802.11-2012, Section 20.3.12.1; see also, e.g.,
`802.11-2016, Sections 21.1.1 & 10.34.5.1 & 10.34.5.2 & 19.3.12.1
`
`
`
`
`NXP’s Accused Instrumentalities transmit feedback information via at least one of said plurality of RF
`channels.
`
`For example, NXP’s Accused Instrumentalities are devices that implement the 802.11ac standard, and
`newer versions of 802.11 that are backwards compatible, and estimate the channel characteristics, and
`send the beamformer feedback information about the channel derived from a set of beamforming
`feedback matrices V(k). See, e.g.:
`
`
`22.1.1 Introduction to the VHT PHY
`
`
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`U.S. Patent No. 7,564,914
`
`Case 1:23-cv-00633 Document 1-6 Filed 06/02/23 Page 16 of 30
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`NXP – INFRINGEMENT CLAIM CHART – U.S. PATENT NO. 7,564,914
`
`
`Exemplary Evidence of Plaintiff’s Theory(ies) of Infringement for the Accused Instrumentalities
`Clause 22 specifies the PHY entity for a very high throughput (VHT) orthogonal frequency
`division multiplexing (OFDM) system.
`
`In addition to the requirements in Clause 22, a VHT STA shall be capable of transmitting and
`receiving PPDUs that are compliant with the mandatory PHY specifications defined in Clause
`20.
`
`The VHT PHY is based on the HT PHY defined in Clause 20, which in turn is based on the
`OFDM PHY defined in Clause 18. The VHT PHY extends the maximum number of space-time
`streams supported to eight and provides support for downlink multi-user (MU) transmissions. A
`downlink MU transmission supports up to four users with up to four space-time streams per user
`with the total number of space-time streams not exceeding eight.
`
`NOTE—A VHT SU PPDU includes individually addressed and group addressed transmissions.
`The VHT PHY provides support for 20 MHz, 40 MHz, 80 MHz, and 160 MHz contiguous
`channel widths and support for 80+80 MHz noncontiguous channel width.
`
`The VHT PHY data subcarriers are modulated using binary phase shift keying (BPSK),
`quadrature phase shift keying (QPSK), 16-quadrature amplitude modulation (16-QAM), 64-
`QAM, and 256-QAM. Forward error correction (FEC) coding (convolutional or LDPC coding)
`is used with coding rates of 1/2, 2/3, 3/4, and 5/6.
`
`...
`
`
`A VHT STA may support the following features:
`— HT-greenfield format (transmit and receive)
`— 2 or more spatial streams (transmit and receive)
`— 400 ns short guard interval (transmit and receive)
`— Beamforming sounding (by sending a VHT NDP)
`— Responding
`to
`transmit beamforming sounding (by providing compressed
`beamforming feedback)
`— STBC (transmit and receive)
`
`
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`U.S. Patent No. 7,564,914
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`Case 1:23-cv-00633 Document 1-6 Filed 06/02/23 Page 17 of 30
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`NXP – INFRINGEMENT CLAIM CHART – U.S. PATENT NO. 7,564,914
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`
`Exemplary Evidence of Plaintiff’s Theory(ies) of Infringement for the Accused Instrumentalities
`— LDPC (transmit and receive)
`— VHT MU PPDUs (transmit and receive)
`— Support for 160 MHz channel width
`— Support for 80+80 MHz channel width
`— VHT-MCSs 8 and 9 (transmit and receive)
`
`9.31.5 VHT sounding protocol
`
`9.31.5.1 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. The VHT beamformer then uses this estimate, perhaps
`combining estimates from multiple VHT beamformees, to derive the steering matrix.
`
`20.3.12.3 Explicit feedback beamforming
`
`20.3.12.3.1 General
`
`In explicit beamforming, in order for STA A to transmit a beamformed packet to STA B, STA B
`
`measures the channel matrices and sends STA A either the effective channel, 𝐻𝐻𝑒𝑒𝑒𝑒𝑒𝑒, 𝑘𝑘, or the
`beamforming feedback matrix, 𝑉𝑉𝑘𝑘, for STA A to determine a steering matrix, 𝑄𝑄𝑠𝑠𝑠𝑠𝑒𝑒𝑒𝑒𝑠𝑠,𝑘𝑘=𝑄𝑄𝑘𝑘𝑉𝑉𝑘𝑘 ,
`with 𝑉𝑉𝑘𝑘 found from 𝐻𝐻𝑘𝑘𝑄𝑄𝑘𝑘, where 𝑄𝑄𝑘𝑘 is the orthonormal spatial mapping matrix that was used to
`transmit the sounding packet that elicited the 𝑉𝑉𝑘𝑘 feedback. The effective channel, 𝐻𝐻𝑒𝑒𝑒𝑒𝑒𝑒, 𝑘𝑘=𝐻𝐻𝑘𝑘𝑄𝑄𝑘𝑘
`new steering matrix 𝑄𝑄𝑠𝑠𝑠𝑠𝑒𝑒𝑒𝑒𝑠𝑠,𝑘𝑘 is found, 𝑄𝑄𝑠𝑠𝑠𝑠𝑒𝑒𝑒𝑒𝑠𝑠,𝑘𝑘 may replace 𝑄𝑄𝑠𝑠𝑠𝑠𝑒𝑒𝑒𝑒𝑠𝑠,𝑘𝑘 for the next beamformed data
`
`, is the product of the spatial mapping matrix used on transmit with the channel matrix. When
`
`transmission.
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`U.S. Patent No. 7,564,914
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`Case 1:23-cv-00633 Document 1-6 Filed 06/02/23 Page 18 of 30
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`NXP – INFRINGEMENT CLAIM CHART – U.S. PATENT NO. 7,564,914
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`
`Exemplary Evidence of Plaintiff’s Theory(ies) of Infringement for the Accused Instrumentalities
`
`NOTE— 𝑄𝑄𝑠𝑠𝑠𝑠𝑒𝑒𝑒𝑒𝑠𝑠,𝑘𝑘 is a mathematical term to update a new steering matrix for in the next
`
`beamformed data transmission.
`
`8.4.1.48 VHT Compressed Beamforming Report field
`
`The VHT Compressed Beamforming Report field is used by the VHT Compressed Beamforming
`feedback (see 8.5.23.2) to carry explicit feedback information in the form of angles representing
`compressed beamforming feedback matrices V for use by a transmit beamformer to determine
`steering matrices Q, as described in 9.29.3 and 20.3.12.3.
`*****
`
`
`
`
`20.3.12.3.6 Compressed beamforming feedback matrix
`
`
`
`In compressed beamforming feedback matrix, the beamformee shall remove the space-time
`stream CSD in Table 20-10 from the measured channel before computing a set of matrices for
`feedback to the beamformer. The beamforming feedback matrices, V(k), found by the
`
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`Case 1:23-cv-00633 Document 1-6 Filed 06/02/23 Page 19 of 30
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`NXP – INFRINGEMENT CLAIM CHART – U.S. PATENT NO. 7,564,914
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`
`Exemplary Evidence of Plaintiff’s Theory(ies) of Infringement for the Accused Instrumentalities
`beamformee are compressed in the form of angles, which are sent to the beamformer. The
`beamformer can use these angles to decompress the matrices and determine the steering matrices
`Qk.
`
`The matrix V per tone shall be compressed as follows: The unitary Nr × Nc beamforming feedback
`matrix found by the beamformee shall be represented as shown in Equation (20-79). When the
`number of rows and columns is equal, the orthonormal column matrix becomes a unitary matrix.
`
`U.S. Patent No. 7,564,914
`
`[c] requesting modification of a
`transmission
`mode
`for
`subsequent
`received data
`in
`transmitted response messages
`comprising
`said
`feedback
`information;
`
`
`
`
`
`802.11ac-2013, Sections 22.1.1 & 9.31.5 & 8.4.1.48 & 802.11-2012, Section 20.3.12.3.1, Section
`20.3.12.3.6; see also, e.g., 802.11-2016, Sections 21.1.1 & 10.34.5.1 & 19.3.12.3.1 & 9.4.1.49
`
`
`
`
`NXP’s Accused Instrumentalities request modification of a transmission mode for subsequent received
`data in transmitted response messages comprising said feedback information.
`
`For example, NXP’s Accused Instrumentalities are devices that implement the 802.11ac standard, and
`newer versions of 802.11 that are backwards compatible, and which send the beamformer the
`beamforming feedback matrix for the beamformer to determine a steering matrix, and when a new
`steering matrix is determined, the new steering matrix may provide a transmission mode for the next
`beamformed data transmission.. See, e.g.:
`
`
`22.1.1 Introduction to the VHT PHY
`
`Clause 22 specifies the PHY entity for a very high throughput (VHT) orthogonal frequency
`division multiplexing (OFDM) system.
`
`In addition to the requirements in Clause 22, a VHT STA shall be capable of transmitting and
`receiving PPDUs that are compliant with the mandatory PHY specifications defined in Clause
`20.
`
`
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`

`

`U.S. Patent No. 7,564,914
`
`Case 1:23-cv-00633 Document 1-6 Filed 06/02/23 Page 20 of 30
`
`NXP – INFRINGEMENT CLAIM CHART – U.S. PATENT NO. 7,564,914
`
`
`Exemplary Evidence of Plaintiff’s Theory(ies) of Infringement for the Accused Instrumentalities
`
`The VHT PHY is based on the HT PHY defined in Clause 20, which in turn is based on the
`OFDM PHY defined in Clause 18. The VHT PHY extends the maximum number of space-time
`streams supported to eight and provides support for downlink multi-user (MU) transmissions. A
`downlink MU transmission supports up to four users with up to four space-time streams per user
`with the total number of space-time streams not exceeding eight.
`
`NOTE—A VHT SU PPDU includes individually addressed and group addressed transmissions.
`The VHT PHY provides support for 20 MHz, 40 MHz, 80 MHz, and 160 MHz contiguous
`channel widths and support for 80+80 MHz noncontiguous channel width.
`
`The VHT PHY data subcarriers are modulated using binary phase shift keying (BPSK),
`quadrature phase shift keying (QPSK), 16-quadrature amplitude modulation (16-QAM), 64-
`QAM, and 256-QAM. Forward error correction (FEC) coding (convolutional or LDPC coding)
`is used with coding rates of 1/2, 2/3, 3/4, and 5/6.
`
`...
`
`
`A VHT STA may support the following features:
`— HT-greenfield format (transmit and receive)
`— 2 or more spatial streams (transmit and receive)
`— 400 ns short guard interval (transmit and receive)
`— Beamforming sounding (by sending a VHT NDP)
`— Responding
`to
`transmit beamforming sounding (by providing compressed
`beamforming feedback)
`— STBC (transmit and receive)
`— LDPC (transmit and receive)
`— VHT MU PPDUs (transmit and receive)
`— Support for 160 MHz channel width
`— Support for 80+80 MHz channel width
`— VHT-MCSs 8 and 9 (transmit and receive)
`
`
`
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`Case 1:23-cv-00633 Document 1-6 Filed 06/02/23 Page 21 of 30
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`NXP – INFRINGEMENT CLAIM CHART – U.S. PATENT NO. 7,564,914
`
`
`Exemplary Evidence of Plaintiff’s Theory(ies) of Infringement for the Accused Instrumentalities
`20.3.12.3 Explicit feedback beamforming
`
`20.3.12.3.1 General
`
`In explicit beamforming, in order for STA A to transmit a beamformed packet to STA B, STA B
`
`, is the product of the spatial mapping matrix used on transmit with the channel matrix. When
`
`measures the channel matrices and sends STA A either the effective channel, 𝐻𝐻𝑒𝑒𝑒𝑒𝑒𝑒, 𝑘𝑘, or the
`beamforming feedback matrix, 𝑉𝑉𝑘𝑘, for STA A to determine a steering matrix, 𝑄𝑄𝑠𝑠𝑠𝑠𝑒𝑒𝑒𝑒𝑠𝑠,𝑘𝑘=𝑄𝑄𝑘𝑘𝑉𝑉𝑘𝑘 ,
`with 𝑉𝑉𝑘𝑘 found from 𝐻𝐻𝑘𝑘𝑄𝑄𝑘𝑘, where 𝑄𝑄𝑘𝑘 is the orthonormal spatial mapping matrix that was used to
`transmit the sounding packet that elicited the 𝑉𝑉𝑘𝑘 feedback. The effective channel, 𝐻𝐻𝑒𝑒𝑒𝑒𝑒𝑒, 𝑘𝑘=𝐻𝐻𝑘𝑘𝑄𝑄𝑘𝑘
`new steering matrix 𝑄𝑄𝑠𝑠𝑠𝑠𝑒𝑒𝑒𝑒𝑠𝑠,𝑘𝑘 is found, 𝑄𝑄𝑠𝑠𝑠𝑠𝑒𝑒𝑒𝑒𝑠𝑠,𝑘𝑘 may replace 𝑄𝑄𝑠𝑠𝑠𝑠𝑒𝑒𝑒𝑒𝑠𝑠,𝑘𝑘 for the next beamformed data
`NOTE— 𝑄𝑄𝑠𝑠𝑠𝑠𝑒𝑒𝑒𝑒𝑠𝑠,𝑘𝑘 is a mathematical term to update a new steering matrix for in the next
`
`transmission.
`
`
`beamformed data transmission.
`
`U.S. Patent No. 7,564,914
`
`[d] transmitting said feedback
`information comprising channel
`estimates based on transmission
`characteristics of said received
`data via at least one of said
`plurality of receiving antennas;
`and
`
`
`
`802.11ac-2013, Section 22.1.1 & 802.11-2012, Section 20.3.12.3.1; see also, e.g., 802.11-2016,
`Sections 21.1.1 & 19.3.12.3. 1
`NXP’s Accused Instrumentalities transmit said feedback information comprising channel estimates
`based on transmission characteristics of said received data via at least one of said plurality of receiving
`antennas.
`
`For example, NXP’s Accused Instrumentalities are devices that implement the 802.11ac standard, and
`newer versions of 802.11 that are backwards compatible, and send feedback information to the
`beamformer derived from a beamforming feedback matrix, which in turn comprises signal to noise
`ratio information for each subcarrier. The feedback information is transmitted to the beamformer via at
`least one of the plurality of receiving antennas used by the beamformee. See, e.g.:
`
`
`22.1.1 Introduction to the VHT PHY
`
`Clause 22 specifies the PHY entity for a very high throughput (VHT) orthogonal frequency
`division multiplexing (OFDM) system.
`
`
`
`- 20 -
`
`

`

`U.S. Patent No. 7,564,914
`
`Case 1:23-cv-00633 Document 1-6 Filed 06/02/23 Page 22 of 30
`
`NXP – INFRINGEMENT CLAIM CHART – U.S. PATENT NO. 7,564,914
`
`
`Exemplary Evidence of Plaintiff’s Theory(ies) of Infringement for the Accused Instrumentalities
`
`In addition to the requirements in Clause 22, a VHT STA shall be capable of transmitting and
`receiving PPDUs that are compliant with the mandatory PHY specifications defined in Clause
`20.
`
`The VHT PHY is based on the HT PHY defined in Clause 20, which in turn is based on the
`OFDM PHY defined in Clause 18. The VHT PHY extends the maximum number of space-time
`streams supported to eight and provides support for downlink multi-user (MU) transmissions. A
`downlink MU transmission supports up to four users with up to four space-time streams per user
`with the total number of space-time streams not exceeding eight.
`
`NOTE—A VHT SU PPDU includes individually addressed and group addressed transmissions.
`The VHT PHY provides support for 20 MHz, 40 MHz, 80 MHz, and 160 MHz contiguous
`channel widths and support for 80+80 MHz noncontiguous channel width.
`
`The VHT PHY data subcarriers are modulated using binary phase shift keying (BPSK),
`quadrature phase shift keying (QPSK), 16-quadrature amplitude modulation (16-QAM), 64-
`QAM, and 256-QAM. Forward error correction (FEC) coding (convolutional or LDPC coding)
`is used with coding rates of 1/2, 2/3, 3/4, and 5/6.
`
`...
`
`
`A VHT STA may support the following features:
`— HT-greenfield format (transmit and receive)
`— 2 or more spatial streams (transmit and receive)
`— 400 ns short guard interval (transmit and receive)
`— Beamforming sounding (by sending a VHT NDP)
`— Responding
`to
`transmit beamforming sounding (by providing compressed
`beamforming feedback)
`— STBC (transmit and receive)
`— LDPC (transmit and receive)
`— VHT MU PPDUs (transmit and receive)
`
`
`
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`

`Case 1:23-cv-00633 Document 1-6 Filed 06/02/23 Page 23 of 30
`
`NXP – INFRINGEMENT CLAIM CHART – U.S. PATENT NO. 7,564,914
`
`
`Exemplary Evidence of Plaintiff’s Theory(ies) of Infringement for the Accused Instrumentalities
`— Support for 160 MHz channel width
`— Support for 80+80 MHz channel width
`— VHT-MCSs 8 and 9 (transmit and receive)
`
`U.S. Patent No. 7,564,914
`
`
`
`8.4.1.48 VHT Compressed Beamforming Report field
`
`The VHT Compressed Beamforming Report field is used by the VHT Compressed Beamforming
`feedback (see 8.5.23.2) to carry explicit feedback information in the form of angles representing
`compressed beamforming feedback matrices V for use by a transmit beamformer to determine
`steering matrices Q, as described in 9.29.3 and 20.3.12.3.
`The VHT Compressed Beamforming Report information has the structure and order defined in
`Table 8-53f, where Na is the number of angles used for the compressed beamforming feedback
`matrix subfield (see Table 8-53d).
`
`
`The AvgSNRi in Table 8-53h is found by computing the SNR per subcarrier in decibels for the
`subcarriers identified in Table 8-53g, and then computing the arithmetic mean of those values.
`
`
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`Case 1:23-cv-00633 Document 1-6 Filed 06/02/23 Page 24 of 30
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`
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`
`
`
`
`U.S. Patent No. 7,564,914
`
`feedback