Apple Inc. v. Samsung Electronics Co. Ltd. et al

Filing 663

EXHIBITS re #660 Administrative Motion to File Under Seal Apple Inc.'s Notice of Motion and Motion for Partial Summary Judgment Exhibits to Mueller Declaration ISO Apple's Motion for Partial Summary Judgment [660-9] filed byApple Inc.(a California corporation). (Attachments: #1 Exhibit Mueller Decl Exhibit 43, #2 Exhibit Mueller Decl Exhibit 44, #3 Exhibit Mueller Decl Exhibit 45, #4 Exhibit Mueller Decl Exhibit 46, #5 Exhibit Mueller Decl Exhibit 47, #6 Exhibit Mueller Decl Exhibit 48, #7 Exhibit Mueller Decl Exhibit 49, #8 Exhibit Mueller Decl Exhibit 50, #9 Exhibit Mueller Decl Exhibit 51, #10 Exhibit Mueller Decl Exhibit 52, #11 Exhibit Mueller Decl Exhibit 53, #12 Exhibit Mueller Decl Exhibit 54, #13 Exhibit Mueller Decl Exhibit 55, #14 Exhibit Mueller Decl Exhibit 56, #15 Exhibit Mueller Decl Exhibit 57, #16 Exhibit Mueller Decl Exhibit 58, #17 Exhibit Mueller Decl Exhibit 59, #18 Exhibit Mueller Decl Exhibit 60, #19 Exhibit Mueller Decl Exhibit 61, #20 Exhibit Mueller Decl Exhibit 62, #21 Exhibit Mueller Decl Exhibit 63, #22 Exhibit Mueller Decl Exhibit 64, #23 Exhibit Mueller Decl Exhibit 65)(Related document(s) #660 ) (Selwyn, Mark) (Filed on 1/25/2012)

Mueller Exhibit 58

EXHIBIT B

SAMSUNG’S PATENT L.R. 3-1(A)-(D) DISCLOSURES FOR
U.S. PATENT NO. 7,050,410

ASSERTED
ACCUSED INSTRUMENTALITY AND HOW EACH ELEMENT IS MET BY ACCUSED INSTRUMENTALITY
CLAIM
(PATENT L.R. 3-1(B)-C))
(PATENT L.R.
3-1(A))
1. An uplink
Apple’s 3G products1 comprise an uplink transmitting device in a mobile communication system. See, e.g.,
transmitting
device in a
Apple iPhone user guide re iOS 3.1: (iPhone 3G or later, p. 21):
mobile
communication
system,
comprising:

http://www.apple.com/iphone/specs.html (iPhone 4):

1

“Apple’s 3G products” include iPhone 3G, iPhone 3GS, iPhone4, iPad 3G, iPad2 3G and any other products compliant with
3GPP UMTS standard.
2

iPad iOS 3.2 user guide (iPad):

3

http://www.apple.com/ipad/specs/ (iPad 2):

4

Apple’s 3G products contain a baseband processor for processing UMTS (“3G”) signals compliant with the
multiplexing and channel coding standards specified in at least 3GPP Release 6 (3GPP Technical Specification
25.212 v6.0.0 (“TS 25.212 v6.0.0”)).
V.6.0.0 specifies the uplink transmitting technique in a mobile communication system as the following diagram
shows.

5

6

[a] an encoder
for receiving a
first
information bit
stream and for
outputting
three streams,
a second
information bit
stream, a first
parity stream,
and a second
parity stream,
by encoding
the first
information bit
stream;

Apple’s 3G products have an encoder for receiving a first information bit stream and for outputting three streams, a
second information bit stream, a first parity stream, and a second parity stream, by encoding the first information bit
stream. See, e.g., TS 25.212 v6.0.0:
For example, Apple’s 3G products are compliant with V6.0.0, which specifies the channel coding block in uplink
transmission.
“Channel coding scheme is a combination of error detection, error correcting, rate matching, interleaving and
transport channels mapping onto/splitting from physical channels.” (V6.0.0, paragraph 4.1, page 9.)

7

(V6.0.0, paragraph 4.2, page 11. Annotation added)
Apple’s 3G products receive a first information bit stream ( oir1, oir 2, …, oir Ki), and output three streams, a second
information bit stream ( x1, x2,…, xK), a first parity stream ( z1, z2, …, zK), and a second parity stream ( z'1, z'2, …, z'K)
by encoding the first information bit stream.
8

“Code blocks are delivered to the channel coding block. They are denoted by oir1 , oir 2 , oir 3 ,, oirK i , where i is the
TrCH number, r is the code block number, and Ki is the number of bits in each code block. The number of code
blocks on TrCH i is denoted by Ci. After encoding the bits are denoted by y ir1 , y ir 2 , y ir 3 ,  , y irYi , where Yi is the
number of encoded bits. The relation between oirk and yirk and between Ki and Yi is dependent on the channel coding
scheme.
The following channel coding schemes can be applied to TrCHs:
- convolutional coding;
- turbo coding.”
(V6.0.0, paragraph 4.2.3, page 15.)
“Output from the Turbo coder is x1, z1, z'1, x2, z2, z'2, …, xK, zK, z'K, where x1, x2, …, xK are the bits input to the Turbo
coder i.e. both first 8-state constituent encoder and Turbo code internal interleaver, and K is the number of bits, and
z1, z2, …, zK and z'1, z'2, …, z'K are the bits output from first and second 8-state constituent encoders, respectively.”
(V6.0.0, paragraph, 4.2.3.2.1, page 16.)

[b] an
interleaver for
interleaving
the encoded
streams by a
predetermined

(V6.0.0, paragraph 4.2.3.2.1, page 17.)
Apple’s 3G products have an interleaver for interleaving the encoded streams by a predetermined interleaving rule.
See, e.g., TS 25.212 v6.0.0:

9

interleaving
rule;

(V6.0.0, paragraph 4.2, page 11. Annotation added)
“(3) Write the input bit sequence into the R1  C1 matrix row by row starting with bit xi ,1 in column 0 of row 0
and ending with bit xi ,( R1C1) in column C1 - 1 of row R1 - 1:
10

xi ,1

 x
 i ,( C11)



 xi ,(( R11)C11)


xi , 2

xi , 3

xi ,( C1 2)


xi ,( C13)


xi ,(( R11)C1 2)

xi ,(( R11)C13)

 xi ,C1 
 xi ,( 2C1) 

  

 xi ,( R1C1) 


(4) Perform the inter-column permutation for the matrix based on the pattern P1C1  j 

j0,1,,C11

shown in table 4,

where P1C1 (j) is the original column position of the j-th permuted column. After permutation of the columns,
the bits are denoted by yik:
 yi ,1 yi ,( R11) yi ,( 2R11)  yi ,(( C11)R11) 
y

 i , 2 yi ,( R1 2 ) yi ,( 2R1 2)  yi ,(( C11)R1 2)  ”
 







yi ,(3R1)  yi ,( C1R1) 
 yi ,R1 yi ,( 2R1)


(V6.0.0, paragraph 4.2.5.2, page 23)
“The bits input to the 1st interleaving are denoted by t i ,1 , t i , 2 , t i ,3 ,, t i ,Ti , where i is the TrCH number and Ti the
number of bits. Hence, zi,k = ti,k and Zi = Ti. The bits output from the 1st interleaving are denoted
by d i ,1 , d i , 2 , d i ,3 ,, d i ,Ti , and di,k = yi,k.” (V6.0.0, paragraph, 4.2.5.3, page 23.)
[c] a radio
frame
segmenter for
receiving the
interleaved
stream from
the interleaver
and mapping
the received
interleaved
stream onto at
least one
consecutive

Apple’s 3G products have a radio frame segmenter for receiving the interleaved stream from the interleaver and
mapping the received interleaved stream onto at least one consecutive radio frame. See, e.g., TS 25.212 v6.0.0:

11

radio frame;

(V6.0.0, paragraph 4.2, page 11. Annotation added)
The radio frame segmenter in Apple’s 3G products maps the received interleaved stream onto at least one
consecutive radio frame when the transmission time interval is longer than 10 ms. In this case, the input bit sequence
is mapped onto consecutive Fi radio frames.
12

“When the transmission time interval is longer than 10 ms, the input bit sequence is segmented and mapped onto
consecutive Fi radio frames. Following rate matching in the DL and radio frame size equalisation in the UL the input
bit sequence length is guaranteed to be an integer multiple of Fi.
The input bit sequence is denoted by xi1 , xi 2 , xi 3 ,, xiX i where i is the TrCH number and Xi is the number bits. The Fi

[d] a
demultiplexer
for separating
each of the at
least one radio
frames
received from
the radio frame
segmenter into
a third
information bit
stream, and
first and
second parity
streams from
the
demultiplexer;
and

output bit sequences per TTI are denoted by yi ,ni 1 , yi ,ni 2 , yi ,ni 3 ,  , yi ,niYi where ni is the radio frame number in current
TTI and Yi is the number of bits per radio frame for TrCH i. The output sequences are defined as follows:
yi ,ni k = xi , ni 1Yi k , ni = 1…Fi, k = 1…Yi
where Yi = (Xi / Fi) is the number of bits per segment.
The ni -th segment is mapped to the ni -th radio frame of the transmission time interval.”
(V6.0.0, paragraph 4.2.6, page 24.)
As part of the rate matching function (shown in the figure below), a demultiplexing operation is performed in
Apple’s 3G products. The demultiplexer in Apple’s 3G products separates each of the at least one radio frames
received from the radio frame segmenter into a third information bit stream (x1ik, i.e., the systematic bits of turbo
encoded TrCHs), and first (x2ik, i.e., first parity bits) and second (x3ik, i.e., second parity) parity streams from the
demultiplexer. See, e.g., TS 25.212 v6.0.0:

13

(V6.0.0, paragraph 4.2, page 11. Annotation added)

14

(V6.0.0, paragraph 4.2.7.3, page 36. Annotation added.)
“The first sequence contains:
- All of the systematic bits that are from turbo encoded TrCHs.
- From 0 to 2 first and/or second parity bits that are from turbo encoded TrCHs. These bits come into the first
sequence when the total number of bits in a block after radio frame segmentation is not a multiple of three.
- Some of the systematic, first parity and second parity bits that are for trellis termination.
The second sequence contains:
- All of the first parity bits that are from turbo encoded TrCHs, except those that go into the first sequence when
the total number of bits is not a multiple of three.
- Some of the systematic, first parity and second parity bits that are for trellis termination.
The third sequence contains:
- All of the second parity bits that are from turbo encoded TrCHs, except those that go into the first sequence
when the total number of bits is not a multiple of three.
- Some of the systematic, first parity and second parity bits that are for trellis termination.
The second and third sequences shall be of equal length, whereas the first sequence can contain from 0 to 2 more bits.
Puncturing is applied only to the second and third sequences.”
(V6.0.0, paragraph 4.2.7.3, pages 35-36.)

15

“For turbo encoded TrCHs with puncturing (Yi=Xi):
z i ,3( k 1)1(1   ni ) mod 3  y1,i ,k k = 1, 2, 3, …, Yi

zi ,3 Ni / 3 k  y1,i , Ni / 3 k

k = 1, …, Ni mod 3

Note: When (Ni mod 3) = 0 this row is not needed.

z i ,3( k 1)1( 2   ni ) mod 3  y 2,i ,k
zi ,3( k 1) 1 ( 3   ni ) mod 3  y3,i , k

[e] a rate
matcher for
bypassing the
third
information bit
stream and for
puncturing a
part of the first
and second
parity streams
from the
demultiplexer
according to a
given rate
matching rule.

k = 1, 2, 3, …, Yi
k = 1, 2, 3, …, Yi

After the bit collection, bits zi,k with value , where {0, 1}, are removed from the bit sequence.”
(V6.0.0, paragraph 4.2.7.3.2, page 38.)
Apple’s 3G products have a rate matcher for bypassing the third information bit stream (x1ik, i.e., the systematic bits
of turbo encoded TrCHs) and for puncturing a part of the first (x2ik) and second (x3ik) parity streams from the
demultiplexer according to a given rate matching rule. See, e.g., TS 25.212 v6.0.0:

(V6.0.0, paragraph 4.2.7.3, page 37. Annotation added.)
“The systematic bits of turbo encoded TrCHs shall not be punctured, the other bits may be punctured. The systematic
bits, first parity bits, and second parity bits in the bit sequence input to the rate matching block are therefore separated
into three sequences.” (V.6.0.0, paragraph 4.2.7.3, page 34.)

16

“The first sequence contains:
- All of the systematic bits that are from turbo encoded TrCHs.
- From 0 to 2 first and/or second parity bits that are from turbo encoded TrCHs. These bits come into the first
sequence when the total number of bits in a block after radio frame segmentation is not a multiple of three.
- Some of the systematic, first parity and second parity bits that are for trellis termination.
The second sequence contains:
- All of the first parity bits that are from turbo encoded TrCHs, except those that go into the first sequence when
the total number of bits is not a multiple of three.
- Some of the systematic, first parity and second parity bits that are for trellis termination.
The third sequence contains:
- All of the second parity bits that are from turbo encoded TrCHs, except those that go into the first sequence
when the total number of bits is not a multiple of three.
- Some of the systematic, first parity and second parity bits that are for trellis termination.
The second and third sequences shall be of equal length, whereas the first sequence can contain from 0 to 2 more bits.
Puncturing is applied only to the second and third sequences.”
(V6.0.0, paragraph 4.2.7.3, pages 35-36.)
2. The
While uplink transmitting, the radio frame segmentation in Apple’s 3G products receives the interleaved stream from
transmitting
the interleaver and maps the interleaved stream onto consecutive Fi radio frames when a transmission time interval
device of claim (TTI) is longer than 10 ms. See, e.g., TS 25.212 v6.0.0:
1, wherein the
interleaved
stream is
mapped onto
consecutive
radio frames
when a
transmission
time interval
(TTI) is longer
than 10 ms.

17

(V6.0.0, paragraph 4.2, page 10. Annotation added)
“When the transmission time interval is longer than 10 ms, the input bit sequence is segmented and mapped onto
consecutive Fi radio frames. Following rate matching in the DL and radio frame size equalisation in the UL the input
bit sequence length is guaranteed to be an integer multiple of Fi.
18

The input bit sequence is denoted by xi1 , xi 2 , xi 3 ,, xiX i where i is the TrCH number and Xi is the number bits. The Fi

3. The
transmitting
device of claim
1, wherein the
transmission
time interval
(TTI) is one of
10, 20, 40, and
80 ms.
4. The
transmitting
device of claim
1, wherein the
interleaving
rule is a bit
reverse
method.

output bit sequences per TTI are denoted by yi ,ni 1 , yi ,ni 2 , yi ,ni 3 ,  , yi ,niYi where ni is the radio frame number in current
TTI and Yi is the number of bits per radio frame for TrCH i. The output sequences are defined as follows:
yi ,ni k = xi , ni 1Yi k , ni = 1…Fi, k = 1…Yi
where Yi = (Xi / Fi) is the number of bits per segment.
The ni -th segment is mapped to the ni -th radio frame of the transmission time interval.”
(V6.0.0, paragraph 4.2.6, page 24.)
Apple’s 3G products conform to V6.0.0 which specifies the transmission time interval (TTI) to be one of 10, 20, 40,
and 80 ms. See, e.g., TS 25.212 v6.0.0:
“Data arrives to the coding/multiplexing unit in form of transport block sets once every transmission time interval.
The transmission time interval is transport-channel specific from the set {10 ms, 20 ms, 40 ms, 80 ms}.” (V6.0.0,
paragraph 4.2, page 10.)

Apple’s 3G products follow the same interleaving rule described as the bit reverse method specified in the ‘410
patent. See, e.g., TS 25.212 v6.0.0:
The following is the column permutation pattern given in V6.0.0, which confirms the interleaving rule specified in
V6.0.0. As it can be seen from the following table from V6.0.0, the Apple 3G products conform to the bit reverse
method discussed in the ‘410 patent.
Table 4 Inter-column permutation patterns for 1st interleaving
TTI
Number of columns
Inter-column permutation
C1
patterns
<P1C1(0), P1C1(1), …, P1C1(C11)>
10 ms
1
<0>
20 ms
2
<0,1>
40 ms
4
<0,2,1,3>
80 ms
8
<0,4,2,6,1,5,3,7>
19

(V.6.0.0, paragraph 4.2.5.2, page 23.)

5. The
transmitting
device of claim
1, wherein an
arrangement of
information
bits and parity
bits in each of
the at least one
radio frames
has a regular
pattern.
6. The
transmitting
device of claim
2, wherein the
consecutive
radio frames
have initial bits
determined by
the TTI.

“P1Fi (x) defines the inter column permutation function for a TTI of length Fi 10ms, as defined in Table 4 in section
4.2.5.2. P1Fi (x) is the Bit Reversal function of x on log2(Fi) bits.” (V6.0.0, paragraph 4.2.5.1, page 22.)
In Apple’s 3G products, the arrangement of information bits and parity bits at the output of the channel encoder has a
regular pattern.
“Output from the Turbo coder is x1, z1, z'1, x2, z2, z'2, …, xK, zK, z'K, where x1, x2, …, xK are the bits input to the Turbo
coder i.e. both first 8-state constituent encoder and Turbo code internal interleaver, and K is the number of bits, and
z1, z2, …, zK and z'1, z'2, …, z'K are the bits output from first and second 8-state constituent encoders, respectively.”
(V6.0.0, paragraph 4.2.3.2.1, page 16-17.)
Before these bits from the channel encoder are put into a radio frame, they are interleaved at the interleaver according
to a specified permutation pattern. After the permutation is done at the interleaver, the resulting bit patterns have a
newly permuted regularity. Thus, the arrangement of information bits and parity bits in the radio frames has a
regular pattern.
In Apple’s 3G products, initial bits in the each of the consecutive radio frames are determined by the TTI. As
described above, the number of consecutive radio frames is a function of the TTI. Then, depending on the number of
bits (p) to be inserted, the initial bits are inserted in the beginning of each of the consecutive radio frames as the
following passage indicates. See, e.g., TS 25.212 v6.0.0:
“C[x], x= 0 to Fi– 1, the number of bits p which have to be inserted in each of the Fisegments of the TTI, where x is
 Fi
the column number before permutation, i.e. in each column of the first interleaver. C[P1Fi(x)] is equal to Npimmax x for
,
x equal 0 to Fi–1 for fixed positions. It is noted NpimFi  x in the following initialisation step.” (V6.0.0, paragraph
4.2.5.1, page 22.)
The algorithm shown below indicates how the initial bits are inserted in each of the Fi segments of the TTI number
m.
“col = 0
while col < Fi do
C[P1Fi (col)] = NpimFi col

-- here col is the column number after column permutation
-- initialisation of number of bits p to be inserted in each of the Fi

20

segments of the TTI number m
cbi[P1Fi (col)] = 0
-- initialisation of counter of
number of bits p inserted in each of the Fi segments of the TTI
col = col +1
end do
n = 0, m = 0
while n < Xi do
-- from here col is the column number before column permutation
col = n mod Fi
if cbi[col] < C[col] do
xi,n = p
-- insert one p bit
cbi[col] = cbi[col]+1
-- update counter of number of bits p inserted
else
-- no more p bit to insert in this segment
xi,n = zi,,m
m = m+1
endif
n = n +1
end do”
(V6.0.0, paragraph 4.2.5.1, page 22.)
7. The
As part of the rate matching function (shown in the figure below), a demultiplexing operation is performed in
transmitting
Apple’s 3G products. The demultiplexer in Apple’s 3G products separates each of the at least one radio frames
device of claim received from the radio frame segmenter into a third information bit stream (x1ik, i.e., the systematic bits of turbo
5, wherein the encoded TrCHs), and first (x2ik, i.e., first parity bits) and second (x3ik, i.e., second parity) parity streams from the
demultiplexer
demultiplexer.
separates bits
of the radio
See, e.g., TS 25.212 v6.0.0:
frame into the
third
information bit
stream, and the
first and
second parity
streams from
the

21

demultiplexer
according to
the regular
pattern.

(V6.0.0, paragraph 4.2, page 11. Annotation added)

22

(V6.0.0, paragraph 4.2.7.3, page 36. Annotation added.)
“The first sequence contains:
- All of the systematic bits that are from turbo encoded TrCHs.
- From 0 to 2 first and/or second parity bits that are from turbo encoded TrCHs. These bits come into the first
sequence when the total number of bits in a block after radio frame segmentation is not a multiple of three.
- Some of the systematic, first parity and second parity bits that are for trellis termination.
The second sequence contains:
- All of the first parity bits that are from turbo encoded TrCHs, except those that go into the first sequence when
the total number of bits is not a multiple of three.
- Some of the systematic, first parity and second parity bits that are for trellis termination.
The third sequence contains:
- All of the second parity bits that are from turbo encoded TrCHs, except those that go into the first sequence
when the total number of bits is not a multiple of three.
- Some of the systematic, first parity and second parity bits that are for trellis termination.
The second and third sequences shall be of equal length, whereas the first sequence can contain from 0 to 2 more bits.
Puncturing is applied only to the second and third sequences.”
(V6.0.0, paragraph 4.2.7.3, pages 35-36.)

23

“For turbo encoded TrCHs with puncturing (Yi=Xi):
z i ,3( k 1)1(1   ni ) mod 3  y1,i ,k k = 1, 2, 3, …, Yi

zi ,3 Ni / 3 k  y1,i , Ni / 3 k

k = 1, …, Ni mod 3

Note: When (Ni mod 3) = 0 this row is not needed.

z i ,3( k 1)1( 2   ni ) mod 3  y 2,i ,k

k = 1, 2, 3, …, Yi

zi ,3( k 1) 1 ( 3   ni ) mod 3  y3,i , k

k = 1, 2, 3, …, Yi

After the bit collection, bits zi,k with value , where {0, 1}, are removed from the bit sequence.”
(V6.0.0, paragraph 4.2.7.3.2, page 38.)
Before these bits from the channel encoder are put into a radio frame, they are interleaved at the interleaver according
to a specified permutation pattern. After the permutation is done at the interleaver, the resulting bit patterns have a
newly permuted regularity. Thus, the arrangement of information bits and parity bits in the radio frames has a
regular pattern.
8. The
Apple’s 3G products have a baseband signal processor that implements uplink transmission, which includes a
transmitting
memory for storing initial symbols of the consecutive radio frames. For example, X-GOLDTM 616 from Infineon is
device of claim a baseband processor used in some of Apple’s 3G products. The following figure from the 616 Datasheet shows a
7, further
memory for storing initial symbols of the consecutive radio frames.
comprising: a
memory for
storing initial
symbols of the
consecutive
radio frames;
and

24

a controller for
controlling the
demultiplexer
according to
the regular
pattern and the
stored initial
bits of the at
least one radio
frames.
9. The
transmitting
device of claim
8, further

(616 Datasheet, page 2. Annotation added.)
Apple’s 3G products have a baseband signal processor that implements uplink transmission, which includes a
controller for controlling the demultiplexer according to the regular pattern and the stored initial bits of the at least
one radio frames. For example, X-GOLDTM 616 from Infineon is a baseband processor used in some of Apple’s 3G
products.

Apple’s 3G products have a baseband signal processor that implements uplink transmission, which includes a
multiplexer for multiplexing the outputs of the rate matcher under a control of the controller. For example, XGOLDTM 616 from Infineon is a baseband processor used in some of Apple’s 3G products.

25

comprising: a
multiplexer for
multiplexing
the outputs of
the rate
matcher under
a control of the
controller.

See, e.g., TS 25.212 v6.0.0:

(V6.0.0, paragraph 4.2.7.3, page 36. Annotation added.)
10. The
transmitting
device of claim
1, wherein the
interleaver
interleaving
the encoded
streams at a
TTI

Apple’s 3G products have the interleaver interleaving the encoded streams at a TTI (Transmission Time Interval)
after inserting filler bits into the encoded streams in order to equalize a size of the at least one radio frames.
See, e.g., TS 25.212 v6.0.0:
“Radio frame size equalisation is padding the input bit sequence in order to ensure that the output can be segmented
in Fi data segments of same size as described in subclause 4.2.7. Radio frame size equalisation is only performed in
the UL.
The input bit sequence to the radio frame size equalisation is denoted by ci1 , ci 2 , ci 3 , , ciEi , where i is TrCH number
26

(Transmission
Time Interval)
after inserting
filler bits into
the encoded
streams in
order to
equalize a size
of the at least
one radio
frames.
11. The
transmitting
device of claim
1, wherein the
rate matcher
comprises: a
first
component rate
matcher for
rate-matching
the information
bits;

and Ei the number of bits. The output bit sequence is denoted by ti1 , ti 2 , ti 3 ,  , tiTi , where Ti is the number of bits. The
output bit sequence is derived as follows:
- tik = cik, for k = 1… Ei; and
- tik = {0, 1} for k= Ei +1… Ti, if Ei < Ti;
where
- Ti = Fi * Ni; and
- N i  Ei Fi  is the number of bits per segment after size equalisation.”
(V6.0.0, paragraph 4.2.4, page 21.)

Apple’s 3G products have the rate matcher with a first component rate matcher for rate-matching the information
bits. See, e.g., TS 25.212 v6.0.0:

(V6.0.0, paragraph 4.2.7.3, page 36. Annotation added.)
[a] a second
Apple’s 3G products have the rate matcher with a second component rate matcher which rate-matches the first parity
component rate bits.
matcher for

27

rate-matching
the first parity
bits; and

(V6.0.0, paragraph 4.2.7.3, page 36. Annotation added.)
[b] a third
Apple’s 3G products have the rate matcher with a second component rate matcher which rate-matches the second
component rate parity bits. See, e.g., TS 25.212 v6.0.0:
matcher for
rate-matching
the second
parity bits.

28

(V6.0.0, paragraph 4.2.7.3, page 35. Annotation added.)
Apple’s 3G products are transmitting devices in a mobile communication system.

12. A
transmitting
device in a
See claim 1.
mobile
communication See also, e.g., TS 25.212 v6.0.0:
system,
“Data stream from/to MAC and higher layers (Transport block / Transport block set) is encoded/decoded to offer
comprising:
transport services over the radio transmission link. Channel coding scheme is a combination of error detection, error
correcting, rate matching, interleaving and transport channels mapping onto/splitting from physical channels.”
(V6.0.0, paragraph 4.1, page 9.)

[a] an encoder
for receiving
an information
bit stream
transmitted at a
predetermined

Apple’s 3G products have an encoder for receiving an information bit stream transmitted at a predetermined
transmission time interval (TTI) and for outputting the information bit stream and at least one type of parity stream
by encoding the information bit stream in accordance with a coding rate of said encoder.
See claim 1[a].

29

transmission
time interval
(TTI) and for
outputting the
information bit
stream and at
least one type
of parity
stream by
encoding the
information bit
stream in
accordance
with a coding
rate of said
encoder;

[b] an
interleaver for
receiving the
information bit
stream and the
at least one
type of parity
stream from
the encoder,

See, e.g., TS 25.212 v6.0.0:
The information bit stream is received by the encoder at a predetermined transmission time interval (TTI) which is
predetermined as one of {10 ms, 20 ms, 40 ms, 80 ms}.
“Data arrives to the coding/multiplexing unit in form of transport block sets once every transmission time interval.
The transmission time interval is transport-channel specific from the set {10 ms, 20 ms, 40 ms, 80 ms}.” (V6.0.0,
paragraph 4.2, page 10.)
The encoder output at least one type of parity stream by encoding the information bit stream in accordance with a
coding rate of the encoder.
“The coding rate of Turbo coder is 1/3. “ (V6.0.0, paragraph 4.2.3.2.1, page 16.)

(V6.0.0, paragraph 4.2.3.2.1, page 17.)
Apple’s 3G products have an interleaver for receiving the information bit stream and the at least one type of parity
stream from the encoder, for interleaving the information bit stream and the at least one type of parity stream and for
outputting interleaved stream.
See claim 1[b].

30

for interleaving
the information
bit stream and
the at least one
type of parity
stream and for
outputting
interleaved
stream;
[c] a radio
Apple’s 3G products have a radio frame segmenter for receiving the interleaved stream from the interleaver, for
frame
dividing the received stream into radio frames, and for outputting the radio frames in sequence.
segmenter for
receiving the
interleaved
stream from
the interleaver,
for dividing
the received
stream into
radio frames,
and for
outputting the
radio frames in
sequence;

31

(V3.9.0, paragraph 4.2, page 10. Annotation added)
The radio frame segmenter in the Accused Products maps the received interleaved stream dividing the received
stream into radio frames, and for outputting the radio frames in sequence.

32

“When the transmission time interval is longer than 10 ms, the input bit sequence is segmented and mapped onto
consecutive Fi radio frames. Following rate matching in the DL and radio frame size equalisation in the UL the input
bit sequence length is guaranteed to be an integer multiple of Fi.
The input bit sequence is denoted by xi1 , xi 2 , xi 3 ,, xiX i where i is the TrCH number and Xi is the number bits. The Fi

[d] a
demultiplexer
for receiving
the radio
frames and for
demultiplexing
the received
radio frames
back into the
information bit
stream and the
at least one
type of parity
stream; and
[e] a rate
matcher for
rate matching
the streams
received from
the
demultiplexer
and outputting

output bit sequences per TTI are denoted by yi ,ni 1 , yi ,ni 2 , yi ,ni 3 ,  , yi ,niYi where ni is the radio frame number in current
TTI and Yi is the number of bits per radio frame for TrCH i. The output sequences are defined as follows:
yi ,ni k = xi , ni 1Yi k , ni = 1…Fi, k = 1…Yi
where Yi = (Xi / Fi) is the number of bits per segment.
The ni -th segment is mapped to the ni -th radio frame of the transmission time interval.”
(V3.9.0, paragraph 4.2.6, page 23.)
The demultiplexer in Apple’s 3G products demultiplexes each of the radio frames received from the radio frame
segmenter into the information bit stream (x1ik, i.e., the systematic bits of turbo encoded TrCHs), and at least one type
of parity stream (x2ik, i.e., first parity bits and x3ik, i.e., second parity).
See claim 1[d].

Apple’s 3G products have a rate matcher for rate-matching the streams received from the demultiplexer and
outputting rate matched streams, said rate matcher having at least one component rate matcher for rate matching a
part of the parity stream, a number of the at least one component rate matcher being equal to a number of the parity
streams.
See claim 1[e].
See, e.g., TS 25.212 v6.0.0:

33

rate matched
streams, said
rate matcher
having at least
one component
rate matcher
for rate
matching a part
of the parity
stream, a
number of the
at least one
component rate
matcher
being equal to
a number of
the parity
streams,

As the following figure from V6.0.0 illustrates, the rate matcher has at least one component rate matcher for rate
matching a part of the parity stream (x2ik, i.e., first parity bits and x3ik, i.e., second parity), and the number of the
component rate matchers is equal to a number of the parity streams. The following figure shows that there are two
component rate matchers for two parity streams.

(V6.0.0, paragraph 4.2.7.3, page 36. Annotation added.)
“The first sequence contains:
- All of the systematic bits that are from turbo encoded TrCHs.
- From 0 to 2 first and/or second parity bits that are from turbo encoded TrCHs. These bits come into the first
sequence when the total number of bits in a block after radio frame segmentation is not a multiple of three.
- Some of the systematic, first parity and second parity bits that are for trellis termination.
The second sequence contains:
- All of the first parity bits that are from turbo encoded TrCHs, except those that go into the first sequence when
the total number of bits is not a multiple of three.
- Some of the systematic, first parity and second parity bits that are for trellis termination.
The third sequence contains:
- All of the second parity bits that are from turbo encoded TrCHs, except those that go into the first sequence

34

when the total number of bits is not a multiple of three.
- Some of the systematic, first parity and second parity bits that are for trellis termination.
The second and third sequences shall be of equal length, whereas the first sequence can contain from 0 to 2 more bits.
Puncturing is applied only to the second and third sequences.”
(V6.0.0, paragraph 4.2.7.3, pages 35-36.)
“For turbo encoded TrCHs with puncturing (Yi=Xi):
z i ,3( k 1)1(1   ni ) mod 3  y1,i ,k k = 1, 2, 3, …, Yi

zi ,3 Ni / 3 k  y1,i , Ni / 3 k

k = 1, …, Ni mod 3

Note: When (Ni mod 3) = 0 this row is not needed.

z i ,3( k 1)1( 2   ni ) mod 3  y 2,i ,k

k = 1, 2, 3, …, Yi

zi ,3( k 1) 1 ( 3   ni ) mod 3  y3,i , k

k = 1, 2, 3, …, Yi

After the bit collection, bits zi,k with value , where {0, 1}, are removed from the bit sequence.”
(V6.0.0, paragraph 4.2.7.3.2, page 38.)
The rate matcher has at least one component rate matcher for rate matching a part of the parity stream, and the
number of the component rate matcher (i.e., two rate matching algorithms in the figure above) is equal to a number of
the parity streams (i.e., two parity streams x2ik, and x3ik in the figure above).
The demultiplexer in the Apple 3G products switches each of the parity bits in the radio frames to the at least one
component rate matcher corresponding to each of the parity bits. See, e.g., TS 25.212 v6.0.0:

[f] wherein the
demultiplexer
switches each
of the parity
In the following figure, the bit separation in the rate matcher receives the stream eik from the radio frame
bits in the
segmentation and switches each of the parity bits (x2ik, and x3ik,) in the radio frames to the component rate matchers
radio frames to corresponding to each of the parity bits.
said at least
one component
rate matcher
corresponding
to each of the
parity bits.

35

(V6.0.0, paragraph 4.2.7.3, page 36. Annotation added.)
13. The
In Apple's 3G products, bits of the radio frame are separated to the at least one component rate matcher
transmitter
corresponding to each type of parity stream in accordance with a regular pattern for arranging information bits and
device of claim parity bits in each radio frame.
12, wherein
bits of the
In Apple’s 3G products, bits of the radio frames, eik are separated by the bit separation in the rate matcher such that
radio frame are each type of parity streams (x2ik, and x3ik,) are sent to the corresponding rate matcher. See, e.g., TS 25.212 v6.0.0:
separated to
the at least one
component rate
matcher
corresponding
to each type of
parity stream
in accordance
with a regular
pattern for
arranging
information

36

bits and parity
bits in each
radio frame.

(V6.0.0, paragraph 4.2.7.3, page 36. Annotation added.)
In Apple’s 3G products, the arrangement of information bits and parity bits has a regular pattern.
“Output from the Turbo coder is x1, z1, z'1, x2, z2, z'2, …, xK, zK, z'K, where x1, x2, …, xK are the bits input to the Turbo
coder i.e. both first 8-state constituent encoder and Turbo code internal interleaver, and K is the number of bits, and
z1, z2, …, zK and z'1, z'2, …, z'K are the bits output from first and second 8-state constituent encoders, respectively.”
(V6.0.0, paragraph 4.2.3.2.1, page 15.)
Before these bits from the channel encoder are put into a radio frame, they are interleaved at the interleaver according
to a specified permutation pattern. After the permutation is done at the interleaver, the resulting bit patterns have a
newly permuted regularity. Thus, the arrangement of information bits and parity bits in the radio frames has a
regular pattern.
In Apple’s 3G products, the arrangement of information bits and parity bits in the radio frames in a regular pattern is
determined by the TTI. See, e.g., TS 25.212 v6.0.0:

14. The
transmitter
device of claim
13, wherein the For example, the newly permuted regularity in the output from the interleaver is determined by TTI, which dictates
regular pattern the permutation pattern among the columns. Moreover, the long bit sequence coming out of the interleaver is now
is determined
put into multiple radio frames each containing 10 ms of the original data and therefore the newly permuted regularity

37

by the TTI.

in the output from the interleaver is preserved in each of the radio frames, the number of which is determined by TTI.
“When the transmission time interval is longer than 10 ms, the input bit sequence is segmented and mapped onto
consecutive Fi radio frames. Following rate matching in the DL and radio frame size equalisation in the UL the input
bit sequence length is guaranteed to be an integer multiple of Fi.
The input bit sequence is denoted by xi1 , xi 2 , xi 3 ,, xiX i where i is the TrCH number and Xi is the number bits. The Fi
output bit sequences per TTI are denoted by yi ,ni 1 , yi ,ni 2 , yi ,ni 3 ,  , yi ,niYi where ni is the radio frame number in current
TTI and Yi is the number of bits per radio frame for TrCH i. The output sequences are defined as follows:
yi ,ni k = xi , ni 1Yi k , ni = 1…Fi, k = 1…Yi
where
Yi = (Xi / Fi) is the number of bits per segment.
The ni -th segment is mapped to the ni -th radio frame of the transmission time interval.”
(V6.0.0, paragraph 4.2.6, page 24.)
In Apple’s 3G products, the arrangement of information bits and parity bits in the radio frames in a regular pattern is
further determined by the coding rate. See, e.g., TS 25.212 v6.0.0:

15. The
transmitter
device of claim
14, wherein the
regular pattern “Output from the rate 1/3 convolutional coder shall be done in the order output0, output1, output2, output0, output1,
is further
output 2, output 0,…,output2. Output from the rate 1/2 convolutional coder shall be done in the order output 0, output
determined by 1, output 0, output 1, output 0, …, output 1.” (V6.0.0, paragraph 4.2.3.1, page 15.)
the coding rate.
“Output from the Turbo coder is x1, z1, z'1, x2, z2, z'2, …, xK, zK, z'K, where x1, x2, …, xK are the bits input to the Turbo
coder i.e. both first 8-state constituent encoder and Turbo code internal interleaver, and K is the number of bits, and
z1, z2, …, zK and z'1, z'2, …, z'K are the bits output from first and second 8-state constituent encoders, respectively.”
(V6.0.0, paragraph 4.2.3.2.1, page 16.)
16. The
Apple’s 3G products have a multiplexer that multiplexes the rate matched streams by switching outputs of the at least
transmitter
one component rate matcher. See, e.g., TS 25.212 v6.0.0:
device of claim
12, further
As the following figure shows, the bit collection in the rate matcher receives outputs y2ik and y3ik from the rate
comprising: a
matchers and switches these outputs together with the information bits y1ik (x2ik, and x3ik,) to form a multiplexed bit
multiplexer for stream fik.
multiplexing

38

the rate
matched
streams by
switching
outputs of the
at least one
component rate
matcher.

17. The
transmitter
device of claim
16, further
comprising: a
controller for
controlling the
switching of
the
demultiplexer
and the
multiplexer
based on at
least one of the
TTI and the
length of each
of the radio

(V6.0.0, paragraph 4.2.7.3, page 36. Annotation added.)
Apple’s 3G products have a baseband signal processor that implements uplink transmission, which includes a
controller for controlling the switching of the demultiplexer and the multiplexer based on at least one of the TTI and
the length of each of the radio frames. The received information bits eik are organized according to the regular
pattern which is based on at least one of the TTI and the length of each of the radio frames. For example, XGOLDTM 616 from Infineon is a baseband processor used in some of Apple’s 3G products.

39

frames.
18. The
transmitter
device of claim
12, wherein a
length of each
of the radio
frames is 10
ms.
19. The
transmitter
device of claim
12, wherein the
TTI is one of
10, 20, 40 and
80 ms.
20. The
transmitter
device of claim
12, wherein the
coding rate is
1/3.

Apple’s 3G products have radio frames of 10 ms for each of the radio frames by segmenting and mapping input bit
sequence when the TTI is longer than 10 ms. See, e.g., TS 25.212 v6.0.0:
“When the transmission time interval is longer than 10 ms, the input bit sequence is segmented and mapped onto
consecutive Fi radio frames.” (V6.0.0, paragraph 4.2.6, page 24.)

In Apple’s 3G products, the transmission time interval (TTI) is one of 10, 20, 40, and 80 ms. See, e.g., TS 25.212
v6.0.0:
“Data arrives to the coding/multiplexing unit in form of transport block sets once every transmission time interval.
The transmission time interval is transport-channel specific from the set {10 ms, 20 ms, 40 ms, 80 ms}.” (V6.0.0,
paragraph 4.2, page 10.)
Apple’s 3G products have the coding rate of 1/3 in the encoder. See, e.g., TS 25.212 v6.0.0:
“The coding rate of Turbo coder is 1/3. “ (V6.0.0, paragraph 4.2.3.2.1, page 16.)

(V6.0.0, paragraph 4.2.3.2.1, page 17.)
21. The
Apple’s 3G products have a baseband signal processor that implements uplink transmission, which includes a
transmitter
memory for storing the regular pattern including an initial symbol corresponding to each of the radio frames. For
device of claim example, X-GOLDTM 616 from Infineon is a baseband processor used in some of Apple’s 3G products. The
40

13, further
comprising a
memory for
storing the
regular pattern
including an
initial symbol
corresponding
to each of the
radio frames.

following figure from the 616 Datasheet shows a memory for storing initial symbols of the consecutive radio frames.

(616 Datasheet, page 2. Annotation added.)
22. The
The encoder in Apple’s 3G products is a turbo encoder. See, e.g., TS 25.212 v6.0.0:
transmitter
device of claim “The following channel coding schemes can be applied to TrCHs:
12, wherein the
- convolutional coding;
encoder is a
- turbo coding.”
turbo encoder. (V6.0.0, paragraph 4.2.3, page 15.)

41

23. A method
of transmitting
in a mobile
communication
system, the
method
comprising the
steps of:

[a] receiving
an information
bit stream
transmitted at a
predetermined
transmission
time interval
(TTI);

[b] encoding

(V6.0.0, paragraph 4.2.3.2.1, page 17.)
Apple infringes this claim because it has performed each and every step of this claim, including but not limited to
through testing and use by its employees. Apple also infringes this claim by selling Apple 3G products to customers
and encouraging those customers to use the products in a manner that meets each and every step of this claim.
Apple’s 3G products practice a method of transmitting in a mobile communication system.
See claims 1 and 12.

The method of transmitting in Apple’s 3G products includes receiving an information bit stream transmitted at a
predetermined transmission time interval (TTI). See, e.g., TS 25.212 v6.0.0:
“Data stream from/to MAC and higher layers (Transport block / Transport block set) is encoded/decoded to offer
transport services over the radio transmission link. Channel coding scheme is a combination of error detection, error
correcting, rate matching, interleaving and transport channels mapping onto/splitting from physical channels.”
(V6.0.0, paragraph 4.1, page 9.)
“All transport blocks in a TTI are serially concatenated. If the number of bits in a TTI is larger than Z, the maximum
size of a code block in question, then code block segmentation is performed after the concatenation of the transport
blocks.” (V6.0.0, paragraph 4.2.2, page 14.)
Apple’s 3G products have an encoder for encoding the information bit stream and outputting the encoded information
42

the information
bit stream and
outputting the
encoded
information bit
stream and at
least one type
of parity
stream
corresponding
to the
information bit
stream, a
number of the
parity streams
corresponding
to a coding rate
of an encoder;

bit stream and at least one type of parity stream corresponding to the information bit stream, a number of the parity
streams corresponding to a coding rate of an encoder.. See, e.g., TS 25.212 v6.0.0:
See claim 1[a].
See, e.g., TS 25.212 v6.0.0:
The encoder output at least one type of parity stream by encoding the information bit stream in accordance with a
coding rate of the encoder.
“The coding rate of Turbo coder is 1/3. “ (V6.0.0, paragraph 4.2.3.2.1, page 16.)

(V6.0.0, paragraph 4.2.3.2.1, page 16.)
[c] interleaving Apple’s 3G products have an interleaver for interleaving the information bit stream and the parity stream and
the information outputting the interleaved stream.
bit stream and
the parity
See claim 1[b].
stream and
outputting the
interleaved
stream;

43

[d] dividing
the interleaved
stream into at
least one radio
frame and
outputting the
at least one
radio frame,
each of the at
least one radio
frame having a
predetermined
time frame;
[e]
demultiplexing
the received
radio frame
back into the
information bit
stream and at
least one type
of parity
stream; and

Apple’s 3G products have a radio frame segmenter that receives the interleaved stream from the interleaver.

[f] rate
matching the
demultiplexed
streams by a
rate matcher;

Apple’s 3G products have a rate matcher that rate-matches the demultiplexed streams.

[g] wherein
parity bits in
the radio frame

In Apple's 3G products, the parity bits in the radio frame are switched to a component rate matcher corresponding to
each of the at least one parity stream, the component rate matcher having at least one parity component rate matcher
for rate matching a part of said at least one parity stream, a number of the at least one parity component rate matcher

The radio frame segmenter in Apple’s 3G products divides the interleaved stream into at least one radio frame and
outputs the at least one radio frame. Each of the at least one radio frame has a predetermined time frame determined
by Yi, which is the number of bits per radio frame.
See claim 1[c].

As part of the rate matching function, a demultiplexing operation is performed in the Accused Products.
The demultiplexer in Apple’s 3G products demultiplexes each of the radio frames received from the radio frame
segmenter back into the information bit stream (x1ik, i.e., the systematic bits of turbo encoded TrCHs), and at least
one type of parity stream (x2ik, i.e., first parity bits and x3ik, i.e., second parity).
See claim 1[d].

See claims 1[e] and 12[e].

44

are switched to
a component
rate matcher
corresponding
to each of the
at least one
parity stream,
said
component rate
matcher having
at least one
parity
component rate
matcher for
rate matching a
part of said at
least one parity
stream, a
number of the
at least one
parity
component rate
matcher being
equal to a
number of the
at least one
parity stream.

being equal to a number of the at least one parity stream.
See, e.g., TS 25.212 v6.0.0:
Apple’s 3G products have a component rate matcher that receives and rate-matches the stream of first parity bits.

(V6.0.0, paragraph 4.2.7.3, page 36. Annotation added.)
Apple’s 3G products have another component rate matcher that receives and rate-matches the stream of second parity
bits.

45

(V6.0.0, paragraph 4.2.7.3, page 36. Annotation added.)

24. The
method of
claim 23,
wherein bits of
the at least one
radio frame are
separated to
the component
rate matcher by
the
demultiplexer
in accordance
with a regular
pattern for
arranging

The number of the component rate matcher (i.e., two rate matching algorithms in the figure above) is equal to a
number of the parity streams (i.e., two parity streams x2ik, and x3ik in the figure above).
As part of the rate matching function (shown in the figure below), a demultiplexing operation is performed in
Apple’s 3G products.
See claim 1[d] and 23.
See, e.g., TS 25.212 v6.0.0:
The demultiplexer in Apple’s 3G products separates each of the at least one radio frames received from the radio
frame segmenter into the information bit stream (x1ik, i.e., the systematic bits of turbo encoded TrCHs), and first (x2ik,
i.e., first parity bits) and second (x3ik, i.e., second parity) parity streams from the demultiplexer.

46

information
bits and parity
bits in each
radio frame.

(V6.0.0, paragraph 4.2, page 10. Annotation added)

47

(V6.0.0, paragraph 4.7.3, page 35. Annotation added.)
“The first sequence contains:
- All of the systematic bits that are from turbo encoded TrCHs.
- From 0 to 2 first and/or second parity bits that are from turbo encoded TrCHs. These bits come into the first
sequence when the total number of bits in a block after radio frame segmentation is not a multiple of three.
- Some of the systematic, first parity and second parity bits that are for trellis termination.
The second sequence contains:
- All of the first parity bits that are from turbo encoded TrCHs, except those that go into the first sequence when
the total number of bits is not a multiple of three.
- Some of the systematic, first parity and second parity bits that are for trellis termination.
The third sequence contains:
- All of the second parity bits that are from turbo encoded TrCHs, except those that go into the first sequence
when the total number of bits is not a multiple of three.
- Some of the systematic, first parity and second parity bits that are for trellis termination.
The second and third sequences shall be of equal length, whereas the first sequence can contain from 0 to 2 more bits.
Puncturing is applied only to the second and third sequences.”
(V6.0.0, paragraph 4.2.7.3, pages 34-35.)

48

“For turbo encoded TrCHs with puncturing (Yi=Xi):
z i ,3( k 1)1(1   ni ) mod 3  y1,i ,k k = 1, 2, 3, …, Yi

zi ,3 Ni / 3 k  y1,i , Ni / 3 k

k = 1, …, Ni mod 3

Note: When (Ni mod 3) = 0 this row is not needed.

z i ,3( k 1)1( 2   ni ) mod 3  y 2,i ,k

k = 1, 2, 3, …, Yi

zi ,3( k 1) 1 ( 3   ni ) mod 3  y3,i , k

k = 1, 2, 3, …, Yi

After the bit collection, bits zi,k with value , where {0, 1}, are removed from the bit sequence.”
(V6.0.0, paragraph 4.2.7.3.2, page 37.)

25. The
method of
claim 24,
wherein the
regular pattern
is determined
by the TTI.
26. The
method of
claim 25,
wherein the
regular pattern
is further
determined by
the coding rate.
27. The
method of
claim 23,
further

Before these bits from the channel encoder are put into a radio frame, they are interleaved at the interleaver according
to a specified permutation pattern. After the permutation is done at the interleaver, the resulting bit patterns have a
newly permuted regularity. Thus, the arrangement of information bits and parity bits in the radio frames has a
regular pattern. The demultiplexer utilizes this regular pattern in separating information bits and parity bits.
See claims 14 and 23.

See claims 15 and 23.

Apple’s 3G products have a multiplexer that multiplexes the rate matched streams by synchronizing the multiplexing
with the multiplexing by switching outputs of the corresponding component rate matchers.
See claims 16 and 23.

49

comprising the
step of:
As the following figure shows, the bit collection in the rate matcher receives outputs y2ik and y3ik from the rate
multiplexing
matchers and switches these outputs together with the information bits y1ik (x2ik, and x3ik,) to form a multiplexed bit
the rate
stream fik.
matched
streams by
synchronizing
the
multiplexing
with the
demultiplexing
by switching to
the
corresponding
component rate
matcher.

(V6.0.0, paragraph 4.2.7.3, page 36. Annotation added.)

28. The
method of
claim 23,
wherein the
predetermined

“Every 10 ms, one radio frame from each TrCH is delivered to the TrCH multiplexing. These radio frames are
serially multiplexed into a coded composite transport channel (CCTrCH).
The bits input to the TrCH multiplexing are denoted by f i1 , f i 2 , f i 3 ,, f iVi , where i is the TrCH number and Vi is the
number of bits in the radio frame of TrCH i. The number of TrCHs is denoted by I.” (V6.0.0, paragraph 4.2.8, page
41.)
Apple’s 3G products have radio frames of the predetermined length 10 ms for each of the radio frame by segmenting
and mapping input bit sequence when the TTI is longer than 10 ms.
See claims 18 and 23.

50

length of the
radio frame is
10 ms.
29. The
method of
claim 23,
wherein the
TTI is one of
10, 20, 40 and
80 ms.
30. The
method of
claim 23,
wherein the
coding rate is
1/3.
31. A
transmitting
device in a
mobile
communication
system,
comprising:
[a] an encoder
for receiving
an information
bit stream
transmitted at a
predetermined
transmission
time interval
(TTI) and for
outputting the

See claims 19 and 23.

See claims 20 and 23.

Apple’s 3G products comprise transmitting devices in a mobile communication system.
See claims 1, 12, and 23.

Apple’s 3G products have an encoder for receiving an information bit stream transmitted at a predetermined
transmission time interval (TTI) and for outputting the information bit stream and at least one kind of parity stream
corresponding to the information bit stream in accordance with a coding rate of said encoder.
See claims 1[a], 12[a], and 23[b].

51

information bit
stream and at
least one kind
of parity
stream
corresponding
to the
information bit
stream in
accordance
with a coding
rate of said
encoder;
[b] an
interleaver for
receiving the
information bit
stream and the
parity stream
from the
encoder, for
interleaving
the information
bit stream and
the parity
stream, and for
outputting an
interleaved
stream;
[c] a
demultiplexer
for receiving
the interleaved

Apple’s 3G products have an interleaver for receiving the information bit stream and the parity stream from the
encoder, for interleaving the information bit stream and the parity stream, and for outputting an interleaved stream.
See claims 1[b], 12[b], and 23[c].

See claim 12[d].

52

stream and for
demultiplexing
the received
interleaved
stream back
into the
information bit
stream and the
at least one
kind of parity
stream; and
[d] a rate
matcher for
rate matching
the information
bit stream and
the at least one
kind of parity
stream
received from
the
demultiplexer,
wherein said
rate matcher
includes at
least one
component rate
matcher for
rate matching a
part of the at
least one kind
of parity
stream, and a

Apple’s 3G products have a rate matcher for rate-matching the information bit stream and the at least one kind of
parity stream received from the demultiplexer, wherein said rate matcher includes at least one component rate
matcher for rate matching a part of the at least one kind of parity stream, and a number of the component rate matcher
is equal to a number of the at least one kind of parity stream.
See claim 12[e].

53

number of the
component rate
matcher is
equal to a
number of the
at least one
kind of parity
stream,
[e] wherein the
demultiplexer
switches bits in
the interleaved
stream to the
component rate
matcher
corresponding
to each of the
at least one
kind of parity
stream.

32. The

Apple’s 3G products has the demultiplexer that switches bits in the interleaved stream to the at least one component
rate matcher corresponding to each of the parity bits.
See, e.g., TS 25.212 v6.0.0:
In the following figure, the bit separation in the rate matcher receives the stream eik from the radio frame
segmentation and switches each of the parity bits (x2ik, and x3ik,) in the radio frames to the component rate matchers
corresponding to each of the at least one kind of parity bits.

(V6.0.0, paragraph 4.2.7.3, page 36. Annotation added.)
Apple’s 3G products have the demultiplexer that switches each of the parity bits of the interleaved stream to the at

54

transmitter
device of claim
31, wherein the
demultiplexer
switches each
of the bits of
the interleaved
stream to the at
least one
component rate
matcher in
accordance
with a regular
pattern for
arranging
information
bits and parity
bits in the
interleaved
stream.

least one component rate matcher in accordance with a regular pattern for arranging information bits and parity bits
in the interleaved stream.
See claim 12[f].
See, e.g., TS 25.212 v6.0.0:
In the following figure, the bit separation in the rate matcher receives the stream eik from the radio frame
segmentation and switches each of the parity bits (x2ik, and x3ik,) in the radio frames to the component rate matchers
corresponding to each of the parity bits.

(V6.0.0, paragraph 4.2.7.3, page 36. Annotation added.)

33. The
transmitter

Before these bits from the channel encoder are put into a radio frame, they are interleaved at the interleaver according
to a specified permutation pattern. After the permutation is done at the interleaver, the resulting bit patterns have a
newly permuted regularity. Thus, the arrangement of information bits and parity bits in the radio frames has a
regular pattern. The demultiplexer utilizes the regular pattern in switching the information bits and parity bits.
See claims 14 and 25.

55

device of claim
32, wherein the
regular pattern
is determined
by the TTI.
34. The
transmitter
device of claim
32, further
comprising: a
multiplexer for
synchronously
multiplexing
output bits of
the at least one
component rate
matcher by
synchronizing
with the
demultiplexer.
35. The
transmitter
device of claim
34, further
comprising: a
controller for
controlling the
demultiplexer
and the
multiplexer
based on the
regular pattern.
36. The

Apple’s 3G products have a multiplexer for synchronously multiplexing output bits of the at least one component rate
matcher by synchronizing with the demultiplexer.
See claim 27.

Apple’s 3G products have a baseband signal processor that implements uplink transmission, which includes a
controller for controlling the demultiplexer and multiplexer. The received information bits eik are organized
according to the regular pattern which is based on at least one of the TTI and the length of each of the radio frames.
For example, X-GOLDTM 616 from Infineon is a baseband processor used in some of Apple’s 3G products.
Before these bits from the channel encoder are put into a radio frame, they are interleaved at the interleaver according
to a specified permutation pattern. After the permutation is done at the interleaver, the resulting bit patterns have a
newly permuted regularity. Thus, the arrangement of information bits and parity bits in the radio frames has a
regular pattern. The demultiplexer and multiplexer utilizes this regular pattern in their respective functions.

Apple’s 3G products have radio frames of 10 ms for each of the radio frames by segmenting and mapping input bit

56

transmitter
device of claim
31, wherein a
length of at
least one of the
information bit
stream and the
interleaved
stream is 10
ms.
37. The
transmitter
device of claim
31, wherein the
TTI is one of
10, 20, 40 and
80 ms.
38. The
transmitter
device of claim
31, wherein the
coding rate is
1/3.
39. The
transmitter
device of claim
33, further
comprising: a
memory for
storing the
regular pattern
including an
initial symbol

sequence when the TTI is longer than 10 ms. Each of the radio frames contains information bit stream. An
interleaved stream is made by interleaving bits in a radio frame and thus also has a length of 10 ms.
See claims 18 and 28.

See claims 19 and 29.

See claims 20 and 30.

Apple’s 3G products have a baseband signal processor that implements uplink transmission, which includes a
memory for storing the regular pattern including an initial symbol corresponding to each of the radio frames. For
example, X-GOLDTM 616 from Infineon is a baseband processor used in some of Apple’s 3G products. The
following figure from the 616 Datasheet shows a memory for storing an initial symbol corresponding to the
interleaved stream.

57

corresponding
to the
interleaved
stream.

40. The
transmitter
device of claim
31, wherein the
encoder is a
turbo encoder.
41. A method
of transmitting
in a mobile
communication
system, the
method
comprising the
steps of:

(616 Datasheet, page 2. Annotation added.)
See claim 22.

Apple infringes this claim because it has performed each and every step of this claim, including but not limited to
through testing and use by its employees. Apple also infringes this claim by selling Apple 3G products to customers
and encouraging those customers to use the products in a manner that meets each and every step of this claim.
See claim 23.

58

[a] receiving
See claim 23[a]
an information
bit stream at a
predetermined
transmission
time interval
(TTI);
[b] encoding
See claim 23[b].
the information
bit stream and
outputting the
encoded
information bit
stream and at
least one kind
of parity
stream
corresponding
to the
information bit
stream in
accordance
with a coding
rate of a
encoder;
[c] interleaving See claim 23[c].
the information
bit stream and
the parity
stream and
outputting an
interleaved
stream;

59

[d]
demultiplexing
the interleaved
stream back
into the
information bit
stream and the
at least one
kind of parity
stream; and
[e] rate
matching the
demultiplexed
streams by a
rate matcher,
said rate
matcher
including at
least one
component rate
matcher for
rate matching a
part of said at
least one kind
of parity
stream;

See claim 23[e].

Apple’s 3G products have a rate matcher that rate-matches the demultiplexed streams.
See claims 1[e] and 12[e].
See, e.g., TS 25.212 v6.0.0:
As the following figure from V6.0.0 illustrates, the rate matcher has at least one component rate matcher for rate
matching a part of at least one kind of parity stream (x2ik, i.e., first parity bits and x3ik, i.e., second parity).

60

(V6.0.0, paragraph 4.7.3, page 35. Annotation added.)
“The first sequence contains:
- All of the systematic bits that are from turbo encoded TrCHs.
- From 0 to 2 first and/or second parity bits that are from turbo encoded TrCHs. These bits come into the first
sequence when the total number of bits in a block after radio frame segmentation is not a multiple of three.
- Some of the systematic, first parity and second parity bits that are for trellis termination.
The second sequence contains:
- All of the first parity bits that are from turbo encoded TrCHs, except those that go into the first sequence when
the total number of bits is not a multiple of three.
- Some of the systematic, first parity and second parity bits that are for trellis termination.
The third sequence contains:
- All of the second parity bits that are from turbo encoded TrCHs, except those that go into the first sequence
when the total number of bits is not a multiple of three.
- Some of the systematic, first parity and second parity bits that are for trellis termination.
The second and third sequences shall be of equal length, whereas the first sequence can contain from 0 to 2 more bits.
Puncturing is applied only to the second and third sequences.”
(V6.0.0, paragraph 4.2.7.3, pages 34-35.)
“For turbo encoded TrCHs with puncturing (Yi=Xi):
z i ,3( k 1)1(1   ni ) mod 3  y1,i ,k k = 1, 2, 3, …, Yi

zi ,3 Ni / 3 k  y1,i , Ni / 3 k

k = 1, …, Ni mod 3

Note: When (Ni mod 3) = 0 this row is not needed.

z i ,3( k 1)1( 2   ni ) mod 3  y 2,i ,k

k = 1, 2, 3, …, Yi

zi ,3( k 1) 1 ( 3   ni ) mod 3  y3,i , k

k = 1, 2, 3, …, Yi

After the bit collection, bits zi,k with value , where {0, 1}, are removed from the bit sequence.”
(V6.0.0, paragraph 4.2.7.3.2, page 37.)
[f] wherein bits Apple’s 3G products have the demultiplexer that switches bits in the interleaved stream to the at least one component
in the
rate matcher corresponding to each of the at least one kind of parity stream, a number of the at least one parity
interleaved
component rate matcher being equal to a number of the at least one parity stream. See, e.g., TS 25.212 v6.0.0:
stream are
switched to at
In the following figure, the bit separation in the rate matcher receives the stream eik from the radio frame

61

least one parity segmentation and switches each of the parity bits (x2ik, and x3ik,) in the radio frames to the component rate matchers
component rate corresponding to each of the at least one kind of parity bits.
matcher
corresponding
to each of the
at least one
kind of parity
stream, a
number of the
at least one
parity
component rate
matcher being
equal to a
number of the
at least one
parity stream.
(V6.0.0, paragraph 4.2.7.3, page 36. Annotation added.)

42. The
method of
claim 41,
wherein the
bits of the
interleaved
stream are
separated in
accordance
with a regular
pattern for

The rate matcher has at least one component rate matcher for rate matching a part of the parity stream, and the
number of the component rate matcher (i.e., two rate matching algorithms in the figure above) is equal to a number of
the parity streams (i.e., two parity streams x2ik, and x3ik in the figure above).
See claim 41.
Apple’s 3G products have a rate matcher that separates the bits of the interleaved stream. See, e.g., TS 25.212 v6.0.0:
In the following figure, the bit separation in the rate matcher receives the stream eik from the radio frame
segmentation and switches each of the parity bits (x2ik, and x3ik,) in the radio frames to the component rate matchers
corresponding to each of the parity bits.

62

arranging
information
bits and parity
bits in the
interleaved
stream.

(V6.0.0, paragraph 4.2.7.3, page 36. Annotation added.)

43. The
method of
claim 42,
wherein the
regular pattern
is determined
by the TTI.
44. The
method of
claim 41,
further
comprising the
step of:

Before these bits from the channel encoder are put into a radio frame, they are interleaved at the interleaver according
to a specified permutation pattern. After the permutation is done at the interleaver, the resulting bit patterns have a
newly permuted regularity. Thus, the arrangement of information bits and parity bits in the radio frames has a
regular pattern. The rate matcher utilizes the regular pattern in separating the information bits and parity bits.
See claims 14, 25, 33, and 41.

Apple’s 3G products have a multiplexer for multiplexing the output bits of the rate matching step by synchronizing
the multiplexing with the demultiplexing by switching in the rate matcher.
See claims 27 and 41.

63

multiplexing
the output bits
of the rate
matching step
by
synchronizing
the
multiplexing
with the
demultiplexing
by switching in
the rate
matcher.
45. The
See claims 36 and 41.
method of
claim 41,
wherein a
length of at
least one of the
information bit
stream and the
interleaved
stream is 10
ms.
46. The
See claims 37 and 41.
method of
claim 41,
wherein the
TTI is one of
10, 20, 40 and
80 ms.
47. The
See claims 38 and 41.
method of

64

claim 41,
wherein the
coding rate is
1/3.
48. A mobile
Apple’s 3G products comprise a mobile communication system.
communication
system,
See claims 1, 12, 23, and 31.
comprising:
[a] an encoder
for receiving
an information
bit stream and
for outputting
three encoder
output streams,
an information
bit stream, a
first parity
stream, and a
second parity
stream, by
encoding the
information bit
stream;
[b] an
interleaver
coupled to the
encoder for
performing an
interleaving
operation
according to a

See claims 1[a] and 12[a].

Apple’s 3G products have an interleaver that is coupled to the encoder for performing an interleaving operation.
See, e.g., TS 25.212 v6.0.0:

65

predetermined
interleaving
rule;

(V6.0.0, paragraph 4.2, page 11. Annotation added)
The interleaver in Apple’s 3G products interleaves the information bit stream and the at least one type of parity
stream and outputs the interleaved stream according to a predetermined interleaving rule.

66

“(3) Write the input bit sequence into the R1  C1 matrix row by row starting with bit xi ,1 in column 0 of row 0
and ending with bit xi ,( R1C1) in column C1 - 1 of row R1 - 1:
xi ,1
xi , 2
xi , 3
 xi ,C1 

 x
xi ,( C1 2)
xi ,( C13)
 xi ,( 2C1) 
 i ,( C11)





  


 xi ,(( R11)C11) xi ,(( R11)C1 2) xi ,(( R11)C13)  xi ,( R1C1) 


(4) Perform the inter-column permutation for the matrix based on the pattern P1C1  j 

j0,1,,C11

shown in table 4,

where P1C1 (j) is the original column position of the j-th permuted column. After permutation of the columns,
the bits are denoted by yik:
 yi ,1 yi ,( R11) yi ,( 2R11)  yi ,(( C11)R11) 
y

 i , 2 yi ,( R1 2 ) yi ,( 2R1 2)  yi ,(( C11)R1 2)  ”
 







yi ,(3R1)  yi ,( C1R1) 
 yi ,R1 yi ,( 2R1)


(V6.0.0, paragraph 4.2.5.2, page 23)
“The bits input to the 1st interleaving are denoted by t i ,1 , t i , 2 , t i ,3 ,, t i ,Ti , where i is the TrCH number and Ti the
number of bits. Hence, zi,k = ti,k and Zi = Ti. The bits output from the 1st interleaving are denoted by
d i ,1 , d i , 2 , d i ,3 ,, d i ,Ti , and di,k = yi,k.” (V6.0.0, paragraph, 4.2.5.3, page 23.)
[c] a radio
frame
segmenter for
receiving an
interleaved
stream from
the interleaver
and mapping
the interleaved
stream onto at

Apple’s 3G products have a radio frame segmenter for receiving the interleaved stream from the interleaver and
mapping the interleaved stream onto at least one radio frame.
See claim 12[c].

67

least one radio
frame;
[d] a
demultiplexer
for separating
the at least one
radio frame
received from
the radio frame
segmenter into
three
demultiplexer
output streams;
and
[e] a rate
matcher for
bypassing an
information bit
stream from
the
demultiplexer
and for
puncturing a
part of a first
and second
parity streams
from the
demultiplexer
according to a
given rate
matching rule.
49. The system
of claim 48,

See claim 1[d].
The demultiplexer in Apple’s 3G products separates each of the radio frames received from the radio frame
segmenter into three demultiplexed output streams: the information bit stream (x1ik, i.e., the systematic bits of turbo
encoded TrCHs), and two parity streams (x2ik, i.e., first parity bits and x3ik, i.e., second parity).

See claim 1[e].

See claim 2.

68

wherein the
interleaved
stream is
mapped onto
consecutive
radio frames
when a
transmission
time interval
(TTI) is longer
than 10 ms.
50. The system
of claim 48,
wherein the
interleaver
performs the
interleaving
operation at a
TTI
(Transmission
Time Interval),
after inserting
filler bits into
an output of
the encoder, in
order to
equalize a size
of the at least
one radio
frames.
51. The system
of claim 48,
wherein the

See claim 10.

See claim 11.

69

rate matcher
comprises: a
first
component rate
matcher for
rate-matching
the information
bit stream from
the
demultiplexer;
[a] a second
component rate
matcher for
rate-matching
the first parity
stream from
the
demultiplexer;
and
[b] a third
component rate
matcher for
rate-matching
the second
parity stream
from the
demultiplexer.
52. A method
for
transmitting
data in a
mobile

See claim 11[a].

See claim 11[b].
Apple’s 3G products have the rate matcher with a second component rate matcher which rate-matches the second
parity stream from the demultiplexer.

Apple infringes this claim because it has performed each and every step of this claim, including but not limited to
through testing and use by its employees. Apple also infringes this claim by selling Apple 3G products to customers
and encouraging those customers to use the products in a manner that meets each and every step of this claim.
See claims 1, 12, 23, and 41.

70

communication
system, the
method
comprising:
[a] encoding an
information bit
stream
corresponding
to a coding rate
of an encoder
and outputting
the information
bit stream, a
first parity
stream, and a
second parity
stream;
[b] performing
an interleaving
operation with
an interleaver
coupled to the
encoder;
[c] mapping an
interleaved
stream from
the interleaver
onto at least
one radio
frame and
outputting the
at least one
radio frame;

See claim 41[b].

Apple’s 3G products perform an interleaving operation with an interleaver coupled to the encoder.
See claim 48[b].

Apple’s 3G products have a radio segmenter for mapping an interleaved stream from the interleaver onto at least one
radio frame and outputting the at least one radio frame.
See claim 48[c].
See, e.g., TS 25.212 v6.0.0:

71

(V6.0.0, paragraph 4.2, page 11. Annotation added)
The radio frame segmentation maps the received interleaved stream onto at least one radio frame and outputting the
at least one radio frame.

72

“When the transmission time interval is longer than 10 ms, the input bit sequence is segmented and mapped onto
consecutive Fi radio frames. Following rate matching in the DL and radio frame size equalisation in the UL the input
bit sequence length is guaranteed to be an integer multiple of Fi.
The input bit sequence is denoted by xi1 , xi 2 , xi 3 ,, xiX i where i is the TrCH number and Xi is the number bits. The Fi
output bit sequences per TTI are denoted by yi ,ni 1 , yi ,ni 2 , yi ,ni 3 ,  , yi ,niYi where ni is the radio frame number in current
TTI and Yi is the number of bits per radio frame for TrCH i. The output sequences are defined as follows:
yi ,ni k = xi , ni 1Yi k , ni = 1…Fi, k = 1…Yi
where Yi = (Xi / Fi) is the number of bits per segment.
The ni -th segment is mapped to the ni -th radio frame of the transmission time interval.”
(V6.0.0, paragraph 4.2.6, page 23.)
See claim 23[e].

[d] performing
an
demultiplexing
operation with
a
demultiplexer
and outputting
an information
bit stream of
the
demultiplexer,
and a first
parity stream
of the
demultiplexer,
and a second
parity stream
of the
demultiplexer;
and
[e] bypassing
See claim 1[e].
the information

73

bit stream of
the
demultiplexer
and puncturing
a part of the
first and
second parity
stream from
the
demultiplexer
according to a
given rate
matching rule.
53. The
method of
claim 52,
wherein the
interleaved
stream is
mapped onto
consecutive
radio frames
when a
transmission
time interval
(TTI) is longer
than 10 ms.
54. The
method of
claim 52,
wherein the
interleaving
operation is

See claims 2, 49, and 52.

See claims 10, 50, and 52.

74

performed at a
TTI
(Transmission
Time Interval),
after inserting
filler bits into
an output of
the encoder, in
order to
equalize a size
of the at least
one radio
frame.
55. A mobile
communication
system,
comprising:
[a] means for
receiving an
information bit
stream and for
outputting an
output stream
including an
information bit
stream, a first
parity stream,
and a second
parity stream,
by encoding
the information
bit stream;
[b] means for

See claims 1, 12, 23, 31, 48, and 52.

Apple’s 3G products have a means for receiving a information bit stream transmitted at a predetermined transmission
time interval (TTI).
See claim 12[a].

Apple’s 3G products have a means for performing an interleaving operation in response to the output stream and

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performing an
interleaving
operation in
response to the
output stream
and outputting
an interleaved
stream;
[c] means for
creating at
least one radio
frame in
response to the
interleaved
stream;

outputting an interleaved stream.
See claim 12[b].

Apple's 3G products have a means for creating at least one radio frame in response to the interleaved stream.
See claim 12[c].
Radio frames are created by the radio frame segmentation shown in the figure below.

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(V6.0.0, paragraph 4.2, page 11. Annotation added)
The radio frame segmentation maps the received interleaved stream onto at least one radio frame and outputting the
at least one radio frame.

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“When the transmission time interval is longer than 10 ms, the input bit sequence is segmented and mapped onto
consecutive Fi radio frames. Following rate matching in the DL and radio frame size equalisation in the UL the input
bit sequence length is guaranteed to be an integer multiple of Fi.
The input bit sequence is denoted by xi1 , xi 2 , xi 3 ,, xiX i where i is the TrCH number and Xi is the number bits. The Fi

[d] means for
separating the
at least one
radio frame
into a separate
information bit
stream, a first
separate parity
stream, and a
second
separate parity
stream; and

output bit sequences per TTI are denoted by yi ,ni 1 , yi ,ni 2 , yi ,ni 3 ,  , yi ,niYi where ni is the radio frame number in current
TTI and Yi is the number of bits per radio frame for TrCH i. The output sequences are defined as follows:
yi ,ni k = xi , ni 1Yi k , ni = 1…Fi, k = 1…Yi
where Yi = (Xi / Fi) is the number of bits per segment.
The ni -th segment is mapped to the ni -th radio frame of the transmission time interval.”
(V6.0.0, paragraph 4.2.6, page 24.)
As part of the rate matching function (shown in the figure below), Apple’s 3G products have a means for separating
the at least one radio frame into a separate information bit stream, a first separate parity stream, and a second separate
parity stream.
See claim 12[d].
See, e.g., TS 25.212 v6.0.0:
The bit separation in Apple’s 3G products separates each of the radio frames received from the radio frame
segmenter into the information bit stream (x1ik, i.e., the systematic bits of turbo encoded TrCHs), and the first and
second separate parity streams (x2ik, i.e., first parity bits and x3ik, i.e., second parity).

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(V6.0.0, paragraph 4.2, page 11. Annotation added)

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(V6.0.0, paragraph 4.7.3, page 36. Annotation added.)
“The first sequence contains:
- All of the systematic bits that are from turbo encoded TrCHs.
- From 0 to 2 first and/or second parity bits that are from turbo encoded TrCHs. These bits come into the first
sequence when the total number of bits in a block after radio frame segmentation is not a multiple of three.
- Some of the systematic, first parity and second parity bits that are for trellis termination.
The second sequence contains:
- All of the first parity bits that are from turbo encoded TrCHs, except those that go into the first sequence when
the total number of bits is not a multiple of three.
- Some of the systematic, first parity and second parity bits that are for trellis termination.
The third sequence contains:
- All of the second parity bits that are from turbo encoded TrCHs, except those that go into the first sequence
when the total number of bits is not a multiple of three.
- Some of the systematic, first parity and second parity bits that are for trellis termination.
The second and third sequences shall be of equal length, whereas the first sequence can contain from 0 to 2 more bits.
Puncturing is applied only to the second and third sequences.”
(V6.0.0, paragraph 4.2.7.3, pages 35-36.)

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“For turbo encoded TrCHs with puncturing (Yi=Xi):
z i ,3( k 1)1(1   ni ) mod 3  y1,i ,k k = 1, 2, 3, …, Yi

zi ,3 Ni / 3 k  y1,i , Ni / 3 k

k = 1, …, Ni mod 3

Note: When (Ni mod 3) = 0 this row is not needed.

z i ,3( k 1)1( 2   ni ) mod 3  y 2,i ,k
zi ,3( k 1) 1 ( 3   ni ) mod 3  y3,i , k

[e] means for
bypassing the
separate
information bit
stream and for
puncturing a
part of the first
and second
separate parity
streams
according to a
given rate
matching rule.
56. The system
of claim 55,
wherein the
interleaved
stream is
mapped onto
consecutive
radio frames
when a
transmission

k = 1, 2, 3, …, Yi
k = 1, 2, 3, …, Yi

After the bit collection, bits zi,k with value , where {0, 1}, are removed from the bit sequence.”
(V6.0.0, paragraph 4.2.7.3.2, page 38.)
Apple’s 3G products have a means for bypassing the separate information bit stream (x1ik, i.e., the systematic bits of
turbo encoded TrCHs) and for puncturing a part of the first (x2ik) and second (x3ik) parity streams from the
demultiplexer according to a given rate matching rule.
The rate matcher corresponds to the means for bypassing the separate information bit stream and for puncturing a
part of the first and second separate parity streams according to a given rate matching rule.
See claims 1[e] and 48[e].

See claims 2, 49, and 53.

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time interval
(TTI) is longer
than 10 ms.
57. The system
of claim 55,
wherein the
interleaving
operation is
performed at a
TTI
(Transmission
Time Interval),
after inserting
filler bits into
the output
stream, in
order to
equalize a size
of the at least
one radio
frame.

See claims 10, 50, and 54.

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