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)

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Mueller Exhibit 59 EXHIBIT E SAMSUNG’S PATENT L.R. 3-1(A)-(D) DISCLOSURES FOR U.S. PATENT NO. 7,200,792 03498.51845/4323110.2 1 ASSERTED CLAIM (PATENT L.R. 3-1(A)) 11. An apparatus for receiving data in a communication system, comprising: ACCUSED INSTRUMENTALITY AND HOW EACH ELEMENT IS MET BY ACCUSED INSTRUMENTALITY (PATENT L.R. 3-1(B)-(D)) Apple’s 3G Products1 include an apparatus for receiving data in a communication system. See, e.g.: Apple iPhone user guide re iOS 3.1: (iPhone 3G or later, p. 21): 1 “Apple’s 3G Products” include iPhone 3G, iPhone 3GS, iPhone4, iPad 3G, iPad2 3G and any other products compliant with 3GPP UMTS standard. 03498.51845/4323110.2 2 http://www.apple.com/iphone/specs.html (iPhone 4) 03498.51845/4323110.2 3 iPad iOS 3.2 user guide: (iPad) http://www.apple.com/ipad/specs/ (iPad 2) 03498.51845/4323110.2 4 [a] a demodulator for demodulating a received symbol into a plurality of systematic bits and parity bits; Apple’s 3G Products include a demodulator for demodulating a received symbol into a plurality of systematic bits and parity bits. The 3GPP Technical Specification 25.212 v6.0.0 (“TS 25.212 v6.0.0”) describe a turbo encoder for coding data bits to generate systematic bits and parity bits. The coded data bits are received by Apple’s 3G products and decoded. See, e.g., TS 25.212 v6.0.0 §4.5: 03498.51845/4323110.2 5 TS 25.212 v6.0.0. § 4.5.3: TS 25.212 v6.0.0 § 4.5.7 and Figure 17: 03498.51845/4323110.2 6 TS 25.212 v6.0.0 § 4.2.3: 03498.51845/4323110.2 7 TS 25.212 v6.0.0 § 4.2.3.2, Figure 4: 03498.51845/4323110.2 8 [b] a first deinterleaver for writing the Apple’s 3G Products include a first deinterleaver for writing the plurality of systematic bits on a plurality of systematic bits on a column by column by column basis and performing inter-column permutation. See, e.g., column basis and performing inter-column permutation; 03498.51845/4323110.2 9 TS 25.212 v6.0.0 § 4.5.4.4: 03498.51845/4323110.2 10 TS 25.212 v6.0.0 § 4.5.5: TS 25.212 v6.0.0 § 4.5.6, Figure 18: 03498.51845/4323110.2 11 TS 25.212 v6.0.0 §4.2.11: … 03498.51845/4323110.2 12 03498.51845/4323110.2 13 Apple’s 3G Products include a second deinterleaver for writing the plurality of parity bits on a [c] a second deinterleaver for writing the column-by-column basis, and performing inter-column permutation. See, e.g., plurality of parity bits on a column by column basis and performing inter-column TS 25.212 v6.0.0 § 4.5.4.4: permutation; 03498.51845/4323110.2 14 03498.51845/4323110.2 15 TS 25.212 v6.0.0 § 4.5.5: TS 25.212 v6.0.0 § 4.5.6, Figure 18: 03498.51845/4323110.2 16 TS 25.212 v6.0.0 §4.2.11: … 03498.51845/4323110.2 17 03498.51845/4323110.2 18 [d] a rate matcher for rate matching the de-interleaved systematic bits and parity bits; and Apple’s 3G Products include a rate matcher for rate matching the de-interleaved systematic bits and parity bits. See, e.g., TS 25.212 v6.0.0. § 4.5.4 and Figure 17: 03498.51845/4323110.2 19 [e] a decoder for decoding the rate matched systematic bits and parity bits, Apple’s 3G Products include a decoder for decoding the rate matched systematic bits and parity bits. TS 25.212 v6.0.0 discloses a turbo encoder for coding data bits to generate systematic bits and parity bits. See, e.g., 3GPP Technical Specification 25.212 v6.0.0 (“TS 25.212 v6.0.0”) §4.5: 03498.51845/4323110.2 20 TS 25.212 v6.0.0. § 4.5.3: TS 25.212 v6.0.0 § 4.5.7 and Figure 17: 03498.51845/4323110.2 21 TS 25.212 v6.0.0 § 4.2.3: 03498.51845/4323110.2 22 TS 25.212 v6.0.0 § 4.2.3.2, Figure 4: 03498.51845/4323110.2 23 [f] wherein a size of the first deinterleaver is equal to a size of the second deinterleaver. Apple’s 3G Products include a first deinterleaver equal in size to the second deinterleaver. See, e.g., TS 25.212 v6.0.0 §4.5.6, Figure 18: 03498.51845/4323110.2 24 12. The apparatus of claim 11, See claim 11. wherein if a number of the systematic bits is less than a number of the parity bits, part of the parity bits is written next to systematic bits in the first deinterleaver. Apple’s 3G Products include part of the parity bits written next to the systematic bits in the first deinterleaver if a number of the systematic bits is less than a number of the parity bits. See, e.g., 03498.51845/4323110.2 25 TS 25.212 v6.0.0 § 4.5.4.4: 03498.51845/4323110.2 26 03498.51845/4323110.2 27 TS 25.212 v6.0.0 § 4.5.5: TS 25.212 v6.0.0 § 4.5.6, Figure 18: 03498.51845/4323110.2 28 13. The apparatus of claim 11, See claim 11. wherein if a number of the systematic bits is greater than a number of the parity bits, part of the systematic bits is written prior to the parity bits in the second deinterleaver. Apple’s 3G Products include part of the systematic bits written prior to the parity bits in the second deinterleaver if a number of the systematic bits is greater than a number of the parity bits. See, e.g., 03498.51845/4323110.2 TS 25.212 v6.0.0 § 4.5.4.4: 29 03498.51845/4323110.2 30 TS 25.212 v6.0.0 § 4.5.5: TS 25.212 v6.0.0 § 4.5.6, Figure 18: 03498.51845/4323110.2 31 14. A method for receiving data in a communication system, comprising: See claim 11. 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's 3G Products to customers and encouraging those customers to use the products in a manner that meets each and every step of this claim. demodulating a received symbol into a plurality of systematic bits and parity bits; See claim 11[a]. writing the plurality of systematic bits on See claim 11[b] and 11[c]. a column by column basis in a first deinterleaver and performing inter-column permutation, and writing the plurality of parity bits on a column by column basis in a second deinterleaver and performing 03498.51845/4323110.2 32 inter-column permutation; rate marching the de-interleaved systematic bits and parity bits; and See claim 11[d]. decoding the rate matched systematic bits and parity bits, See claim 11[e]. wherein a size of the first deinterleaver is equal to a size of the second deinterleaver. See claim 11[f]. 15. The method of claim 14, See claim 14. wherein if a number of the systematic bits is less than a number of the parity bits, part of the parity bits is written next to the systematic bits in the first deinterleaver. See claim 12. 16. The method of claim 14, See claim 14. wherein if a number of the systematic bits is greater than a number of the parity bits, part of the systematic bits is written prior to the parity bits in the second deinterleaver. See claim 13. 03498.51845/4323110.2 33

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