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 61

EXHIBIT G

SAMSUNG’S PATENT L.R. 3-1(A)-(D) DISCLOSURES FOR
U.S. PATENT NO. 7,386,001

ASSERTED CLAIM
(PATENT L.R. 3-1(A))
1. A channel coding and
multiplexing apparatus for
a CDMA communication
system, in which data
frames that have different
transmission time intervals
(TTIs) are received in
parallel via a plurality of
transport channels and
multiplexed to a serial
data frame, the apparatus
comprising:

ACCUSED INSTRUMENTALITY AND HOW EACH ELEMENT IS MET BY ACCUSED INSTRUMENTALITY
(PATENT L.R. 3-1(B)-(D))
1
Apple's 3G Products comprise a channel coding and multiplexing apparatus for a CDMA communication
system, in which data frames that have different transmission time intervals (TTIs) are received in parallel
via a plurality of transport channels and multiplexed to a serial data frame.
See, e.g.,
Apple iPhone user guide re iOS 3.1: (iPhone 3G or later, p. 21):

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):

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
4

Specification 25.212 v6.0.0 (“TS 25.212 v6.0.0”)).
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.)

5

(V6.0.0, paragraph 4.2, page 11.)
As specified in V.6.0.0, Apple's 3G products receive data frames that have different transmission time
intervals (TTIs).
“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

6

concatenation of the transport blocks. The maximum size of the code blocks depends on whether
convolutional coding or turbo coding is used for the TrCH.” (V6.0.0, paragraph 4.2.2, page 14.)
As it can be seen from the following figure, data frames that have different transmission time intervals
(TTIs) are received in parallel via a plurality of transport channels and multiplexed to a serial data frame.

(V6.0.0, paragraph 4.2, page 11. Annotations 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.
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:
7

[a] a number of radio
frame matchers, the
number of radio frame
matchers being at least
equal to the number of the
transport channels, each
radio frame matcher
having a radio frame
segmenter for receiving
the data frames and
segmenting the data
frames into radio frames;
and

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 have a number of radio frame matchers, the number of radio frame matchers being at
least equal to the number of the transport channels, each radio frame segmenter for receiving the data
frames and segmenting the data frames into radio frames. The transport channels are denoted in the figure
below as TrCH. Each of the radio frame matchers generates a transport channel and thus the number of
radio frame matchers is at least equal to the number of the transport channels.
See, e.g., TS 25.212 v6.0.0:

8

(V6.0.0, paragraph 4.2, page 11. Annotations added.)
Each radio frame matcher in Apple's 3G products has a radio frame segmenter.

9

(V6.0.0, paragraph 4.2, page 11. Annotation added.)
The radio frame segmenter receives the data frames and segments the data frames into radio frames.

10

“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.)
“The input bit sequence to the radio frame segmentation is denoted by d i1 , d i 2 , d i 3 ,  , d iTi , where i is the
TrCH number and Ti the number of bits. Hence, xik = dik and Xi = Ti.
The output bit sequence corresponding to radio frame ni is denoted by ei1 , ei 2 , ei 3 ,, eiN i , where i is the

[b] a multiplexer for
multiplexing the radio
frames to the serial data
frame,

TrCH number and Ni is the number of bits. Hence, ei ,k  yi ,ni k and Ni = Yi.” (V6.0.0, paragraph 4.2.6.1,
page 24.)
Apple's 3G products have a multiplexer for multiplexing the radio frames to the serial data frame. See, e.g.,
TS 25.212 v6.0.0:

11

(V6.0.0, paragraph 4.2, page 11. Annotation added.)
The multiplexer in the Accused Product receives radio frames from the rate matcher and multiplexes the
radio frames to the serial data frame.
12

“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. The bits
output from TrCH multiplexing are denoted by s1 , s2 , s3 ,, sS , where S is the number of bits, i.e. S  Vi .
i

The TrCH multiplexing is defined by the following relations:
sk  f1k
k = 1, 2, …, V1

sk  f 2, ( k V1 )

k = V1+1, V1+2, …, V1+V2

sk  f 3, ( k  (V1 V2 ))

k = (V1+V2)+1, (V1+V2)+2, …, (V1+V2)+V3



sk  f I , ( k  (V1 V2 VI 1 ))

k = (V1+V2+…+VI-1)+1, (V1+V2+…+VI-1)+2, …, (V1+V2+…+VI-1)+VI ”

(V6.0.0, paragraph 4.2.8, pages 41-42.)
[c] wherein each radio
frame segmenter
determines the bit number
of a radio frame according
to the size of the data
frames received by the
corresponding frame
matcher and the TTI of a
radio frame and divides
the data frames by the bit
number of the radio frame.

Each radio frame segmenter determines the bit number of a radio frame according to the size of the data
frames received by the corresponding frame matcher and the TTI of a radio frame and divides the data
frames by the bit number of the radio frame. See, e.g., TS 25.212 v6.0.0:
As the following passage explains, the ith transport channel receives xi1, xi2, xi3…xiXi where Xi is the size of
the data frames received by the corresponding frame matcher and the TTI of a radio frame.
“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
13

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 the above passage also shows, the bit number of a radio frame is Yi. The radio frame segmenter divides
the data frames by the bit number of the radio frame and maps the received data frame into one or more
radio frames. For example, the first radio frame of transport channel i maps the first Yi bits of the received
data frame (i.e., yi,1,k – xi,k, k=1,2,…,Yi). The second radio frame of transport channel i maps the next Yi
bits of the received data frame (i.e., yi,2,k – xi,Yi +k, k=1,2,…,Yi), the third radio frame of transport channel i
maps the next Yi bits of the received data frame (i.e., yi,3,k – xi,2Yi +k, k=1,2,…,Yi), and so on.
Each radio frame matcher in Apple's 3G products includes an interleaver for interleaving the data frames
received by the corresponding frame matcher and applying the interleaved data to a corresponding radio
frame segmenter. See, e.g., TS 25.212 v6.0.0:

2. The channel coding and
multiplexing apparatus of
claim 1, wherein each
radio frame matcher
further includes an
As the following figure shows, the interleaver interleaves the data frames received by the corresponding
interleaver for interleaving frame matcher. The interleaved data from the interleaver are applied to a corresponding radio frame
the data frames received
segmenter.
by the corresponding
frame matcher and
applying the interleaved
data to a corresponding
radio frame segmenter.

14

(V6.0.0, paragraph 4.2, page 11. Annotation added)
The interleaver interleaves data in the manner described below.
“(3) Write the input bit sequence into the R1  C1 matrix row by row starting with bit xi ,1 in column 0
15

of row 0 and ending with bit xi ,( R1C1) in column C1 - 1 of row R1 - 1:
(4)Perform the inter-column permutation for the matrix based on the pattern P1C1  j 

3. The channel coding and
multiplexing apparatus of
claim 1, wherein each
radio frame matcher
further includes a rate
matcher for adjusting the
data rate of a radio frame
received from a radio
frame segmenter by one of
puncturing and repeating
parts of the radio frame to
match the data rate of the
radio frame to that of a
physical channel frame.

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 denot by yik:
“The bits input to the 1st i is the TrC and Ti the number of bits. Hence, zi,k = ti,k and Zi = Ti. The bis 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.)
Each radio frame matcher in Apple's 3G products further includes a rate matcher for adjusting the data rate
of a radio frame received from a radio frame segmenter by one of puncturing and repeating parts of the
radio frame to match the data rate of the radio frame to that of a physical channel frame. See, e.g., TS
25.212 v6.0.0:

16

(V6.0.0, paragraph 4.2, page 11. Annotation added.)
The radio frame matcher in Apple's 3G products adjusts the data rate of a radio frame received from a
radio frame segmenter by either puncturing (when there are too many bits) or repeating parts of the radio
frame (when there are not enough bits) to match the data rate of the radio frame to that of a physical
17

channel frame.
“Rate matching means that bits on a transport channel are repeated or punctured. Higher layers assign a
rate-matching attribute for each transport channel. This attribute is semi-static and can only be changed
through higher layer signaling. The rate-matching attribute is used when the number of bits to be repeated
or punctured is calculated.
The number of bits on a transport channel can vary between different transmission time intervals. In the
downlink the transmission is interrupted if the number of bits is lower than maximum. When the number
of bits between different transmission time intervals in uplink is changed, bits are repeated or punctured to
ensure that the total bit rate after TrCH multiplexing is identical to the total channel bit rate of the allocated
dedicated physical channels.” (V6.0.0, paragraph 4.2.7, page 24.)
Puncturing or repeating of bits follows the following rate matching rule specified in V.6.0.0.
“The rate matching rule is as follows:
if puncturing is to be performed
e = eini

-- initial error between current and desired puncturing ratio

m=1

-- index of current bit

do while m <= Xi
e = e – eminus

-- update error

if e <= 0 then

-- check if bit number m should be punctured

set bit xi,m to  where {0, 1}
e = e + eplus

-- update error

end if
m=m+1

-- next bit

18

end do
else
e = eini

-- initial error between current and desired puncturing ratio

m=1

-- index of current bit

do while m <= Xi
e = e – eminus

-- update error

do while e <= 0

-- check if bit number m should be repeated

repeat bit xi,m
e = e + eplus

-- update error

end do
m=m+1

-- next bit

end do
end if
4. The channel coding and
multiplexing apparatus of
claim 1, wherein the radio
frame matchers are
connected between
channel coders and the
multiplexer in an uplink
frame transmitting device,
and each of the radio
frame matchers of the
uplink channel

A repeated bit is placed directly after the original one.” (V6.0.0, paragraph 4.2.7.5, pages 40-41.)
The radio frame matchers in Apple's 3G products are connected between channel coders and the
multiplexer in an uplink frame transmitting device. See, e.g., TS 25.212 v6.0.0:
Apple's 3G products have channel coders that connect the radio frame matchers and the multiplexer in an
uplink frame transmitting device as the following figure shows.

19

transmitting device
comprises:

[a] an interleaver for
interleaving the data
frames received by the
corresponding frame
matcher;

(V6.0.0, paragraph 4.2, page 11. Annotations added.)
Each of the radio frame matchers of the uplink channel transmitting device in Apple's 3G products
includes an interleaver for interleaving the data frames received by the corresponding frame matcher. See,
e.g., TS 25.212 v6.0.0:
As the following figure shows, the interleaver interleaves the data frames received by the corresponding
frame matcher.

20

(V6.0.0, paragraph 4.2, page 1. Annotation added)
The interleaver interleaves data in the manner described below.
21

“(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

 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.)
[b] a radio frame
segmenter for determining
the bit number of a radio
frame according to the
size of the data frames
received by the
corresponding frame
matcher and a radio frame
TTI and dividing the data

Each of the radio frame matchers of the uplink channel transmitting device in Apple's 3G products
includes a radio frame segmenter for determining the bit number of a radio frame according to the size of
the data frames received by the corresponding frame matcher and a radio frame TTI and dividing the data
frames by a variable, said variable being a function of the radio frame TTI. See, e.g., TS 25.212 v6.0.0:
As the following passage explains, the ith transport channel receives xi1, xi2, xi3…xiXi where Xi is the size of
the data frames received by the corresponding frame matcher and the TTI of a radio frame.
“When the transmission time interval is longer than 10 ms, the input bit sequence is segmented and

22

frames by a variable, said
variable being a function
of the radio frame TTI;
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.)
As the above passage also shows, the bit number of a radio frame is Yi. The radio frame segmenter divides
the data frames by the bit number of the radio frame and maps the received data frame into one or more
radio frames. For example, the first radio frame of transport channel i maps the first Yi bits of the received
data frame (i.e., yi,1,k – xi,k, k=1,2,…,Yi). The second radio frame of transport channel i maps the next Yi
bits of the received data frame (i.e., yi,2,k – xi,Yi +k, k=1,2,…,Yi), the third radio frame of transport channel i
maps the next Yi bits of the received data frame (i.e., yi,3,k – xi,2Yi +k, k=1,2,…,Yi), and so on.

[c] a rate matcher for
adjusting the data rate of a
radio frame received from
the radio frame segmenter
by one of puncturing and
repeating parts of the radio
frame to match the data
rate of the radio frame to
that of a physical channel
frame.

The bit number of a radio frame is Yi is determined by Yi = (Xi / Fi), where variable Fi is the output bit
sequences per TTI, which thus is a function of the radio frame TTI.
Each of the radio frame matchers of the uplink channel transmitting device in Apple's 3G products further
includes a rate matcher for adjusting the data rate of a radio frame received from the radio frame segmenter
by one of puncturing and repeating parts of the radio frame to match the data rate of the radio frame to that
of a physical channel frame. See, e.g., TS 25.212 v6.0.0:

23

(V6.0.0, paragraph 4.2, page 11. Annotation added.)
The radio frame matcher in Apple's 3G products adjusts the data rate of a radio frame received from a
radio frame segmenter by either puncturing (when there are too many bits) or repeating parts of the radio
24

frame (when there are not enough bits) to match the data rate of the radio frame to that of a physical
channel frame.
“Rate matching means that bits on a transport channel are repeated or punctured. Higher layers assign a
rate-matching attribute for each transport channel. This attribute is semi-static and can only be changed
through higher layer signaling. The rate-matching attribute is used when the number of bits to be repeated
or punctured is calculated.
The number of bits on a transport channel can vary between different transmission time intervals. In the
downlink the transmission is interrupted if the number of bits is lower than maximum. When the number
of bits between different transmission time intervals in uplink is changed, bits are repeated or punctured to
ensure that the total bit rate after TrCH multiplexing is identical to the total channel bit rate of the allocated
dedicated physical channels.” (V6.0.0, paragraph 4.2.7, page 24.)
Puncturing or repeating of bits follows the following rate matching rule specified in V.6.0.0.
“The rate matching rule is as follows:
if puncturing is to be performed
e = eini

-- initial error between current and desired puncturing ratio

m=1

-- index of current bit

do while m <= Xi
e = e – eminus

-- update error

if e <= 0 then

-- check if bit number m should be punctured

set bit xi,m to  where {0, 1}
e = e + eplus

-- update error

end if
m=m+1

-- next bit

25

end do
else
e = eini

-- initial error between current and desired puncturing ratio

m=1

-- index of current bit

do while m <= Xi
e = e – eminus

-- update error

do while e <= 0

-- check if bit number m should be repeated

repeat bit xi,m
e = e + eplus

-- update error

end do
m=m+1

-- next bit

end do
end if
5. The channel coding and
multiplexing apparatus of
claim 1, wherein the radio
frame matchers are
connected between
channel coders and a
multiplexer in a downlink
channel transmitting
device, and each of the
radio frame matchers of
the downlink channel

A repeated bit is placed directly after the original one.” (V6.0.0, paragraph 4.2.7.5, pages 40-41.)
In Apple's 3G products, the radio frame matchers are connected between channel coders and a multiplexer
in a downlink channel transmitting device. See, e.g., TS 25.212 v6.0.0:
Apple's 3G products have channel coders that connect the radio frame matchers and the multiplexer in a
downlink channel transmitting device as the following figure shows.

26

transmitting device
comprises:

[a] an interleaver for
interleaving the data
frames received by the
corresponding frame

(V6.0.0, paragraph 4.2, page 12. Annotation added.)
Each of the radio frame matchers of the downlink channel transmitting device in Apple's 3G products
includes an interleaver for interleaving the data frames received by the corresponding frame matcher. See,
e.g., TS 25.212 v6.0.0:

27

matcher;

As the following figure shows, the interleaver interleaves the data frames received by the corresponding
frame matcher.

(V6.0.0, paragraph 4.2, page 12. Annotation added)

28

The interleaver in the downlink transmitting device interleaves data in the manner described below.
“(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.)
“If fixed positions of the TrCHs in a radio frame is used then the bits input to the 1st interleaving are
denoted by hi1 , hi 2 , hi 3 , , hiDi , where i is the TrCH number. Hence, zik = hik and Zi = Di.
If flexible positions of the TrCHs in a radio frame is used then the bits input to the 1st interleaving are
denoted by gi1 , gi 2 , gi 3 ,, g iGi , where i is the TrCH number. Hence, zik = gik and Zi = Gi.

[b] a radio frame
segmenter for determining
the bit number of a radio
frame according to the

The bits output from the 1st interleaving are denoted by qi1 , qi 2 , qi 3 ,, qiQi , where i is the TrCH number and
Qi is the number of bits. Hence, qik = yik, Qi = FiHi if fixed positions are used, and Qi = Gi if flexible
positions are used.” (V6.0.0, paragraph, 4.2.5.4, page 23.)
Each of the radio frame matchers of the downlink channel transmitting device in Apple's 3G products
includes a radio frame segmenter for determining the bit number of a radio frame according to the size of
the data frames received by the corresponding frame matcher and a radio frame TTI and dividing the data
frame by a variable, said variable being a function of the radio frame TTI. See, e.g., TS 25.212 v6.0.0:

29

size of the data frames
received by the
corresponding frame
matcher and a radio frame
TTI and dividing the data
frame by a variable, said
variable being a function
of the radio frame TTI.

As the following passage explains, the ith transport channel receives xi1, xi2, xi3…xiXi where Xi is the size of
the data frames received by the corresponding frame matcher and the TTI of a radio frame.
“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.)
As the above passage also shows, the bit number of a radio frame is Yi. The radio frame segmenter divides
the data frames by the bit number of the radio frame and maps the received data frame into one or more
radio frames. For example, the first radio frame of transport channel i maps the first Yi bits of the received
data frame (i.e., yi,1,k – xi,k, k=1,2,…,Yi). The second radio frame of transport channel i maps the next Yi
bits of the received data frame (i.e., yi,2,k – xi,Yi +k, k=1,2,…,Yi), the third radio frame of transport channel i
maps the next Yi bits of the received data frame (i.e., yi,3,k – xi,2Yi +k, k=1,2,…,Yi), and so on.

6. A channel coding and
multiplexing apparatus for
a CDMA communication
system, in which data
frames that have one or
more transmission time

The bit number of a radio frame is Yi is determined by Yi = (Xi / Fi), where variable Fi is the output bit
sequences per TTI, which thus is a function of the radio frame TTI.
See claim 1.
Apple's 3G products comprise a channel coding and multiplexing apparatus for a CDMA communication
system, in which data frames that have one or more transmission time intervals (TTIs) are received in
parallel via a plurality of transport channels and converted to data frames of multi-code physical channels.

30

intervals (TTIs) are
received in parallel via a
plurality of transport
channels and converted to
data frames of multi-code
physical channels, the
apparatus comprising:

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.)

31

(V6.0.0, paragraph 4.2, page 11.)
As specified in V.6.0.0, Apple's 3G products receive data frames that have one or more transmission time
intervals (TTIs).

32

“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. The maximum size of the code blocks depends on whether
convolutional coding or turbo coding is used for the TrCH.” (V6.0.0, paragraph 4.2.2, page 14.)
As it can be seen from the following figure, data frames that have one or more transmission time intervals
(TTIs) are received in parallel via a plurality of transport channels and converted to data frames of physical
channels.

(V6.0.0, paragraph 4.2, page 11. Annotations added.)
“When the transmission time interval is longer than 10 ms, the input bit sequence is segmented and

33

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 43.)
Apple's 3G products have multi-code physical channels that are used in CDMA communication systems.
“For all modes, some bits of the input flow are mapped to each code until the number of bits on the code is
U.” (V.6.0.0, paragraph 4.2.10, page 45.)

[a] a number of radio
frame matchers, each
radio frame matcher
having a radio frame
segmenter for segmenting
the data frames into radio
frames;

V.6.0.0 further states that “[t]he PhCH for both uplink and downlink is defined in [2].” (V.6.0.0,
paragraph 4.2.12, page 45.) [2] is a document entitled “3rd Generation Partnership Project; Technical
Specification Group Radio Access Network; Physical channels and mapping of transport channels onto
physical channels (FDD) (Release 6),” which is dated December 2003. This document states in paragraph
5.2.1 on page 10 that “[t]here are three types of uplink dedicated physical channels, the uplink Dedicated
Physical Data Channel (uplink DPDCH), the uplink Dedicated Physical Control Channel (uplink DPCCH),
and the uplink Dedicated Control Channel associated with HS-DSCH transmission (uplink HS-DPCCH).
The DPDCH, the DPCCH and the HS-DPCCH are I/Q code multiplexed (see [4]),” which illustrates the
multi-code physical channels used in Apple's 3G products.
Apple's 3G products have a number of radio frame matchers, each radio frame matcher having a radio
frame segmenter for segmenting the data frames into radio frames.
See, e.g., TS 25.212 v6.0.0:
The transport channels are denoted in the figure below as TrCH.

34

(V6.0.0, paragraph 4.2, page 11. Annotations added.)
Each radio frame matcher in Apple's 3G products has a radio frame segmenter.

35

36

(V6.0.0, paragraph 4.2, page 11. Annotation added.)
Each radio frame matcher in Apple's 3G products receives the data frames and segments the data frames
into radio frames.
“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.)
“The input bit sequence to the radio frame segmentation is denoted by d i1 , d i 2 , d i 3 ,  , d iTi , where i is the
TrCH number and Ti the number of bits. Hence, xik = dik and Xi = Ti.
The output bit sequence corresponding to radio frame ni is denoted by ei1 , ei 2 , ei 3 ,, eiN i , where i is the

[b] a multiplexer for
multiplexing the radio
frames into a serial data
frame; and

TrCH number and Ni is the number of bits. Hence, ei ,k  yi ,ni k and Ni = Yi.” (V6.0.0, paragraph 4.2.6.1,
page 24.)
Apple's 3G products have a multiplexer for multiplexing the radio frames into a serial data frame.
See claim 1[b].

37

[c] a physical channel
segmenter adapted to
segment the serial data
frame by the number of
the physical channels and
outputting the segmented
physical channel frames to
corresponding physical
channels,

Apple's 3G products have a physical channel segmenter adapted to segment the serial data frame by the
number of the physical channels and outputting the segmented physical channel frames to corresponding
physical channels.
See, e.g., TS 25.212 v6.0.0:

38

39

(V6.0.0, paragraph 4.2, page 11. Annotation added.)
The physical channel segmenter is adapted to segment the serial data frame by the number of the physical
channels and outputting the segmented physical channel frames to corresponding physical channels.
“When more than one PhCH is used, physical channel segmentation divides the bits among the different
PhCHs.” (V6.0.0, paragraph 4.2.10, page 43.)
“Bits on first PhCH after physical channel segmentation:
u1, k = xf(k) k = 1, 2 , …, U
Bits on second PhCH after physical channel segmentation:
u2, k = xf(k+U)
k = 1, 2 , …, U
…
Bits on the Pth PhCH after physical channel segmentation:
uP,k = xf(k+(P-1)U)
k = 1, 2 , …, U
where f is such that :
- for modes other than compressed mode by puncturing, xf(k) = xk , i.e. f(k) = k, for all k.
- for compressed mode by puncturing, bit u1,1 corresponds to the bit xk with smallest index k when the
bits p are not counted, bit u1,2 corresponds to the bit xk with second smallest index k when the bits p
are not counted, and so on for bits u1,3, … u1, U, u2, 1, u2, 2, …u2, U, …uP,1, uP,2,… uP,U .”
(V6.0.0, paragraph 4.2.10, pages 43-44.)
[d] wherein the segmented
physical channel frames
for a physical channel #1
are output as e1,j=dj, the
segmented physical
channel frames for a
physical channel #2 are

In Apple's 3G products, the segmented physical channel frames for a physical channel #1 are output as
e1,j=dj, the segmented physical channel frames for a physical channel #2 are output as e2,j=d(j+P/M) and the
segmented physical channel frames for a physical channel #M are output as eM,j=d(j+(M-1)P/M, and wherein
the bits of the serial data frame output from the multiplexer are d1, d2, . . . , dp, the number of physical
channels is M, the size of the serial data frame output from the multiplexer is P and j=1, 2, . . . , P/M.
See, e.g., TS 25.212 v6.0.0:
40

output as e2,j=d(j+P/M) and
the segmented physical
channel frames for a
physical channel #M are
output as eM,j=d(j+(M-1)P/M,
and wherein the bits of the
serial data frame output
from the multiplexer are
d1, d2, . . . , dp, the number
of physical channels is M,
the size of the serial data
frame output from the
multiplexer is P and j=1,
2, . . . , P/M.

“The bits input to the physical channel segmentation are denoted by x1 , x2 , x3 ,, x X , where X is the
number of bits input to the physical channel segmentation block. The number of PhCHs is denoted by P.
The bits after physical channel segmentation are denoted u p,1 , u p,2 , u p,3 ,, u p,U , where p is PhCH number
and U is the number of bits in one radio frame for each PhCH, i.e. U= (X – NTGL - (Ndata,* – N’data,* )) / P
for compressed mode by puncturing, and U 

X
P

otherwise.” (V6.0.0, paragraph 4.2.10, page 43.)

“Bits on first PhCH after physical channel segmentation:
u1, k = xf(k) k = 1, 2 , …, U
Bits on second PhCH after physical channel segmentation:
u2, k = xf(k+U)
k = 1, 2 , …, U
…
Bits on the Pth PhCH after physical channel segmentation:
uP,k = xf(k+(P-1)U)
k = 1, 2 , …, U
where f is such that :
- for modes other than compressed mode by puncturing, xf(k) = xk , i.e. f(k) = k, for all k.
- for compressed mode by puncturing, bit u1,1 corresponds to the bit xk with smallest index k when the
bits p are not counted, bit u1,2 corresponds to the bit xk with second smallest index k when the bits p
are not counted, and so on for bits u1,3, … u1, U, u2, 1, u2, 2, …u2, U, …uP,1, uP,2,… uP,U .”
(V6.0.0, paragraph 4.2.10, pages 43-44.)
Based on the above passages from V.6.0.0, the following correspondence is made between the claim
elements and the above-cited notation from V.6.0.0.
Claim Element
Notation for Claim Element
Notation from V.6.0.0
“number of physical channels”
M
P
“size of the serial data frame
P
X
output from the multiplexer” ( i.e.,
number of input bits to physical
channel segmenter to be
segmented by physical channel
segmenter)
“serial data frame output from the
d1, d2, … dP
x1, x2, … xX

41

multiplexer” ( i.e., input bits to
physical channel segmenter)
position of a bit in a segmented
physical channel frame
“the segmented physical channel
frames for a physical channel #1
are output”
the segmented physical channel
frames for a physical channel #2
are output”
“the segmented physical channel
frames for a physical channel #M
are output”

7. A channel coding and
multiplexing apparatus for
a CDMA communication
system, in which data
frames that have one or
more transmission time
intervals (TTIs) are
received in parallel via a
plurality of transport
channels and multiplexed
to a serial data frame, the
apparatus comprising:

j

k

e1,j

u1,k

e2,j

u2,k

eM,j

uP,k
Note: The number of physical
channels is “M” for the claim and “P”
for V.6.0.0.

Based on the correspondence shown above, it is clear that “u1, k = xf(k) k = 1, 2 , …,U” (where U=X/P)
shows the same “segmented physical channel frames for a physical channel #1” as the claimed “e1,j=dj,”
“u2, k = xf(k+U) k = 1, 2 , …,U” shows the same “segmented physical channel frames for a physical channel
#2” as the claimed “e2,j=d(j+P/M),” and “uP,k = xf(k+(P-1)U) k = 1, 2 , …, U” shows the same “segmented
physical channel frames for a physical channel #M” as the claimed “as eM,j=d(j+(M-1)P/M.”
Apple's 3G products comprise a channel coding and multiplexing apparatus for a CDMA communication
system, in which data frames that have one or more transmission time intervals (TTIs) are received in
parallel via a plurality of transport channels and multiplexed to a serial data frame.
See, e.g.,
Apple iPhone user guide re iOS 3.1: (iPhone 3G or later, p. 21):

42

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

iPad iOS 3.2 user guide (iPad):

43

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

44

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”)).
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.)

45

(V6.0.0, paragraph 4.2, page 11.)
As specified in V.6.0.0, Apple's 3G products receive data frames that have different transmission time
intervals (TTIs).

46

“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. The maximum size of the code blocks depends on whether
convolutional coding or turbo coding is used for the TrCH.” (V6.0.0, paragraph 4.2.2, page 14.)
As it can be seen from the following figure, data frames that have different transmission time intervals
(TTIs) are received in parallel via a plurality of transport channels and multiplexed to a serial data frame.

(V6.0.0, paragraph 4.2, page 11. Annotations 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

47

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

[a] a number of radio
frame matchers, each of
the radio frame matchers
adapted to determine a
number of filler bits and
inserting the determined
number of filler bits into
the data frames, and each
of the radio frame
matchers having a radio
frame segmenter for
segmenting the data
frames having the inserted
number of filler bits into
radio frames; and

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.)
Apple's 3G products have a number of radio frame matchers, each of the radio frame matchers adapted to
determine a number of filler bits and inserting the determined number of filler bits into the data frames,
and each of the radio frame matchers having a radio frame segmenter for segmenting the data frames
having the inserted number of filler bits into radio frames.
See, e.g., TS 25.212 v6.0.0:
The transport channels are denoted in the figure below as TrCH. Each of the radio frame matchers
generates a transport channel and thus the number of radio frame matchers is at least equal to the number
of the transport channels.

48

(V6.0.0, paragraph 4.2, page 11. Annotations added.)
“The input bit sequence to the radio frame segmentation is denoted by d i1 , d i 2 , d i 3 ,  , d iTi , where i is the
TrCH number and Ti the number of bits. Hence, xik = dik and Xi = Ti.
The output bit sequence corresponding to radio frame ni is denoted by ei1 , ei 2 , ei 3 ,, eiN i , where i is the
49

TrCH number and Ni is the number of bits. Hence, ei ,k  yi ,ni k and Ni = Yi.” (V6.0.0, paragraph 4.2.6.1,
page 24.)
Each of the radio frame matchers in Apple's 3G products is adapted to determine a number of filler bits and
insert the determined number of filler bits into the data frames.
“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 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.)
Each radio frame matcher in Apple's 3G products has a radio frame segmenter.

50

51

(V6.0.0, paragraph 4.2, page 11. Annotation added.)
The radio frame segmenter receives the data frames having the inserted number of filler bits into radio
frames and segments the data frames.
“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.)
“The input bit sequence to the radio frame segmentation is denoted by d i1 , d i 2 , d i 3 ,  , d iTi , where i is the
TrCH number and Ti the number of bits. Hence, xik = dik and Xi = Ti.
The output bit sequence corresponding to radio frame ni is denoted by ei1 , ei 2 , ei 3 ,, eiN i , where i is the

[b] a multiplexer for
multiplexing the radio
frames into the serial data
frame.

TrCH number and Ni is the number of bits. Hence, ei ,k  yi ,ni k and Ni = Yi.” (V6.0.0, paragraph 4.2.6.1,
page 24.)
Apple's 3G products have a multiplexer for multiplexing the radio frames into the serial data frame. See,
e.g., TS 25.212 v6.0.0:

52

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

53

The multiplexer in Apple's 3G products receives radio frames from the rate matcher and multiplexes the
radio frames to the serial data frame.
“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. The bits
output from TrCH multiplexing are denoted by s1 , s2 , s3 ,, sS , where S is the number of bits, i.e. S  Vi .
i

The TrCH multiplexing is defined by the following relations:
sk  f1k
k = 1, 2, …, V1

sk  f 2, ( k V1 )

k = V1+1, V1+2, …, V1+V2

sk  f 3, ( k  (V1 V2 ))

k = (V1+V2)+1, (V1+V2)+2, …, (V1+V2)+V3



sk  f I , ( k  (V1 V2 VI 1 ))

k = (V1+V2+…+VI-1)+1, (V1+V2+…+VI-1)+2, …, (V1+V2+…+VI-1)+VI ”

(V6.0.0, paragraph 4.2.8, pages 41-42.)
8. The channel coding and
multiplexing apparatus of
claim 7, wherein each
radio frame segmenter
determines the bit number
of the radio frames
according to the size of
the corresponding data
frame, a radio frame TTI,
and the number of filler
bits, and divides the

Each radio frame segmenter in Apple's 3G products determines the bit number of the radio frames
according to the size of the corresponding data frame, a radio frame TTI, and the number of filler bits, and
divides the corresponding data frame by the bit number of the radio frames.
See, e.g., TS 25.212 v6.0.0:
As the following passage explains, the ith transport channel receives xi1, xi2, xi3…xiXi where Xi is the size of
the data frames received by the corresponding frame matcher and the TTI of a radio frame. The received
data frame by the radio frame segmenter contains the inserted filler bits.
“When the transmission time interval is longer than 10 ms, the input bit sequence is segmented and
54

corresponding data frame
by the bit number of the
radio frames.

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.)

9. The channel coding and
multiplexing apparatus of
claim 7, wherein each
radio frame matcher
further includes an
interleaver for interleaving
the data frames received
by the corresponding
frame matcher and
applying the interleaved
data frames to a
corresponding radio frame
segmenter.

As the above passage also shows, the bit number of a radio frame is Yi. The radio frame segmenter divides
the data frames by the bit number of the radio frame and maps the received data frame into one or more
radio frames. For example, the first radio frame of transport channel i maps the first Yi bits of the received
data frame (i.e., yi,1,k – xi,k, k=1,2,…,Yi). The second radio frame of transport channel i maps the next Yi
bits of the received data frame (i.e., yi,2,k – xi,Yi +k, k=1,2,…,Yi), the third radio frame of transport channel i
maps the next Yi bits of the received data frame (i.e., yi,3,k – xi,2Yi +k, k=1,2,…,Yi), and so on.
Each radio frame matcher in Apple's 3G products further includes an interleaver for interleaving the data
frames received by the corresponding frame matcher and applying the interleaved data frames to a
corresponding radio frame segmenter.
See, e.g., TS 25.212 v6.0.0:
As the following figure shows, the interleaver interleaves the data frames received by the corresponding
frame matcher. The interleaved data from the interleaver are applied to a corresponding radio frame
segmenter.

55

(V6.0.0, paragraph 4.2, page 11. Annotation added)
The interleaver interleaves data in the manner described below.

56

“(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:
(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 denot by yik:
“The bits input to the 1st i is the TrC and Ti the number of bits. Hence, zi,k = ti,k and Zi = Ti. The bis 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.)
Each radio frame matcher in Apple's 3G products further includes a rate matcher for adjusting the data rate
of a radio frame received from a radio frame segmenter by one of puncturing and repeating parts of the
radio frame to match the data rate of the radio frame to that of a physical channel frame.

10. The channel coding
and multiplexing
apparatus of claim 7,
wherein each radio frame
matcher further includes a See, e.g., TS 25.212 v6.0.0:
rate matcher for adjusting
the data rate of a radio
frame received from a
radio frame segmenter by
one of puncturing and
repeating parts of the radio
frame to match the data
rate of the radio frame to
that of a physical channel
frame.

57

(V6.0.0, paragraph 4.2, page 11. Annotation added.)
The radio frame matcher in Apple's 3G products adjusts the data rate of a radio frame received from a
radio frame segmenter by either puncturing (when there are too many bits) or repeating parts of the radio
58

frame (when there are not enough bits) to match the data rate of the radio frame to that of a physical
channel frame.
“Rate matching means that bits on a transport channel are repeated or punctured. Higher layers assign a
rate-matching attribute for each transport channel. This attribute is semi-static and can only be changed
through higher layer signaling. The rate-matching attribute is used when the number of bits to be repeated
or punctured is calculated.
The number of bits on a transport channel can vary between different transmission time intervals. In the
downlink the transmission is interrupted if the number of bits is lower than maximum. When the number
of bits between different transmission time intervals in uplink is changed, bits are repeated or punctured to
ensure that the total bit rate after TrCH multiplexing is identical to the total channel bit rate of the allocated
dedicated physical channels.” (V6.0.0, paragraph 4.2.7, page 24.)
Puncturing or repeating of bits follows the following rate matching rule specified in V.6.0.0.
“The rate matching rule is as follows:
if puncturing is to be performed
e = eini

-- initial error between current and desired puncturing ratio

m=1

-- index of current bit

do while m <= Xi
e = e – eminus

-- update error

if e <= 0 then

-- check if bit number m should be punctured

set bit xi,m to  where {0, 1}
e = e + eplus

-- update error

end if
m=m+1

-- next bit

59

end do
else
e = eini

-- initial error between current and desired puncturing ratio

m=1

-- index of current bit

do while m <= Xi
e = e – eminus

-- update error

do while e <= 0

-- check if bit number m should be repeated

repeat bit xi,m
e = e + eplus

-- update error

end do
m=m+1

-- next bit

end do
end if
11. A channel coding and
multiplexing apparatus for
a CDMA communication
system, in which data
frames that have one or
more transmission time
intervals (TTIs) are
received in parallel via a
plurality of transport
channels and converted to
data frames of multi-code

A repeated bit is placed directly after the original one.” (V6.0.0, paragraph 4.2.7.5, pages 40-41.)
See claim 7.
Apple's 3G products comprise a channel coding and multiplexing apparatus for a CDMA communication
system, in which data frames that have one or more transmission time intervals (TTIs) are received in
parallel via a plurality of transport channels and converted to data frames of multi-code physical channels.
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
60

physical channels, the
apparatus comprising:

error detection, error correcting, rate matching, interleaving and transport channels mapping onto/splitting
from physical channels.” (V6.0.0, paragraph 4.1, page 9.)

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

61

As specified in V.6.0.0, Apple's 3G products receive data frames that have one or more transmission time
intervals (TTIs).
“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. The maximum size of the code blocks depends on whether
convolutional coding or turbo coding is used for the TrCH.” (V6.0.0, paragraph 4.2.2, page 14.)
As it can be seen from the following figure, data frames that have one or more transmission time intervals
(TTIs) are received in parallel via a plurality of transport channels and converted to data frames of physical
channels.

62

(V6.0.0, paragraph 4.2, page 11. Annotations 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.
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

63

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 43.)
Apple's 3G products have multi-code physical channels that are used in CDMA communication systems.
“For all modes, some bits of the input flow are mapped to each code until the number of bits on the code is
U.” (V.6.0.0, paragraph 4.2.10, page 45.)

[a] a number of radio
frame matchers, each of
the radio frame matchers
determining a number of
filler bits and inserting the
determined number of
filler bits into the data
frames and each of the
radio frame matchers
having a radio frame
segmenter for segmenting
the data frames having the
inserted number of filler
bits into radio frames;
[b] a multiplexer for
multiplexing the radio

V.6.0.0 further states that “[t]he PhCH for both uplink and downlink is defined in [2].” (V.6.0.0,
paragraph 4.2.12, page 45.) [2] is a document entitled “3rd Generation Partnership Project; Technical
Specification Group Radio Access Network; Physical channels and mapping of transport channels onto
physical channels (FDD) (Release 6),” which is dated December 2003. This document states in paragraph
5.2.1 on page 10 that “[t]here are three types of uplink dedicated physical channels, the uplink Dedicated
Physical Data Channel (uplink DPDCH), the uplink Dedicated Physical Control Channel (uplink DPCCH),
and the uplink Dedicated Control Channel associated with HS-DSCH transmission (uplink HS-DPCCH).
The DPDCH, the DPCCH and the HS-DPCCH are I/Q code multiplexed (see [4]),” which illustrates the
multi-code physical channels used in Apple's 3G products.
Apple's 3G products have a number of radio frame matchers, each of the radio frame matchers determining
a number of filler bits and inserting the determined number of filler bits into the data frames and each of
the radio frame matchers having a radio frame segmenter for segmenting the data frames having the
inserted number of filler bits into radio frames.
See claim 7[a].

Apple's 3G products have a multiplexer for multiplexing the radio frames into a serial data frame.

64

frames into a serial data
frame; and

See claim 7[b].

[c] a physical channel
segmenter for segmenting
the multiplexed serial data
frame by the number of
the physical channels and
outputting the segmented
physical channel frames to
corresponding physical
channels.

Apple's 3G products have a physical channel segmenter for segmenting the multiplexed serial data frame
by the number of the physical channels and outputting the segmented physical channel frames to
corresponding physical channels.
See, e.g., TS 25.212 v6.0.0:

65

66

(V6.0.0, paragraph 4.2, page 11. Annotation added.)
The physical channel segmenter segments the multiplexed serial data frame by the number of the physical
channels and outputs the segmented physical channel frames to corresponding physical channels.
“When more than one PhCH is used, physical channel segmentation divides the bits among the different
PhCHs.” (V6.0.0, paragraph 4.2.10, page 43.)
“Bits on first PhCH after physical channel segmentation:
u1, k = xf(k) k = 1, 2 , …, U
Bits on second PhCH after physical channel segmentation:
u2, k = xf(k+U)
k = 1, 2 , …, U
…
Bits on the Pth PhCH after physical channel segmentation:
uP,k = xf(k+(P-1)U)
k = 1, 2 , …, U
where f is such that :
- for modes other than compressed mode by puncturing, xf(k) = xk , i.e. f(k) = k, for all k.
- for compressed mode by puncturing, bit u1,1 corresponds to the bit xk with smallest index k when the
bits p are not counted, bit u1,2 corresponds to the bit xk with second smallest index k when the bits p
are not counted, and so on for bits u1,3, … u1, U, u2, 1, u2, 2, …u2, U, …uP,1, uP,2,… uP,U .”
(V6.0.0, paragraph 4.2.10, pages 43-44.)
12. A channel coding and
multiplexing method for a
CDMA communication
system in which data
frames that have one or
more transmission time
intervals (TTIs) are

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 channel coding and multiplexing method for a CDMA communication
system, in which data frames that have one or more transmission time intervals (TTIs) are received in
67

received in parallel via a
plurality of transport
channels and multiplexed
into a serial data frame,
the method comprising:

parallel via a plurality of transport channels and multiplexed into a serial data frame.

[a] receiving data frames;

Apple's 3G products practice receiving data frames. A data frame corresponds to data transmitted in a
transmission time interval (TTI).

See claim 7.

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

[b] determining a number
of filler bits;

“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. The maximum size of the code blocks depends on whether
convolutional coding or turbo coding is used for the TrCH.” (V6.0.0, paragraph 4.2.2, page 14.)
Apple's 3G products practice determining a number of filler bits.
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 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.)
[c] inserting the number of Apple's 3G products practice inserting the number of filler bits into the data frames.

68

filler bits into the data
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 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.)

[d] segmenting the data
frames including the filler
bits into radio frames in a
number of radio frame
matchers; and

Apple's 3G products practice segmenting the data frames including the filler bits into radio frames in a
number of radio frame matchers. Each radio frame segmenter determines the bit number of a radio frame
according to the size of the corresponding data frame, a radio frame TTI.
See, e.g., TS 25.212 v6.0.0:
As the following passage explains, the ith transport channel receives xi1, xi2, xi3…xiXi where Xi is the size of
the data frames received by the corresponding frame matcher and the TTI of a radio frame. The received
data frame by the radio frame segmenter contains the inserted filler bits.
“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

69

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.)

[e] multiplexing the radio
frames into the serial data
frame.

As the above passage also shows, the bit number of a radio frame is Yi. The radio frame segmenter divides
the data frames by the bit number of the radio frame and maps the received data frame into one or more
radio frames. For example, the first radio frame of transport channel i maps the first Yi bits of the received
data frame (i.e., yi,1,k – xi,k, k=1,2,…,Yi). The second radio frame of transport channel i maps the next Yi
bits of the received data frame (i.e., yi,2,k – xi,Yi +k, k=1,2,…,Yi), the third radio frame of transport channel i
maps the next Yi bits of the received data frame (i.e., yi,3,k – xi,2Yi +k, k=1,2,…,Yi), and so on.
Apple's 3G products practice multiplexing the radio frames into the serial data frame.
See, e.g., TS 25.212 v6.0.0:

70

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

71

The multiplexer in the Accused Product receives radio frames from the rate matcher and multiplexes the
radio frames to the serial data frame.
“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. The bits
output from TrCH multiplexing are denoted by s1 , s2 , s3 ,, sS , where S is the number of bits, i.e. S  Vi .
i

The TrCH multiplexing is defined by the following relations:
sk  f1k
k = 1, 2, …, V1

sk  f 2, ( k V1 )

k = V1+1, V1+2, …, V1+V2

sk  f 3, ( k  (V1 V2 ))

k = (V1+V2)+1, (V1+V2)+2, …, (V1+V2)+V3



sk  f I , ( k  (V1 V2 VI 1 ))

k = (V1+V2+…+VI-1)+1, (V1+V2+…+VI-1)+2, …, (V1+V2+…+VI-1)+VI ”

(V6.0.0, paragraph 4.2.8, pages 41-42.)
13. The channel coding
and multiplexing method
of claim 12, further
comprising: segmenting
the serial data frame by
the number of the physical
channels; and

See claim 12.
Apple's 3G products further practice segmenting the serial data frame by the number of the physical
channels.
See, e.g., TS 25.212 v6.0.0:

72

73

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

[a] assigning the
segmented physical
channel frames to the
corresponding physical
channels.

“When more than one PhCH is used, physical channel segmentation divides the bits among the different
PhCHs.” (V6.0.0, paragraph 4.2.10, page 43.)
Apple's 3G products further practice assigning the segmented physical channel frames to the corresponding
physical channels.
See, e.g., TS 25.212 v6.0.0:

74

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

75

“The PhCH for both uplink and downlink is defined in [2]. The bits input to the physical channel mapping
are denoted by v p ,1 , v p , 2 ,, v p ,U , where p is the PhCH number and U is the number of bits in one radio
frame for one PhCH. The bits vp,k are mapped to the PhCHs so that the bits for each PhCH are transmitted
over the air in ascending order with respect to k.” (V6.0.0, paragraph 4.2.12, page 45.)

14. A channel coding and
multiplexing apparatus for
a CDMA communication
system, in which data
frames that have one or
more transmission time
intervals (TTIs) are
received in parallel via a
plurality of transport
channels and multiplexed
into a serial data frame,
the apparatus comprising:
[a] a plurality of radio
frame matchers, each of
the radio frame matchers
adapted to determine a
number of filler bits and to
insert the determined
number of the filler bits
into the data frames and,
each of the radio frame
matchers comprising a
radio frame segmenter for
segmenting the data
frames having the inserted

“In uplink, the PhCHs used during a radio frame are either completely filled with bits that are transmitted
over the air or not used at all. The only exception is when the UE is in compressed mode. The transmission
can then be turned off during consecutive slots of the radio frame.” (V6.0.0, paragraph 4.2.12.1, page 45.)
See claim 7.

Apple's 3G products have a plurality of radio frame matchers, each of the radio frame matchers adapted to
determine a number of filler bits and to insert the determined number of the filler bits into the data frames
and, each of the radio frame matchers comprising a radio frame segmenter for segmenting the data frames
having the inserted number of filler bits into radio frames.
See clam 7[a].

76

number of filler bits into
radio frames; and
[b] a multiplexer for
multiplexing the radio
frames into a serial data
frame,
[c] wherein the number of
filler bits is determined
such that the filler bit
inserted data frames can
be segmented into equally
sized radio frames.

15. A channel coding and
multiplexing method for a
CDMA communication
system in which data
frames that have one or
more transmission time
intervals (TTIs) are

Apple's 3G products have a multiplexer for multiplexing the radio frames into a serial data frame.
See claim 7[b].

The radio frame matcher in Apple's 3G products determines the number of filler bits such that the filler bit
inserted data frames can be segmented into equally sized 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 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 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 12.

77

received in parallel via a
plurality of transport
channels and multiplexed
into a serial data frame,
the method comprising:
[a] receiving data frames;

See claim 12[a].

[b] determining a number
of filler bits;

See claim 12[b].

[c] inserting the number
filler bits into the data
frames;
[d] segmenting the data
frames including the filler
bits into radio frames in a
number of radio frame
matchers; and
[e] multiplexing the radio
frames into the serial data
frame,

See claim 12[c].

[f] wherein the number of
filler bits is determined
such that the filler bit
inserted data frames can
be segmented into equally
sized radio frames.
16. A channel coding and
multiplexing method for a
CDMA communication
system, in which data

See claim 14[c].

See claim 7[d].

See claim 7[e].

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.

78

frames that have one or
more transmission time
intervals (TTIs) are
received in parallel via a
plurality of transport
channels and converted to
data frames of multi-code
physical channels, the
method comprising:

Apple's 3G products practice a channel coding and multiplexing method for a CDMA communication
system, in which data frames that have one or more transmission time intervals (TTIs) are received in
parallel via a plurality of transport channels and converted to data frames of multi-code physical channels.
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.)

79

(V6.0.0, paragraph 4.2, page 11.)
As specified in V.6.0.0, Apple's 3G products receive data frames that have one or more transmission time
intervals (TTIs).

80

“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. The maximum size of the code blocks depends on whether
convolutional coding or turbo coding is used for the TrCH.” (V6.0.0, paragraph 4.2.2, page 14.)
As it can be seen from the following figure, data frames that have one or more transmission time intervals
(TTIs) are received in parallel via a plurality of transport channels and converted to data frames of physical
channels.

(V6.0.0, paragraph 4.2, page 11. Annotations added.)
“When the transmission time interval is longer than 10 ms, the input bit sequence is segmented and

81

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 43.)
Apple's 3G products have multi-code physical channels that are used in CDMA communication systems.
“For all modes, some bits of the input flow are mapped to each code until the number of bits on the code is
U.” (V.6.0.0, paragraph 4.2.10, page 45.)

[a] segmenting the
received data frames into
radio frames in a number
of radio frame matchers;

V.6.0.0 further states that “[t]he PhCH for both uplink and downlink is defined in [2].” (V.6.0.0,
paragraph 4.2.12, page 45.) [2] is a document entitled “3rd Generation Partnership Project; Technical
Specification Group Radio Access Network; Physical channels and mapping of transport channels onto
physical channels (FDD) (Release 6),” which is dated December 2003. This document states in paragraph
5.2.1 on page 10 that “[t]here are three types of uplink dedicated physical channels, the uplink Dedicated
Physical Data Channel (uplink DPDCH), the uplink Dedicated Physical Control Channel (uplink DPCCH),
and the uplink Dedicated Control Channel associated with HS-DSCH transmission (uplink HS-DPCCH).
The DPDCH, the DPCCH and the HS-DPCCH are I/Q code multiplexed (see [4]),” which illustrates the
multi-code physical channels used in Apple's 3G products.
Apple's 3G products practice segmenting the received data frames into radio frames in a number of radio
frame matchers. Each radio frame segmenter determines the bit number of a radio frame according to the
size of the corresponding data frame, a radio frame TTI.
See, e.g., TS 25.212 v6.0.0:
As the following passage explains, the ith transport channel receives xi1, xi2, xi3…xiXi where Xi is the size of

82

the data frames received by the corresponding frame matcher and the TTI of a radio frame. The received
data frame by the radio frame segmenter contains the inserted filler bits.
“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.)

[b] multiplexing the radio
frames into a serial data
frame; and

As the above passage also shows, the bit number of a radio frame is Yi. The radio frame segmenter divides
the data frames by the bit number of the radio frame and maps the received data frame into one or more
radio frames. For example, the first radio frame of transport channel i maps the first Yi bits of the received
data frame (i.e., yi,1,k – xi,k, k=1,2,…,Yi). The second radio frame of transport channel i maps the next Yi
bits of the received data frame (i.e., yi,2,k – xi,Yi +k, k=1,2,…,Yi), the third radio frame of transport channel i
maps the next Yi bits of the received data frame (i.e., yi,3,k – xi,2Yi +k, k=1,2,…,Yi), and so on.
Apple's 3G products practice multiplexing the radio frames into a serial data frame.
See, e.g., TS 25.212 v6.0.0:

83

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

84

The multiplexer in the Accused Product receives radio frames from the rate matcher and multiplexes the
radio frames to the serial data frame.
“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. The bits
output from TrCH multiplexing are denoted by s1 , s2 , s3 ,, sS , where S is the number of bits, i.e. S  Vi .
i

The TrCH multiplexing is defined by the following relations:
sk  f1k
k = 1, 2, …, V1

sk  f 2, ( k V1 )

k = V1+1, V1+2, …, V1+V2

sk  f 3, ( k  (V1 V2 ))

k = (V1+V2)+1, (V1+V2)+2, …, (V1+V2)+V3



sk  f I , ( k  (V1 V2 VI 1 ))

k = (V1+V2+…+VI-1)+1, (V1+V2+…+VI-1)+2, …, (V1+V2+…+VI-1)+VI ”

(V6.0.0, paragraph 4.2.8, pages 41-42.)
[c] segmenting the serial
data frame by the number
of the physical channels
and outputting the
segmented physical
channel frames to
corresponding physical
channels,

Apple's 3G products practice segmenting the serial data frame by the number of the physical channels and
outputting the segmented physical channel frames to corresponding physical channels.

85

86

(V6.0.0, paragraph 4.2, page 11. Annotation added.)
The physical channel segmenter segments the serial data frame by the number of the physical channels and
outputs the segmented physical channel frames to corresponding physical channels.
“When more than one PhCH is used, physical channel segmentation divides the bits among the different
PhCHs.” (V6.0.0, paragraph 4.2.10, page 43.)
“Bits on first PhCH after physical channel segmentation:
u1, k = xf(k) k = 1, 2 , …, U
Bits on second PhCH after physical channel segmentation:
u2, k = xf(k+U)
k = 1, 2 , …, U
…
Bits on the Pth PhCH after physical channel segmentation:
uP,k = xf(k+(P-1)U)
k = 1, 2 , …, U
where f is such that :
- for modes other than compressed mode by puncturing, xf(k) = xk , i.e. f(k) = k, for all k.
- for compressed mode by puncturing, bit u1,1 corresponds to the bit xk with smallest index k when the
bits p are not counted, bit u1,2 corresponds to the bit xk with second smallest index k when the bits p
are not counted, and so on for bits u1,3, … u1, U, u2, 1, u2, 2, …u2, U, …uP,1, uP,2,… uP,U .”
(V6.0.0, paragraph 4.2.10, pages 43-44.)
[d] wherein the segmented
physical channel frames
for physical channel #1
are output as e1,j=dj, the
segmented physical
channel frames for
physical channel #2 are

In Apple's 3G products, the segmented physical channel frames for a physical channel #1 are output as
e1,j=dj, the segmented physical channel frames for a physical channel #2 are output as e2,j=d(j+P/M) and the
segmented physical channel frames for a physical channel #M are output as eM,j=d(j+(M-1)P/M, and wherein
the bits of the serial data frame output from the multiplexer are d1, d2, . . . , dp, the number of physical
channels is M, the size of the serial data frame output from the multiplexer is P and j=1, 2, . . . , P/M.

87

output as e2,j=d(j+P/M) and
the segmented physical
channel frames for
physical channel #M are
output as eM,j=d(j+(M-1)P/M,
and wherein the bits of the
serial data frame output
from the multiplexer are
d1, d2, . . . , dp, the number
o physical channels is M,
the size of the serial data
frame output from the
multiplexing step is P and
j=1,2, . . . , P/M.

“The bits input to the physical channel segmentation are denoted by x1 , x2 , x3 ,, x X , where X is the
number of bits input to the physical channel segmentation block. The number of PhCHs is denoted by P.
The bits after physical channel segmentation are denoted u p,1 , u p,2 , u p,3 ,, u p,U , where p is PhCH number
and U is the number of bits in one radio frame for each PhCH, i.e. U= (X – NTGL - (Ndata,* – N’data,* )) / P
for compressed mode by puncturing, and U 

X
P

otherwise.” (V6.0.0, paragraph 4.2.10, page 43.)

“Bits on first PhCH after physical channel segmentation:
u1, k = xf(k) k = 1, 2 , …, U
Bits on second PhCH after physical channel segmentation:
u2, k = xf(k+U)
k = 1, 2 , …, U
…
Bits on the Pth PhCH after physical channel segmentation:
uP,k = xf(k+(P-1)U)
k = 1, 2 , …, U
where f is such that :
- for modes other than compressed mode by puncturing, xf(k) = xk , i.e. f(k) = k, for all k.
- for compressed mode by puncturing, bit u1,1 corresponds to the bit xk with smallest index k when the
bits p are not counted, bit u1,2 corresponds to the bit xk with second smallest index k when the bits p
are not counted, and so on for bits u1,3, … u1, U, u2, 1, u2, 2, …u2, U, …uP,1, uP,2,… uP,U .”
(V6.0.0, paragraph 4.2.10, pages 43-44.)
Based on the above passages from V.6.0.0, the following correspondence is made between the claim
elements and the above-cited notation from V.6.0.0.
Claim Element
Notation for Claim Element
Notation from V.6.0.0
“number of physical channels”
M
P
“size of the serial data frame
P
X
output from the multiplexer” ( i.e.,
number of input bits to physical
channel segmenter to be
segmented by physical channel
segmenter)
“serial data frame output from the
d1, d2, … dP
x1, x2, … xX
multiplexer” ( i.e., input bits to

88

physical channel segmenter)
position of a bit in a segmented
physical channel frame
“the segmented physical channel
frames for a physical channel #1
are output”
the segmented physical channel
frames for a physical channel #2
are output”
“the segmented physical channel
frames for a physical channel #M
are output”

j

k

e1,j

u1,k

e2,j

u2,k

eM,j

uP,k
Note: The number of physical
channels is “M” for the claim and “P”
for V.6.0.0.

Based on the correspondence shown above, it is clear that “u1, k = xf(k) k = 1, 2 , …,U” (where U=X/P)
shows the same “segmented physical channel frames for a physical channel #1” as the claimed “e1,j=dj,”
“u2, k = xf(k+U) k = 1, 2 , …,U” shows the same “segmented physical channel frames for a physical channel
#2” as the claimed “e2,j=d(j+P/M),” and “uP,k = xf(k+(P-1)U) k = 1, 2 , …, U” shows the same “segmented
physical channel frames for a physical channel #M” as the claimed “as eM,j=d(j+(M-1)P/M.”

89

17. The channel coding
and multiplexing
apparatus of claim 7,
wherein one filler bit is
added to the end of each
radio frame having frame
time index t>=Ti-ri+1
where ri indicates the
number of filler bits and Ti
indicates a TTI.

In Apple's 3G products, one filler bit is added to the end of each radio frame having frame time index
t>=Ti-ri+1 where ri indicates the number of filler bits and Ti indicates a TTI.

18. The channel coding
and multiplexing
apparatus of claim 11,
wherein one filler bit is
added to the end of each
radio frame having frame
time index t>=Ti-ri+1
where ri indicates the
number of filler bits and Ti
indicates a TTI.

In Apple's 3G products, one filler bit is added to the end of each radio frame having frame time index
t>=Ti-ri+1 where ri indicates the number of filler bits and Ti indicates a TTI.

“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 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.)

“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 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.”
90

(V6.0.0, paragraph 4.2.4, page 21.)
19. The channel coding
and multiplexing
apparatus of claim 12,
wherein one filler bit is
added to the end of each
radio frame having frame
time index t>=Ti-ri+1
where ri indicates the
number of filler bits and Ti
indicates a TTI.

In Apple's 3G products, one filler bit is added to the end of each radio frame having frame time index
t>=Ti-ri+1 where ri indicates the number of filler bits and Ti indicates a TTI.

20. The channel coding
and multiplexing
apparatus of claim 14,
wherein one filler bit is
added to the end of each
radio frame having frame
time index t>=Ti-ri+1
where ri indicates the
number of filler bits and Ti
indicates a TTI.

In Apple's 3G products, one filler bit is added to the end of each radio frame having frame time index
t>=Ti-ri+1 where ri indicates the number of filler bits and Ti indicates a TTI.

“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 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.)

“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 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
91

- 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.)
21. The channel coding
and multiplexing
apparatus of claim 15,
wherein one filler bit is
added to the end of each
radio frame having frame
time index t>=Ti-ri+1
where ri indicates the
number of filler bits and Ti
indicates a TTI.

In Apple's 3G products, one filler bit is added to the end of each radio frame having frame time index
t>=Ti-ri+1 where ri indicates the number of filler bits and Ti indicates a TTI.
“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 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.)

92