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 63

EXHIBIT K

SAMSUNG’S PATENT L.R. 3-1(A)-(D) DISCLOSURES FOR
U.S. PATENT NO. 7,675,941

ASSERTED CLAIM
(PATENT L.R. 3-1(A))
1. A method of transmitting data in a mobile
communication system, comprising:

receiving a service data unit (SDU) from a
higher layer and determining whether the SDU
can be comprised in one protocol data unit
(PDU);

if the SDU is not comprised in one PDU,

ACCUSED INSTRUMENTALITY AND HOW EACH ELEMENT IS MET BY
ACCUSED INSTRUMENTALITY
(PATENT L.R. 3-1(B)-(D))
Apple's 3G Products1 transmit data in a mobile communication system. Apple infringes
this claim because it has performed each and every step of this claim, including but not
limited to through testing and use by its employees. Apple also infringes this claim by
selling Apple's 3G Products to customers and encouraging those customers to use the
products in a manner that meets each and every step of this claim.
For example, Apple's 3G Products support transmitting and receiving data using UMTS
radio technology2 described in 3GPP3 using a radio transceiver including a baseband
processor. See 3GPP § 4.2.1; Figures 4.1, 4.3, and 4.3A.
Apple's 3G Products receive a service data unit (SDU) from a higher layer and determine
whether the SDU can be comprised in one protocol data unit (PDU).
For example, peer-to-peer communication can proceed in at least three modes: (1)
Transparent Mode Data PDU (TMD PDU); (2) Unacknowledged Mode Data PDU (UMD
PDS); and (3) Acknowledged Mode Data PDU (AMD PDU).4 See 3GPP § 9.1.1. All
three of these modes are used to convey RLC SDU data. Id.
As described in 3GPP, “Length Indicators are used to define boundaries between RLC
SDUs within UMD PDUs unless the ‘Extension bit’ already indicates that a UMD PDU
contains exactly one complete SDU.” Id. § 4.2.1.2.1.
Apple's 3G Products segment, if the SDU is not comprised in one PDU, the SDU into a

1

“Apple’s 3G Products” include iPhone 3G, iPhone 3GS, iPhone4, iPad 3G, iPad2 3G and any other products compliant with 3GPP UMTS standard.
See, e.g., iPhone 4 Technical Specifications, available at http://www.apple.com/iphone/specs.html. Similar technical specifications are available for the
other Apple 3G Products, indicating that each supports and uses UMTS.
3
As defined herein, “3GPP” means 3GPP TS 25.322 v6.4.0 (2005-06) (Release 6); corresponding disclosure may be found in earlier versions.
4
Although only "Unacknowledged Mode" is detailed in this preliminary infringement contention, the analysis described herein may apply equally, mutatis
mutandis, to the other modes of communication listed in this paragraph.
2

2

segmenting the SDU into a plurality of segments plurality of segments according to a transmittable PDU size, and construct one or more
according to a transmittable PDU size, and
PDUs, each PDU comprising a header and a data field, wherein the data field comprises a
constructing one or more PDUs, each PDU
segment of the SDU.
comprising a header and a data field,
For example, “the transmitting UM RLC entity segments the RLC SDU into UMD PDUs
of appropriate size, if the RLC SDU is larger than the length of available space in the
UMD PDU. The UMD PDU may contain segmented and/or concatenated RLC SDUs.”
Id.
The actual format of the constructed UMD PDU is described in § 9.2.1.3 and shown
below. Each PDU includes a header and data field. Id. § 9.2.1.3.
9.2.1.3

UMD PDU

The UMD PDU is used to transfer user data when RLC is operating in unacknowledged
mode. The length of the data part shall be a multiple of 8 bits. The UMD PDU header
consists of the first octet, which contains the “Sequence Number”. The RLC header
consists of the first octet and all the octets that contain "Length Indicators".
Sequence Number
Length Indicator

E
E

Oct1
(Optional) (1)

.
.
.

Length Indicator

(Optional)

E

Data

PAD

(Optional)
Last Octet

Figure 9.2: UMD PDU
3

wherein the data field comprises a segment of
the SDU,

wherein the header comprises a serial number
(SN) field, a one-bit field indicating that the
PDU does not contain an entire SDU in the data
field and at least one Length Indicator (LI) field,

In Apple's 3G Products the data field comprises a segment of the SDU.
For example, Figure 9.2 above shows the “data” field payload in a UMD PDU. As
described above, “[t]he UMD PDU may contain segmented and/or concatenated RLC
SDUs,” Id. § 4.2.1.2.1.
The PDUs constructed by Apple's 3G Products include a header that comprises a serial
number (SN) field, a one-bit field indicating that the PDU does not contain an entire SDU
in the data field and at least one Length Indicator (LI) field.
For example, [t]he RLC header consists of the first octet and all the octets that contain
“Length Indicators”. Id. The one-bit “Extension bit” (labeled “E” in Figure 9.2) is
included in the first octet. Id. § 9.2.2.5.
Sequence Number
Length Indicator

E
E

Oct1
(Optional) (1)

.
.
.

Length Indicator

(Optional)

E

Data

PAD

(Optional)
Last Octet

Figure 9.2: UMD PDU
If the “Extension bit” in the first octet of the header is ‘0’ then this indicates that the nest
field is a complete SDU, as shown in the table below. Id. at § 9.2.2.5. If the bit is ‘1’
then this indicates that that the next field is a Length Indicator and Extension bit, as shown
in Figure 9.2 above. Id.
Bit
4

Description

The next field is a complete SDU, which
is not segmented, concatenated or
padded.
The next field is Length Indicator and E
1
bit
wherein if the data field of the PDU contains an Apple's 3G Products include an LI field in the PDU that is set to a predefined value
intermediate segment of the SDU, the LI field in indicating that the PDU contains neither a first segment nor a last segment of the SDU.
the PDU contains the intermediate segment of
the SDU is set to a predefined value indicating
For example:
that the PDU contains neither a first segment nor
a last segment of the SDU; and
In the case where the "alternative E-bit interpretation" is configured for UM RLC and an
RLC PDU contains a segment of an SDU but neither the first octet nor the last octet of
this SDU:
0

-

the "Length Indicator" with value "111 1110" shall be used.

-

if a 15-bit "Length Indicator" is used:

sending the PDUs to a receiver.

if a 7-bit "Length Indicator" is used:

the "Length Indicator" with value "111 1111 1111 1110" shall be used.

Id. § 9.2.2.8.
Apple's 3G Products send the PDUs to a receiver.
For example, “[t]he transmitting UM-RLC entity receives RLC SDUs from upper layers
through the UM-SAP” and “submits UMD PDUs to the lower layer through either a
CCCH, SHCCH, DCCH, CTCH, DTCH, MCCH, MSCH or an MTCH logical channel.”
Id. at § 4.2.1.2.1. The PDUs are then sent to a receiver using at least the CTCH
(Common Traffic Channel) and DTCH (Dedicated Traffic Channel). See also Figures
4-1 and § 4.2.1 (noting that “submitting to the lower layer” is the same as “transmitting”).
5

Claim 2
2. The method of claim 1, further comprising the Apple's 3G Products construct one PDU comprising a header and a data field, if the SDU is
step of, if the SDU is comprised in one PDU,
comprised in one PDU.
constructing one PDU comprising a header and a
data field,
For example, “the transmitting UM RLC entity segments the RLC SDU into UMD PDUs
of appropriate size, if the RLC SDU is larger than the length of available space in the
UMD PDU. The UMD PDU may contain segmented and/or concatenated RLC SDUs.”
Id. § 4.2.1.2.1. As shown above in Figure 9-2, the PDU includes a header and a data
field.
wherein the header comprises a SN field, and a The PDUs constructed by Apple's 3G Products include a header field with a SN field, and
one-bit field indicating that the PDU contains the a one-bit field indicating that the PDU contains the entire SDU in the data field.
entire SDU in the data field.
The SN field is shown above in Figure 9-2. See id. § 9.2.1.3. If the “Extension bit” in
the first octet of the header is ‘0’ then this indicates that the next field is a complete SDU,
as shown in the table below. Id. at § 9.2.2.5.

Bit
0

1

Claim 4
4. The method of claim 1, wherein LI fields of
PDUs comprising the first and last segments of
the SDU in data fields are set to values
indicating inclusion of the first segment of the
SDU and inclusion of the last segment of the

Description
The next field is a complete SDU, which
is not segmented, concatenated or
padded.
The next field is Length Indicator and E
bit

Apple's 3G Products include LI fields of PDUs comprising the first and last segments of
the SDU in data fields that are set to values indicating inclusion of the first segment of the
SDU and inclusion of the last segment of the SDU.
For example, § 9.2.2.8 of 3GPP describes the operation of the LI fields in Apple's 3G
6

SDU.

Products. The Length Indicator indicates the last octet of each SDU ending within the
PDU and signals inclusion of the first and last segments.
9.2.2.8

Length Indicator (LI)

Unless the "Extension bit" indicates that a UMD PDU contains a complete SDU which is
not segmented, concatenated or padded, a "Length Indicator" is used to indicate the last
octet of each RLC SDU ending within the PDU. If the "Extension bit" indicates that the
UMD PDU contains a complete SDU which is not segmented, concatenated or padded, no
LIs are present in this UMD PDU.
Except for the predefined values reserved for special purposes and listed in the tables
below, the "Length Indicator" shall:
- be set to the number of octets between the end of the RLC header and up to and
including the last octet of an RLC SDU segment;
- be included in the PDUs that they refer to.
Claim 6
6. A method of receiving data in a mobile
communication system, comprising:
receiving a protocol data unit (PDU) from a
transmitter and detecting a sequence number
(SN) field and a one-bit field indicating whether
the PDU contains an entire service data unit
(SDU) in its data field from the header;

Apple's 3G Products receive data in a mobile communication system. See claim 1 above.
Apple's 3G Products receive a protocol data unit (PDU) from a transmitter and detect a
sequence number (SN) field and a one-bit field indicating whether the PDU contains an
entire service data unit (SDU) in its data field from the header.
For example, “[t]he receiving UM-RLC entity receives UMD PDUs through the
configured logical channels from the lower layer…. The receiving UM RLC entity
deciphers (if ciphering is configured and started) the received UMD PDUs (except for the
UMD PDU header). It removes RLC headers from received UMD PDUs, and reassembles
RLC SDUs (if segmentation and/or concatenation has been performed by the transmitting
7

if the one-bit field indicates that the PDU does
not contain an entire SDU in its data field,
detecting the following length indicator (LI)
field from the header of the PDU, and
determining whether the LI field is set to a value
indicating that the PDU contains an intermediate
segment that is neither a first segment nor a last
segment of the SDU;
storing the PDU until the PDU can be assembled
with a previous segment and a following
segment, if the LI field is set to the predefined
value; and

constructing the SDU by combining the
intermediate segment from the data field of the
PDU with at least one previous segment
extracted from a data field of at least one
previous PDU and at least one following
segment extracted from a data field of at least
one following PDU.

Claim 7
7. The method of claim 6, further comprising, if

UM RLC entity).” 3GPP § 4.2.1.2.2. See claim 1 for a description of SN field and E-bit
which indicates whether the PDU contains an entire service data unit (SDU) in its data
field.
Apple's 3G Products detect the following length indicator (LI) field from the header of the
PDU, if the one-bit field indicates that the PDU does not contain an entire SDU in its data
field. See claim 1 above.
Apple's 3G Products determine whether the LI field is set to a value indicating that the
PDU contains an intermediate segment that is neither a first segment nor a last segment of
the SDU. See claim 1 above.
Apple's 3G Products store the PDU until the PDU can be assembled with a previous
segment and a following segment, if the LI field is set to the predefined value.
For example, “[t]he receiving UM RLC entity deciphers (if ciphering is configured and
started) the received UMD PDUs (except for the UMD PDU header). It removes RLC
headers from received UMD PDUs, and reassembles RLC SDUs (if segmentation and/or
concatenation has been performed by the transmitting UM RLC entity).” 3GPP §
4.2.1.2.2.
Apple's 3G Products construct the SDU by combining the intermediate segment from the
data field of the PDU with at least one previous segment extracted from a data field of at
least one previous PDU and at least one following segment extracted from a data field of at
least one following PDU. See 3GPP § 4.2.1.2.2.
In addition, a sophisticated duplicate avoidance and reordering function is used that
“combines PDU sequences received from several sources and/or repeat transmissions from
a single source to form a single ordered PDU sequence that is passed to the header removal
and reassembly functions.” Id. at § 9.7.10. This function handles duplicate detection,
discard and re-ordering based on the UM PDU sequence number. Id.
Apple's 3G Products acquire the entire SDU from the data field of the PDU, if the one-bit
8

the one-bit field indicates that the PDU contains
the entire SDU in its data field, acquiring the
entire SDU from the data field of the PDU.
Claim 8
8. The method of claim 6, wherein the storing
comprises the steps of storing the PDU in a
reception buffer according to the SN field of the
PDU.

Claim 9
9. The method of claim 8, wherein the
constructing comprises constructing the SDU by
combining segments extracted from data fields
of a set of PDUs stored in the reception buffer, if
the first of the PDUs comprises an LI field
indicating inclusion of the first segment of the
SDU, if at least one intermediate PDU among
the PDUs comprises an LI field set to the value,
and if the first LI field of the last of the PDUs
indicates the position of the last byte of the SDU.
Claim 10
10. An apparatus for transmitting data in a
mobile communication system, comprising:
a transmission buffer for receiving a service data
unit (SDU) from a higher layer,

field indicates that the PDU contains the entire SDU in its data field. See claim 1 above.

Apple's 3G Products store the PDU in a reception buffer according to the SN field of the
PDU.
For example, the duplicate avoidance and reordering function handles reordering based on
UM PDU sequence number. Id. at § 9.7.10. A reception buffer is used for the
temporary storage of PDUs during the reordering process. Id.
Apple's 3G Products Products construct the SDU by combining segments extracted from
data fields of a set of PDUs stored in the reception buffer, if the first of the PDUs
comprises an LI field indicating inclusion of the first segment of the SDU, if at least one
intermediate PDU among the PDUs comprises an LI field set to the value, and if the first
LI field of the last of the PDUs indicates the position of the last byte of the SDU.
For example, “Length Indicators are used to define boundaries between RLC SDUs within
UMD PDUs unless the "Extension bit" already indicates that a UMD PDU contains exactly
one complete SDU. Length Indicators are also used to define whether Padding is
included in the UMD PDU.” Id. at § 4.2.1.2.1. See also § 9.2.2.8 “Length Indicator
(LI).”
Apple's 3G Products each include an apparatus for transmitting data in a mobile
communication system. See claim 1 above.
Apple's 3G Products include a transmission buffer for receiving a service data unit (SDU)
from a higher layer.
For example, “[t]he transmitting UM-RLC entity receives RLC SDUs from upper layers
through the UM-SAP.” Id. at § 4.2.1.2.1 and Figures 4.3 and 4.3A.
9

determining whether the SDU can be comprised
in one protocol data unit (PDU)
segmenting the SDU into a plurality of segments
according to a transmittable PDU size if the
SDU does not be comprised in one PDU, and
constructing one or more PDUs;
a header inserter for constructing a header of
each PDU, wherein the header comprises a serial
number (SN) field, a one-bit field, at least one
Length Indicator (LI) field;
a one-bit field setter for setting the one-bit field
of the at least one PDU to indicate whether the
PDU contains an entire SDU in the data field;
an LI inserter for inserting an LI field after the
one-bit field in the at least one PDU if the SDU
is not comprised in one PDU, and
setting an LI field to a predefined value
indicating that the PDU contains neither a first
segment nor a last segment of the SDU to
contain the intermediate segment of the SDU;
and
a transmitter for sending the PDUs to a receiver.
Claim 11
11. The apparatus of claim 10, wherein if the
SDU is comprised in one PDU, constructing one
PDU comprising a header and a data field,
wherein the header comprises a SN field, and a
one-bit field indicating that the PDU contains the
entire SDU in the data field.
Claim 13

Apple's 3G Products determine whether the SDU can be comprised in one protocol data
unit (PDU). See claim 1 above.
Apple's 3G Products segment the SDU into a plurality of segments according to a
transmittable PDU size if the SDU does not be comprised in one PDU. See claim 1
above.
Apple's 3G Products construct one or more PDUs. See claim 1 above.
Apple's 3G Products include a header inserter for constructing a header of each PDU,
wherein the header comprises a serial number (SN) field, a one-bit field, at least one
Length Indicator (LI) field. See claim 1 above.
Apple's 3G Products include a one-bit field setter for setting the one-bit field of the at least
one PDU to indicate whether the PDU contains an entire SDU in the data field. See claim
1 above.
Apple's 3G Products include an LI inserter for inserting an LI field after the one-bit field in
the at least one PDU if the SDU is not comprised in one PDU. See claim 1 above.
The LI inserter of Apple's 3G Products sets an LI field to a predefined value indicating that
the PDU contains neither a first segment nor a last segment of the SDU to contain the
intermediate segment of the SDU. See claim 1 above.

Apple's 3G Products include a transmitter for sending the PDUs to a receiver. See claim
1 above.
Apple's 3G Products construct one PDU comprising a header and a data field, wherein if
the SDU is comprised in one PDU. See claim 2 above.
The PDUs constructed by Apple's 3G Products include a header field with a SN field, and
a one-bit field indicating that the PDU contains the entire SDU in the data field. See
claim 2 above.
10

13. The apparatus of claim 10, wherein the LI
inserter sets LI fields of PDUs comprising the
first and last segments of the SDU in data fields
to values indicating inclusion of the first segment
of the SDU and inclusion of the last segment of
the SDU.
Claim 15
15. An apparatus for receiving data in a mobile
communication system, comprising:
a reception buffer for receiving a protocol data
unit (PDU) from a transmitter and storing the
PDU;

Apple's 3G Products include an LI inserter that sets LI fields of PDUs comprising the first
and last segments of the SDU in data fields to values indicating inclusion of the first
segment of the SDU and inclusion of the last segment of the SDU. See claim 4 above.

Apple's 3G Products each include an apparatus for receiving data in a mobile
communication system. See claim 1.
Apple's 3G Products include a reception buffer for receiving a protocol data unit (PDU)
from a transmitter and storing the PDU.

For example, “[t]he receiving UM-RLC entity receives UMD PDUs through the
configured logical channels from the lower layer.” Id. at § 4.2.1.2.2 and Figures 4.3 and
4.3A.
a reassembly controller for detecting a sequence Apple's 3G Products include a reassembly controller for detecting a sequence number (SN)
number (SN) field and a one-bit field indicating field and a one-bit field indicating whether the PDU contains an entire service data unit
whether the PDU contains an entire service data (SDU) in its data field from the header. See claim 1.
unit (SDU) in its data field from the header,
detecting the following length indicator (LI)
The reassembly controller of Apple's 3G Products detects the following length indicator
field from the header of the PDU and
(LI) field from the header of the PDU and determines whether the LI field is set to a
predefined value indicating that the PDU contains an intermediate segment that is neither a
determining whether the LI field is set to a
first segment nor a last segment of the SDU if the one-bit field indicates that the PDU does
predefined value indicating that the PDU
contains an intermediate segment that is neither a not contain an entire SDU in its data field. See claim 1.
first segment nor a last segment of the SDU if
the one-bit field indicates that the PDU does not
contain an entire SDU in its data field;
a header and LI remover for eliminating the SN Apple's 3G Products include a header and LI remover for eliminating the SN field, the
field, the one-bit field, and the LI field if the
one-bit field, and the LI field if the one-bit field indicates that the PDU does not contain
one-bit field indicates that the PDU does not
the entire SDU in its data field. See claim 1.
contain the entire SDU in its data field; and
11

a reassembler for receiving the intermediate
segment from the header and LI remover and
constructing the SDU by combining the
intermediate segment with at least one previous
segment extracted from a data field of at least
one previous PDU and at least one following
segment extracted from a data field of at least
one following PDU.
Claim 16
16. The apparatus of claim 15, wherein the
header and LI remover eliminate the SN field
and the one-bit field from the PDU and acquire
the entire SDU from the data field of the PDU if
the one-bit field indicates that the PDU contains
the entire SDU in its data field.
Claim 17
17. The apparatus of claim 15, wherein the
reception buffer stores the PDU according to the
SN field of the PDU.
Claim 18
18. The apparatus of claim 17, wherein the
reassembler constructs the SDU by combining
segments extracted from data fields of a set of
PDUs stored in the reception buffer, if the first
of the PDUs comprises an LI field indicating
inclusion of the first segment of the SDU, if at
least one intermediate PDU among the PDUs
comprises an LI field set to the value, and if the
first LI field of the last of the PDUs indicates the
position of the last byte of the SDU.

Apple's 3G Products include a reassembler for receiving the intermediate segment from the
header and LI remover and constructing the SDU by combining the intermediate segment
with at least one previous segment extracted from a data field of at least one previous PDU
and at least one following segment extracted from a data field of at least one following
PDU. See claim 1.

The header and LI remover of Apple's 3G Products eliminates the SN field and the one-bit
field from the PDU and acquires the entire SDU from the data field of the PDU if the
one-bit field indicates that the PDU contains the entire SDU in its data field. See claim 1.

Apple's 3G Products store the PDU according to the SN field of the PDU in the reception
buffer. See claim 8.

The reassembler of Apple's 3G Products constructs the SDU by combining segments
extracted from data fields of a set of PDUs stored in the reception buffer, if the first of the
PDUs comprises an LI field indicating inclusion of the first segment of the SDU, if at least
one intermediate PDU among the PDUs comprises an LI field set to the value, and if the
first LI field of the last of the PDUs indicates the position of the last byte of the SDU.
See claim 9.

12