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

Filing 925

Administrative Motion to File Under Seal Apple's Motion for Summary Judgment of Non-Infringement of U.S. Patent Number 7,362,867 and Invalidity of U.S. Patent Numbers 7,456,893 and 7,577,460 filed by Apple Inc.(a California corporation). (Attachments: #1 Declaration of Erica Tierney in Support of Apple's Administrative Motion to File Documents Under Seal, #2 Declaration of Mark D. Selwyn in Support of Apple's Administrative Motion to File Documents Under Seal, #3 Proposed Order Granting Apple Inc.'s Administrative Motion to File Documents Under Seal, #4 Plaintiff and Counterclaim-Defendant Apple Inc.'s Notice of Motion and Motion for Summary Judgment of Non-Infringement of U.S. Patent Number 7,362,867 and Invalidity of U.S. Patent Numbers 7,456,893 and 7,577,460, #5 Declaration of Mark D. Selwyn in Support of Apple's Motion for Summary Judgment of Non-Infringement of U.S. Patent Number 7,362,867 and Invalidity of U.S. Patent Numbers 7,456,893 and 7,577,460, #6 Exhibit 1, #7 Exhibit 2, #8 Exhibit 3, #9 Exhibit 4, #10 Exhibit 5, #11 Exhibit 6, #12 Exhibit 7, #13 Exhibit 8, #14 Exhibit 9, #15 Exhibit 10, #16 Exhibit 11, #17 Exhibit 12, #18 Exhibit 13, #19 Exhibit 14, #20 Exhibit 15, #21 Exhibit 16, #22 Exhibit 17, #23 Exhibit 18, #24 Exhibit 19, #25 Exhibit 20, #26 Exhibit 21, #27 Exhibit 22, #28 Exhibit 23, #29 Exhibit 24, #30 Exhibit 25, #31 Exhibit 26, #32 [Proposed] Order Granting Apple Inc.'s Motion for Partial Summary Judgment)(Selwyn, Mark) (Filed on 5/17/2012) Modified on 5/21/2012 attachment #1 and 2 sealed pursuant to General Order No. 62 (dhm, COURT STAFF).

EXHIBIT 18

PATENT

Response under 37 C.F.R. 1.116Expedited Procedure- Examining Group Art Unit 2136
Attorney Docket No.: 678-509 (P9463)
IN THE UNITED STATES PATENT AND TRADEMARK OFFICE

APPLICANT(S):

Jae-Yoel KIM, et al.

GROUP ART UNIT: 2136

APPLICATION NO.:

09/611,518

EXAMINER: Colin, Carl G.

FILING DATE:

July 7, 2000

DATED: April 28, 2006

FOR: APPARATUS AND METHOD FOR GENERATING SCRAMBLING
- CODE IN UMTS MOBILE COMMUNICATION SYSTEM
Mail Stop AF
Commissioner for Patents
P.O. Box 1450
Alexandria, VA 22313-1450
AMENDMENT

Sir:
In response to the Office Action of the United States Patent and Trademark Office, wbJch
was mailed on January 28, 2006, please consider the following amendments and remarks..

CERTIFICATE OF MAILING UNDER 37 C,F.R. ~1.8(a)
I hereby cerlify that this correspondence is being deposited with the United States Postal Service as first
class mail, postpaid in an envelope, addressed to: Mail Stop Amendment, Commissirner for Patents, P.O. Box 1450, .
Alexandria, VA 22313-1450.
Dated: April 28, 2006

J. Musella
1

APLNDC-WH-A 0000017904

AMENDMENTS IN THE CLAIMS
’ 1. (Previously Presented) A method for generating a primary scrambling code, the
method comprising the steps of:
generating a first m-sequence from a first m-sequence generator including first shift
registers having first shift register values a~, wherein i = 0 to c-1 and where c is the total number
of the registers;
generating a second m-sequence from a second m-sequence generator including second
shift registers having values bj, wherein j = 0 to c-l, and where c is the total number of the
registers;
masking the first shift register values ai with a first set of mask values Kt, wherein i = 0 to
c-I to generate a third m-sequence;
adding the first m-sequence with the second m-sequence to generate a primary
s~rambling code; and
adding the third m-sequence and the second m-sequence to generate a secondary
scrambling code;
wherein, the masking step shifts the first m-sequence cyclically by L chips to generate an
th secondary scrambling code associated with the primary scrambling code.
L
2-20. (Cancelled)
21. (Previously Presented) A scrambling code generator, comprising: .. a first m-sequence generator to generate a first m-sequence by t~sing a plurality of first ¯
registers with first shift register values a~, wherein i -- 0 to c-I and where c is the total number of
the first registers;
a second m-sequence generator to generate a second m-sequence by usir~g’a plurality of
second registers with second shift register values bj, wherein j = 0 to c-l and where e is the total
number of second registers;
..
a masking section, to mask the first shift register values ai with a.first set of mask values
Ki to generate a third m-sequence, wherein i = 0 to c-1 to generate a thirdm-sequence;

APLNDC-WH-A 0000017905

a firstadder to add the first m-sequence and the second m-sequence to generate a primary
scrambling code; and
a second adder to add the third m-sequence and the second m-sequence to generate a
secondary scrambling code,
wherein the masking section shifts the first m-sequence cyclically by L chips to generate
an Lm secondary scrambling code associated with the primary scrambling code.

22-30. (Cancelled)

31. (Previously Presented) The method of claim 1, wherein the primary sc[ambling code
is one of a plurality primary scrambling codes and a Kth primary scrambling code is a ((K1)*M+K)th gold code, where M is a total number of secondary scrambling codes per primary
scrambling code and 1 <K<512.
32. (Previously Presented) The method of claim 1, wherein the secondary scrambling
codes associated with a Kth primary scrambling code are from ((K-1)~’M+K+I)~h to (K*M+K)’h
gold codes, where M is a total number of secondary scrambling codes per primary scrambling
code and l<K<512.
33. (Previously Presented) The method of claim 1, wherein I<L<M, where M is a total
number of secondary scrambling codes per primary scrambling code.
34. (Previously Presented) The method of claim 1, wherein the masking step is expressed
by ~(ksxa~).
35. (Previously Presented) The method of claim 1, further comprising:
masking the first shift register values ai with a second set of mask valuesKj to generate a
fourth m-sequence, wherein j = 0 to c-l; and
adding the fourth m-sequence and the second m-sequence to generate an Nth secondary
scrambling code associated with the primary scrambling code;

APLNDC-WH-A 0000017906

wherein, the masking step shifts the first m-sequence cyclically by N chips to generate an
secondary scrambling code.
36. (Previously Presented) The method of claim 35, wherein I<N<M, where M is a total
number of secondary scrambling codes per primary scrambling code.
37. (Previously Presented) The method of claim 1, further comprising the step of
delaying at least one of the primary scrambling code and secondary scrambling code to produce
a Q-channel component, wherein the primary scrambling code and secondary scrambling code
are I-channel components.
38. (Previously Presented) The scrambling code generator of claim 21, wherein the
primary scrambling code is one of a plurality of primary scrambling codes and a Kth primary
scrambling code is a ((K-I)*M+K)th gold code, where M is a total number ~f secondary
scrambling codes per primary scrambling code and l<K<512.
39. (Previously P~’esented) The scrambling code generator of claim 38, wherein the
secondary scrambling codes associated with the Kth primary scrambling code are ((K1)*M+K+ l)th to (K*M+K)t~ gold codes.
40. (Previously Presented) The scrambling code generator of claim 21, further
comprising:.
a second masking section to mask the first shill register values ai, with a second set of
mask values Kj, wherein j = 0 to c-l, to generate a fourth m-sequence; and
a third adder to add the fourth m-sequence and the second m-sequence t0 generate an Nth secondary scrambling code associated with the primary scrambling code, . .
wherein the second masking section shifts the first m-sequence cyclically by N chips to
generate the Nth secondary scrambling code.

APLNDC-WH-A 0000017907

41. (Previously Presented) The scrambling code generator of claim 21, wherein the
masking section shifts the first m-sequence cyclically by masking the first shift register values ai
in accordance with ~(K, ×ai).
42. (Previously Presented) The scrambling code generator of claim 21, wherein the first
m-sequence generator cyclically shiRs the first shift register values and the second m-sequence
generator cyclically shifts the second shift register values.
43. (Previously Presented) The scrambling code generator of claim 21, wherein the first
m-sequence generator adds predetermined shift register values of the first shift registers based on
a first generating polynomial of the first m-sequence, right shifts the first shift register values
of the first shift registers, and replaces the first register value a¢.~ with the result of the addition of
the predetermined register values.
¯ 44. (Previously Presented) The scrambling code generator of ciaim 21, wherein the first
m-sequence genm:ator adds a first shift register value a0 with a first shift register a7 to form a next
first shift register
45. (Previously Presented) The scrambling code generator of claim 21, wherein the
second m-sequence generator adds predetermined shift register values0f the second shift
registers based on a second generating polynomial of the second m-sequence, right shifts the
second shift register values bj of the second shift registers, and replaces the second register value
bc.~ with the result of the addition of the predetermined register values..
46. (Previously Presented) The scrambling code generator of claim .21., wherein the
second m-sequence generator adds a second shift register value b0 with a second shift register
value bs, by, and a second shift register value b~0 to form a next second shift register value bc.~.
47. (Previously Presented) The apparatus of claim 21, further comprising a means for
delaying at least one of the primary scrambling code and the secondary scrambling code to

APLNDC-WH-A 0000017908

produce Q-channel component, wherein the primary scrambling code and the secondary
scrambling code are !-channel components.
48 - 53. (Cancelled)
54. (New) A method for generating scrambling codes in mobile communication system
having a scrambling code generator, the method comprising steps of:
generating a ((K-I)*M+K)th gold code as a Kth primary scrambling code, where K is a
natural number and M is a total number of secondary scrambling codes per one primary
scrambling code; and
generating ((K-1)*M+K+I)t~ through (K*M+K)’h gold codesas secondary scrambling
codes associated with the K~ primary scrambling code,
wherein the Lth Gold code is generated by adding an (L-1)-times shit~ed first m-sequence
and a second m-sequence.

¯.

55. (New) The method as claimed in claim 54, wherein K is a primary scrambling codenumber and 1_< K_< 512.
56. (New) The method as claimed in claim 55, ~vherein the first m-sequence is generated
from a first sfiift register memory having a plurality of first shift registers with first shift register
values ai, wherein i = 0 to c-1 and where c is the total number of the first registe~’s and the (L-1)times shifted first m-sequence is generated by masking the first shift r~gister valt~es ai with mask
values Ki , where i = 0 to c-1.
57. (New) The method as claimed in claim 56, wherein the masking is performed
according to: ~’~(K~ xa;).
58. (New) The method as claimed in claim 54, wherein the generated primary scrambling
code and secondary scrambling code are I-channel components and the method further comprises

APLNDC-WH-A 0000017909

delaying at 1east one of the primary scrambling code and secondary scrambling code to produce
Q-channel components.
59. (New) An apparatus for generating scrambling codes in mobile communication
system having a scrambling code generator, comprising:
a first m-sequence generator to generate a first m-sequence;
a second m-sequence generator to generate a second m-sequence; and
at least one adder for generating a ((K-I)*M+K)th Gold code as a Kt~ primary scrambling
code by adding a ((K-1)*M+K-l)-times shifted first m-sequence and the second m-sequence,
wherein K is a natural number and M is a total number of secondary scrambling codes
per one primary scrambling code.
60. (New) The apparatus of claim 59, wherein the secondary scrambling codes of the K’h
primary scrambling codes are the ((K-1)*M+K+I)t~ through (K*M+K)~a Gold codes.
61. (New) The apparatus as claimed in claim 60, wherein K is a primary scrambling code
number and 1< K< 512.

62. (New) The apparatus as claimed in claim 59, wherein the first m-sequence generator
comprises a plurality of first registers with first shift register values ai, Wherein i.= 0 to c-1 and
where c is the total number of the first shift registers, and the scrambling code generator further
comprising at least one masking section for generating the n-times shined first m-sequence by
masking the first shift register values ai with mask values K~, where i = 0 to c-1.
63. (New) The apparatus as claimed in claim 62, wherein the masking is performed
according to: ~ (K, x ai).
64. (New) The apparatus as claimed in claim 59, wherein the primary scrambling code
and secondary scrambling code are I-channel components and the apparatus further comprises a

APLNDC-WH-A 0000017910

means for delaying at least one of the primary scrambling codes and se.ondary scrambling code
to produce Q-channel components.
65. (New) A method t’or generating scrambling codes in mobile communication system
having a scrambling code generator, comprising the steps of:
generating a first m-sequence;
generating a second m-sequence; and
generating a ((K-1)*M+K)th Gold code as a Kth primary scrambling code by adding a ((Kl)*M+K-1)-times shifted first m-sequence and the second m-sequence,
wherein K is a natural number and M is a total number of secondary scrambling codes
per one primary scrambling code.
66. (New) The method as claimed in claim 65, further comprising generating ((KI)*M+K+I)t~ to (K*M+K)th Gold codes as secondary scrambling codes corresponding to the Kth
primary scrambling code.
67. (New) The method as claimed in claim 65, wherein K is a .primary. scrambling code
number and 1_< K.~ 512.

68. (New) The method as claimed in claim 65, wherein the first m-sequence is generated
from a first shift register memory having a plurality of first, shift registers with first shift register
values ai, wherein i = 0 to c-1 and where c is the total number of the fir’st registers and the ntimes shifted first m-sequence is generated by masking the first shift ~egister values ai with mask
values K~, where i = 0 to c-l.
69. (New) The method as claimed in claim 68, wherein the masking is performed
according to: ~-~(K, ×a,).

APLNDC-WH-A 0000017911

70. (New) The method as claimed in claim 65, wherein each scrambling code is used as
an I-channel component and a Q-channel component, corresponding to the I-channel component,
is generated by delaying the I-channel component for a predetermined time.

APLNDC-WH-A 0000017912

REMARKS
Prior to entry of this amendment, Claims l, 21 and 31-53 are pending in the application.
Claims 48 and 51 have been rejected under 35 U.S.C. §112, first paragraph. Claims 1, 21, and
31-53 have been rejected under 35 U.S.C. § 103(a) as allegedly being unpatentable over Dahlman
et al. (U.S. 6,339,646) in view of Burns (U.S. 6,141,374). Claims 48-53 have been rejected under
35 U.S.C. § 103(a) as allegedly being unpatentable over Dahlman et al. (U. S. 6,339,646
- "Dahlman ’646") in view of Dahlman et ah (WO 99/12284 "Dahlman WO").
Please cancel Claims 48-53, without prejudice.

Please add new Claims 54-70 as set forth herein. No new matter has been added.
Initially, Applicants respectfully submit the following reply to the Examiner’s comments
contained in the Response to Arguments section of the Office Action. Regarding item 1.2, the
Examiner alleges that certain features that are relied on by the Applicants, Le., managing a
scrambling code (the relationship between scrambling codes) and a method for assigning a
scrambling code, are not recited in rejected Claims 1 and 21. Each of Claims I and 21 recites
"the masking step shifts the first m-sequence cyclically by L chips to generate an Lth secondary
scrambling code associated with the primary scrambling code". It is respectfully submitted that
this is in fact the relation between the primary scrambling code and the .secondary scrambling
code. In other words, Claims 1 and 21 recite that "the Ltl~ secondary scrambling code associated
,,vith the primary scrambling code" is a result of adding "the second m-sequence" and "L-times
shifted first m-sequence". Therefore it is respectfully submitted that the feature~ relied on by the
Applicants, i.e., managing a scrambling code (the relationship between scrambling codes) and a
method for assigning a scrambling code, is in fact fully contained in Claims l and 21. It is
respectfully requested that the claims be examined in light thereof.
Regarding the rejection of independent Claims 1 and 21 under §103(a), the Examiner
states that Dahlman ’646 in view of Bums renders the claims unpatentable. Dahlman ’646
discloses slotted code usage in a cellular communications system; and, Burns discloses a method
10

APLNDC-WH-A 0000017913

and apparatus for generating multiple matched-filter PN vectors in a CDMA demodulator. Each
of Claims ! and 21 recite "wherein, the masking step shi~s the first m-s~quence cyclically by L
chips to generate an L’h secondary scrambling code associated with the primary scrambling
code" and then using the masked sequence to generate a third m-sequence. The Examiner states
that Dahlman ’646 (at col. 3, line 60 - col. 4, line 6) and Bums (at col. 4, line 40 - col. 4, line 5)
both disclose this element. The cited section of Dahlman ’646 speaks about scrambling codes,
but makes no reference to cyclically shifting an m-sequence to generate a secondary scrambling
code and using a masked sequence to generate a third m-sequence. Further, the cited section of
Bums states that extra values are inserted into each sequence, and combining sequences, but
again, makes no reference to cyclically shifting an m-sequence to generate a secondary
scrambling code and using a masked sequence to generate a third m-sequence.
Referring to col. 3 line 60 - col. 4 line 6 of Dahlman cited by the Examiner, the Dahlman
codes are expanded by using the form "a channelization code + scrambling code + another
code". It is well known that in a conventional CDMA communication system,, a scrambling code
is usually used to identify a base station and a mobile station, and a channelization code is
usually used to distinguish channels transmitted from a mobile station or a base station. During
implementation, each channel data is multiplied by different charmelization codes; the sum of the
multiplied result is multiplied by a scrambling code, and then transmitted. One skilled in the art
would understand that col. 3 line 60 - col. 4 line 6 of Dahlman illustrates increasin~ a
channelization code, wherein charmelized and scrambled data is multiplied by another code.
That is, it is clear that Dahlman represents "data x (channelization code x scrambling code x
another code)".

.- .

~.

On the contrary, the adder of the present invention, which is located within a scrambling
code generator for generating scrambling codes, is for adding a first m-sequence.to a second msequence or a shifted first m-sequence, and generating the scramblingcode. Dahlman fails to
disclose the adder of the present invention for generating the scrambling, code and merely
discloses processing data using the channelization code, the scrambling code and another code,
not generating a scrambling code itself.

11

APLNDC-WH-A 0000017914

Additionally, referring again to eel. 3, line 60 - col. 4, line 6 of Dahlman, one cell can use
N scrambling codes, and if two scrambling codes, i.e., Cil, Ci2, are used, each of the scrambling
codes will be related to Cj. Channelization codes are then allocated to each of the scrambling
codes. In other words, Dahlman simply suggests that the scrambling codes used in one cell are
related to each other. Dahlman fails to disclose any specific relationship between the scrambling
codes.
Claims 1 and 21 of the present application recite that the masking step shifts the first msequence cyclically hy L chips to generate an Lth secondary scrambling code associated with the
primary scrambling code as the relationship between the primary scrambling code and the
secondary scrambl!ng code. That is, the Lth secondary scrambling code is the result of adding
"the second m-sequence" and "an L times shifted first m-sequence associated with the primary
scrambling code". Dahlman merely mentions the background, conventional methods or problems
of the prior art, but fails to teach the solutions and technical features of the present invention.
One problem of the conventional method, described on page 4, lines 30-31 of the specification of
the present invention, is that in the present UMTS standard specification, there is no description
for scrambling code numbering and its generation, a problem solved b.y the claims of the present
application .....
Still further, Bums only teaches the concept era "masking process" (see col. 3, line 40col. 4, line 5), and the scrambling code managing method of Burns is completely different from
that of the claims of the present application. More specifically, Burns in col. 3 describes the IS95 or CDMA 2000 based scrambling code structure. As shown in coh 3, lines 4-20 of Burns,
although all base stations use the same PN code (or a scrambling code), h unique shift offset for
each basestation ~s applied to each PN code. The masking of Bums is performed to apply a
unique offset to a.loeal PN code for each base station after generating the.local PN eerie used in
all of the base stations. However, the masking process of the claims of the presen!, application is
not applied to a PN code (or a scrambling code), but to a m-sequence, which is not taught or
disclosed by Bums.
¯ ~.’~

12

APLNDC-WH-A 0000017915

Final’ly, although the Examiner asserts that Dahlman provides motivation ~’or the present
invention, Bums merely discloses that the use of an additional scrambling code is necessary to
increase a charmelization code. However, such disclosure is also taught in the background of the
present invention and none of the references, either alone on in combination, discloses which
codes are to be assigned as primary scrambling codes from among a plurality of Gold codes and
which codes are to be assigned as secondary scrambling codes corresponding to each of the
primary scrambling codes, as contained in the claims of the present application.
li is well known that Gold codes have no specific order. Likewise, in order to use Gold
codes having no priority as primary and secondary scrambling codes, it is required to identify the
currently used primary scrambling code and the corresponding secondary scrambling codes to a
base station and a mobile station. The claims of the present application drastically simplify this
process, since if a primary scrambling code and the corresponding secondary scrambling codes
are generated from only two predetermined m-sequences, the corresponding secondary
scrambling codes as well as the primary scrambling code to be used in the base station can be
simply generated by notifying the base station and the mobile stationgfonly the primary
scrambling code.
Based on at least the foregoing, withdrawal of the rejections ofClaim 1 and 21 is
respectfully requested.

...

Turning now to the new claims presented herein, the following.description is provided to
assist in prosecution and in identifying support for the claimed subject matter in’ the
specification.

.-

Regarding new Claim 54, new Claim 54 recites, "a method for generating scrambling
codes in mobile communication system having a scrambling code generator"’. As. mentioned
abovel the application as originally filed not only discloses a generator for concurrently
~eneratin~ multiple Gold sequences using the mask functions but also.describes on page 8, lines
3 to 6, that it is an object of the present invention to provide a method .for efficiently dividing the
set of Gold sequences into a primary scrambling code set and a seconda~ scrambling code set to
13

APLNDC-WH-A 0000017916

reduce the number of mask functions stored in the memory. New Claim 54refers to the second
embodiment of the present invention as described in the specification at pages 12 to 16. This
embodiment refers to a structure of primary and secondary scrambling codes as shown in Figure
9. Page 12, lines 19 to 23 states that while the first embodiment masks both m-sequences rot(t)
and m2(t) to generate scrambling codes, the second embodiment involves cyclic shift of the msequence m2(t) only other than ml (1) to generate scrambling sequences, and as expressed by
Equation 1 therein.
Furthermore, new Claim 54 recites, "generating a ((K-1)*M+K)-th gold code as a K-th
primary scrambling code, where K is a natural number and M is a total number of secondary
scrambling codes per one primary scrambling code". The description on page 12, lines 24 to 29
discloses:
Referring to Fig. 9, when M secondary scrambling codes correspond to
one primaryscrambling code, the first, 0VI+2)’th, (2M+3)’th, .2q ((K-1)*M+K)’th,
..., and [511M+512)’th Gold codes are used as prim ave scrambling codes. The
secondary scrambling codes corresponding to the (((K-l)*M+K)’th Gold code
used as the (K)’th primary scrambling code are composed of M Gold codes, i.e.,
((K- 1)*M+(K+I)), ((K-1)*M+(K+2))..., and (K*M+K)’th gold codes. (Emphasis
added.)

Additionally, new Claim 54 recites, "generating from ((K-1)*M+K+I)-th to (K*M+K)-th
Gold codes as secondary scrambling codes associated with the K-th primary scrambling code".
The description on page 12, lines 26 to 29 discloses that the secondary scrambling codes
corresponding to the (((K-1)*M+K)’th Gold code used as the (K)’th primary scrambling code are
composed of M Gold codes, i.e., ((K-1)*M+CK+I)). ((K-1)*M+(K+2))..5, and (K*M+K)’th Gold
codes.
Moreover, new Claim 54 recites, "wherein the L-th Gold code is generated by adding the
(L-1 )-times shifted first m sequence and the second m-sequence". Thedescriptlon on page 7,
lines 23 to 25, which refers to the above-mentioned Equation 1, disclosers that for the purpose of
the present invention, the sum of the m-sequence ml{t) cTclicall7 shifted time and the msequence m2(t) willbe designated as a Gold code g. That is, g (t) = ml(t + )+m2(t).

14

APLNDC-WH-A 0000017917

Regarding new Claim 59, new Claim 59 recites, "an apparatus for generating scrambling
codes in mobile communication system having a scrambling code generator", "a first msequence generator to generate a first m-sequence", and "a second m-sequence generator to
generate a second m-sequence". In this context, the description on page 7 discloses in lines 14
and 15 that a Gold code used herein as a scrambling code is generated through binary adding of
two distinct m-sequences.
Moreover, new Claim 59 recites, "at least one adder for generating a ((K-l)*M+K)-th
gold code as a K-th primary scrambling code by adding a ((K-1)*M+K-1)-times shifted first msequence and the second m-sequence". The description on page 12, lines 24 to 26 discloses,
referring to Fig. 9, that when M secondary scrambling codes correspond to one primary
scrambling code, the first, (M+2)’th, (2M÷3)’th ..... ({K-l)*M+K)’th ..... and (511M+512)’th
Gold ’codes are used as primary scrambling codes. The description also discloses on page 7, lines
23 to 25, that for the purpose of the present invention, the sum of the m-sequence ml(t)
cyclically shifted time and the m-sequence m2(t) will be designated as .aGold code g, that is, g
(t) = ml(t + )÷m2(t).

.

Finally, new Claim 59 recites, "wherein K is a natural number and M is a.total number of
secondary scramb!ing codes per one primary scrambling code". The description on page 12, lines
26 to 29 discloses that the secondary scrambling codes corresponding to the (((K-1)*M+K)’th
Gold code used as the (K)’th primary scrambling code are composed of M Gold codes, i.e., ((K1)*M+(K+ 1)), ((K- I)*M+(K+2))..., and (K*M+K)’th Gold codes.
" Regarding new Claim 65, new Claim 65 recites, "a method for generating scrambling
codes in mobile communication system having a scrambling code generator"; "generating a first
m-sequence" and "generating a second m-sequence", and "generating a ((K-I)~’M+K)-th Gold
code as a K-th primary scrambling code by adding the ((K-l)*M+K-1)-times shifled first msequence and the second m-sequence". The description on page 12, !in.es 24.to 26 discloses,
referring to Fig. 9, that when M secondary scrambling codes correspond to one .primary
scrambling code, the first, (M+2)’tl~, (2M+3)’th, ..., ((K-I)*M+K)’th, ..., and (511M+512)’th Gold
codes are used as primary scrambling codes. Further, the description On page 7, lines 23 to 25

APLNDC-WH-A 0000017918

discloses that for the purpose of the present invention, the sum of the m-sequence ml(t)
cyclically shifted time and the m-sequence m2(t) will be designated asa Gold code g, that is, g
(t) = ml(t + )+m2(t).
Moreover, new Claim 65 recites, "wherein K is a natural number and M is a total number
of secondary scrambling codes per one primary scrambling code". The description on page 12,
lines 26 to 29 discloses thai the seconda~ scramblin~ codes corresponding to the ((K1)*M+K)’th Gold code used as the (K)’th primary scrambling code are composed of M Gold
codes, i.e., ((K-1)*M+(K+I)), ((K-1)*M+(K+2))..., and (K*M+K)’th Gold codes.
Independent Claims l and 21 are believed to be in condition for allowance. Without
conceding the patentability per se of dependent Claims 31-47, these are likewise believed to be
allowable by virtue of their dependence on their respective amended independent claims.
Accordingly, reconsideration and withdrawal of the rejections of dependent Claims 31-47 is
respectfully requested.
Accordingly, all of the claims pending in the Application, namely, Claims 1, 21, 31-47
and 54-70, are believed to be in condition for allowance. Should the Examiner believe that a
telephone conference or personal interview would facilitate resolution o.f any remaining matters,
the Examiner may contact Applicants’ attorney at the number given below, . ~

l~.eg. No’. 33,494
Attorney for Applicant(s)
DILWORTH & BARRESE, LLP ¯
333 Earle Ovington Boulevard
Uniondale, New York 11553
Tel: [phone]
Fax: [phone]
PJF/MJM/dr
16

APLNDC-WH-A 0000017919