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).
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EXHIBIT 21
EXHIBIT F
SAMSUNG’S PATENT L.R. 3-1(A)-(D) DISCLOSURES FOR
U.S. PATENT NO. 7,362,867
02198.51845/4337814.1
1
ASSERTED CLAIM
(PATENT L.R. 3-1(A))
25. An apparatus for generating
scrambling codes in mobile
communication system having a
scrambling code generator, comprising:
ACCUSED INSTRUMENTALITY AND HOW EACH ELEMENT IS MET BY
ACCUSED INSTRUMENTALITY
(PATENT L.R. 3-1(B)-(D))
1
Apple’s 3G Products contain an apparatus for generating scrambling codes in a mobile
communications system having a scrambling code generator.
For example, Apple’s 3G Products contain a baseband processor that generates scrambling
codes used to transmit data in accordance with 3GPP Release 6 protocol.
See iPhone 3 Technical Specifications, http://support.apple.com/kb/sp495 (“Figure 1”
shows Apple’s description that the iPhone 3 is a Universal Mobile Telecommunications
System (“UMTS”) compliant device); iPhone 3G Teardown,
http://www.ifixit.com/Teardown/iPhone-3G-Teardown/600/3 (stating the iPhone 3
contains an Infineon BGA736 (Tri-Band HSDPA LNA) baseband processor); see also
iPhone 3GS Technical Specifications, http://www.apple.com/iphone/iphone3gs/specs.html (“Figure 2” shows Apple’s description that the iPhone 3GS is a UMTS
compliant device); Apple's iPhone 3GS Costs $178.96 to Manufacture,
http://www.cellular-news.com/story/38186.php (“Infineon has held onto this critical
[component of the iPhone 3GS] with its PMB8878 [X-GOLD 608] baseband chip . . . .”);
see also iPad 3G Technical Specifications, http://support.apple.com/kb/SP580 (“Figure 3”
shows Apple’s description that the iPad 3G is a UMTS compliant device); iPad 3G
Teardown, http://www.ifixit.com/Teardown/iPad-3G-Teardown/2374/2 (stating the iPad
3G contains an Infineon 337S3754 PMB 8878 X-Gold 608 baseband IC 5Y06115
processor); see also iPhone 4 Technical Specifications,
http://www.apple.com/iphone/specs.html (“Figure 4” shows Apple’s description that the
iPhone 4 “GSM Model” is a UMTS compliant device); iPhone 4 Teardown,
http://www.tgdaily.com/hardware-features/50344-the-real-iphone-4-teardown (stating the
iPhone 4 contains an Infineon X-GOLD 61x Baseband Processor); see also iPad 2
Technical Specifications, http://www.apple.com/ipad/specs/ (“Figure 5” shows Apple’s
description that the iPad 2 3G “Wi-Fi +3G model” is a UMTS compliant device); iPad 2
1
“Apple’s 3G Products” include iPhone 3G, iPhone 3GS, iPhone4, iPad 3G, iPad2 3G and any other products compliant with
3GPP UMTS standard.
02198.51845/4337814.1
2
ASSERTED CLAIM
(PATENT L.R. 3-1(A))
ACCUSED INSTRUMENTALITY AND HOW EACH ELEMENT IS MET BY
ACCUSED INSTRUMENTALITY
(PATENT L.R. 3-1(B)-(D))
Teardown, http://www.ifixit.com/Teardown/iPad-2-3G-GSM-CDMA-Teardown/5127/1
(stating the iPad 2 contains an Infineon 337S3833 (X-GOLD 61x) Baseband Processor);
see also Definition of UMTS, http://www.3gpp.org/article/umts (describing UMTS as a
third generation (“3G”) wireless technology that uses a wideband CDMA (“WCDMA”)
radio interface, the standards of which are created and governed by the Third Generation
Partnership Project (“3GPP”); see also 3GPP TS 25.213 v5.0.0 at 28 (noting the inclusion
of HDSPA into the 3GPP standard); see also X-GOLD 608 Technical Specification,
http://www.infineon.com/dgdl/X-GOLD608PMB8878+PB.pdf?folderId=db3a304312fcb1bc0113000c158f0004&fileId=db3a30431be3
9b97011c09549f077a1a (“Figure 6” shows Infineon’s assertion that the X-GOLD 608
Processor uses HSDPA); see also X-GOLD 616 Technical Specification,
http://www.infineon.com/dgdl/XGOLD+616.pdf?folderId=db3a304312fcb1bc0113000c158f0004&fileId=db3a30431ed1d7
b2011f5bee88ef75eb (“Figure 7” shows Infineon’s assertion that the X-GOLD 61x
Baseband Processor is compatible with 3GPP Release 6 protocols).
Figure 1 – iPhone 3 Technical Specifications
02198.51845/4337814.1
3
ASSERTED CLAIM
(PATENT L.R. 3-1(A))
ACCUSED INSTRUMENTALITY AND HOW EACH ELEMENT IS MET BY
ACCUSED INSTRUMENTALITY
(PATENT L.R. 3-1(B)-(D))
Figure 2 – iPhone 3GS Technical Specifications
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4
ASSERTED CLAIM
(PATENT L.R. 3-1(A))
ACCUSED INSTRUMENTALITY AND HOW EACH ELEMENT IS MET BY
ACCUSED INSTRUMENTALITY
(PATENT L.R. 3-1(B)-(D))
Figure 3 – iPad 3G Technical Specifications
Figure 4 – iPhone 4 Technical Specifications
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5
ASSERTED CLAIM
(PATENT L.R. 3-1(A))
ACCUSED INSTRUMENTALITY AND HOW EACH ELEMENT IS MET BY
ACCUSED INSTRUMENTALITY
(PATENT L.R. 3-1(B)-(D))
Figure 5 – iPad 2 Technical Specifications
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6
ASSERTED CLAIM
(PATENT L.R. 3-1(A))
ACCUSED INSTRUMENTALITY AND HOW EACH ELEMENT IS MET BY
ACCUSED INSTRUMENTALITY
(PATENT L.R. 3-1(B)-(D))
Figure 6 – Product Brief of Infineon X-GOLD 608 Processor
Figure 7 – Product Brief of Infineon X-GOLD 616 Processor
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7
ASSERTED CLAIM
(PATENT L.R. 3-1(A))
a first m-sequence generator to generate
a first m-sequence;
ACCUSED INSTRUMENTALITY AND HOW EACH ELEMENT IS MET BY
ACCUSED INSTRUMENTALITY
(PATENT L.R. 3-1(B)-(D))
Apple’s 3G Products contain a first m-sequence generator to generate a first m-sequence.
For example, Apple’s 3G Products contain a UMTS/WCDMA compliant baseband
processor for processing the UMTS (“3G”) signals, compliant with 3GPP protocols that
generates two binary m-sequences by means of two generator polynomials of degree 18.
The first m-sequence, referred to as the “x sequence” is constructed using the primitive
(over GF(2)) polynomial 1+ X7+X18.
See iPhone 3G Teardown (“Figure 8” shows a breakdown of the iPhone 3G components
including an Infineon BGA736 (Tri-Band HSDPA LNA) Processor); see also iPhone 3GS
Teardown (“Figure 9” shows a breakdown of the iPhone 3GS components including the
Infineon PMB 8878 X-GOLD Baseband Processor); iPad 3G Teardown (“Figure 10”
shows a breakdown of one set of components on the iPad 3 3G Model including the
Infineon 337S3754 PMB 8878 X-GOLD Baseband Processor); see also iPhone 4
Teardown (“Figure 8” shows a breakdown of the components located on the rear of the
iPhone 4 including the Infineon X-GOLD Baseband Processor); iPad 2 Teardown (“Figure
5” shows a breakdown of one set of components on the iPad 2 Wi-Fi +3G Model including
the Infineon 337S3833 Baseband Processor); see also Figure 3 (describing the Infineon XGOLD Baseband Processor as 3GPP Release 6 Protocol compliant); see also BGA736
Data Sheet; see also X-GOLD 608 Product Brief; see also X-GOLD 616 Technical
Specification; see also 3GPP TS 25.213 v5.0.0 at 22, §5.2.2 “Scrambling code” (“Each of
the two real sequences are constructed as the position wise modulo 2 sum of 38400 chip
segments of two binary m-sequences generated by means of two generator polynomials of
degree 18. The resulting sequences thus constitute segments of a set of Gold sequences . . .
Let x and y be the two sequences respectively. The x sequence is constructed using the
primitive (over GF(2)) polynomial 1+ X7+X18.”); see also 3GPP TS 25.213 v6.0.0 at 22.
02198.51845/4337814.1
8
ASSERTED CLAIM
(PATENT L.R. 3-1(A))
ACCUSED INSTRUMENTALITY AND HOW EACH ELEMENT IS MET BY
ACCUSED INSTRUMENTALITY
(PATENT L.R. 3-1(B)-(D))
Figure 8 – iPhone 3G Components
Figure 9 – iPhone 3GS Components
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9
ASSERTED CLAIM
(PATENT L.R. 3-1(A))
ACCUSED INSTRUMENTALITY AND HOW EACH ELEMENT IS MET BY
ACCUSED INSTRUMENTALITY
(PATENT L.R. 3-1(B)-(D))
Figure 10 – iPad 3G Components
Figure 11 – iPhone 4 Components
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10
ASSERTED CLAIM
(PATENT L.R. 3-1(A))
ACCUSED INSTRUMENTALITY AND HOW EACH ELEMENT IS MET BY
ACCUSED INSTRUMENTALITY
(PATENT L.R. 3-1(B)-(D))
Figure 12 – iPad 2 Wi-Fi +3G Components
a second m-sequence generator to
generate a first m-sequence; and
Apple’s 3G Products contain a second m-sequence generator to generate a first msequence.
For example, Apple’s 3G Products construct the second m-sequence, referred to as the “y
sequence,” using the primitive (over GF(2)) polynomial 1+X5+X7+X10+X18.
See 3GPP TS 25.213 v5.0.0 at 22, §5.2.2 “Scrambling code” (“Each of the two real
sequences are constructed as the position wise modulo 2 sum of 38400 chip segments of
two binary m-sequences generated by means of two generator polynomials of degree 18.
The resulting sequences thus constitute segments of a set of Gold sequences . . . Let x and y
be the two sequences respectively . . . The y sequence is constructed using the polynomial
1+X5+X7+X10+X18.”); see also 3GPP TS 25.213 v6.0.0 at 22.
at least one adder for generating a ((K1)*M+K)th Gold code as a Kth primary
scrambling code by adding a (((K1)*M+K)-1)-times shifted first m02198.51845/4337814.1
Apple’s 3G Products contain at least one adder for generating a ((K-1)*M+K)th Gold code
as a Kth primary scrambling code by adding a (((K-1)*M+K)-1)-times shifted first msequence 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.
11
ASSERTED CLAIM
(PATENT L.R. 3-1(A))
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.
ACCUSED INSTRUMENTALITY AND HOW EACH ELEMENT IS MET BY
ACCUSED INSTRUMENTALITY
(PATENT L.R. 3-1(B)-(D))
For example, Apple’s 3G Products divide scrambling codes into 512 sets, each having one
primary scrambling code and 15 secondary scrambling codes. As a result, K = [1 through
512] and M = 15. Apple’s 3G Products add an “n” shifted first m-sequence with a second
m-sequence to produce an n:th Gold code zn(i).
Example No. 1:
The primary scrambling codes consists of the scrambling codes n=16*i, where i = 0, 1,
2…511.
For K=1, the first primary code is the 1st Gold code. This is calculated by substituting
K=1 and M=15 into the equation (K-1)*M+K. As a result, the first primary code is the (11)*15+1= 1st Gold code. For K=1, n=0 because i[1] = 0 and n=16*i.
The first Gold code is composed of a ((K-1)*M+K)-1 shifted first m-sequence and second
m-sequence. The value of the shift for K=1 is ((1-1)*15+1)-1 = 0. For Gold code zn(i) =
x((i+n) modulo (218 - 1)) + y(i) modulo 2, where i=0,…, 218-2, z0(i)=x((i) modulo (218 - 1))
+ y(i) modulo 2.
Example No. 2:
For K=2, the second primary code is the 17th Gold code. This is calculated by substituting
K=2 and M=15 into the equation (K-1)*M+K. As a result, the second primary code is the
(2-1)*15+2= 17th Gold code. For K=2, n=16 because i[2] = 1 and n=16*i.
The 17th Gold code is composed of a ((K-1)*M+K)-1 shifted first m-sequence and second
m-sequence. The value of the shift for K=2 is ((2-1)*15+2)-1 = 16. For Gold code zn(i) =
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12
ASSERTED CLAIM
(PATENT L.R. 3-1(A))
ACCUSED INSTRUMENTALITY AND HOW EACH ELEMENT IS MET BY
ACCUSED INSTRUMENTALITY
(PATENT L.R. 3-1(B)-(D))
18
x((i+n) modulo (2 - 1)) + y(i) modulo 2, where i=0,…, 218-2, z16(i)=x((i+16) modulo (218
- 1)) + y(i) modulo 2.
Example No. 3:
For K=3, the third primary code is the 33rd Gold code. This is calculated by substituting
K=3 and M=15 into the equation (K-1)*M+K. As a result, the third primary code is the (31)*15+3= 33rd Gold code. For K=3, n=32 because i[3] = 2 and n=16*i.
The 33rd Gold code is composed of a ((K-1)*M+K)-1 shifted first m-sequence and second
m-sequence. The value of the shift for K=3 is ((3-1)*15+3)-1 = 32. For Gold code zn(i) =
x((i+n) modulo (218 - 1)) + y(i) modulo 2, where i=0,…, 218-2, z32(i)=x((i+32) modulo (218
- 1)) + y(i) modulo 2.
See 3GPP TS 25.213 v5.0.0 at 22, § 5.2.2 “Scrambling code,” (describing the n:th Gold
code sequence “zn, n= 0,1,2,…,218-2,” as defined as “zn(i) = x((i+n) modulo (218 - 1)) + y(i)
modulo 2, i=0,…, 218-2” where “n= 16*i where i=0…511.”); see also id. at 22 (“A total of
218-1 = 262,143 scrambling codes, numbered 0 . . . 262,142 can be generated. However
not all the scrambling codes are used. The scrambling codes are divided into 512 sets each
of a primary scrambling code and 15 secondary scrambling codes.”); see also 3GPP TS
25.213 v6.0.0.
26. The apparatus of claim 25, wherein
the secondary scrambling codes of the
Kth primary scrambling codes are the
((K-1)*M+K+1)th through (K*M+K)th
Gold codes.
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Apple’s 3G Products contain secondary scrambling codes of the Kth primary scrambling
codes that are the ((K-1)*M+K+1)th through (K*M+K)th Gold codes.
For example, Apple’s 3G Products divide scrambling codes into 512 sets, each having one
primary scrambling code and 15 secondary scrambling codes. The primary scrambling
codes consist of scrambling codes n=16*i where i=0…511. The i:th set of secondary
13
ASSERTED CLAIM
(PATENT L.R. 3-1(A))
ACCUSED INSTRUMENTALITY AND HOW EACH ELEMENT IS MET BY
ACCUSED INSTRUMENTALITY
(PATENT L.R. 3-1(B)-(D))
scrambling codes consists of scrambling codes 16*i+k, where k=1…15. As a result, for
every 16 scrambling codes, the first code is a primary scrambling code whereas the 2nd
through 16th codes are secondary codes.
Example No. 1:
For K=1, ((K-1)*M+K+1) = (1-1)*15+1+1) = (0+2) = 2 and (K*M+K) = (1*15+1) =
(15+1) = 16. In Apple’s 3G Products, the first primary scrambling code is n=16*0 = 0,
while the secondary scrambling codes consists of 16*0+k (where k = 1…15) = [1…15].
As a result, for the first group of 16 scrambling codes (0 through 15), the first scrambling
code is a primary scrambling code (code 0), whereas codes 2 through 16 are secondary
scrambling codes.
Example No. 2:
For K=2, ((K-1)*M+K+1) = ((2-1)*15+2+1) = (15+3) = 18 and (K*M+K) = (2*15+2) =
(30+2) = 32. In Apple’s 3G Products, the second primary scrambling code is n=16*1 = 16,
while the second group of secondary scrambling codes consists of 16*1+k (where k =
1…15) = [17…31].
As a result, for the second group of 16 scrambling codes (16 through 31), the first
scrambling code (code 16) is a primary scrambling code whereas codes 2 through 16
(codes 17 through 31) are secondary scrambling codes.
Example No. 3:
For K=3, ((K-1)*M+K+1) = ((3-1)*15+3+1) = (30+4) = 34 and (K*M+K) = (3*15+3) =
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14
ASSERTED CLAIM
(PATENT L.R. 3-1(A))
ACCUSED INSTRUMENTALITY AND HOW EACH ELEMENT IS MET BY
ACCUSED INSTRUMENTALITY
(PATENT L.R. 3-1(B)-(D))
(45+3) = 48. In Apple’s 3G Products, the third primary scrambling code is n=16*2 = 32,
while the third group of secondary scrambling codes consists of 16*2+k (where k = 1…15)
= [33…47].
As a result, for the third group of 16 scrambling codes, the first scrambling code (code 32)
is a primary scrambling code whereas codes 2 through 16 (codes 33 through 47) are
secondary scrambling codes.
See 3GPP TS 25.213 v5.0.0 at 21, §5.2.2 “Scrambling code” (“A total of 218 – 1 = 262,143
scrambling codes, numbered 0 . . . 262,142 can be generated. However not all the
scrambling codes are used. The scrambling codes are divided into 512 sets each of a
primary scrambling code and 15 secondary scrambling codes. The primary scrambling
codes consist of scrambling codes n=16*i where i=0…511. The i:th set of secondary
scrambling codes consists of scrambling codes 16*i+k, where k=1…15.”); see also 3GPP
TS 25.213 v6.0.0 at 22.
27. The apparatus as claimed in claim
26, wherein K is a primary scrambling
code number and 1≤K≤512.
Apple’s 3G Products contain a primary scrambling code number, K, where 1≤K≤512.
For example, Apple’s 3G Products divide scrambling codes into 512 sets, each having one
primary scrambling code and 15 secondary scrambling codes.
See 3GPP TS 25.213 v5.0.0 at 22, §5.2.2 “Scrambling code” (“A total of 218 – 1 = 262,143
scrambling codes, numbered 0 . . . 262,142 can be generated. However not all the
scrambling codes are used. The scrambling codes are divided into 512 sets each of a
primary scrambling code and 15 secondary scrambling codes.”); see also 3GPP TS 25.213
v6.0.0 at 22.
30. The apparatus as claimed in claim
25, wherein the primary scrambling
02198.51845/4337814.1
Apple’s 3G Products contain a primary scrambling code and secondary scrambling code
that are I-channel components and a means for delaying at least one of the primary
15
ASSERTED CLAIM
(PATENT L.R. 3-1(A))
code and secondary scrambling code are
I-channel components and the apparatus
further comprises a means for delaying
at least one of the primary scrambling
codes and secondary code to produce Qchannel components.
ACCUSED INSTRUMENTALITY AND HOW EACH ELEMENT IS MET BY
ACCUSED INSTRUMENTALITY
(PATENT L.R. 3-1(B)-(D))
scrambling codes and secondary code to produce Q-channel components.
For example, Apple’s 3G Products transform the binary sequence generated by the n:th
Gold code sequence zn into a real valued sequence Zn(i), which in turn is used to generate a
complex scrambling code sequence Sdl,n having a real component I and an imaginary
component Q.
See 3GPP TS 25.213 v5.0.0 at 22, §5.2.2 “Scrambling code” (“Figure 13” shows the
transformation from zn to real valued sequence Zn(i), and the definition of Sdl,n); see also id.
at 23 (“Figure 14” shows the output signals I and Q); see also 3GPP TS 25.213 v6.0.0 at
23.
Figure 13 – Excerpt from 3GPP Standard Describing Definition of zn and Sdl,n
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16
ASSERTED CLAIM
(PATENT L.R. 3-1(A))
ACCUSED INSTRUMENTALITY AND HOW EACH ELEMENT IS MET BY
ACCUSED INSTRUMENTALITY
(PATENT L.R. 3-1(B)-(D))
Figure 14 – Configuration of downlink scrambling code generator
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17 16 15
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