WI-LAN Inc. v. Alcatel-Lucent USA Inc. et al

Filing 167

OPENING CLAIM CONSTRUCTION BRIEF filed by WI-LAN Inc.. (Attachments: # 1 Affidavit DECLARATION OF JEFFREY T. HAN IN SUPPORT OF WI-LANS OPENING CLAIM CONSTRUCTION BRIEF, # 2 Exhibit A-U.S. Patent No. 6,088,326, # 3 Exhibit B-U.S. Patent No. 6,195,327, # 4 Exhibit C-U.S. Patent No. 6,222,819, # 5 Exhibit D-U.S. Patent No. 6,381,211, # 6 Exhibit E-copy of The IEEE Standard Dictionary of Electrical and Electronics Terms (6th ed. 1996), # 7 Exhibit F-copy of Alan Freedman, The ComputerGlossary (7th ed. 1995), # 8 Exhibit G-copy of Harry Newton, Newtons Telecom Dictionary (11th ed. 1996), # 9 Exhibit H-copy of Ramjee Prasad, CDMA for Wireless Personal Communications (1996), # 10 Exhibit I-copy of Theodore S. Rappaport,Wireless Communications (1996), # 11 Exhibit J-copy of Shing-Fong Su, The UMTS Air-Interface in RF Engineering (2007), # 12 Exhibit K-copy of 3GPP TS 25.211,v.6.10.0 (Release 6), # 13 Exhibit L-copy of Jean Conan & Rolando Oliver, Hardware and Software Implementation of the Viterbi Decoding Algorithm for Convolutional Codes, in MIMI 76: Proceedings of the International Symposium on Mini and Micro Computers (M.H. Hamza ed., 1977), # 14 Exhibit M-Definition of Overlay, OxfordDictionaries Online, http://oxforddictionaries.com/definition/overlay?q=overlay, # 15 Exhibit N-copy of the Manual of Patent Examining Procedure (6th ed. rev. 3, July 1997))(Weaver, David)

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Kirkland &. EllisLibrary

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NEWTON'S TELECOM DICTIONARY

NEWTON'S TELECOM DICTIONARY
A Flatiron Publishing, Inc. Book
copyright © 1996 Harry Newton

published by Flatiron Publishing, Inc.
All rights reserved under International and Pan-American Copyright conventions, including the
right to reproduce this book or portions thereof in any form whatsoever. Published in the United
States by Flatiron Publishing, Inc., New York.
12West 21 Street
New York, NY 10010
212-691-8215 Fax [phone]
1-800-999-0345
1-800-L1BRARY
Email [e-mail]
ISBN # 0-936648-87-2
July, 1996
Manufactured in the United States of America
Eleventh Edition
Cover design by Mara Seinfeld
Printed at Command Web, New Jersey

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vates circuit use. The result isclipping of the first bit ofthe speech, but more efficient use ofthe transmission facility. TASI isused on expensive circuits, such as long submarine cables. See TASI.
Time Congestion The time resources (outgoing trunks) are busy.
Time Divert To Attendant Asystem feature which automatically transfers aphone tothe attendant if the phone has been left off-hook
too long
Time Diversity Amethod of transmission wherein asignal representing the same information issent over the same channel at different
times. Often used over systems subject to burst error conditions and with the spacing adjusted to be longer than an error burst.
Time Division Controller TOC. Adevice which commands functions, monitors status and connects channels of TOM cards.
Time Division Multiple Access TOMA. Atechnique originated insatellite communications to 'Interweave multiple conversations into
one transponder so as to appear to get simultaneous conversations. Avariation on TASI. Atechnique now used incellular and other wireless communications. See TOMA.
Time Division Multiplex TOM. Atechnique for transmitting anumber ofseparate data, voice and/or video signals simultaneously over
one communications medium by quickly interleavlnq apiece ofeach signal one after another. Here's our problem. We have to transport the
freight of five manufacturers from Chicago toNew York. Each manufacturer's freight will fit into 20 rail boxcars. We have three basic solutions. First, build five separate railway lines from Chicago to New York. Second, rent five engines and schlepp live complete trains toNew
York on one railway track. Or, third, join all the boxcars together into one train of 100 boxcars and run them on one track. The train might
look like this: Engine, Boxcar from Producer A, Box Car from Producer B, Producer C, Producer 0, Producer E, and then the order begins
again...Boxcar from Producer A, Producer B...Moving one large train 01 100 boxcars islikely tobe cheaper and more efficient than moving
five smaller trains each of 20 boxcars on five separate railway tracks. Time Division Multiplexing, thus, represents substantial savings over
have five separate networks (five separate tracks) and sending five separate transmissions (five separate trains).
This iswhat Time Division Multiplexing isall about. And the analogy isperfect. Take one large train (fast communications channel) and interleave
pieces (boxcars) from each conversation one after another. Ifyou do this fast enough, you'll never notice you've broken the conversations apart,
moved them separately, and then put them back together at the distant end. In TOM, you "sampte" each voice conversation, interleave the samples, send them on their way, then reconstruct the several conversations at the other end. There are several ways to do the sampling. You can sample eight bits (one byte) of each conversation, or you can sample one bit. The fanner iscalled word interleaving; the latter bit interleaving. The
basic goal ofmultiplexing - whether itbe time division multiplexing, or any other form
- isto save money, to cram more conversations (voice, data, video orfacsimite) onto fewer phone lines. To substitute electronics for copper. See also the following three definitions.
Time Division Multiplexer TOM. Adevice which derives multiple channels on asingle transmission facility by connecting bit streams
one at atime at regular intervals. Itinterleaves bits or characters from each terminal or device using the time. See TIME DIVISION MULTIPLEX.
Time Division Signaling Signaling over atime division multiplex system inwhich all voice channels share acommon signaling channel, with time division providing the separation between signaling channels. See SIGNALING SYSTEM 7.
Time Division Switching The connection oftwo circuits inanetwork by assigning fhem tothe same time slot on acommon time division switched bus.
Time Domain Reflectometer TOR. Atesting device that acts on radar-like principles todetermine the location of metallic circuit faults.
Time Guard Band Atime interval left vacant on achannel toprovide amargin ofsafety against interterence inthe time domain between
sequential operations, such as detection, integration, differentiation, transmission, encoding, decoding, orswitching.
Time Jitters Short-term variation orinstability inthe duration ofaspecified interval.
Time Marker Areference signal, often repeated periodically, enabling the correlation ofspecific events with atime scale. markers are
used insome systems for establishing synchronization.
Time Multiplexed Switch The space switch ofwhich the cross point settings are changed ineach time slot.
Time Of Day Display The time and date displays on phones. Actually, it's very useful information. Sometimes it's not displayed on the operator's console. As aresult, the operator may never know that every phone inthe office isshowing the wrong time and date.
Time Of Day Routing 1. This feature automatically changes access to certain types oflines at times when the lines change from being
expensive to cheap, orvice versa. For example, it's cheaper to use WATS lines before 8:00 AM inthe morning. Acompany has offices inNew
York and Los Angeles. Itmight be cheaper toroute calls to Chicago inthe morning over the tie lines to LA and then out the LA WATS lines to
Chicago, than to go directly out the New York WATS lines. This isaway toallocate bandwidth for LAN traffic over corporate T-1 Networks. By
programming T-1 multiplexers, customers can allocate the amount ofT1 bandwidth that can be used by voice, data, and LAN traffic on atime
of day basis. For example, during the day, most ofthe T1 bandwidth can be allocated for voice. At night, after employees go home, more bandwidth can be allocated to LAN and other computer data traffic so that file transfers can be done faster. This isparticularly useful in IBM mainframe environments where large amounts ofdata needs tobe transferred form remote offices/divisions tothe headquarters.
Time Out In telecommunications and computer networks, an event which occurs at the end ofapredetermined interval oftime iscalled Time
Out. For example ifyou lift the phone off the cradle and do not proceed todial, after acertain number of seconds you will hear either avoice telling
you toget on with it orahowling sound ofsome sort. Data networks have the same thing. Don't do anything for x minutes and the system will
knock you off the air, i.e. hang up on you. In more technical terms, time out isthe amount oftime that hardware or software waits for an expected
event before taking corrective action. In its most common form, time out isthe amount oftime an OCC or telephone system waits after your call
goes through before itbegins bitling or timing the call. Also see ANSWER SUPERVISION.
Time Sharing Amode of operation that provides for the interleaving oftwo or more independent processes on one functional unit. Its
most common use isthe interleaved use oftime on acomputing system enabling two ormore users toexecute computer programs concurrently. Time sharing ofcomputer resources isnow relatively obsolete. See also TIMESHARING below.
Time Slice In amulti tasking environment, each task isallotted aportion ofthe CPU's overall processing power. This portion iscalled a
time-slice. And it's usually measured in milliseconds. The CPU switches between tasks, and those with higher priority receive more timeslices than lower-priority tasks. See TIME SLICING.
Time Slicing The term used to describe the dividing ofacomputer resource so multiple applications ortasks requesting the resource are

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allocated some amount ofthe resource's time. See TIME SLICE.

Time Slot 1. In time division multiplexing or switching, the slot belonging toavoice, data or video conversation. Itcan be occupied with
conversation orleft blank. But the slot IS always present. You can tell the capacity of the switch orthe transmission channel by figuring how
many slots are present.
2. An SCSA term. The smallest switchable data unit on the SCbus or SCxbus Data Bus. Atime slot consists ofeight consecutive bits ofdata.
One time slol isequivalent to adata path with abandwidth of64 Kbps.
Time Space Time System TST. The most common form ofswitching matrix for small digital telephone exchanges inwhich aspace
switch issandwiched between two time switches.
Time Switch Adevice incorporating aclock which arranges to switch equipment on or off alpredetermined times.
Time Varying Media An SCSA definition. Time-varying media, such as audio data (as opposed to space-varying media, such as image data).
Timed Detection As asubstitute for answer supervision, some long distance phone companies use call timing and estimate that acall
iscompleted if the caller remains off-hook for 30 seconds ormore. This isnot necessarily accurate, ofcourse. The caller might be holding,
thinking the person isinthe shower, out inthe garden, etc. Little does the caller know he isnow being charged to listen to ringing signals.
Along distance phone company that is "equal accessed" doesn't have this problem. Along distance company that isn't equal accessed one that you have to dial directly with alocal call - might well have this problem. Rule: When in doubt, don't wait too long on the phone
listening to endless ringing. Hang up. Count to ten. Then redial.
Timed Purge Afeature ofinteractive voice response systems, especially fax-back systems. Ifthe document isn't requested for x number
of days orweeks orif the document ages to acertain point, the system automatically deletes the document.
Timed Recall Your PBX can be instructed to place acall at adesignated time. When the time comes, your PBX rings your phone. When
you answer your phone, the PBX places the call.
Timed Reminders At 20-second intervals, timed reminders will alert an attendant that acall isstill waiting, acalled line has not yet been
answered oracall isstill on hold. Timed reminders can be made longer or shorter. They can alert attendants to all sorts of events and non-events.
Timeout Two computers are "tatking." One (for any reason) to respond. The other computer will keep on trying for acertain amount oftime,
but will eventually "give up." This iscalled time-out. Atime also happens in asingle computer. If adevice (e.g. aprinter) isnot performing a
task or responding, timeout isthe amount oftime the computer should wait before detecting itas an error. That period iscalled time-out.
Timesharing The use ofone computer by many users at one time. Each user istypically sitting in front ofadata terminal and connected
to the master computer through communications lines - local orlong distance. The user asks the computer to work on his task, whether
it be asimple as looking up some stock prices, checking an airline reservation ordoing some accounting calculations. Itappears to each
user as if he/she has acomputer dedicated to his own task, but the computer islarge and powerful, and ismoving rapidly from one user's
task to the next. Timesharing's advantages are twofold:
1.The user may find it cheaper to time share acomputer than to buy his own. 2. The computer may have valuable and extensive information init,which would be Virtually impossible to duplicate or handle inmany stand-alone computers. Timesharing was more popular when
computers were more expensive.
Timing Jitter Deviation ofclock recovery that can occur when a receiver attempts to recover clocking as well as data from the received
signal. The clock recovery will deviate inarandom fashion from the transitions of the received signal.
Timing Recovery The derivation of atiming signal from areceived signal.
Timing Signal The output ofaclock. Asignal used to synchronize connected equipment.
Timing Slip Asudden timing delay change during high-speed digital transmission often caused by using T-1 carriers from different suppliers.
TINA·C Telecommunications Information Networking Architecture Consortium. An international standards body.
Tinned Wire Copper wire coated with tin to make soldering easier.
Tinsel Acomponent ofsome phone line cord conductors. Tinsel ismade by rolling copper into very thin, narrow rolls and then winding
several strands oftinsel around anon-metallic core (a string) and then placing an insulating cover over the resulting conductor. Acord is
then built up oftwo ormore conductors encased inaplastic jacket. The essential reason for this type ofconstruction isto obtain good cord
flexibility and long life.
Tint Another name for hue.
Tip The first wire inapair ofphone wires. The second wire iscalled the "ring" wire. The tip isthe conductor inatelephone cable pair which
isusually connected to positive side ofabattery at the telephone company's central office. Itisthe phone industry's equivalent ofGround in
anormal electrical circuit. See TIP & RING.
Tip & Ring An old fashioned way ofsaying "plus" and "minus," orground and positive inelectrical circuits. Tip and Ring are telephony
terms. They derive their names from the operator's cordboard plug. The tip wire was connected to the tip ofthe plug, and the ring wire was
connected to the slip ring around the jack. Athird conductor on some jacks was called the sleeve. That's it. Nothing more sinister. Nothing
more interesting. See TIP, RING & GROUND.
Tip Cable Asmall cable connecting terminals on adistributing frame to cable pairs inthe cable vault.
Tip Conductor The first conductor ofacustomer line.
Tip Side That conductor ofacircuit which isassociated with the tip ofaplug, orofatelephone circuit.
Tip, Ring, Ground The conductive paths between acentral office and aphone. The tip and ring leads constitute the circuit that carries abalanced speech or adata signal. The ground path in combination with the conductor isused occasionally for signaling.
TlPI Telephone Industry Price Index.
TlQ Telrate International Quotations.
TIS Technical Information Sheets.
Titanic On December 21, 1993 Vice President, AI Gore, told the National Press Club in Washington, "There isalot ofromance surrounding the sinking ofthe Titanic 91 years ago. But when you strip the romance away, atragic story emerges that tells us a lot about human
beings - and telecommunications. Why did the ship that couldn't be sunk steam full speed into an ice field? For inthe last few hours before
the Titanic collided, other ships were sending messages like this one from the Mesaba: "Lat42N to 41.25 Long 49W to Long 50.30W. Saw

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