WI-LAN Inc. v. Alcatel-Lucent USA Inc. et al
Filing
192
AMENDED JOINT CLAIM CONSTRUCTION CHART filed by Alcatel-Lucent USA Inc., Ericsson Inc., Exedea INC., HTC America, Inc., HTC Corporation, Sony Mobile Communications (USA) Inc., Sony Mobile Communications AB, Telefonaktiebolaget LM Ericsson, WI-LAN Inc. and NOTICE OF COMPLIANCE WITH PATENT RULE 4-5(d). (Attachments: # 1 Exhibit A-Amended Joint Claim Construction Chart, # 2 Exhibit B-Redline Comparison of Amended Chart)(Weaver, David)
EXHIBIT B
P.R. 4-5(d) Joint Claim Construction Chart
Note: Terms being construed are in bold. For brevity, (1) only asserted claims are listed in the chart, and (2) proposed constructions for
claim terms are only listed once per patent, where they first appear. The presence of the term in subsequent claims (asserted and
non-asserted) within the same patent or other asserted patents, if applicable, is indicated in a parenthetical accompanying each disputed
claim term.
U.S. Patent No. 6,088,326
’326 Patent Claim
Element
Claim 1
1. A transmission
controller for processing
data items to be
transmitted over a
wireless link connecting
a central terminal and a
subscriber terminal of a
wireless
telecommunications
system, a single
frequency channel being
employed for
transmitting data items
pertaining to a plurality
of wireless links, the
transmission controller
comprising:
an orthogonal code
generator for providing
an orthogonal code
from a set of `m`
orthogonal codes used
Disputed Term
wireless link
Plaintiff’s Proposed
Construction
[AGREED]
Defendants’ Proposed
Construction
[AGREED]
(Appears in ’326 Patent
cls. 1, 2, 5, 9, 11–13;
’211 Patent cls. 1, 2, 5–7;
’819 Patent cls. 1, 7, 8,
11, 12, 18, 21–25, 29;
’327 Patent 1, 11–22.)
subscriber terminal
“user equipment”
[AGREED]
“a radio connection
between a central
terminal and a particular
subscriber terminal for
communicating data
items therebetween”
“a fixed-location device”
(Appears in ’326 Patent
cls. 1, 6, 8–12, 14; ’211
Patent cls. 1, 5, 6, 8, 9;
’819 Patent cls. 1, 8–12,
19, 21–25, 27, 29, 31;
’327 Patent cls. 1, 11,
13–22.)
orthogonal codes
Court’s Construction
[AGREED]
(Appears in ’326 Patent
cls. 1, 3–5, 11, 12; ’211
Patent cls. 1, 3–6; ’819
1
“codes that
cross-correlate to zero
with respect to each
other”
’326 Patent Claim
Element
to create `m` orthogonal
channels within the
single frequency
channel;
Disputed Term
Patent cls. 1, 3, 5, 7, 12,
14, 16, 18, 21–25, 29;
’327 Patent cls. 10,
12–16.)
orthogonal
channel(s)channels
(Appears in ’326 Patent
cls. 1, 2, 5–15; ’211
Patent cls. 1, 2, 5–10;
’819 Patent cls. 1, 7–12,
18–25, 27–29, 31, 32;
’327 Patent cls. 10,
13–16.)
Plaintiff’s Proposed
Construction
Wi-LAN proposes
construing “orthogonal
channels” (plural) and
“orthogonal channel”
(singular) separately, as
follows:
orthogonal channels: “a
set of channels created
using orthogonal codes
that cross-correlate to
zero with respect to each
other”
orthogonal channel:
“one of the set of
orthogonal
channels”[AGREED]
a first encoder for
combining a data item to
be transmitted on the
single frequency channel
with said orthogonal
code from the
orthogonal code
generator, the
orthogonal code
2
Defendants’ Proposed
Construction
Court’s Construction
orthogonal channel: “a
“a set of channels created
communication channel using the orthogonal
defined by an orthogonal codes”
code”[AGREED]
’326 Patent Claim
Element
determining the
orthogonal channel
over which the data item
is transmitted, whereby
data items pertaining to
different wireless links
may be transmitted
simultaneously within
different orthogonal
channels of said single
frequency channel; and
a TDM encoder
arranged to apply time
division multiplexing
(TDM) techniques to
the data item in order to
insert the data item
within a time slot of the
orthogonal channel,
whereby a plurality of
data items relating to
different wireless links
may be transmitted
within the same
orthogonal channel
during a predetermined
frame period.
Disputed Term
TDM encoder
Plaintiff’s Proposed
Construction
“hardware and/or
software for applying
TDM techniques”
Defendants’ Proposed
Construction
“a device that applies
time division
(Appears in ’326 Patent
multiplexing (TDM)
cls. 1, 2, 5, 8–11; ’819
techniques to share a
Patent cl. 11; ’327 Patent
communication channel
cl. 15.)
among multiple wireless
links”
time division
“techniques for
“methods in which a
multiplexing (TDM)
allocating an interval of communication channel
techniques
time within a
is shared among multiple
predetermined frame
wireless links by
(Appears in ’326 Patent period to a data item,
allowing each to use the
cls. 1, 5–8, 11, 12, 14,
based on one or more
channel for a given
15; ’211 Patent cls. 8–10; characteristics associated period of time in a
’819 Patent cl. 11; ’327
with the data item”
defined, repeated
Patent cl. 15.)
sequence”
time slot
“an interval of time”
“a period of time during
which a single wireless
(Appears in ’326 Patent
link is permitted to use a
cls. 1, 5, 7, 11, 12, 15;
shared communication
3
Court’s Construction
’326 Patent Claim
Element
Disputed Term
Plaintiff’s Proposed
Construction
’211 Patent cls. 1, 5, 6,
10; ’327 Patent cls. 15,
16.)
Defendants’ Proposed
Construction
channel”
Claim 2
2. A transmission
controller as claimed in
claim 1, further
comprising:
an overlay code
generator for providing
an overlay code from a
first set of ‘n’ overlay
codes which are
orthogonal to each other;
and
overlay code
“orthogonal codes used
“a second code applied in
to increase the number of series with the
(Appears in ’326 Patent orthogonal channels that orthogonal code”
cls. 2, 5, 9–11, 13; ’211
would otherwise be
Patent cls. 2, 5, 7, 8; ’819 available”
Patent cls. 1, 2, 4, 6–10,
12, 13, 15, 17–32; ’327
Patent cls. 13, 14.)
a second encoder,
selectively operable
instead of the TDM
encoder, to apply the
overlay code from the
overlay code generator
to said data item,
whereby ‘n’ data items
pertaining to different
wireless links may be
transmitted
simultaneously within
the same orthogonal
channel.
4
Court’s Construction
’326 Patent Claim
Element
Claim 3
3. A transmission
controller as claimed in
claim 1, wherein the
orthogonal code
generator is a storage
arranged to store the set
of orthogonal codes.
Disputed Term
Plaintiff’s Proposed
Construction
Claim 4
4. A transmission
controller as claimed in
claim 1, wherein the set
of orthogonal codes
comprise a set of
Rademacher-Walsh
(RW) codes.
Claim 5
5. A central terminal of a
wireless
telecommunications
system, comprising a
transmission controller
having:
an orthogonal code
generator for providing
an orthogonal code
from a set of ‘m’
orthogonal codes used
to create ‘m’ orthogonal
channels within the
5
Defendants’ Proposed
Construction
Court’s Construction
’326 Patent Claim
Element
single frequency
channel;
Disputed Term
Plaintiff’s Proposed
Construction
a first encoder for
combining a data item to
be transmitted on the
single frequency channel
with said orthogonal
code from the
orthogonal code
generator, the
orthogonal code
determining the
orthogonal channel
over which the data item
is transmitted, whereby
data items pertaining to
different wireless links
may be transmitted
simultaneously within
different orthogonal
channels of said single
frequency channel;
a TDM encoder
arranged to apply time
division multiplexing
(TDM) techniques to
the data item in order to
insert the data item
within a time slot of the
orthogonal channel,
6
Defendants’ Proposed
Construction
Court’s Construction
’326 Patent Claim
Element
whereby a plurality of
data items relating to
different wireless links
may be transmitted
within the same
orthogonal channel
during a predetermined
frame period;
Disputed Term
Plaintiff’s Proposed
Construction
an overlay code
generator for providing
an overlay code from a
first set of ‘n’ overlay
codes which are
orthogonal to each other;
a second encoder,
selectively operable
instead of the TDM
encoder, to apply the
overlay code from the
overlay code generator
to said data item,
whereby ‘n’ data items
pertaining to different
wireless links may be
transmitted
simultaneously within
the same orthogonal
channel, wherein the
orthogonal code
generator is a storage
7
Defendants’ Proposed
Construction
Court’s Construction
’326 Patent Claim
Element
arranged to store the set
of orthogonal codes and
wherein the set of
orthogonal codes
comprise a set of
Rademacher-Walsh
(RW) codes.
Claim 6
6. A central terminal as
claimed in claim 5,
further comprising
channelisation means
for determining which
of the orthogonal
channels will be subject
to TDM techniques,
and for transmitting
that information to a
plurality of subscriber
terminals within the
wireless
telecommunications
system.
Disputed Term
channelisation means for
determining which of the
orthogonal channels will
be subject to TDM
techniques, and for
transmitting that
information to a plurality
of subscriber terminals
within the wireless
telecommunications
system
Plaintiff’s Proposed
Construction
Defendants’ Proposed
Construction
Indefinite under 35 USC
Function: determining
which of the orthogonal § 112
channels will be subject
to TDM techniques, and
transmitting that
information to a plurality
of subscriber terminals
within the wireless
telecommunications
system
Corresponding
Structure: modem shelf
including a demand
assignment engine
connected to a network
and one or more
modems, the demand
assignment engine
determining which of the
orthogonal channels will
be subject to TDM
techniques based on
8
Court’s Construction
’326 Patent Claim
Element
Disputed Term
Plaintiff’s Proposed
Construction
information regarding
the capability of
subscriber terminals to
support TDM techniques
and/or the type of data
items to be transmitted,
and equivalents thereof
Corresponding Structure
(alternate construction):
modem shelf including a
demand assignment
engine connected to a
network and one or more
modems, the demand
assignment engine
determining which of the
orthogonal channels will
be subject to TDM
techniques using the
algorithm: (1) consider
whether the subscriber
terminal to which data
will be transmitted
incorporates the features
necessary to support
TDM techniques; (2)
consider the type of data
that is to be transmitted
in an orthogonal channel;
and (3) if the subscriber
9
Defendants’ Proposed
Construction
Court’s Construction
’326 Patent Claim
Element
Claim 7
7. A central terminal as
claimed in claim 6,
wherein the
channelisation means
also determines, for
those orthogonal
channels subject to
TDM techniques, how
many time slots will be
provided within each
orthogonal channel.
Disputed Term
channelisation means
also determines, for
those orthogonal
channels subject to TDM
techniques, how many
time slots will be
provided within each
orthogonal channel
Plaintiff’s Proposed
Construction
terminal supports TDM
techniques and the data
type is one for which
TDM techniques should
be applied, then apply
TDM techniques
(otherwise do not), and
equivalents thereof
Defendants’ Proposed
Construction
Indefinite under 35 USC
Function: determining,
for those orthogonal
§ 112
channels subject to TDM
techniques, how many
time slots will be
provided within each
orthogonal channel
Corresponding
Structure: demand
assignment engine
connected to a network
and one or more
modems, the demand
assignment engine
determining how many
time slots will be
provided within each
orthogonal channel
based on information
regarding the type of data
items to be transmitted,
10
Court’s Construction
’326 Patent Claim
Element
Disputed Term
Plaintiff’s Proposed
Construction
and equivalents thereof
Corresponding Structure
(alternate construction):
demand assignment
engine connected to a
network and one or more
modems, the demand
assignment engine
determining how many
time slots will be
provided within each
orthogonal channel using
the algorithm: (1)
consider the type of data
that is to be transmitted
in an orthogonal channel,
and (2) choose a suitable
number of time slots to
provide within the
orthogonal channel to
achieve an acceptable
data rate, and equivalents
thereof
Claim 8
8. A central terminal as
claimed in claim 7,
wherein a number of said
orthogonal channels are
designated as traffic
channels for the
11
Defendants’ Proposed
Construction
Court’s Construction
’326 Patent Claim
Element
transmission of data
items relating to
communication content,
and the TDM encoder is
employed to apply time
division multiplexing
(TDM) techniques to
data items to be sent over
a traffic channel from
said central terminal to
said subscriber
terminal.
Disputed Term
Plaintiff’s Proposed
Construction
Claim 9
9. A central terminal as
claimed in claim 5,
wherein a first of the
orthogonal channels is
reserved for the
transmission of signals
relating to the acquisition
of wireless links, and the
second encoder is used
instead of the TDM
encoder to enable
overlay codes to be
applied to data items to
be sent within said first
orthogonal channel
from the central terminal
to one of said subscriber
12
Defendants’ Proposed
Construction
Court’s Construction
’326 Patent Claim
Element
terminals.
Disputed Term
Plaintiff’s Proposed
Construction
Defendants’ Proposed
Construction
Court’s Construction
Plaintiff’s Proposed
Construction
Defendants’ Proposed
Construction
Court’s Construction
Claim 10
10. A central terminal as
claimed in claim 5,
wherein a second of the
orthogonal channels is
reserved for the
transmission of signals
relating to the control of
calls, and the second
encoder is used instead
of the TDM encoder to
enable overlay codes to
be applied to data items
to be sent within said
second orthogonal
channel from the central
terminal to one of said
subscriber terminals.
U.S. Patent No. 6,381,211
’211 Patent Claim
Disputed Term
Element
Claim 1
1. A reception controller wireless link
for processing data items
received over a wireless (Appears in ’326 Patent
link connecting a central cls. 1, 2, 5, 9, 11–13;
[AGREED]
13
[AGREED]
“a radio connection
between a central
terminal and a particular
subscriber terminal for
’211 Patent Claim
Element
terminal and a
subscriber terminal of a
wireless
telecommunications
system, a single
frequency channel being
employed for
transmitting data items
pertaining to a plurality
of wireless links, and
‘m’ orthogonal
channels being provided
within the single
frequency channel, the
receiver controller
comprising:
Disputed Term
Plaintiff’s Proposed
Construction
’211 Patent cls. 1, 2, 5–7;
’819 Patent cls. 1, 7, 8,
11, 12, 18, 21–25, 29;
’327 Patent 1, 11–22.)
subscriber terminal
“user equipment”
(Appears in ’326 Patent
cls. 1, 6, 8–12, 14; ’211
Patent cls. 1, 5, 6, 8, 9;
’819 Patent cls. 1, 8–12,
19, 21–25, 27, 29, 31;
’327 Patent cls. 1, 11,
13–22.)
orthogonal
channel(s)channels
(Appears in ’326 Patent
cls. 1, 2, 5–15; ’211
Patent cls. 1, 2, 5–10;
’819 Patent cls. 1, 7–12,
18–25, 27–29, 31, 32;
’327 Patent cls. 10,
13–16.)
Wi-LAN proposes
construing “orthogonal
channels” (plural) and
“orthogonal channel”
(singular) separately, as
follows:
orthogonal channels: “a
set of channels created
using orthogonal codes
that cross-correlate to
zero with respect to each
other”
orthogonal channel:
“one of the set of
orthogonal
channels”[AGREED]
14
Defendants’ Proposed
Construction
Court’s Construction
communicating data
items therebetween”
“a fixed-location device”
orthogonal channel: “a
“a set of channels created
communication channel using the orthogonal
defined by an orthogonal codes”
code”[AGREED]
’211 Patent Claim
Element
an orthogonal code
generator for providing
an orthogonal code
from a set of ‘m’
orthogonal codes used
to create said ‘m’
orthogonal channels
within the single
frequency channel;
Disputed Term
orthogonal codes
Plaintiff’s Proposed
Construction
[AGREED]
Defendants’ Proposed
Construction
[AGREED]
(Appears in ’326 Patent
cls. 1, 3–5, 11, 12; ’211
Patent cls. 1, 3–6; ’819
Patent cls. 1, 3, 5, 7, 12,
14, 16, 18, 21–25, 29;
’327 Patent cls. 10,
12–16.)
a first decoder for
applying, to signals
received on the single
frequency channel, the
orthogonal code
provided by the
orthogonal code
generator, in order to
isolate data items
transmitted within the
corresponding
orthogonal channel;
and
a TDM decoder
arranged to extract a data
item from a
predetermined time slot
within said orthogonal
channel, a plurality of
data items relating to
different wireless links
TDM decoder
“hardware and/or
software for extracting a
(Appears in ’211 Patent data item from a
cls. 1, 2, 5, 7; ’327 Patent predetermined time slot
cl. 16.)
within the orthogonal
channel”
15
“a device used to extract
information from a
communication channel
that is shared among
multiple wireless links
by allocating a given
period of time to each
such link in a defined,
Court’s Construction
“codes that
cross-correlate to zero
with respect to each
other”
’211 Patent Claim
Element
being transmitted within
the same orthogonal
channel during a
predetermined frame
period.
Disputed Term
time slot
Plaintiff’s Proposed
Construction
“an interval of time”
(Appears in ’326 Patent
cls. 1, 5, 7, 11, 12, 15;
’211 Patent cls. 1, 5, 6,
10; ’327 Patent cls. 15,
16.)
Defendants’ Proposed
Construction
repeated sequence”
“a period of time during
which a single wireless
link is permitted to use a
shared communication
channel”
Claim 2
2. A reception controller
as claimed in claim 1,
further comprising:
an overlay code
generator for providing
an overlay code from a
first set of ‘n’ overlay
codes which are
orthogonal to each other,
the set of ‘n’ overlay
codes enabling ‘n’ data
items pertaining to
different wireless links
to be transmitted
simultaneously within
the same orthogonal
channel; and
overlay code
“orthogonal codes used
“a second code applied in
to increase the number of series with the
(Appears in ’326 Patent orthogonal channels that orthogonal code”
cls. 2, 5, 9–11, 13; ’211
would otherwise be
Patent cls. 2, 5, 7, 8; ’819 available”
Patent cls. 1, 2, 4, 6–10,
12, 13, 15, 17–32; ’327
Patent cls. 13, 14.)
a second decoder,
selectively operable
instead of the TDM
decoder, to apply to the
16
Court’s Construction
’211 Patent Claim
Element
data items of the
orthogonal channel, the
overlay code from the
overlay code generator
so as to isolate a
particular data item
transmitted using that
overlay code.
Disputed Term
Plaintiff’s Proposed
Construction
Claim 3
3. A reception controller
as claimed in claim 1,
wherein the orthogonal
code generator is a
storage arranged to store
the set of orthogonal
codes.
Claim 4
4. A reception controller
as claimed in claim 1,
wherein the set of
orthogonal codes
comprise a set of
Rademacher-Walsh
(RW) codes.
Claim 5
5. A subscriber
terminal of a wireless
telecommunications
system, comprising a
reception controller
17
Defendants’ Proposed
Construction
Court’s Construction
’211 Patent Claim
Element
having:
Disputed Term
Plaintiff’s Proposed
Construction
an orthogonal code
generator for providing
an orthogonal code
from a set of ‘m’
orthogonal codes used
to create said ‘m’
orthogonal channels
within the single
frequency channel;
a first decoder for
applying, to signals
received on the single
frequency channel, the
orthogonal code
provided by the
orthogonal code
generator, in order to
isolate data items
transmitted within the
corresponding
orthogonal channel;
a TDM decoder
arranged to extract a data
item from a
predetermined time slot
within said orthogonal
channel, a plurality of
data items relating to
different wireless links
18
Defendants’ Proposed
Construction
Court’s Construction
’211 Patent Claim
Element
being transmitted within
the same orthogonal
channel during a
predetermined frame
period;
Disputed Term
Plaintiff’s Proposed
Construction
an overlay code
generator for providing
an overlay code from a
first set of ‘n’ overlay
codes which are
orthogonal to each other,
the set of ‘n’ overlay
codes enabling ‘n’ data
items pertaining to
different wireless links
to be transmitted
simultaneously within
the same orthogonal
channel;
a second decoder,
selectively operable
instead of the TDM
decoder, to apply to the
data items of the
orthogonal channel, the
overlay code from the
overlay code generator
so as to isolate a
particular data item
transmitted using that
19
Defendants’ Proposed
Construction
Court’s Construction
’211 Patent Claim
Element
overlay code, wherein
the set of orthogonal
codes comprise a set of
Rademacher-Walsh
(RW) codes and wherein
the set of orthogonal
codes comprise a set of
Rademacher-Walsh
(RW) codes.
Disputed Term
Plaintiff’s Proposed
Construction
Defendants’ Proposed
Construction
Court’s Construction
Disputed Term
Plaintiff’s Proposed
Construction
Defendants’ Proposed
Construction
Court’s Construction
U.S. Patent No. 6,222,819
’819 Patent Claim
Element
Claim 1
1. A transmission
controller for processing
data items to be
transmitted over a
wireless link connecting
a central terminal and a
subscriber terminal of a
wireless
telecommunications
system, a single
frequency channel being
employed for
transmitting data items
pertaining to a plurality
of wireless links, the
wireless link
[AGREED]
(Appears in ’326 Patent
cls. 1, 2, 5, 9, 11–13;
’211 Patent cls. 1, 2, 5–7;
’819 Patent cls. 1, 7, 8,
11, 12, 18, 21–25, 29;
’327 Patent 1, 11–22.)
subscriber terminal
“user equipment”
(Appears in ’326 Patent
cls. 1, 6, 8–12, 14; ’211
Patent cls. 1, 5, 6, 8, 9;
’819 Patent cls. 1, 8–12,
19, 21–25, 27, 29, 31;
20
[AGREED]
“a fixed-location device”
“a radio connection
between a central
terminal and a particular
subscriber terminal for
communicating data
items therebetween”
’819 Patent Claim
Element
transmission controller
comprising:
an orthogonal code
generator for providing
an orthogonal code
from a set of ‘m’
orthogonal codes used
to create ‘m’ orthogonal
channels within the
single frequency
channel, wherein ‘m’ is a
positive integer;
Disputed Term
Plaintiff’s Proposed
Construction
Defendants’ Proposed
Construction
Court’s Construction
’327 Patent cls. 1, 11,
13–22.)
orthogonal codes
(Appears in ’326 Patent
cls. 1, 3–5, 11, 12; ’211
Patent cls. 1, 3–6; ’819
Patent cls. 1, 3, 5, 7, 12,
14, 16, 18, 21–25, 29;
’327 Patent cls. 10,
12–16.)
orthogonal
channel(s)channels
(Appears in ’326 Patent
cls. 1, 2, 5–15; ’211
Patent cls. 1, 2, 5–10;
’819 Patent cls. 1, 7–12,
18–25, 27–29, 31, 32;
’327 Patent cls. 10,
13–16.)
[AGREED]
[AGREED]
Wi-LAN proposes
construing “orthogonal
channels” (plural) and
“orthogonal channel”
(singular) separately, as
follows:
orthogonal channel: “a
“a set of channels created
communication channel using the orthogonal
defined by an orthogonal codes”
code”[AGREED]
orthogonal channels: “a
set of channels created
using orthogonal codes
that cross-correlate to
zero with respect to each
other”
orthogonal channel:
“one of the set of
orthogonal
channels”[AGREED]
a first encoder for
combining a data item to
21
“codes that
cross-correlate to zero
with respect to each
other”
’819 Patent Claim
Element
be transmitted on the
single frequency channel
with said orthogonal
code from the
orthogonal code
generator, the
orthogonal code
determining the
orthogonal channel
over which the data item
is transmitted, whereby
data items pertaining to
different wireless links
may be transmitted
simultaneously within
different orthogonal
channels of said single
frequency channel;
an overlay code
generator for providing
an overlay code from a
first set of ‘n’ overlay
codes which are
orthogonal to each other,
wherein ‘n’ is a positive
integer; and
Disputed Term
Plaintiff’s Proposed
Construction
overlay code
Defendants’ Proposed
Construction
“orthogonal codes used
“a second code applied in
to increase the number of series with the
(Appears in ’326 Patent orthogonal channels that orthogonal code”
cls. 2, 5, 9–11, 13; ’211
would otherwise be
Patent cls. 2, 5, 7, 8; ’819 available”
Patent cls. 1, 2, 4, 6–10,
12, 13, 15, 17–32; ’327
Patent cls. 13, 14.)
a second encoder
arranged to apply the
overlay code from the
overlay code generator
22
Court’s Construction
’819 Patent Claim
Element
to said data item,
whereby ‘n’ data items
pertaining to different
wireless links may be
transmitted
simultaneously within
the same orthogonal
channel.
Disputed Term
Plaintiff’s Proposed
Construction
Claim 2
2. A transmission
controller as claimed in
claim 1, wherein the
overlay code generator
is arranged to provide
overlay codes from one
or more further sets of
overlay codes having
different numbers of
overlay codes to said
first set of overlay
codes.
Claim 3
3. A transmission
controller as claimed in
claim 1, wherein the
orthogonal code
generator is a storage
arranged to store the set
of orthogonal codes.
Claim 4
23
Defendants’ Proposed
Construction
Court’s Construction
’819 Patent Claim
Element
4. A transmission
controller as claimed in
claim 1, wherein the
overlay code generator
is a storage arranged to
store the set of overlay
codes.
Disputed Term
Plaintiff’s Proposed
Construction
Claim 5
5. A transmission
controller as claimed in
claim 1, wherein the set
of orthogonal codes
comprise a set of
Rademacher-Walsh
(RW) codes.
Claim 6
6. A transmission
controller as claimed in
claim 5, wherein the set
of overlay codes are
derived from RW codes,
each set of ‘n’ overlay
codes comprising an n×n
matrix of RW codes.
Claim 7
7. A central terminal of a
wireless
telecommunications
system, comprising:
24
Defendants’ Proposed
Construction
Court’s Construction
’819 Patent Claim
Element
a transmission controller
having:
Disputed Term
Plaintiff’s Proposed
Construction
an orthogonal code
generator for providing
an orthogonal code
from a set of ‘m’
orthogonal codes used
to create ‘m’ orthogonal
channels within the
single frequency
channel, wherein ‘m’ is a
positive integer;
a first encoder for
combining a data item to
be transmitted on the
single frequency channel
with said orthogonal
code from the
orthogonal code
generator, the
orthogonal code
determining the
orthogonal channel
over which the data item
is transmitted, whereby
data items pertaining to
different wireless links
may be transmitted
simultaneously within
different orthogonal
25
Defendants’ Proposed
Construction
Court’s Construction
’819 Patent Claim
Element
channels of said single
frequency channel;
Disputed Term
Plaintiff’s Proposed
Construction
an overlay code
generator for providing
an overlay code from a
first set of ‘n’ overlay
codes which are
orthogonal to each other,
wherein ‘n’ is a positive
integer;
a second encoder
arranged to apply the
overlay code from the
overlay code generator
to said data item,
whereby ‘n’ data items
pertaining to different
wireless links may be
transmitted
simultaneously within
the same orthogonal
channel, wherein the
overlay code generator
is arranged to provide
overlay codes from one
or more further sets of
overlay codes having
different numbers of
overlay codes to said
first set of overlay
26
Defendants’ Proposed
Construction
Court’s Construction
’819 Patent Claim
Element
codes, wherein the
orthogonal code
generator is a storage
arranged to store the set
of orthogonal codes,
wherein the overlay
code generator is a
storage arranged to store
the set of overlay codes,
wherein the set of
orthogonal codes
comprise a set of
Rademacher-Walsh
(RW) codes, and wherein
the set of overlay codes
are derived from RW
codes, each set of ‘n’
overlay codes
comprising an n×n
matrix of RW codes.
Disputed Term
Plaintiff’s Proposed
Construction
Claim 8
8. A central terminal as
claimed in claim 7,
wherein a first of the
orthogonal channels is
reserved for the
transmission of signals
relating to the acquisition
of wireless links, and the
transmission controller is
provided in the central
27
Defendants’ Proposed
Construction
Court’s Construction
’819 Patent Claim
Element
terminal to enable
overlay codes to be
applied to data items to
be sent within said first
orthogonal channel
from the central terminal
to one of said subscriber
terminals.
Disputed Term
Plaintiff’s Proposed
Construction
Defendants’ Proposed
Construction
Claim 9
9. A central terminal as
claimed in claim 8,
wherein a second of the
orthogonal channels is
reserved for the
transmission of signals
relating to the control of
calls, and the
transmission controller is
provided in the central
terminal to enable
overlay codes to be
applied to data items to
be sent within said
second orthogonal
channel from the central
terminal to one of said
subscriber terminals.
Claim 10
10. A central terminal as
claimed in claim 7,
channelisation means for Function: determining
determining which of the which of the orthogonal
28
Indefinite under 35
U.S.C. § 112
Court’s Construction
’819 Patent Claim
Element
further comprising
channelisation means
for determining which
of the orthogonal
channels will be subject
to overlay codes, and
for transmitting that
information to a
plurality of subscriber
terminals within the
wireless
telecommunications
system.
Disputed Term
Plaintiff’s Proposed
Construction
orthogonal channels will channels will be subject
be subject to overlay
to overlay codes, and
codes, and for
transmitting that
transmitting that
information to a plurality
information to a plurality of subscriber terminals
of subscriber terminals
within the wireless
within the wireless
telecommunications
telecommunications
system
system
Corresponding
Structure: modem shelf
including a demand
assignment engine
connected to a network
and one or more
modems, the demand
assignment engine
determining which of the
orthogonal channels will
be subject to overlay
codes based on
information regarding
the capability of
subscriber terminals to
support overlay codes
and/or the type of data
items to be transmitted,
and equivalents thereof
Corresponding Structure
(alternate construction):
29
Defendants’ Proposed
Construction
Court’s Construction
’819 Patent Claim
Element
Disputed Term
Plaintiff’s Proposed
Construction
modem shelf including a
demand assignment
engine connected to a
network and one or more
modems, the demand
assignment engine
determining which of the
orthogonal channels will
be subject to overlay
codes using the
algorithm: (1) consider
whether the subscriber
terminal to which data
will be transmitted
incorporates the features
necessary to support
overlay codes; (2)
consider the type of data
that is to be transmitted
in an orthogonal channel;
and (3) if the subscriber
terminal supports
overlay codes and the
data type is one for
which overlay codes
should be applied, then
apply overlay codes
(otherwise do not), and
equivalents thereof
Claim 11
11. A central terminal as
30
Defendants’ Proposed
Construction
Court’s Construction
’819 Patent Claim
Element
claimed in claim 7,
wherein a number of said
orthogonal channels are
designated as traffic
channels for the
transmission of data
items relating to
communication content,
said central terminal
further comprising:
a TDM encoder
arranged to apply time
division multiplexing
(TDM) techniques to
data items to be sent over
a traffic channel from
said central terminal to
said subscriber
terminal, so as to enable
a plurality of data items
pertaining to different
wireless links to be sent
within one orthogonal
traffic channel during a
predetermined frame
period.
Disputed Term
TDM encoder
Plaintiff’s Proposed
Construction
“hardware and/or
software for applying
TDM techniques”
Defendants’ Proposed
Construction
“a device that applies
time division
(Appears in ’326 Patent
multiplexing (TDM)
cls. 1, 2, 5, 8–11; ’819
techniques to share a
Patent cl. 11; ’327 Patent
communication channel
cl. 15.)
among multiple wireless
links”
time division
“techniques for
“methods in which a
multiplexing (TDM)
allocating an interval of communication channel
techniques
time within a
is shared among multiple
predetermined frame
wireless links by
(Appears in ’326 Patent period to a data item,
allowing each to use the
cls. 1, 5–8, 11, 12, 14,
based on one or more
channel for a given
15; ’211 Patent cls. 8–10; characteristics associated period of time in a
’819 Patent cl. 11; ’327
with the data item”
defined, repeated
Patent cl. 15.)
sequence”
Claim 12
12. A reception
controller for processing
data items received over
31
Court’s Construction
’819 Patent Claim
Element
a wireless link
connecting a central
terminal and a
subscriber terminal of a
wireless
telecommunications
system, a single
frequency channel being
employed for
transmitting data items
pertaining to a plurality
of wireless links, the
receiver controller
comprising:
Disputed Term
Plaintiff’s Proposed
Construction
an orthogonal code
generator for providing
an orthogonal code
from a set of ‘m’
orthogonal codes used
to create ‘m’ orthogonal
channels within the
single frequency
channel, wherein ‘m’ is a
positive integer;
a first encoder for
applying, to signals
received on the single
frequency channel, the
orthogonal code
provided by the
32
Defendants’ Proposed
Construction
Court’s Construction
’819 Patent Claim
Element
orthogonal code
generator, in order to
isolate data items
transmitted within the
corresponding
orthogonal code;
Disputed Term
Plaintiff’s Proposed
Construction
an overlay code
generator for providing
an overlay code from a
first set of ‘n’ overlay
codes which are
orthogonal to each other,
the set of ‘n’ overlay
codes enabling ‘n’ data
items pertaining to
different wireless links
to be transmitted
simultaneously within
the same orthogonal
channel, wherein ‘n’ is a
positive integer; and
a second encoder for
applying, to the data
items of the orthogonal
channel, the overlay
code from the overlay
code generator so as to
isolate a particular data
item transmitted using
that overlay code.
33
Defendants’ Proposed
Construction
Court’s Construction
’819 Patent Claim
Element
Claim 13
13. A reception
controller as claimed in
claim 12, wherein the
overlay code generator
is arranged to provide
overlay codes from one
or more further sets of
overlay codes having
different numbers of
overlay codes to said
first set of overlay
codes.
Disputed Term
Plaintiff’s Proposed
Construction
Claim 14
14. A reception
controller as claimed in
claim 12, wherein the
orthogonal code
generator is a storage
arranged to store the set
of orthogonal codes.
Claim 15
15. A reception
controller as claimed in
claim 12, wherein the
overlay code generator
is a storage arranged to
store the set of overlay
codes.
Claim 16
34
Defendants’ Proposed
Construction
Court’s Construction
’819 Patent Claim
Element
16. A reception
controller as claimed in
claim 12, wherein the set
of orthogonal codes
comprise a set of
Rademacher-Walsh
(RW) codes.
Disputed Term
Plaintiff’s Proposed
Construction
Claim 17
17. A controller as
claimed in claim 12,
wherein the set of
overlay codes are
derived from RW codes,
each set of ‘n’ overlay
codes comprising an n×n
matrix of RW codes.
Claim 21
21. A subscriber
terminal of a wireless
telecommunications
system, comprising:
a transmission controller
having:
an orthogonal code
generator for providing
an orthogonal code
from a set of ‘m’
orthogonal codes used
to create ‘m’ orthogonal
35
Defendants’ Proposed
Construction
Court’s Construction
’819 Patent Claim
Element
channels within the
single frequency
channel, wherein ‘m’ is a
positive integer;
Disputed Term
Plaintiff’s Proposed
Construction
a first encoder for
combining a data item to
be transmitted on the
single frequency channel
with said orthogonal
code from the
orthogonal code
generator, the
orthogonal code
determining the
orthogonal channel
over which the data item
is transmitted, whereby
data items pertaining to
different wireless links
may be transmitted
simultaneously within
different orthogonal
channels of said single
frequency channel;
an overlay code
generator for providing
an overlay code from a
first set of ‘n’ overlay
codes which are
orthogonal to each other,
36
Defendants’ Proposed
Construction
Court’s Construction
’819 Patent Claim
Element
wherein ‘m’ is a positive
integer;
Disputed Term
Plaintiff’s Proposed
Construction
a second encoder
arranged to apply the
overlay code from the
overlay code generator
to said data item,
whereby ‘n’ data items
pertaining to different
wireless links may be
transmitted
simultaneously within
the same orthogonal
channel, wherein the
overlay code generator
is arranged to provide
overlay codes from one
or more further sets of
overlay codes having
different numbers of
overlay codes to said
first set of overlay
codes, wherein the
orthogonal code
generator is a storage
arranged to store the set
of orthogonal codes,
wherein the set of
orthogonal codes
comprise a set of
Rademacher-Walsh
37
Defendants’ Proposed
Construction
Court’s Construction
’819 Patent Claim
Element
(RW) codes, and wherein
the set of overlay codes
are derived from RW
codes, each set of ‘n’
overlay codes
comprising an n×n
matrix of RW codes; the
transmission controller
operable to enable
overlay codes to be
applied to data items sent
from the subscriber
terminals to the central
terminal.
Disputed Term
Plaintiff’s Proposed
Construction
Claim 22
22. A subscriber
terminal of a wireless
telecommunications
system, comprising:
a reception controller
having:
an orthogonal code
generator for providing
an orthogonal code
from a set of ‘m’
orthogonal codes used
to create ‘m’ orthogonal
channels within the
single frequency
channel, wherein ‘m’ is a
38
Defendants’ Proposed
Construction
Court’s Construction
’819 Patent Claim
Element
positive integer;
Disputed Term
Plaintiff’s Proposed
Construction
a first decoder for
applying, to signals
received on the single
frequency channel, the
orthogonal code
provided by the
orthogonal code
generator, in order to
isolate data items
transmitted within the
corresponding
orthogonal channel;
an overlay code
generator for providing
an overlay code from a
first set of ‘n’ overlay
codes which are
orthogonal to each other,
the set of ‘n’ overlay
codes enabling ‘n’ data
items pertaining to
different wireless links
to be transmitted
simultaneously within
the same orthogonal
channel, wherein ‘n’ is a
positive integer;
a second decoder for
applying, to the data
39
Defendants’ Proposed
Construction
Court’s Construction
’819 Patent Claim
Element
items of the orthogonal
channel, the overlay
code from the overlay
code generator so as to
isolate a particular data
item transmitted using
that overlay code,
wherein the overlay
code generator is
arranged to provide
overlay codes from one
or more further sets of
overlay codes having
different numbers of
overlay codes to said
first set of overlay
codes, wherein the
orthogonal code
generator is a storage
arranged to store the set
of orthogonal codes,
wherein the overlay
code generator is a
storage arranged to store
the set of overlay codes,
wherein the set of
orthogonal codes
comprise a set of
Rademacher-Walsh
(RW) codes, and wherein
the set of overlay codes
Disputed Term
Plaintiff’s Proposed
Construction
40
Defendants’ Proposed
Construction
Court’s Construction
’819 Patent Claim
Element
are derived from RW
codes, each set of ‘n’
overlay codes
comprising an n×n
matrix of RW codes.
Disputed Term
Plaintiff’s Proposed
Construction
Defendants’ Proposed
Construction
Court’s Construction
Disputed Term
Plaintiff’s Proposed
Construction
Defendants’ Proposed
Construction
Court’s Construction
U.S. Patent No. 6,195,327
’327 Patent Claim
Element
Claim 1
1. An interference
controller for limiting in
one cell the effect of
interference generated by
other cells of a wireless
telecommunications
system, each cell of the
wireless
telecommunications
system having a central
terminal and a plurality
of subscriber terminals,
communication between
a central terminal and a
subscriber terminal
being arranged to occur
over a wireless link, a
plurality of code division
multiplexed channels
wireless link
[AGREED]
(Appears in ’326 Patent
cls. 1, 2, 5, 9, 11–13;
’211 Patent cls. 1, 2, 5–7;
’819 Patent cls. 1, 7, 8,
11, 12, 18, 21–25, 29;
’327 Patent 1, 11–22.)
subscriber terminal
“user equipment”
(Appears in ’326 Patent
cls. 1, 6, 8–12, 14; ’211
Patent cls. 1, 5, 6, 8, 9;
’819 Patent cls. 1, 8–12,
19, 21–25, 27, 29, 31;
’327 Patent cls. 1, 11,
13–22.)
41
[AGREED]
“a fixed-location device”
“a radio connection
between a central
terminal and a particular
subscriber terminal for
communicating data
items therebetween”
’327 Patent Claim
Element
being provided within a
single frequency channel
to enable data items
pertaining to a plurality
of wireless links to be
transmitted
simultaneously within
different code division
multiplexed channels of
said single frequency
channel, the interference
controller comprising:
Disputed Term
Plaintiff’s Proposed
Construction
a channel controller
arranged to allocate a
number of said plurality
of code division
multiplexed channels as
a channel pool of code
division multiplexed
channels available for
the establishment of said
wireless links;
channel pool
Plain and ordinary
meaning
an analyzer for receiving
parameters pertaining
to a wireless link within
the cell indicative of
whether that wireless
link is subject to
interference from
signals generated by
parameters pertaining to Plain and ordinary
a wireless link within the meaning
cell indicative of whether
that wireless link is
subject to interference
from signals generated
by said other cells
(Appears in ’327 Patent
cls. 1–7, 11, 21–27.)
42
Defendants’ Proposed
Construction
“the set of orthogonal
channels available to a
central terminal to use to
establish wireless links”
“two or more indicators
that an individual
wireless link is
experiencing
interference from other
cells”
Court’s Construction
’327 Patent Claim
Element
said other cells, the
analyzer being arranged
to compare those
parameters with
predetermined criteria
and to generate an output
signal dependent on the
comparison;
Disputed Term
Plaintiff’s Proposed
Construction
(Appears in ’327 Patent
cls. 1, 11, 21, 22.
Appears in short form in
’327 Patent cls. 5, 27.)
a channel controller
being responsive to the
output signal from the
analyser, to selectively
reduce the number of
code division
multiplexed channels in
the channel pool in
order to reduce the effect
of the interference from
said other cells.
Claim 2
2. An interference
controller as claimed in
claim 1, wherein a
parameter provided to
the analyser is the bit
error rate (BER) for
signals transmitted
within said code division
multiplexed channels,
and the predetermined
43
Defendants’ Proposed
Construction
Court’s Construction
’327 Patent Claim
Element
criteria with which the
analyser compares said
BER is a threshold BER
value identifying a
predetermined maximum
acceptable BER, the
channel controller being
responsive to the
analyser indicating that
the BER exceeds the
predetermined maximum
acceptable BER to
remove a code division
multiplexed channel
from the channel pool.
Claim 5
5. An interference
controller as claimed in
claim 1, wherein a
plurality of the code
division multiplexed
channels are designated
as traffic channels, the
analyser is arranged to
monitor the parameters
relating to interference
on those traffic channels,
and the channel
controller is arranged to
selectively designate
one or more of said
Disputed Term
Plaintiff’s Proposed
Construction
selectively designate one [AGREED]
or more of said traffic
channels as locked
channels
(Appears in ’327 Patent
cls. 5, 21.)
44
Defendants’ Proposed
Construction
[AGREED]
Court’s Construction
“make one or more data
channels unavailable for
transmission”
’327 Patent Claim
Element
traffic channels as
locked channels which
should not be included in
the channel pool so as to
reduce the effect of the
interference from said
other cells.
Disputed Term
Plaintiff’s Proposed
Construction
Claim 6
6. An interference
controller as claimed in
claim 5, wherein if the
analyser determines that
a BER signal is below a
predetermined minimum
BER value, the channel
controller is arranged to
designate one of said
locked channels as a free
traffic channel and to
include that traffic
channel in the channel
pool so that it can
subsequently be used for
data traffic.
Claim 8
8. An interference
controller as claimed in
claim 5, wherein the
channel controller is
provided with a value
45
Defendants’ Proposed
Construction
Court’s Construction
’327 Patent Claim
Element
indicating a maximum
number of code division
multiplexed channels
that can be designated as
traffic channels, the
channel controller only
adding code division
multiplexed channels
upon request from the
analyser if doing so
would not exceed the
maximum number of
code division
multiplexed channels.
Claim 10
10. An interference
controller as claimed in
claim 1, wherein said
code division
multiplexed channels are
orthogonal channels, a
set of orthogonal codes
being used to create said
orthogonal channels.
Disputed Term
orthogonal
channel(s)channels
(Appears in ’326 Patent
cls. 1, 2, 5–15; ’211
Patent cls. 1, 2, 5–10;
’819 Patent cls. 1, 7–12,
18–25, 27–29, 31, 32;
’327 Patent cls. 10,
13–16)
Plaintiff’s Proposed
Construction
Wi-LAN proposes
construing “orthogonal
channels” (plural) and
“orthogonal channel”
(singular) separately, as
follows:
orthogonal channels: “a
set of channels created
using orthogonal codes
that cross-correlate to
zero with respect to each
other”
orthogonal channel:
“one of the set of
46
Defendants’ Proposed
Construction
Court’s Construction
orthogonal channel: “a
“a set of channels created
communication channel using the orthogonal
defined by an orthogonal codes”
code”[AGREED]
’327 Patent Claim
Element
Disputed Term
orthogonal codes
Plaintiff’s Proposed
Construction
orthogonal
channels”[AGREED]
[AGREED]
(Appears in ’326 Patent
cls. 1, 3–5, 11, 12; ’211
Patent cls. 1, 3–6; ’819
Patent cls. 1, 3, 5, 7, 12,
14, 16, 18, 21–25, 29;
’327 Patent cls. 10,
12–16)
Claim 11
11. A central terminal for
a cell of a wireless
telecommunications
system, the
telecommunications
system having a plurality
of cells, and each cell
having a central terminal
and a plurality of
subscriber terminals,
communication between
the central terminal and a
subscriber terminal in
said cell being arranged
to occur over a wireless
link, a plurality of code
division multiplexed
channels being provided
within a single frequency
47
Defendants’ Proposed
Construction
[AGREED]
Court’s Construction
“codes that
cross-correlate to zero
with respect to each
other”
’327 Patent Claim
Element
channel to enable data
items pertaining to a
plurality of wireless
links to be transmitted
simultaneously within
different code division
multiplexed channels of
said single frequency
channel, the central
terminal comprising an
interference controller
for limiting the effect of
interference generated by
other cells of said
wireless
telecommunications
system, the interference
controller having;
Disputed Term
Plaintiff’s Proposed
Construction
a channel controller
arranged to allocate a
number of said plurality
of code division
multiplexed channels as
a channel pool of code
division multiplexed
channels available for
the establishment of said
wireless links;
an analyzer for receiving
parameters pertaining
48
Defendants’ Proposed
Construction
Court’s Construction
’327 Patent Claim
Element
to a wireless link within
the cell indicative of
whether that wireless
link is subject to
interference from
signals generated by
said other cells, the
analyzer being arranged
to compare those
parameters with
predetermined criteria
and to generate an output
signal dependent on the
comparison,
Disputed Term
Plaintiff’s Proposed
Construction
a channel controller
being responsive to the
output signal from the
analyser, to selectively
reduce the number of
code division
multiplexed channels in
the channel pool in
order to reduce the effect
of the interference from
said other cells.
Claim 12
12. A central terminal as
claimed in claim 11,
further comprising:
an orthogonal code
49
Defendants’ Proposed
Construction
Court’s Construction
’327 Patent Claim
Element
generator for providing
an orthogonal code
from a set of orthogonal
codes used to create said
code division
multiplexed channels
within the single
frequency channel;
Disputed Term
Plaintiff’s Proposed
Construction
a first encoder for
combining a data item to
be transmitted on the
single frequency channel
with said orthogonal
code from the
orthogonal code
generator, the
orthogonal code
determining the code
division multiplexed
channel over which the
data item is transmitted,
thereby enabling data
items pertaining to
different wireless links
to be transmitted
simultaneously within
different code division
multiplexed channels of
said single frequency
channel.
50
Defendants’ Proposed
Construction
Court’s Construction
’327 Patent Claim
Element
Claim 13
13. An interference
controller as claimed in
claim 1, further
comprising a
transmission controller
for processing data items
to be transmitted over a
wireless link connecting
a central terminal and a
subscriber terminal of a
wireless
telecommunications
system, a single
frequency channel being
employed for
transmitting data items
pertaining to a plurality
of wireless links, the
transmission controller
comprising:
Disputed Term
Plaintiff’s Proposed
Construction
an orthogonal code
generator for providing
an orthogonal code
from a set of ‘m’
orthogonal codes used
to create ‘m’ orthogonal
channels within the
single frequency
channel;
51
Defendants’ Proposed
Construction
Court’s Construction
’327 Patent Claim
Element
a first encoder for
combining a data item to
be transmitted on the
single frequency channel
with said orthogonal
code from the
orthogonal code
generator, the
orthogonal code
determining the
orthogonal channel
over which the data item
is transmitted, whereby
data items pertaining to
different wireless links
may be transmitted
simultaneously within
different orthogonal
channels of said single
frequency channel;
an overlay code
generator for providing
an overlay code from a
first set of ‘n’ overlay
codes which are
orthogonal to each other;
and
Disputed Term
Plaintiff’s Proposed
Construction
overlay code
Defendants’ Proposed
Construction
“orthogonal codes used
“a second code applied in
to increase the number of series with the
(Appears in ’326 Patent orthogonal channels that orthogonal code”
cls. 2, 5, 9–11, 13; ’211
would otherwise be
Patent cls. 2, 5, 7, 8; ’819 available”
Patent cls. 1, 2, 4, 6–10,
12, 13, 15, 17–32; ’327
Patent cls. 13, 14)
a second encoder
arranged to apply the
overlay code from the
52
Court’s Construction
’327 Patent Claim
Element
overlay code generator
to said data item,
whereby ‘n’ data items
pertaining to different
wireless links may be
transmitted
simultaneously within
the same orthogonal
channel.
Claim 15
15. An interference
controller as claimed in
claim 1, further
comprising a
transmission controller
for processing data items
to be transmitted over a
wireless link connecting
a central terminal and a
subscriber terminal of a
wireless
telecommunications
system, a single
frequency channel being
employed for
transmitting data items
pertaining to a plurality
of wireless links, the
transmission controller
comprising:
an orthogonal code
Disputed Term
Plaintiff’s Proposed
Construction
53
Defendants’ Proposed
Construction
Court’s Construction
’327 Patent Claim
Disputed Term
Element
generator for providing
an orthogonal code
from a set of ‘m’
orthogonal codes used
to create ‘m’ orthogonal
channels within the
single frequency
channel;
a first encoder for
combining a data item to
be transmitted on the
single frequency channel
with said orthogonal
code from the
orthogonal code
generator, the
orthogonal code
determining the
orthogonal channel
over which the data item
is transmitted, whereby
data items pertaining to
different wireless links
may be transmitted
simultaneously within
different orthogonal
channels of said single
frequency channel; and
a TDM encoder
TDM encoder
arranged to apply time
(Appears in ’326 Patent
division multiplexing
Plaintiff’s Proposed
Construction
“hardware and/or
software for applying
TDM techniques”
54
Defendants’ Proposed
Construction
“a device that applies
time division
multiplexing (TDM)
Court’s Construction
’327 Patent Claim
Element
(TDM) techniques to
the data item in order to
insert the data item
within a time slot of the
orthogonal channel,
whereby a plurality of
data items relating to
different wireless links
may be transmitted
within the same
orthogonal channel
during a predetermined
frame period.
Disputed Term
Plaintiff’s Proposed
Construction
Defendants’ Proposed
Construction
cls. 1, 2, 5, 8–11; ’819
techniques to share a
Patent cl. 11; ’327 Patent
communication channel
cl. 15)
among multiple wireless
links”
time division
“techniques for
“methods in which a
multiplexing (TDM)
allocating an interval of communication channel
techniques
time within a
is shared among multiple
predetermined frame
wireless links by
(Appears in ’326 Patent period to a data item,
allowing each to use the
cls. 1, 5–8, 11, 12, 14,
based on one or more
channel for a given
15; ’211 Patent cls. 8–10; characteristics associated period of time in a
’819 Patent cl. 11; ’327
with the data item”
defined, repeated
Patent cl. 15)
sequence”
time slot
“an interval of time”
“a period of time during
which a single wireless
(Appears in ’326 Patent
link is permitted to use a
cls. 1, 5, 7, 11, 12, 15;
shared communication
’211 Patent cls. 1, 5, 6,
channel”
10; ’327 Patent cls. 15,
16)
Claim 17
17. An interference
controller as claimed in
claim 13, further
comprising a channel
selection controller for
establishing a wireless
link connecting a central
terminal and a
subscriber terminal of a
wireless
55
Court’s Construction
’327 Patent Claim
Element
telecommunications
system, at least two
frequency channels
being provided over
which said wireless link
could be established, the
channel controller
comprising:
a storage for storing data
identifying the at least
two frequency channels;
a selector for selecting a
frequency channel from
those listed in said
storage;
link acquisition logic for
establishing a wireless
link on the frequency
channel selected by the
selector;
the selector being
responsive to the link
acquisition logic being
unable to establish said
wireless link, to select
an alternative frequency
channel from those listed
in said storage.
Claim 19
19. An interference
controller as claimed in
Disputed Term
Plaintiff’s Proposed
Construction
56
Defendants’ Proposed
Construction
Court’s Construction
’327 Patent Claim
Element
claim 15, further
comprising a channel
selection controller for
establishing a wireless
link connecting a central
terminal and a
subscriber terminal of a
wireless
telecommunications
system, at least two
frequency channels
being provided over
which said wireless link
could be established, the
channel controller
comprising:
a storage for storing data
identifying the at least
two frequency channels;
a selector for selecting a
frequency channel from
those listed in said
storage;
link acquisition logic for
establishing a wireless
link on the frequency
channel selected by the
selector;
the selector being
responsive to the link
acquisition logic being
Disputed Term
Plaintiff’s Proposed
Construction
57
Defendants’ Proposed
Construction
Court’s Construction
’327 Patent Claim
Element
unable to establish said
wireless link, to select
an alternative frequency
channel from those listed
in said storage.
Disputed Term
Plaintiff’s Proposed
Construction
US 1362585v.1
58
Defendants’ Proposed
Construction
Court’s Construction
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