EXHIBIT 4

Case 6:20-cv-00541-ADA Document 46-4 Filed 03/05/21 Page 1 of 31
IN THE UNITED STATES DISTRICT COURT

FOR THE WESTERN DISTRICT OF TEXAS

WACO DIVISION

WSOU INVESTMENTS, LLC d/b/a §

BRAZOS LICENSING AND §

DEVELOPMENT, §

§

Plaintiff, §

§

v. § NO. 6:20-CV-533-ADA

§ 

HUAWEI TECHNOLOGIES CO. LTD., §

ET AL. § 

§

Defendants. §

_________________________________________________________________

WSOU INVESTMENTS, LLC d/b/a §

BRAZOS LICENSING AND §

DEVELOPMENT, §

§

Plaintiff, §

§

v. § NO. 6:20-CV-534-ADA

§ 

HUAWEI TECHNOLOGIES CO. LTD., §

ET AL. § 

§

Defendants. §

_________________________________________________________________

WSOU INVESTMENTS, LLC d/b/a §

BRAZOS LICENSING AND §

DEVELOPMENT, §

§

Plaintiff, §

§

v. § NO. 6:20-CV-535-ADA

§ 

HUAWEI TECHNOLOGIES CO. LTD., §

ET AL. § 

§

Defendants. §

_________________________________________________________________

Case 6:20-cv-00541-ADA Document 46-4 Filed 03/05/21 Page 2 of 31
WSOU INVESTMENTS, LLC d/b/a §

BRAZOS LICENSING AND §

DEVELOPMENT, §

§

Plaintiff, §

§

v. § NO. 6:20-CV-536-ADA

§ 

HUAWEI TECHNOLOGIES CO. LTD., §

ET AL. § 

§

Defendants. §

_________________________________________________________________

WSOU INVESTMENTS, LLC d/b/a §

BRAZOS LICENSING AND §

DEVELOPMENT, §

§

Plaintiff, §

§

v. § NO. 6:20-CV-537-ADA

§ 

HUAWEI TECHNOLOGIES CO. LTD., §

ET AL. § 

§

Defendants. §

_________________________________________________________________

WSOU INVESTMENTS, LLC d/b/a §

BRAZOS LICENSING AND §

DEVELOPMENT, §

§

Plaintiff, §

§

v. § NO. 6:20-CV-538-ADA

§ 

HUAWEI TECHNOLOGIES CO. LTD., §

ET AL. § 

§

Defendants. §

_________________________________________________________________

Case 6:20-cv-00541-ADA Document 46-4 Filed 03/05/21 Page 3 of 31
WSOU INVESTMENTS, LLC d/b/a §

BRAZOS LICENSING AND §

DEVELOPMENT, §

§

Plaintiff, §

§

v. § NO. 6:20-CV-539-ADA

§ 

HUAWEI TECHNOLOGIES CO. LTD., §

ET AL. § 

§

Defendants. §

_________________________________________________________________

WSOU INVESTMENTS, LLC d/b/a §

BRAZOS LICENSING AND §

DEVELOPMENT, §

§

Plaintiff, §

§

v. § NO. 6:20-CV-540-ADA

§ 

HUAWEI TECHNOLOGIES CO. LTD., §

ET AL. § 

§

Defendants. §

_________________________________________________________________

WSOU INVESTMENTS, LLC d/b/a §

BRAZOS LICENSING AND §

DEVELOPMENT, §

§

Plaintiff, §

§

v. § NO. 6:20-CV-541-ADA

§ 

HUAWEI TECHNOLOGIES CO. LTD., §

ET AL. § 

§

Defendants. §

_________________________________________________________________

Case 6:20-cv-00541-ADA Document 46-4 Filed 03/05/21 Page 4 of 31
WSOU INVESTMENTS, LLC d/b/a §

BRAZOS LICENSING AND §

DEVELOPMENT, §

§

Plaintiff, §

§

v. § NO. 6:20-CV-542-ADA

§ 

HUAWEI TECHNOLOGIES CO. LTD., §

ET AL. § 

§

Defendants. §

_________________________________________________________________

WSOU INVESTMENTS, LLC d/b/a §

BRAZOS LICENSING AND §

DEVELOPMENT, §

§

Plaintiff, §

§

v. § NO. 6:20-CV-543-ADA

§ 

HUAWEI INVESTMENT & HOLDING §

CO., LTD., §

§

Defendants. §

§

_________________________________________________________________

WSOU INVESTMENTS, LLC d/b/a §

BRAZOS LICENSING AND §

DEVELOPMENT, §

§

Plaintiff, §

§

v. § NO. 6:20-CV-544-ADA

§ 

HUAWEI INVESTMENT & HOLDING §

CO., LTD., §

§

Defendants. §

_________________________________________________________________

HUAWEI’S PRELIMINARY CLAIM CONSTRUCTIONS

Pursuant to the Scheduling Order, Defendants (collectively “Huawei” or “Defendants”) 

hereby provide the following preliminary claim constructions for those terms from the asserted 

Case 6:20-cv-00541-ADA Document 46-4 Filed 03/05/21 Page 5 of 31
claims of U.S. Patent Nos. 6,882,627 (“the ’627 Patent”), 7,095,713 (“the ’713 Patent”), 7,508,755 

(“the ’755 Patent”), 7,515,546 (“the ’546 Patent”), 7,860,512 (“the ’512 Patent”), 7,872,973 (“the 

’973 Patent”), 8,200,224 (“the ’224 Patent”), 8,417,112 (“the ’112 Patent”), 9,084,199 (“the ’199 

Patent”), 8,249,446 (“the ’446 Patent”), 6,999,727 (“the ’727 Patent”), and 8,429,480 (“the ’480 

Patent”) that the parties have collectively identified as requiring construction or that are indefinite. 

Huawei reserves the right to update, supplement, revise, or otherwise modify the proposed 

constructions in light of further investigation and discovery, including evidence not yet produced 

by Plaintiff, or in light of modification or supplementation of Plaintiff’s infringement contentions.

Case 6:20-cv-00541-ADA Document 46-4 Filed 03/05/21 Page 6 of 31
U.S. Patent No. 6,882,627 (-533 Case)

Claim Claim Term Proposed Construction

1 29, 

30

“performing a SRG (shared risk group) 

topology transformation of the network 

topology into a virtual topology that 

discourages the use of network resources”

“performing a transformation of links and/or nodes of a 

SRG (shared risk group) of the network into a virtual 

topology that discourages the use of network resources”

29

30

“second code means adapted to, for at least 

one shared risk group, determine if any of the 

at least one shared risk group includes any of 

the first sequence of network resources”

“means adapted to, for at least one shared risk 

group, determine if any of the at least one 

shared risk group includes any of the first 

sequence of network resources”

Subject to 35 U.S.C. § 112, ¶6

Indefinite for failure to disclose sufficient structure

29

30

“third code means for performing a SRG 

(shared risk group) topology transformation 

of the network topology into a virtual 

topology which discourages the use of 

network resources”

“means for performing a SRG (shared risk 

group) topology transformation of the 

network topology into a virtual topology 

which discourages the use of network 

resources”

Subject to 35 U.S.C. § 112, ¶6

Function: performing a SRG (shard risk group) topology 

transformation of the network topology into a virtual 

topology which discourages the use of network resources

Structure: Algorithms for link and node transformations 

such as those described in Figures 3C, 3D, 4A, and 4B, 

and equivalents thereof.

Case 6:20-cv-00541-ADA Document 46-4 Filed 03/05/21 Page 7 of 31
Claim Claim Term Proposed Construction

1, 29, 

30

“determining if any of the at least one shared 

risk group includes any of the first sequence 

of network resources”

“determining if each shared risk group includes any of 

the first sequence of network resources”

4 “transforming the node requiring 

transformation into two interconnected 

nodes”

“splitting the node requiring transformation into two 

interconnected nodes”

4 “transforming any bi-directional link into the 

node requiring transformation into a first 

unidirectional link into one of the two 

interconnected nodes, and a second 

unidirectional link out of the other of the two 

interconnected nodes”

“splitting any bi-directional link into the node requiring 

transformation into a first unidirectional link into one of 

the two interconnected nodes, and a second 

unidirectional link out of the other of the two 

interconnected nodes”

29 “A processing platform-readable medium 

having code means stored thereon for 

instructing a processing platform to select 

multiple paths through a network represented 

by a network topology representing an 

interconnected set of network resources”

Subject to 35 U.S.C. § 112, ¶6

Function: instructing a processing platform to select 

multiple paths through a network

Structure: a multi-path routing algorithm (e.g., Figure 2 

steps 2-2 to 2-5), and equivalents thereof

Case 6:20-cv-00541-ADA Document 46-4 Filed 03/05/21 Page 8 of 31
Claim Claim Term Proposed Construction

30 “means for maintaining or obtaining network 

topology information”

Subject to 35 U.S.C. § 112, ¶6

Function: maintaining or obtaining network topology 

information

Structure: nodes and known routing protocols such as 

OSPF (open shortest path first) or BGP (border gateway 

protocol), and equivalents thereof

29

30

“first code means for identifying a first path 

through the network topology, the first path 

comprising a first sequence of network 

resources”

“means for identifying a first path through the 

network topology, the first path comprising a 

first sequence of network resources”

Subject to 35 U.S.C. § 112, ¶6 

Function: identifying a first path through the network 

topology

Structure: a known routing algorithm such as multiple 

constraint routing (MCR), best path in network, or 

minimum hop, and equivalents thereof

29

30

“fourth code means adapted to identify a 

second path through the virtual topology from 

the source node to the destination node”

“means adapted to identify a second path 

through the virtual topology from the source 

node to the destination node”

Subject to 35 U.S.C. § 112, ¶6

Function: identify a second path through the virtual 

topology from the source node to the destination node

Structure: known routing algorithms such as multiple 

constraint routing (MCR), best path in network, or 

minimum hop, and equivalents thereof

Case 6:20-cv-00541-ADA Document 46-4 Filed 03/05/21 Page 9 of 31
9

U.S. Patent No. 7,095,713 (-534 Case)

Claim Claim Term Proposed Construction

5 switch data having a destination address 

associated with a logical port associated with 

the second fabric access device to a link 

associated with the first fabric access device

No construction necessary

5 destination address No construction necessary

1, 3, 5 third system interface No construction necessary

1, 5 third system interface configured to receive 

data from and send data to a second external 

system

No construction necessary

6 include with the data a port address associated 

with the second fabric access device

No construction necessary

Case 6:20-cv-00541-ADA Document 46-4 Filed 03/05/21 Page 10 of 31
10

U.S. Patent No. 7,508,755 (-535 Case)

Claim Claim Term Proposed Construction

1, 3 “originating network device” “a network device of a primary LSP which is not a 

source network device of the same primary LSP”

8, 23, 

25

“means for re-routing traffic traveling along 

the bi-directional LSP in the backwards 

direction to the alternate path in the 

backwards direction based on the switch over 

message.”

Subject to 35 U.S.C. § 112, ¶6

Indefinite for failure to disclose sufficient structure.

1, 5, 8, 

10, 13, 

16, 18, 

23, 25

“switch over message” “a message which instructs a device to perform a switch 

over to the alternate path and which is not a message that 

indicates a fault has occurred in the network”

1, 5, 7, 

8, 10,

12, 13, 

23

“merging network device” No construction required

Case 6:20-cv-00541-ADA Document 46-4 Filed 03/05/21 Page 11 of 31
11

Claim Claim Term Proposed Construction

1, 4, 5, 

8, 10, 

13, 15, 

16, 18, 

22, 23, 

25

“bi-directional LSP” “a primary LSP with both a forward and a backward LSP 

(label switched path.)”

1, 5, 8, 

10, 13, 

16, 18, 

23, 25

“alternate path” or “alternative path” “a secondary bi-directional LSP which is used for 

protecting the bi-directional LSP [as construed] and uses 

the same network elements as the bi-directional LSP [as 

construed]”

8, 25 “means for receiving the switch over 

message”

Subject to 35 U.S.C. § 112, ¶6

Indefinite for failure to disclose sufficient structure.

23, 25 “means for means for [sic] receiving traffic 

traveling along a bi-directional LSP in a 

forward direction to an alternate path in the 

forward direction”

Subject to 35 U.S.C. § 112, ¶6

Indefinite for failure to disclose sufficient structure.

Case 6:20-cv-00541-ADA Document 46-4 Filed 03/05/21 Page 12 of 31
12

Claim Claim Term Proposed Construction

23 “[means for] receiving a switch over message 

along the alternative path in the forward 

direction”

Subject to 35 U.S.C. § 112, ¶6

Indefinite for failure to disclose sufficient structure.

25 “means for transmitting a switch over 

message, along the alternate path in the 

forward direction, for re-routing traffic 

traveling along the bi-directional LSP in a 

backward direction”

Subject to 35 U.S.C. § 112, ¶6

Indefinite for failure to disclose sufficient structure.

25 “means for re-routing traffic traveling along a 

bi-directional LSP in a backwards direction to 

the same alternate path in the backwards 

direction based on the switch over message”

Subject to 35 U.S.C. § 112, ¶6

Indefinite for failure to disclose sufficient structure.

20 “means for re-routing traffic traveling along a 

bi-directional LSP in a forward direction to an 

alternate path in the forward direction”

Subject to 35 U.S.C. § 112, ¶6

Indefinite for failure to disclose sufficient structure.

Case 6:20-cv-00541-ADA Document 46-4 Filed 03/05/21 Page 13 of 31
13

Claim Claim Term Proposed Construction

20 “means for transmitting a switch over 

message along the alternate path in the 

forward direction to a merging network 

device responsive for re-routing traffic 

traveling along the bi-directional LSP in a 

backward direction to the alternate path in the 

backward direction”

Subject to 35 U.S.C. § 112, ¶6

Indefinite for failure to disclose sufficient structure.

Case 6:20-cv-00541-ADA Document 46-4 Filed 03/05/21 Page 14 of 31
14

U.S. Patent No. 7,515,546 (-536 Case)

Claim Claim Term Proposed Construction

1 “first appropriate response” No construction necessary

1 “if said first device provides routing 

capabilities, making said first device available 

for selection for management by a network 

management system”

No construction necessary

1 “determining if said first device provides 

routing capabilities”

No construction necessary

Case 6:20-cv-00541-ADA Document 46-4 Filed 03/05/21 Page 15 of 31
15

U.S. Patent No. 7,860,512 (-537 Case)

Claim Claim Term Proposed Construction

1-18, 

21-24, 

27

capacity “load”

1, 2, 6, 

7, 11, 

12, 18, 

22-24, 

27

transport capacity limit No construction necessary

22 the transport resource management unit No construction necessary

Case 6:20-cv-00541-ADA Document 46-4 Filed 03/05/21 Page 16 of 31
16

U.S. Patent No. 7,872,973 (-538 Case)

Claim Claim Term Proposed Construction

1, 9 a message to the upstream device to reduce a 

rate at which packets are sent to the queuing 

device to prevent the queue from filling

“a message controlling the upstream device to reduce a 

rate at which packets are sent to the queuing device to 

prevent the queue from filing”

1, 9 the message Indefinite

9 a module for sending the message from the e 

stream device to an upstream network device 

to thereby control a rate at which the upstream 

device receives packets from the upstream 

network device

Subject to 35 U.S.C. § 112, ¶6 

Indefinite for failure to disclose sufficient structure.

9 a module for, if the depth of the queue passes 

a predetermined threshold, sending a message 

to the upstream device to reduce a rate at 

which packets are sent to the queuing device 

to prevent the queue from filling, thereby 

preventing packet discarding and loss by the 

queuing device

Subject to 35 U.S.C. § 112, ¶6 

Indefinite for failure to disclose sufficient structure.

9 a module for sending a message reporting the 

depth of the queue to the upstream device to 

thereby enable the upstream device to 

determine whether to reduce or increase the 

rate at which the upstream device sends 

packets to the queuing device

Subject to 35 U.S.C. § 112, ¶6 

Indefinite for failure to disclose sufficient structure.

9 a module for monitoring a depth of a queue in 

the queuing device

Subject to 35 U.S.C. § 112, ¶6 

Case 6:20-cv-00541-ADA Document 46-4 Filed 03/05/21 Page 17 of 31
17

Claim Claim Term Proposed Construction

Indefinite for failure to disclose sufficient structure.

1, 9 traffic manager No construction necessary

Case 6:20-cv-00541-ADA Document 46-4 Filed 03/05/21 Page 18 of 31
18

U.S. Patent No. 8,200,224 (-539 Case)

Claim Claim Term Proposed Construction

1 “wherein said plurality of candidate base 

stations for said second handover preparation 

includes at least one of said candidate base 

stations identified in said second 

measurement report”

”wherein a second measurement report is received from 

said user equipment” 

must take place prior to 

“initiating a second handover preparation by transmitting 

a second handover request to a plurality of said set of

candidate base stations, if said first handover preparation

has failed”

1 “selecting a set of candidate base stations 

including at least some of said candidate base 

stations identified in said first measurement 

report”

No construction necessary

11 “said complete set of radio bearers” No construction necessary

Case 6:20-cv-00541-ADA Document 46-4 Filed 03/05/21 Page 19 of 31
19

Claim Claim Term Proposed Construction

15 “executable program means for causing a 

base station to perform the method when the 

program is run on the base station”

Subject to 35 U.S.C. § 112, ¶6

Function: Causing a base station to perform the method 

when the program is run on the base station.

Structure: the FIG. 1 flowchart 100 of a handover 

method in a base station of a mobile communication 

system, and equivalents thereof.

1 “transmitting a second handover request to a 

plurality of said set of candidate base 

stations”

No construction necessary

Case 6:20-cv-00541-ADA Document 46-4 Filed 03/05/21 Page 20 of 31
20

U.S. Patent No. 8,417,112 (-540 Case)

Claim Claim Term Proposed Construction

1, 11 determining whether said collected BER 

values worsen over time

“determining whether said collected BER values worsen 

over time by comparing one or more of said recent ones 

of said collected BER values with said other collected 

BER values”

1, 11 in response to a determination that said 

collected BER values worsen over time, 

detecting an indication of BER degradation

“in response to an affirmative determination that said 

collected BER values worsen over time, detecting a 

signal indicating BER degradation”

1, 11 a predetermined BER threshold level No construction necessary

Case 6:20-cv-00541-ADA Document 46-4 Filed 03/05/21 Page 21 of 31
21

U.S. Patent No. 9,084,199 (-541 Case)

Claim Claim Term Proposed Construction

1

15

“generating quality metrics from a decoding 

process for a received channel quality 

indicator (CQI)”

“generating quality soft decision metrics in a 

decoding process associated with a quality of 

the received channel quality indicator (CQI)

“generating soft decision metrics in a decoding process 

associated with a quality of received channel quality 

indicator (CQI)”

No construction necessary

1

15

“associated with a quality of the received 

CQI”

“associated with a quality of the received 

channel quality indicator (CQI)”

“associated with a quality of received CQI channel”

1 “dynamically adjust a CQI channel 

configuration based on the comparison”

“a closed-loop process which dynamically adjusts a CQI 

channel configuration based upon the comparison of the 

short term or long term quality metrics”

1 “generated by filtering frame based quality 

metrics over a plurality of frames”

“created by processing frame based quality metrics over 

a plurality of frames in order to reject those long-term 

soft decision quality metrics that are unwanted”

Case 6:20-cv-00541-ADA Document 46-4 Filed 03/05/21 Page 22 of 31
22

Claim Claim Term Proposed Construction

9 “means for generating soft decision quality 

metrics from a decoding process for a 

received channel quality indicator (CQI)”

Subject to 35 U.S.C. § 112, ¶6

Function: generating soft decision quality metrics from a 

decoding process for a received channel quality indicator 

(CQI)

Structure: a base station that includes a CQI 

recovery/decoding unit, CQI metric generation unit, and 

a decision making unit, and equivalents thereof

9 “means for comparing at least one of the 

quality metrics to a quality setting”

Subject to 35 U.S.C. § 112, ¶6

Function: comparing at least one of the quality metrics to 

a quality setting

Structure: decision making unit 34, and equivalents 

thereof

9 “means for determining whether to 

dynamically adjust a CQI channel 

configuration based on the comparison” 

Subject to 35 U.S.C. § 112, ¶6

Function: Determining whether to dynamically adjust a 

CQI channel configuration based on the comparison

Structure: decision making unit 34, and equivalents 

thereof

Case 6:20-cv-00541-ADA Document 46-4 Filed 03/05/21 Page 23 of 31
23

U.S. Patent No. 8,249,446 (-542 Case)

Claim Claim Term Proposed Construction

1, 15 [A method/Apparatus] of regulating rogue 

behavior in an [optical network component 

comprising an optical transmitter/

optical transmission device]

“[A method/Apparatus] of regulating rogue behavior by a 

subscriber-based [optical network component comprising 

an optical transmitter/optical transmission device]”

1, 15 output indicator “indicator indicating an optical output being transmitted

1, 15 output [indicator] threshold “time length or a percentage of a total time window 

duration”

1, 15 optical transmitter output indicator No construction necessary

1, 15 output indicator monitor No construction necessary

Case 6:20-cv-00541-ADA Document 46-4 Filed 03/05/21 Page 24 of 31
24

U.S. Patent No. 6,999,727 (-543 Case)

Claim Claim Term Proposed Construction

All 

asserted 

claims

“a number of corrected errors (BCE) in a 

non-SCS base reference time period”

“the number of background corrected errors within a 

base reference time period which is different than the 

base reference time period used to calculate uncorrected 

blocks”

All 

asserted 

claims

“classifying said blocks as either corrected 

or uncorrected through said Forward Error 

Correction function”

No construction required

All 

asserted 

claims

“corrected errors” “number of errors that have been corrected by the FEC 

mechanism in the time interval considered”

All 

asserted 

claims

“calculating a Performance Monitoring 

function by implementing a correlation of 

the information regarding said corrected 

and uncorrected blocks”

No construction required

Case 6:20-cv-00541-ADA Document 46-4 Filed 03/05/21 Page 25 of 31
25

Claim Claim Term Proposed Construction

4, 5 “means for implementing a Performance 

Monitoring function based on data 

retrieved through a Forward Error 

Correction function”

Subject to 35 U.S.C. § 112, ¶6

Function: implementing a Performance Monitoring 

function based on data retrieved through a Forward Error 

Correction function

Structure: Algorithm disclosed in Figure 1, and 

equivalents thereof

4, 5 “means for receiving blocks of data” Subject to 35 U.S.C. § 112, ¶6

Indefinite for lack of structure.

4, 5 “means for obtaining data through the 

Forward Error Correction function carried 

out on the blocks of received data”

Subject to 35 U.S.C. § 112, ¶6

Indefinite for lack of structure.

4, 5 “means for classifying said blocks either as 

corrected or uncorrected through the 

Forward Error Correction function”

Subject to 35 U.S.C. § 112, ¶6

Indefinite for lack of structure.

Case 6:20-cv-00541-ADA Document 46-4 Filed 03/05/21 Page 26 of 31
26

Claim Claim Term Proposed Construction

4, 5 “means for calculating the Performance 

Monitoring function by implementing a 

correlation of the information regarding 

said corrected and uncorrected blocks”

Subject to 35 U.S.C. § 112, ¶6

Function: calculating the Performance Monitoring 

Function by implementing a correlation of the 

information regarding said corrected and uncorrected 

blocks wherein said correlation of the information 

regarding said corrected and uncorrected blocks includes 

calculating information comprising: a defected base 

reference time period (SCS) or a time period where at 

least an uncorrected block (UB) has been detected and a 

number of corrected errors (BCE) in a non-SCS base 

reference time period.

Structure: Algorithmic structure: 

, and equivalents thereof

6, 7 “implementing a Performance Monitoring 

function based on data retrieved through a 

Forward Error Correction Function”

Subject to 35 U.S.C. § 112, ¶6

Function: implementing a Performance Monitoring 

function based on data retrieved through a Forward Error 

Correction function

Structure: Algorithm disclosed in Figure 1, and 

equivalents thereof.

Case 6:20-cv-00541-ADA Document 46-4 Filed 03/05/21 Page 27 of 31
27

Claim Claim Term Proposed Construction

6, 7 “receiving blocks of data” Subject to 35 U.S.C. § 112, ¶6

Indefinite for lack of structure.

6, 7 “obtaining data through the Forward Error 

Correction function carried out on the 

blocks of received data”

Subject to 35 U.S.C. § 112, ¶6

Indefinite for lack of structure

6, 7 “classifying said blocks either as corrected 

or uncorrected through the Forward Error 

Correction function”

Subject to 35 U.S.C. § 112, ¶6

Indefinite for lack of structure

Case 6:20-cv-00541-ADA Document 46-4 Filed 03/05/21 Page 28 of 31
28

U.S. Patent No. 8,429,480 (-544 Case)

Claim Claim Term Proposed Construction

2 the resources are persistently allocated for 

transmitting the new uplink packet transmission 

(claim 2)

Indefinite

6, 9, 

12, 15, 

18

resources are persistently allocated for 

transmitting the new uplink packet transmission 

(claims 6 and 9)

persistently allocating a resource for 

transmitting the new packet transmission (claim 

12)

a resource is persistently allocated for 

transmitting the new packet transmission 

(claims 15 and 18)

No construction necessary

1, 2, 5, 

6, 7, 9, 

11-19

hybrid automatic repeat request process “process implementing a stop and wait protocol and soft 

combining where in the uplink a UE adjusts the PUSCH 

transmission according to PDCCH and/or PHICH 

information as detected by the UE”

Case 6:20-cv-00541-ADA Document 46-4 Filed 03/05/21 Page 29 of 31
29

Dated: January 8, 2021 Respectfully submitted,

/s/ Jason W. Cook

Jason W. Cook

Texas Bar No. 24028537

Shaun W. Hassett

Texas Bar No. 24074372

McGuireWoods LLP

2000 McKinney Avenue, Suite 1400 

Dallas, TX 75201 

Telephone: (214) 932-6400 

jcook@mcguirewoods.com

shassett@mcguirewoods.com

Tyler T. VanHoutan

Texas Bar No. 24033290

McGuireWoods LLP

600 Travis St., Suite 7500

Houston, TX 77002

Telephone: (713) 571-9191

tvanhoutan@mcguirewoods.com

J. Mark Mann

Texas Bar No. 12926150

G. Blake Thompson

Texas Bar No. 24042033

MANN | TINDEL | THOMPSON

300 West Main Street

Henderson, Texas 75652

Telephone: (903) 657-8540

mark@themannfirm.com

blake@themannfirm.com

Counsel for Defendants Huawei Technologies 

Co., Ltd., Huawei Technologies USA, Inc., 

Huawei Device Co. Ltd. (f/k/a Huawei Device 

(Dongguan) Co.), Huawei Device (Shenzhen) Co., 

Ltd. (f/k/a Huawei Device Co. Ltd.) and Huawei 

Device USA

Case 6:20-cv-00541-ADA Document 46-4 Filed 03/05/21 Page 30 of 31
30

CERTIFICATE OF SERVICE

I hereby certify that a true and correct copy of the above and foregoing document was 

served on all counsel of record who are deemed to have consented to electronic service via 

electronic mail on January 8, 2021.

/s/ Shaun W. Hassett

Shaun W. Hassett

Case 6:20-cv-00541-ADA Document 46-4 Filed 03/05/21 Page 31 of 31