EXHIBIT C

Case 2:23-cv-00285-JRG-RSP Document 59-3 Filed 07/11/24 Page 1 of 46 PageID #: 1521
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Exhibit A-21

Invalidity Claim Chart for U.S. Patent No. 7,924,802 vs. U.S. Patent No. 6,516,206

U.S. Patent No. 6,516,206 (“Jäntti”) was filed on May 29, 2001, published on November 1, 2001 (U.S. Patent Application Publication 

No. 2001/0036842), and issued on February 4, 20023. Jäntti anticipates asserted claims 1–4, 6–10, 13, 14, 17, and 21–24 of U.S. 

Patent No. 7,924,802 (“the ’802 Patent”) under 35 U.S.C. § 102. Jäntti also renders obvious asserted claims 1–4, 6–10, 13, 14, 17, and

21–24 of the ’802 Patent under 35 U.S.C. § 103, alone based on the state of the art and/or in combination with one or more other 

references identified in Exs. A-1–A-31, Cover Pleading, and First Supplemental Ex. A-Obviousness Chart.

1

 

To the extent Plaintiff alleges that Jäntti does not disclose any particular limitation of the asserted claims in the ’802 Patent, either 

expressly or inherently, it would have been obvious to a person of ordinary skill in the art as of the priority date of the ’802 Patent to 

modify Jäntti and/or to combine the teachings of Jäntti with other prior art references, including but not limited to the present prior art 

references found in Exs. A-1–A-31, Cover Pleading, First Supplemental Ex. A-Obviousness Chart, and the relevant section of charts 

for other prior art for the ’802 Patent in a manner that would render the asserted claims of these patents invalid as obvious.

With respect to the obviousness of the asserted claims of the ’802 Patent under 35 U.S.C. § 103, one or more of the principles 

enumerated by the United States Supreme Court in KSR v. Teleflex, 550 U.S. 398 (2007) apply, including: (a) combining various 

claimed elements known in the prior art according to known methods to yield a predictable result; and/or (b) making a simple 

substitution of one or more known elements for another to obtain a predictable result; and/or (c) using a known technique to improve a 

similar device or method in the same way; and/or (d) applying a known technique to a known device or method ready for 

improvement to yield a predictable result; and/or (e) choosing from a finite number of identified, predictable solutions with a 

reasonable expectation of success or, in other words, the solution was one which was “obvious to try”; and/or (f) a known work in one 

field of endeavor prompting variations of it for use either in the same field or a different field based on given design incentives or 

other market forces in which the variations were predictable to one of ordinary skill in the art; and/or (g) a teaching, suggestion, or 

motivation in the prior art that would have led one of ordinary skill in the art to modify the prior art reference or to combine the 

teachings of various prior art references to arrive at the claimed invention. It therefore would have been obvious to one of ordinary 

skill in the art to combine the disclosures of these references in accordance with the principles and rationales set forth above. 

1

 Samsung is investigating this prior art and has not yet completed discovery from third parties, who may have relevant information 

concerning the prior art, and therefore, Samsung reserves the right to supplement this chart after additional discovery is received. To 

the extent that any of the prior art discloses the same or similar functionality or feature(s) of any of the accused products, Samsung

reserves the right to argue that said feature or functionality does not practice any limitation of any of the asserted claims, and to argue, 

in the alternative, that if said feature or functionality is found to practice any limitation of any of the asserted claims in the ’802 Patent, 

then the prior art reference teaches the limitation and that the claim is not patentable. 

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The citations to portions of any reference in this chart are exemplary only. For example, a citation that refers to or discusses a figure or 

figure item should be understood to also incorporate by reference that figure and any additional descriptions of that figure as if set 

forth fully therein. Samsung reserves the right to rely on the entirety of the references cited in this chart to show that the asserted 

claims of the ’802 Patent are invalid. Citations presented for one claim limitation are expressly incorporated by reference into all 

other limitations for that claim as well as all limitations of all claims on which that claim depends. Samsung also reserves the right to 

rely on additional citations or sources of evidence that also may be applicable, or that may become applicable in light of cl aim 

construction, changes in Plaintiff’s infringement contentions, and/or information obtained durin g discovery as the case progresses. 

Claim 1 of the ’802 Patent Prior Art Reference – Jäntti

[1.1] A method of 

transmitting information in a 

wireless communication 

channel comprising:

To the extent the preamble is limiting, Jäntti discloses “A method of transmitting information in a 

wireless communication channel comprising.” See, e.g.: 

The base stations in a mobile system are usually sectored to enhance transceiver operation. In 

accordance with prior art, the transmitter functions of two sectors having different carriers are 

implemented with different transmitters. Each sector-specific transmitter comprises a transmitter unit, 

a power amplifier and a filter unit, and cables between these units. The drawbacks of said separate 

structures include high costs due to the amounts of components and different cables called for by the 

separate structures. The minimization of transmission losses requires large, and expensive, cables at 

the base station. Separate structures require relatively much space owing to the large size of the 

power amplifier, in particular. Radio systems based on the WCDMA technology require the use of 

expensive and complex linear amplifiers as power amplifiers in transmitter operation. The need for a 

separate linear amplifier for each transmitter is a significant drawback

See, e.g., Jäntti at 1:27-43.

In a first preferred embodiment of the invention, shown in FIG. 3, the transmitter operation of two 

sectors is arranged in a centralized manner. The signal block 100 comprises for different sectors two 

transmitter units 300, 302 for generating the signals to be transmitted. Said signals generated by the 

different transmitter units have different frequencies. These different frequencies are typically 

implemented by generating in each transmitter unit for the signal a carrier that is on a different 

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Claim 1 of the ’802 Patent Prior Art Reference – Jäntti

frequency than a carrier generated by another transmitter unit. The carrier is a wave with which a 

signal is modulated. In the modulation, the signal to be transmitted, including information, is 

combined with the carrier is the transmitter unit. When carriers are at different frequencies, they are 

typically on entirely different frequency ranges, or frequency bands.

The method and arrangement of the invention typically utilizes the WCDMA technology, associated 

with which linear modulation is used in signal processing. Referring still to FIG. 3, the signals having 

different carrier frequencies and modulated by the transmitter units are combined in an adder in the 

transmitter block. The adder is typically of the Wilkinson type, such as a Wilkinson hybrid adder. 

After the combination, the signals are amplified in a multifrequency amplifier 304 acting as the 

power amplifier of the amplifier block 102. In a system according to the WCDMA technology, a 

linear amplifier is used as the power amplifier 306, which enables the simultaneous processing of 

several signals at different frequencies. Herein, simultaneity means that signals at different 

frequencies are combined into signals combined with for example the adder 304, as was described 

above. In a typical case according to the invention, the multifrequency amplifier thus simultaneously 

amplifies at least two combined signals at different carrier frequencies.

See, e.g., Jäntti at 4:62-5:27.

Furthermore, this claim element is obvious in light of Jäntti itself, when combined with any of the 

other references as charted for this claim element in Exs. A-1–A-31, First Supplemental Ex. AObviousness Chart, and/or when combined with the knowledge of one of ordinary skill in the art. 

Motivations to combine may come from the knowledge of the person of ordinary skill themselves, or 

from the known problems and predictable solutions as embodied in these reference s. Further 

motivations to combine references and additional details may be found in the Cover Pleading and 

First Supplemental Ex. A-Obviousness Chart.

[1.2] transmitting first 

information across a first 

frequency range using a 

wireless transmitter, the first 

Jäntti discloses “transmitting first information across a first frequency range using a wireless 

transmitter, the first frequency range having a first center frequency, a first highest frequency, and a 

first lowest frequency.” See, e.g.: 

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Claim 1 of the ’802 Patent Prior Art Reference – Jäntti

frequency range having a first 

center frequency, a first 

highest frequency, and a first 

lowest frequency; and

See, e.g., Jäntti at Figure 3.

The base stations in a mobile system are usually sectored to enhance transceiver operation. In 

accordance with prior art, the transmitter functions of two sectors having different carriers are 

implemented with different transmitters. Each sector-specific transmitter comprises a transmitter unit, 

a power amplifier and a filter unit, and cables between these units. The drawbacks of said separate 

structures include high costs due to the amounts of components and different cables called for by the 

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Claim 1 of the ’802 Patent Prior Art Reference – Jäntti

separate structures. The minimization of transmission losses requires large, and expensive, cables at 

the base station. Separate structures require relatively much space owing to the large size of the 

power amplifier, in particular. Radio systems based on the WCDMA technology require the use of 

expensive and complex linear amplifiers as power amplifiers in transmitter operation. The need for a 

separate linear amplifier for each transmitter is a significant drawback

See, e.g., Jäntti at 1:27-43.

In a first preferred embodiment of the invention, shown in FIG. 3, the transmitter operation of two 

sectors is arranged in a centralized manner. The signal block 100 comprises for different sectors two 

transmitter units 300, 302 for generating the signals to be transmitted. Said signals generated by the 

different transmitter units have different frequencies. These different frequencies are typically 

implemented by generating in each transmitter unit for the signal a carrier that is on a different 

frequency than a carrier generated by another transmitter unit. The carrier is a wave with which a 

signal is modulated. In the modulation, the signal to be transmitted, including information, is 

combined with the carrier is the transmitter unit. When carriers are at different frequencies, they are 

typically on entirely different frequency ranges, or frequency bands.

The method and arrangement of the invention typically utilizes the WCDMA technology, associated 

with which linear modulation is used in signal processing. Referring still to FIG. 3, the signals having 

different carrier frequencies and modulated by the transmitter units are combined in an adder in the 

transmitter block. The adder is typically of the Wilkinson type, such as a Wilkinson hybrid adder. 

After the combination, the signals are amplified in a multifrequency amplifier 304 acting as the 

power amplifier of the amplifier block 102. In a system according to the WCDMA technology, a 

linear amplifier is used as the power amplifier 306, which enables the simultaneous processing of 

several signals at different frequencies. Herein, simultaneity means that signals at different 

frequencies are combined into signals combined with for example the adder 304, as was described 

above. In a typical case according to the invention, the multifrequency amplifier thus simultaneously 

amplifies at least two combined signals at different carrier frequencies.

See, e.g., Jäntti at 4:62-5:27.

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Claim 1 of the ’802 Patent Prior Art Reference – Jäntti

Furthermore, this claim element is obvious in light of Jäntti itself, when combined with any of the 

other references as charted for this claim element in Exs. A-1–A-31, First Supplemental Ex. AObviousness Chart, and/or when combined with the knowledge of one of ordinary skill in the art. 

Motivations to combine may come from the knowledge of the person of ordinary skill themselves, or 

from the known problems and predictable solutions as embodied in these references. Further 

motivations to combine references and additional details may be found in the Cover Pleading a nd 

First Supplemental Ex. A-Obviousness Chart.

[1.3] simultaneously 

transmitting second 

information across a second 

frequency range using the 

same wireless transmitter, the 

second frequency range 

having a second center 

frequency greater than the 

first center frequency, a 

second highest frequency, and 

a second lowest frequency.

Jäntti discloses “simultaneously transmitting second information across a second frequency range 

using the same wireless transmitter, the second frequency range having a second cente r frequency 

greater than the first center frequency, a second highest frequency, and a second lowest frequency .” 

See, e.g.: 

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Claim 1 of the ’802 Patent Prior Art Reference – Jäntti

See, e.g., Jäntti at Figure 3.

The base stations in a mobile system are usually sectored to enhance transceiver operation. In 

accordance with prior art, the transmitter functions of two sectors having different carriers are 

implemented with different transmitters. Each sector-specific transmitter comprises a transmitter unit, 

a power amplifier and a filter unit, and cables between these units. The drawbacks of said separate 

structures include high costs due to the amounts of components and different cables called for by the 

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Claim 1 of the ’802 Patent Prior Art Reference – Jäntti

separate structures. The minimization of transmission losses requires large, and expensive, cables at 

the base station. Separate structures require relatively much space owing to the large size of the 

power amplifier, in particular. Radio systems based on the WCDMA technology require the use of 

expensive and complex linear amplifiers as power amplifiers in transmitter operation. The need for a 

separate linear amplifier for each transmitter is a significant drawback

See, e.g., Jäntti at 1:27-43.

In a first preferred embodiment of the invention, shown in FIG. 3, the transmitter operation of two 

sectors is arranged in a centralized manner. The signal block 100 comprises for different sectors two 

transmitter units 300, 302 for generating the signals to be transmitted. Said signals generated by the 

different transmitter units have different frequencies. These different frequencies are typically 

implemented by generating in each transmitter unit for the signal a carrier that is on a different 

frequency than a carrier generated by another transmitter unit. The carrier is a wave with which a 

signal is modulated. In the modulation, the signal to be transmitted, including information, is 

combined with the carrier is the transmitter unit. When carriers are at different frequencies, they are 

typically on entirely different frequency ranges, or frequency bands.

The method and arrangement of the invention typically utilizes the WCDMA technology, associated 

with which linear modulation is used in signal processing. Referring still to FIG. 3, the signals having 

different carrier frequencies and modulated by the transmitter units are combined in an adder in the 

transmitter block. The adder is typically of the Wilkinson type, such as a Wilkinson hybrid adder. 

After the combination, the signals are amplified in a multifrequency amplifier 304 acting as the 

power amplifier of the amplifier block 102. In a system according to the WCDMA technology, a 

linear amplifier is used as the power amplifier 306, which enables the simultaneous processing o f 

several signals at different frequencies. Herein, simultaneity means that signals at different 

frequencies are combined into signals combined with for example the adder 304, as was described 

above. In a typical case according to the invention, the multifrequency amplifier thus simultaneously 

amplifies at least two combined signals at different carrier frequencies.

See, e.g., Jäntti at 4:62-5:27.

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Claim 1 of the ’802 Patent Prior Art Reference – Jäntti

Furthermore, this claim element is obvious in light of Jäntti itself, when combined with any of the 

other references as charted for this claim element in Exs. A-1–A-31, First Supplemental Ex. AObviousness Chart, and/or when combined with the knowledge of one of ordinary skill in the art. 

Motivations to combine may come from the knowledge of the person of ordinary skill themselves, or 

from the known problems and predictable solutions as embodied in these references. Further 

motivations to combine references and additional details may be found in the Cover Pleading and 

First Supplemental Ex. A-Obviousness Chart.

Claim 2 of the ’802 Patent Prior Art Reference – Jäntti

[2.1] The method of claim 1 Jäntti discloses all the elements of claim 1 for all the reasons provided above.

[2.2] wherein frequency 

difference between the first 

center frequency and the 

second center frequency is 

greater than the sum of onehalf the first frequency range 

and one-half the second 

frequency range.

Jäntti discloses “wherein frequency difference between the first center frequency and the second 

center frequency is greater than the sum of one-half the first frequency range and one-half the second 

frequency range.” 

Furthermore, this claim element is obvious in light of Jäntti itself, when combined with any of the 

other references as charted for this claim element in Exs. A-1–A-31, First Supplemental Ex. AObviousness Chart, and/or when combined with the knowledge of one of ordinary skill in the art. 

Motivations to combine may come from the knowledge of the person of ordinary skill themselves, or 

from the known problems and predictable solutions as embodied in these references. Further 

motivations to combine references and additional details may be found in the Cover Pleading and 

First Supplemental Ex. A-Obviousness Chart.

Claim 3 of the ’802 Patent Prior Art Reference – Jäntti

[3.1] The method of claim 1 Jäntti discloses all the elements of claim 1 for all the reasons provided above.

[3.2] wherein the first and 

second information are 

Jäntti discloses “wherein the first and second information are transmitted using the same power 

amplifier in said wireless transmitter.” See, e.g.: 

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Claim 3 of the ’802 Patent Prior Art Reference – Jäntti

transmitted using the same 

power amplifier in said 

wireless transmitter.

See, e.g., Jäntti at Figure 3.

The base stations in a mobile system are usually sectored to enhance transceiver operation. In 

accordance with prior art, the transmitter functions of two sectors having different carriers are 

implemented with different transmitters. Each sector-specific transmitter comprises a transmitter unit, 

a power amplifier and a filter unit, and cables between these units. The drawbacks of said separate 

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Claim 3 of the ’802 Patent Prior Art Reference – Jäntti

structures include high costs due to the amounts of components and different cables called for by the 

separate structures. The minimization of transmission losses requires large, and expensive, cables at 

the base station. Separate structures require relatively much space owing to the large size of the 

power amplifier, in particular. Radio systems based on the WCDMA technology require the use of 

expensive and complex linear amplifiers as power amplifiers in transmitter operation. The need for a 

separate linear amplifier for each transmitter is a significant drawback

See, e.g., Jäntti at 1:27-43.

In a first preferred embodiment of the invention, shown in FIG. 3, the transmitter operation of two 

sectors is arranged in a centralized manner. The signal block 100 comprises for different sectors two 

transmitter units 300, 302 for generating the signals to be transmitted. Said signals generated by the 

different transmitter units have different frequencies. These different frequencies are typically 

implemented by generating in each transmitter unit for the signal a carrier that is on a different 

frequency than a carrier generated by another transmitter unit. The carrier is a wave with which a 

signal is modulated. In the modulation, the signal to be transmitted, including information, is 

combined with the carrier is the transmitter unit. When carriers are at different frequencies, they are 

typically on entirely different frequency ranges, or frequency bands.

The method and arrangement of the invention typically utilizes the WCDMA technology, associated 

with which linear modulation is used in signal processing. Referring still to FIG. 3, the signals having 

different carrier frequencies and modulated by the transmitter units are combined in an adder in the 

transmitter block. The adder is typically of the Wilkinson type, such as a Wilkinson hybrid adder. 

After the combination, the signals are amplified in a multifrequency amplifier 304 acting as the 

power amplifier of the amplifier block 102. In a system according to the WCDMA technology, a 

linear amplifier is used as the power amplifier 306, which enables the simultaneous processing of 

several signals at different frequencies. Herein, simultaneity means that signals at different 

frequencies are combined into signals combined with for example the adder 304, as was described 

above. In a typical case according to the invention, the multifrequency amplifier thus simultaneously 

amplifies at least two combined signals at different carrier frequencies.

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Claim 3 of the ’802 Patent Prior Art Reference – Jäntti

See, e.g., Jäntti at 4:62-5:27.

Furthermore, this claim element is obvious in light of Jäntti itself, when combined with any of the 

other references as charted for this claim element in Exs. A-1–A-31, First Supplemental Ex. AObviousness Chart, and/or when combined with the knowledge of one of ordinary skill in the art. 

Motivations to combine may come from the knowledge of the person of ordinary skill themselves, or 

from the known problems and predictable solutions as embodied in these references. Further 

motivations to combine references and additional details may be found in the Cover Pleading and 

First Supplemental Ex. A-Obviousness Chart.

Claim 4 of the ’802 Patent Prior Art Reference – Jäntti

[4.1] The method of claim 3 Jäntti discloses all the elements of claim 3 for all the reasons provided above.

[4.2] wherein the bandwidth 

of said power amplifier is 

greater than the difference 

between the first lowest 

frequency and the second 

highest frequency.

Jäntti discloses “wherein the bandwidth of said power amplifier is greater than the difference between 

the first lowest frequency and the second highest frequency.” See, e.g.: 

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Claim 4 of the ’802 Patent Prior Art Reference – Jäntti

See, e.g., Jäntti at Figure 3.

The base stations in a mobile system are usually sectored to enhance transceiver operation. In 

accordance with prior art, the transmitter functions of two sectors having different carriers are 

implemented with different transmitters. Each sector-specific transmitter comprises a transmitter unit, 

a power amplifier and a filter unit, and cables between these units. The drawbacks of said separate 

structures include high costs due to the amounts of components and different cables called for by the 

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Claim 4 of the ’802 Patent Prior Art Reference – Jäntti

separate structures. The minimization of transmission losses requires large, and expensive, cables at 

the base station. Separate structures require relatively much space owing to the large size of the 

power amplifier, in particular. Radio systems based on the WCDMA technology require the use of 

expensive and complex linear amplifiers as power amplifiers in transmitter operation. The need for a 

separate linear amplifier for each transmitter is a significant drawback

See, e.g., Jäntti at 1:27-43.

In a first preferred embodiment of the invention, shown in FIG. 3, the transmitter operation of two 

sectors is arranged in a centralized manner. The signal block 100 comprises for different sectors two 

transmitter units 300, 302 for generating the signals to be transmitted. Said signals generated by the 

different transmitter units have different frequencies. These different frequencies are typically 

implemented by generating in each transmitter unit for the signal a carrier that is on a different 

frequency than a carrier generated by another transmitter unit. The carrier is a wave with which a 

signal is modulated. In the modulation, the signal to be transmitted, including information, is 

combined with the carrier is the transmitter unit. When carriers are at different frequencies, they are 

typically on entirely different frequency ranges, or frequency bands.

The method and arrangement of the invention typically utilizes the WCDMA technology, associated 

with which linear modulation is used in signal processing. Referring still to FIG. 3, the signals having 

different carrier frequencies and modulated by the transmitter units are combined in an adder in the 

transmitter block. The adder is typically of the Wilkinson type, such as a Wilkinson hybrid adder. 

After the combination, the signals are amplified in a multifrequency amplifier 304 acting as the 

power amplifier of the amplifier block 102. In a system according to the WCDMA technology, a 

linear amplifier is used as the power amplifier 306, which enables the simultaneous processing o f 

several signals at different frequencies. Herein, simultaneity means that signals at different 

frequencies are combined into signals combined with for example the adder 304, as was described 

above. In a typical case according to the invention, the multifrequency amplifier thus simultaneously 

amplifies at least two combined signals at different carrier frequencies.

See, e.g., Jäntti at 4:62-5:27.

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Claim 4 of the ’802 Patent Prior Art Reference – Jäntti

Furthermore, this claim element is obvious in light of Jäntti itself, when combined with any of the 

other references as charted for this claim element in Exs. A-1–A-31, First Supplemental Ex. AObviousness Chart, and/or when combined with the knowledge of one of ordinary skill in the art. 

Motivations to combine may come from the knowledge of the person of ordinary skill themselves, or 

from the known problems and predictable solutions as embodied in these references. Further 

motivations to combine references and additional details may be found in the Cover Pleading and 

First Supplemental Ex. A-Obviousness Chart.

Claim 6 of the ’802 Patent Prior Art Reference – Jäntti

[6.1] The method of claim 1 Jäntti discloses all the elements of claim 1 for all the reasons provided above.

[6.2] wherein the first 

information corresponds to a 

first wireless protocol and the 

second information 

corresponds to a second 

wireless protocol.

Jäntti discloses “wherein the first information corresponds to a first wireless protocol and the second 

information corresponds to a second wireless protocol.” 

Furthermore, this claim element is obvious in light of Jäntti itself, when combined with any of the 

other references as charted for this claim element in Exs. A-1–A-31, First Supplemental Ex. AObviousness Chart, and/or when combined with the knowledge of one of ordinary skill in the art. 

Motivations to combine may come from the knowledge of the person of ordinary skill themselves, or 

from the known problems and predictable solutions as embodied in these references. Further 

motivations to combine references and additional details may be found in the Cover Pleading and 

First Supplemental Ex. A-Obviousness Chart.

Claim 7 of the ’802 Patent Prior Art Reference – Jäntti

[7.1] The method of claim 1 Jäntti discloses all the elements of claim 1 for all the reasons provided above.

[7.2] wherein the first 

information and the second 

information are the same data 

Jäntti discloses “wherein the first information and the second information are the same data 

transmitted across two different frequencies.” 

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Claim 7 of the ’802 Patent Prior Art Reference – Jäntti

transmitted across two 

different frequencies.

Furthermore, this claim element is obvious in light of Jäntti itself, when combined with any of the 

other references as charted for this claim element in Exs. A-1–A-31, First Supplemental Ex. AObviousness Chart, and/or when combined with the knowledge of one of ordinary skill in the art. 

Motivations to combine may come from the knowledge of the person of ordinary skill themselves, or 

from the known problems and predictable solutions as embodied in these references. Further 

motivations to combine references and additional details may be found in the Cover Pleading and 

First Supplemental Ex. A-Obviousness Chart.

Claim 8 of the ’802 Patent Prior Art Reference – Jäntti

[8.1] The method of claim 1 Jäntti discloses all the elements of claim 1 for all the reasons provided above.

[8.2] wherein the first 

information and the second 

information are from the same 

data stream.

Jäntti discloses “wherein the first information and the second information are from the same data 

stream.” 

Furthermore, this claim element is obvious in light of Jäntti itself, when combined with any of the 

other references as charted for this claim element in Exs. A-1–A-31, First Supplemental Ex. AObviousness Chart, and/or when combined with the knowledge of one of ordinary skill in the art. 

Motivations to combine may come from the knowledge of the person of ordinary skill themselves, or 

from the known problems and predictable solutions as embodied in these references. Further 

motivations to combine references and additional details may be found in the Cover Pleading and 

First Supplemental Ex. A-Obviousness Chart.

Claim 9 of the ’802 Patent Prior Art Reference – Jäntti

[9.1] The method of claim 1 Jäntti discloses all the elements of claim 1 for all the reasons provided above.

[9.2] wherein first information 

and second information 

comprise a plurality of OFDM 

symbols, wherein a first 

Jäntti discloses “wherein first information and second information comprise a plurality of OFDM 

symbols, wherein a first symbol is transmitted during a first time slot across the first frequency range 

and a second symbol is transmitted during the first time slot across the second frequency range, and 

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Claim 9 of the ’802 Patent Prior Art Reference – Jäntti

symbol is transmitted during a 

first time slot across the first 

frequency range and a second 

symbol is transmitted during 

the first time slot across the 

second frequency range, and 

wherein a third symbol is 

transmitted during a second 

time slot across the first 

frequency range and a fourth 

symbol is transmitted during 

the second time slot across a 

second frequency range.

wherein a third symbol is transmitted during a second time slot across the first frequency range and a 

fourth symbol is transmitted during the second time slot across a second frequency range .” 

Furthermore, this claim element is obvious in light of Jäntti itself, when combined with any of the 

other references as charted for this claim element in Exs. A-1–A-31, First Supplemental Ex. AObviousness Chart, and/or when combined with the knowledge of one of ordinary skill in the art. 

Motivations to combine may come from the knowledge of the person of ordinary skill themselves, or 

from the known problems and predictable solutions as embodied in these references. Further 

motivations to combine references and additional details may be found in the Cover Pleading and 

First Supplemental Ex. A-Obviousness Chart.

Claim 10 of the ’802 Patent Prior Art Reference – Jäntti

[10.1] A method of 

transmitting information in a 

wireless communication 

channel comprising:

To the extent the preamble is limiting, Jäntti discloses “A method of transmitting information in a 

wireless communication channel comprising.” 

Furthermore, this claim element is obvious in light of Jäntti itself, when combined with any of the 

other references as charted for this claim element in Exs. A-1–A-31, First Supplemental Ex. AObviousness Chart, and/or when combined with the knowledge of one of ordinary skill in the art. 

Motivations to combine may come from the knowledge of the person of ordinary skill themselves, or 

from the known problems and predictable solutions as embodied in these references. Further 

motivations to combine references and additional details may be found in the Cover Pleading and 

First Supplemental Ex. A-Obviousness Chart.

[10.2] receiving a first digital 

signal comprising first data to 

be transmitted;

Jäntti discloses “receiving a first digital signal comprising first data to be transmitted.” 

Case 2:23-cv-00285-JRG-RSP Document 59-3 Filed 07/11/24 Page 18 of 46 PageID #:

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Claim 10 of the ’802 Patent Prior Art Reference – Jäntti

Furthermore, this claim element is obvious in light of Jäntti itself, when combined with any of the 

other references as charted for this claim element in Exs. A-1–A-31, First Supplemental Ex. AObviousness Chart, and/or when combined with the knowledge of one of ordinary skill in the art. 

Motivations to combine may come from the knowledge of the person of ordinary skill themselves, or 

from the known problems and predictable solutions as embodied in these references. Further 

motivations to combine references and additional details may be found in the Cover Pleading and 

First Supplemental Ex. A-Obviousness Chart.

[10.3] receiving a second 

digital signal comprising 

second data to be transmitted;

Jäntti discloses “receiving a second digital signal comprising second data to be transmitted.” 

Furthermore, this claim element is obvious in light of Jäntti itself, when combined with any of the 

other references as charted for this claim element in Exs. A-1–A-31, First Supplemental Ex. AObviousness Chart, and/or when combined with the knowledge of one of ordinary skill in the art. 

Motivations to combine may come from the knowledge of the person of ordinary skill themselves, or 

from the known problems and predictable solutions as embodied in these references. Further 

motivations to combine references and additional details may be found in the Cover Pleading and 

First Supplemental Ex. A-Obviousness Chart.

[10.4] converting the first 

digital signal into a first 

analog signal using a first 

digital-to-analog converter, 

the first analog signal carrying 

the first data across a first 

frequency range;.

Jäntti discloses “converting the first digital signal into a first analog signal using a first digital-toanalog converter, the first analog signal carrying the first data across a first frequency range.” 

Furthermore, this claim element is obvious in light of Jäntti itself, when combined with any of the 

other references as charted for this claim element in Exs. A-1–A-31, First Supplemental Ex. AObviousness Chart, and/or when combined with the knowledge of one of ordinary skill in the art. 

Motivations to combine may come from the knowledge of the person of ordinary skill themselves, or 

from the known problems and predictable solutions as embodied in these references. Further 

motivations to combine references and additional details may be found in the Cover Pleading a nd 

First Supplemental Ex. A-Obviousness Chart.

[10.5] converting the second 

digital signal into a second 

analog signal using a second 

digital-to-analog converter, 

the second analog signal 

Jäntti discloses “converting the second digital signal into a second analog signal using a second 

digital-to-analog converter, the second analog signal carrying the second data across a second 

frequency range.” 

Case 2:23-cv-00285-JRG-RSP Document 59-3 Filed 07/11/24 Page 19 of 46 PageID #:

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Claim 10 of the ’802 Patent Prior Art Reference – Jäntti

carrying the second data 

across a second frequency 

range;

Furthermore, this claim element is obvious in light of Jäntti itself, when combined with any of the 

other references as charted for this claim element in Exs. A-1–A-31, First Supplemental Ex. AObviousness Chart, and/or when combined with the knowledge of one of ordinary skill in the art. 

Motivations to combine may come from the knowledge of the person of ordinary skill themselves, or 

from the known problems and predictable solutions as embodied in these references. Further 

motivations to combine references and additional details may be found in the Cover Pleading and 

First Supplemental Ex. A-Obviousness Chart.

[10.6] up-converting the first 

analog signal to a first RF 

center frequency to produce a 

first up-converted analog 

signal, wherein the first upconverted analog signal 

comprises a first up-converted 

frequency range from the first 

RF center frequency minus 

one-half the first frequency 

range to the first RF center 

frequency plus one-half the 

first frequency range;

Jäntti discloses “up-converting the first analog signal to a first RF center frequency to produce a first 

up-converted analog signal, wherein the first up-converted analog signal comprises a first upconverted frequency range from the first RF center frequency minus one-half the first frequency 

range to the first RF center frequency plus one-half the first frequency range.” 

Furthermore, this claim element is obvious in light of Jäntti itself, when combined with any of the 

other references as charted for this claim element in Exs. A-1–A-31, First Supplemental Ex. AObviousness Chart, and/or when combined with the knowledge of one of ordinary skill in the art. 

Motivations to combine may come from the knowledge of the person of ordinary skill themselves, or 

from the known problems and predictable solutions as embodied in these references. Further 

motivations to combine references and additional details may be found in the Cover Pleading and 

First Supplemental Ex. A-Obviousness Chart.

[10.7] up-converting the 

second analog signal to a 

second RF center frequency 

greater than the first center RF 

frequency to produce a second 

up-converted analog signal, 

wherein the second upconverted analog signal 

comprises a second upconverted frequency range 

from the second RF center 

Jäntti discloses “up-converting the second analog signal to a second RF center frequency greater than 

the first center RF frequency to produce a second up-converted analog signal, wherein the second upconverted analog signal comprises a second up-converted frequency range from the second RF center 

frequency minus one-half the second frequency range to the second RF center frequency plus onehalf the second frequency range, and wherein a frequency difference between the first RF center 

frequency and the second RF center frequency is greater than the sum of one-half the first frequency 

range and one-half the second frequency range.” 

Furthermore, this claim element is obvious in light of Jäntti itself, when combined with any of the 

other references as charted for this claim element in Exs. A-1–A-31, First Supplemental Ex. AObviousness Chart, and/or when combined with the knowledge of one of ordinary skill in the art. 

Case 2:23-cv-00285-JRG-RSP Document 59-3 Filed 07/11/24 Page 20 of 46 PageID #:

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20

Claim 10 of the ’802 Patent Prior Art Reference – Jäntti

frequency minus one-half the 

second frequency range to the 

second RF center frequency 

plus one-half the second 

frequency range, and wherein 

a frequency difference 

between the first RF center 

frequency and the second RF 

center frequency is greater 

than the sum of one-half the 

first frequency range and onehalf the second frequency 

range;

Motivations to combine may come from the knowledge of the person of ordinary skill themselves, or 

from the known problems and predictable solutions as embodied in these references. Further 

motivations to combine references and additional details may be found in the Cover Pleading and 

First Supplemental Ex. A-Obviousness Chart.

[10.8] combining the first upconverted analog signal and 

the second up-converted 

analog signal to produce a 

combined up-converted 

signal;

Jäntti discloses “combining the first up-converted analog signal and the second up-converted analog 

signal to produce a combined up-converted signal.” See, e.g.: 

Case 2:23-cv-00285-JRG-RSP Document 59-3 Filed 07/11/24 Page 21 of 46 PageID #:

1541
21

Claim 10 of the ’802 Patent Prior Art Reference – Jäntti

See, e.g., Jäntti at Figure 3.

The base stations in a mobile system are usually sectored to enhance transceiver operation. In 

accordance with prior art, the transmitter functions of two sectors having different carriers are 

implemented with different transmitters. Each sector-specific transmitter comprises a transmitter unit, 

a power amplifier and a filter unit, and cables between these units. The drawbacks of said sepa rate 

structures include high costs due to the amounts of components and different cables called for by the 

Case 2:23-cv-00285-JRG-RSP Document 59-3 Filed 07/11/24 Page 22 of 46 PageID #:

1542
22

Claim 10 of the ’802 Patent Prior Art Reference – Jäntti

separate structures. The minimization of transmission losses requires large, and expensive, cables at 

the base station. Separate structures require relatively much space owing to the large size of the 

power amplifier, in particular. Radio systems based on the WCDMA technology require the use of 

expensive and complex linear amplifiers as power amplifiers in transmitter operation. The need for a 

separate linear amplifier for each transmitter is a significant drawback

See, e.g., Jäntti at 1:27-43.

In a first preferred embodiment of the invention, shown in FIG. 3, the transmitter operation of two 

sectors is arranged in a centralized manner. The signal block 100 comprises for different sectors two 

transmitter units 300, 302 for generating the signals to be transmitted. Said signals generated by the 

different transmitter units have different frequencies. These different frequencies are typically 

implemented by generating in each transmitter unit for the signal a carrier that is on a different 

frequency than a carrier generated by another transmitter unit. The carrier is a wave with which a 

signal is modulated. In the modulation, the signal to be transmitted, including information, is 

combined with the carrier is the transmitter unit. When carriers are at different frequencies, they are 

typically on entirely different frequency ranges, or frequency bands.

The method and arrangement of the invention typically utilizes the WCDMA technology, associated 

with which linear modulation is used in signal processing. Referring still to FIG. 3, the signals having 

different carrier frequencies and modulated by the transmitter units are combined in an adder in the 

transmitter block. The adder is typically of the Wilkinson type, such as a Wilkinson hybrid adder. 

After the combination, the signals are amplified in a multifrequency amplifier 304 acting as the 

power amplifier of the amplifier block 102. In a system according to the WCDMA technology, a 

linear amplifier is used as the power amplifier 306, which enables the simultaneous processing of 

several signals at different frequencies. Herein, simultaneity means that signals at different 

frequencies are combined into signals combined with for example the adder 304, as was described 

above. In a typical case according to the invention, the multifrequency amplifier thus simultaneously 

amplifies at least two combined signals at different carrier frequencies.

See, e.g., Jäntti at 4:62-5:27.

Case 2:23-cv-00285-JRG-RSP Document 59-3 Filed 07/11/24 Page 23 of 46 PageID #:

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23

Claim 10 of the ’802 Patent Prior Art Reference – Jäntti

Furthermore, this claim element is obvious in light of Jäntti itself, when combined with any of the 

other references as charted for this claim element in Exs. A-1–A-31, First Supplemental Ex. AObviousness Chart, and/or when combined with the knowledge of one of ordinary skill in the art. 

Motivations to combine may come from the knowledge of the person of ordinary skill themselves, or 

from the known problems and predictable solutions as embodied in these reference s. Further 

motivations to combine references and additional details may be found in the Cover Pleading and 

First Supplemental Ex. A-Obviousness Chart.

[10.9] amplifying the 

combined up-converted signal 

in a power amplifier resulting 

in an amplified combined upconverted signal; and

Jäntti discloses “amplifying the combined up-converted signal in a power amplifier resulting in an 

amplified combined up-converted signal.” See, e.g.: 

Case 2:23-cv-00285-JRG-RSP Document 59-3 Filed 07/11/24 Page 24 of 46 PageID #:

1544
24

Claim 10 of the ’802 Patent Prior Art Reference – Jäntti

See, e.g., Jäntti at Figure 3.

The base stations in a mobile system are usually sectored to enhance transceiver operation. In 

accordance with prior art, the transmitter functions of two sectors having different carriers are 

implemented with different transmitters. Each sector-specific transmitter comprises a transmitter unit, 

a power amplifier and a filter unit, and cables between these units. The drawbacks of said separate 

structures include high costs due to the amounts of components and different cables called for by the 

Case 2:23-cv-00285-JRG-RSP Document 59-3 Filed 07/11/24 Page 25 of 46 PageID #:

1545
25

Claim 10 of the ’802 Patent Prior Art Reference – Jäntti

separate structures. The minimization of transmission losses requires large, and expensive, cables at 

the base station. Separate structures require relatively much space owing to the large size of the 

power amplifier, in particular. Radio systems based on the WCDMA technology require the use of 

expensive and complex linear amplifiers as power amplifiers in transmitter operation. The need for a 

separate linear amplifier for each transmitter is a significant drawback

See, e.g., Jäntti at 1:27-43.

In a first preferred embodiment of the invention, shown in FIG. 3, the transmitter operation of two 

sectors is arranged in a centralized manner. The signal block 100 comprises for different sectors two 

transmitter units 300, 302 for generating the signals to be transmitted. Said signals generated by the 

different transmitter units have different frequencies. These different frequencies are typically 

implemented by generating in each transmitter unit for the signal a carrier that is on a different 

frequency than a carrier generated by another transmitter unit. The carrier is a wave with which a 

signal is modulated. In the modulation, the signal to be transmitted, including information, is 

combined with the carrier is the transmitter unit. When carriers are at different frequencies, they are 

typically on entirely different frequency ranges, or frequency bands.

The method and arrangement of the invention typically utilizes the WCDMA technology, associated 

with which linear modulation is used in signal processing. Referring still to FIG. 3, the signals having 

different carrier frequencies and modulated by the transmitter units are combined in an adder in the 

transmitter block. The adder is typically of the Wilkinson type, such as a Wilkinson hybrid adder. 

After the combination, the signals are amplified in a multifrequency amplifier 304 acting as the 

power amplifier of the amplifier block 102. In a system according to the WCDMA technology, a 

linear amplifier is used as the power amplifier 306, which enables the simultaneous processing of 

several signals at different frequencies. Herein, simultaneity means that signals at different 

frequencies are combined into signals combined with for example the adder 304, as was described 

above. In a typical case according to the invention, the multifrequency amplifier thus simultaneously 

amplifies at least two combined signals at different carrier frequencies.

See, e.g., Jäntti at 4:62-5:27.

Case 2:23-cv-00285-JRG-RSP Document 59-3 Filed 07/11/24 Page 26 of 46 PageID #:

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26

Claim 10 of the ’802 Patent Prior Art Reference – Jäntti

Furthermore, this claim element is obvious in light of Jäntti itself, when combined with any of the 

other references as charted for this claim element in Exs. A-1–A-31, First Supplemental Ex. AObviousness Chart, and/or when combined with the knowledge of one of ordinary skill in the art. 

Motivations to combine may come from the knowledge of the person of ordinary skill themselves, or 

from the known problems and predictable solutions as embodied in these references. Further 

motivations to combine references and additional details may be found in the Cover Pleading and 

First Supplemental Ex. A-Obviousness Chart.

[10.10] transmitting the 

amplified combined upconverted signal on a first 

antenna,

Jäntti discloses “transmitting the amplified combined up-converted signal on a first antenna.” See, 

e.g.: 

Case 2:23-cv-00285-JRG-RSP Document 59-3 Filed 07/11/24 Page 27 of 46 PageID #:

1547
27

Claim 10 of the ’802 Patent Prior Art Reference – Jäntti

See, e.g., Jäntti at Figure 3.

The base stations in a mobile system are usually sectored to enhance transceiver operation. In 

accordance with prior art, the transmitter functions of two sectors having different carriers are 

implemented with different transmitters. Each sector-specific transmitter comprises a transmitter unit, 

a power amplifier and a filter unit, and cables between these units. The drawbacks of said separate 

structures include high costs due to the amounts of components and different cables called for by the 

Case 2:23-cv-00285-JRG-RSP Document 59-3 Filed 07/11/24 Page 28 of 46 PageID #:

1548
28

Claim 10 of the ’802 Patent Prior Art Reference – Jäntti

separate structures. The minimization of transmission losses requires large, and expensive, cables at 

the base station. Separate structures require relatively much space owing to the large size of the 

power amplifier, in particular. Radio systems based on the WCDMA technology require the use of 

expensive and complex linear amplifiers as power amplifiers in transmitter operation. The need for a 

separate linear amplifier for each transmitter is a significant drawback

See, e.g., Jäntti at 1:27-43.

In a first preferred embodiment of the invention, shown in FIG. 3, the transmitter operation of two 

sectors is arranged in a centralized manner. The signal block 100 comprises for different sectors two 

transmitter units 300, 302 for generating the signals to be transmitted. Said signals generated by the 

different transmitter units have different frequencies. These different frequencies are typically 

implemented by generating in each transmitter unit for the signal a carrier that is on a different 

frequency than a carrier generated by another transmitter unit. The carrier is a wave with which a 

signal is modulated. In the modulation, the signal to be transmitted, including information, is 

combined with the carrier is the transmitter unit. When carriers are at different frequencies, they are 

typically on entirely different frequency ranges, or frequency bands.

The method and arrangement of the invention typically utilizes the WCDMA technology, associated 

with which linear modulation is used in signal processing. Referring still to FIG. 3, the signals having 

different carrier frequencies and modulated by the transmitter units are combined in an adder in the 

transmitter block. The adder is typically of the Wilkinson type, such as a Wilkinson hybrid adder. 

After the combination, the signals are amplified in a multifrequency amplifier 304 acting as the 

power amplifier of the amplifier block 102. In a system according to the WCDMA technology, a 

linear amplifier is used as the power amplifier 306, which enables the simultaneous processing of 

several signals at different frequencies. Herein, simultaneity means that signals at different 

frequencies are combined into signals combined with for example the adder 304, as was described 

above. In a typical case according to the invention, the multifrequency amplifier thus simultaneously 

amplifies at least two combined signals at different carrier frequencies.

See, e.g., Jäntti at 4:62-5:27.

Case 2:23-cv-00285-JRG-RSP Document 59-3 Filed 07/11/24 Page 29 of 46 PageID #:

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Claim 10 of the ’802 Patent Prior Art Reference – Jäntti

Furthermore, this claim element is obvious in light of Jäntti itself, when combined with any of the 

other references as charted for this claim element in Exs. A-1–A-31, First Supplemental Ex. AObviousness Chart, and/or when combined with the knowledge of one of ordinary skill in the art. 

Motivations to combine may come from the knowledge of the person of ordinary skill themselves, or 

from the known problems and predictable solutions as embodied in these references. Further 

motivations to combine references and additional details may be found in the Cover Pleading and 

First Supplemental Ex. A-Obviousness Chart.

[10.11] wherein the 

bandwidth of said power 

amplifier is greater than the 

difference between a lowest 

frequency in the first upconverted frequency range 

and a highest frequency in the 

second up-converted 

frequency range.

Jäntti discloses “wherein the bandwidth of said power amplifier is greater than the difference between 

a lowest frequency in the first up-converted frequency range and a highest frequency in the second 

up-converted frequency range.” See, e.g.: 

Case 2:23-cv-00285-JRG-RSP Document 59-3 Filed 07/11/24 Page 30 of 46 PageID #:

1550
30

Claim 10 of the ’802 Patent Prior Art Reference – Jäntti

See, e.g., Jäntti at Figure 3.

The base stations in a mobile system are usually sectored to enhance transceiver operation. In 

accordance with prior art, the transmitter functions of two sectors having different carriers are 

implemented with different transmitters. Each sector-specific transmitter comprises a transmitter unit, 

a power amplifier and a filter unit, and cables between these units. The drawbacks of said separate 

structures include high costs due to the amounts of components and different cables called for by the 

Case 2:23-cv-00285-JRG-RSP Document 59-3 Filed 07/11/24 Page 31 of 46 PageID #:

1551
31

Claim 10 of the ’802 Patent Prior Art Reference – Jäntti

separate structures. The minimization of transmission losses requires large, and expensive, cables at 

the base station. Separate structures require relatively much space owing to the large size of the 

power amplifier, in particular. Radio systems based on the WCDMA technology require the use of 

expensive and complex linear amplifiers as power amplifiers in transmitter operation. The need for a 

separate linear amplifier for each transmitter is a significant drawback

See, e.g., Jäntti at 1:27-43.

In a first preferred embodiment of the invention, shown in FIG. 3, the transmitter operation of two 

sectors is arranged in a centralized manner. The signal block 100 comprises for different sectors two 

transmitter units 300, 302 for generating the signals to be transmitted. Said signals generated by the 

different transmitter units have different frequencies. These different frequencies are typically 

implemented by generating in each transmitter unit for the signal a carrier that is on a different 

frequency than a carrier generated by another transmitter unit. The carrier is a wave with which a 

signal is modulated. In the modulation, the signal to be transmitted, including information, is 

combined with the carrier is the transmitter unit. When carriers are at different frequencies, they are 

typically on entirely different frequency ranges, or frequency bands.

The method and arrangement of the invention typically utilizes the WCDMA technology, associated 

with which linear modulation is used in signal processing. Referring still to FIG. 3, the signals having 

different carrier frequencies and modulated by the transmitter units are combined in an adder in the 

transmitter block. The adder is typically of the Wilkinson type, such as a Wilkinson hybrid adder. 

After the combination, the signals are amplified in a multifrequency amplifier 304 acting as the 

power amplifier of the amplifier block 102. In a system according to the WCDMA technology, a 

linear amplifier is used as the power amplifier 306, which enables the simultaneous processing of 

several signals at different frequencies. Herein, simultaneity means that signals at different 

frequencies are combined into signals combined with for example the adder 304, as was described 

above. In a typical case according to the invention, the multifrequency amplifier thus simultaneously 

amplifies at least two combined signals at different carrier frequencies.

See, e.g., Jäntti at 4:62-5:27.

Case 2:23-cv-00285-JRG-RSP Document 59-3 Filed 07/11/24 Page 32 of 46 PageID #:

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Claim 10 of the ’802 Patent Prior Art Reference – Jäntti

Furthermore, this claim element is obvious in light of Jäntti itself, when combined with any of the 

other references as charted for this claim element in Exs. A-1–A-31, First Supplemental Ex. AObviousness Chart, and/or when combined with the knowledge of one of ordinary skill in the art. 

Motivations to combine may come from the knowledge of the person of ordinary skill themselves, or 

from the known problems and predictable solutions as embodied in these references. Further 

motivations to combine references and additional details may be found in the Cover Pleading and 

First Supplemental Ex. A-Obviousness Chart.

Claim 13 of the ’802 Patent Prior Art Reference – Jäntti

[13.1] The method of claim 10 Jäntti discloses all the elements of claim 10 for all the reasons provided above.

[13.2] wherein the first digital 

signal is encoded using a first 

wireless protocol and the 

second digital signal is 

encoded using a second 

wireless protocol.

Jäntti discloses “wherein the first digital signal is encoded using a first wireless protocol and the 

second digital signal is encoded using a second wireless protocol.” 

Furthermore, this claim element is obvious in light of Jäntti itself, when combined with any of the 

other references as charted for this claim element in Exs. A-1–A-31, First Supplemental Ex. AObviousness Chart, and/or when combined with the knowledge of one of ordinary skill in the art. 

Motivations to combine may come from the knowledge of the person of ordinary skill themselves, or 

from the known problems and predictable solutions as embodied in these references. Further 

motivations to combine references and additional details may be found in the Cover Pleading and 

First Supplemental Ex. A-Obviousness Chart.

Claim 14 of the ’802 Patent Prior Art Reference – Jäntti

[14.1] The method of claim 10 Jäntti discloses all the elements of claim 10 for all the reasons provided above.

[14.2] wherein the second 

data is the same as the first 

Jäntti discloses “wherein the second data is the same as the first data, the method further comprising.” 

Case 2:23-cv-00285-JRG-RSP Document 59-3 Filed 07/11/24 Page 33 of 46 PageID #:

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Claim 14 of the ’802 Patent Prior Art Reference – Jäntti

data, the method further 

comprising:

Furthermore, this claim element is obvious in light of Jäntti itself, when combined with any of the 

other references as charted for this claim element in Exs. A-1–A-31, First Supplemental Ex. AObviousness Chart, and/or when combined with the knowledge of one of ordinary skill in the art. 

Motivations to combine may come from the knowledge of the person of ordinary skill themselves, or 

from the known problems and predictable solutions as embodied in these references. Further 

motivations to combine references and additional details may be found in the Cover Pleading and 

First Supplemental Ex. A-Obviousness Chart.

[14.3] receiving the 

transmitted signal on a second 

antenna;

Jäntti discloses “receiving the transmitted signal on a second antenna.” 

Furthermore, this claim element is obvious in light of Jäntti itself, when combined with any of the 

other references as charted for this claim element in Exs. A-1–A-31, First Supplemental Ex. AObviousness Chart, and/or when combined with the knowledge of one of ordinary skill in the art. 

Motivations to combine may come from the knowledge of the person of ordinary skill themselves, or 

from the known problems and predictable solutions as embodied in these references. Further 

motivations to combine references and additional details may be found in the Cover Pleading and 

First Supplemental Ex. A-Obviousness Chart.

[14.4] amplifying the received 

signal in a low noise amplifier 

resulting in an amplified 

received up-converted signal, 

wherein the bandwidth of said 

low noise amplifier is greater 

than the difference between 

the lowest frequency in the 

first up-converted frequency 

range and the highest 

frequency in the second upconverted frequency range;

Jäntti discloses “amplifying the received signal in a low noise amplifier resulting in an amplified 

received up-converted signal, wherein the bandwidth of said low noise amplifier is greater than the 

difference between the lowest frequency in the first up-converted frequency range and the highest 

frequency in the second up-converted frequency range.” 

Furthermore, this claim element is obvious in light of Jäntti itself, when combined with any of the 

other references as charted for this claim element in Exs. A-1–A-31, First Supplemental Ex. AObviousness Chart, and/or when combined with the knowledge of one of ordinary skill in the art. 

Motivations to combine may come from the knowledge of the person of ordinary skill themselves, or 

from the known problems and predictable solutions as embodied in these re ferences. Further 

motivations to combine references and additional details may be found in the Cover Pleading and 

First Supplemental Ex. A-Obviousness Chart.

[14.5] down-converting the 

amplified received upconverted signal using a first 

Jäntti discloses “down-converting the amplified received up-converted signal using a first downconverter and a signal corresponding to the first RF center frequency to produce a fourth analog 

signal corresponding to the first analog signal.” 

Case 2:23-cv-00285-JRG-RSP Document 59-3 Filed 07/11/24 Page 34 of 46 PageID #:

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Claim 14 of the ’802 Patent Prior Art Reference – Jäntti

down-converter and a signal 

corresponding to the first RF 

center frequency to produce a 

fourth analog signal 

corresponding to the first 

analog signal; and

Furthermore, this claim element is obvious in light of Jäntti itself, when combined with any of the 

other references as charted for this claim element in Exs. A-1–A-31, First Supplemental Ex. AObviousness Chart, and/or when combined with the knowledge of one of ordinary skill in the art. 

Motivations to combine may come from the knowledge of the person of ordinary skill themselves, or 

from the known problems and predictable solutions as embodied in these references. Further 

motivations to combine references and additional details may be found in the Cover Pleading a nd 

First Supplemental Ex. A-Obviousness Chart.

[14.6] down-converting the 

amplified received upconverted analog signal using 

a second down-converter and 

a signal corresponding to the 

second RF center frequency to 

produce a fifth analog signal 

corresponding to the second 

analog signal.

Jäntti discloses “down-converting the amplified received up-converted analog signal using a second 

down-converter and a signal corresponding to the second RF center frequency to produce a fifth 

analog signal corresponding to the second analog signal.” 

Furthermore, this claim element is obvious in light of Jäntti itself, when combined with any of the 

other references as charted for this claim element in Exs. A-1–A-31, First Supplemental Ex. AObviousness Chart, and/or when combined with the knowledge of one of ordinary skill in the art. 

Motivations to combine may come from the knowledge of the person of ordinary skill themselves, or 

from the known problems and predictable solutions as embodied in these references. Further 

motivations to combine references and additional details may be found in the Cover Pleading a nd 

First Supplemental Ex. A-Obviousness Chart.

Claim 17 of the ’802 Patent Prior Art Reference – Jäntti

[17.1] A wireless 

communication system 

comprising:

To the extent the preamble is limiting, Jäntti discloses “A wireless communication system 

comprising.” See, e.g.: 

Case 2:23-cv-00285-JRG-RSP Document 59-3 Filed 07/11/24 Page 35 of 46 PageID #:

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35

Claim 17 of the ’802 Patent Prior Art Reference – Jäntti

See, e.g., Jäntti at Figure 3.

The base stations in a mobile system are usually sectored to enhance transceiver operation. In 

accordance with prior art, the transmitter functions of two sectors having different carriers are 

implemented with different transmitters. Each sector-specific transmitter comprises a transmitter unit, 

a power amplifier and a filter unit, and cables between these units. The drawbacks of said separate 

structures include high costs due to the amounts of components and different cables called for by the 

Case 2:23-cv-00285-JRG-RSP Document 59-3 Filed 07/11/24 Page 36 of 46 PageID #:

1556
36

Claim 17 of the ’802 Patent Prior Art Reference – Jäntti

separate structures. The minimization of transmission losses requires large, and expensive, cables at 

the base station. Separate structures require relatively much space owing to the large size of the 

power amplifier, in particular. Radio systems based on the WCDMA technology require the use of 

expensive and complex linear amplifiers as power amplifiers in transmitter operation. The need for a 

separate linear amplifier for each transmitter is a significant drawback

See, e.g., Jäntti at 1:27-43.

In a first preferred embodiment of the invention, shown in FIG. 3, the transmitter operation of two 

sectors is arranged in a centralized manner. The signal block 100 comprises for different sectors two 

transmitter units 300, 302 for generating the signals to be transmitted. Said signals generated by the 

different transmitter units have different frequencies. These different frequencies are typically 

implemented by generating in each transmitter unit for the signal a carrier that is on a different 

frequency than a carrier generated by another transmitter unit. The carrier is a wave with which a 

signal is modulated. In the modulation, the signal to be transmitted, including information, is 

combined with the carrier is the transmitter unit. When carriers are at different frequencies, they are 

typically on entirely different frequency ranges, or frequency bands.

The method and arrangement of the invention typically utilizes the WCDMA technology, associated 

with which linear modulation is used in signal processing. Referring still to FIG. 3, the signals having 

different carrier frequencies and modulated by the transmitter units are combined in an adder in the 

transmitter block. The adder is typically of the Wilkinson type, such as a Wilkinson hybrid adder. 

After the combination, the signals are amplified in a multifrequency amplifier 304 acting as the 

power amplifier of the amplifier block 102. In a system according to the WCDMA technology, a 

linear amplifier is used as the power amplifier 306, which enables the simultaneous processing of 

several signals at different frequencies. Herein, simultaneity means that signals at different 

frequencies are combined into signals combined with for example the adder 304, as was described 

above. In a typical case according to the invention, the multifrequency amplifier thus simultaneously 

amplifies at least two combined signals at different carrier frequencies.

See, e.g., Jäntti at 4:62-5:27.

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Claim 17 of the ’802 Patent Prior Art Reference – Jäntti

Furthermore, this claim element is obvious in light of Jäntti itself, when combined with any of the 

other references as charted for this claim element in Exs. A-1–A-31, First Supplemental Ex. AObviousness Chart, and/or when combined with the knowledge of one of ordinary skill in the art. 

Motivations to combine may come from the knowledge of the person of ordinary skill themselves, or 

from the known problems and predictable solutions as embodied in these references. Further 

motivations to combine references and additional details may be found in the Cover Pleading and 

First Supplemental Ex. A-Obviousness Chart.

[17.2] a baseband digital 

system for providing a first 

digital signal comprising a 

first data to be transmitted and 

a second digital signal 

comprising a second data to 

be transmitted;

Jäntti discloses “a baseband digital system for providing a first digital signal comprising a first data to 

be transmitted and a second digital signal comprising a second data to be transmitted .” 

Furthermore, this claim element is obvious in light of Jäntti itself, when combined with any of the 

other references as charted for this claim element in Exs. A-1–A-31, First Supplemental Ex. AObviousness Chart, and/or when combined with the knowledge of one of ordinary skill in the art. 

Motivations to combine may come from the knowledge of the person of ordinary skill themselves, or 

from the known problems and predictable solutions as embodied in these references. Further 

motivations to combine references and additional details may be found in the Cover Pleading and 

First Supplemental Ex. A-Obviousness Chart.

[17.3] a first digital-to-analog 

converter for receiving the 

first digital signal and 

converting the first digital 

signal into a first analog 

signal, the first analog signal 

carrying the first data across a 

first frequency range;

Jäntti discloses “a first digital-to-analog converter for receiving the first digital signal and converting 

the first digital signal into a first analog signal, the first analog signal carrying the first data across a 

first frequency range.” 

Furthermore, this claim element is obvious in light of Jäntti itself, when combined with any of the 

other references as charted for this claim element in Exs. A-1–A-31, First Supplemental Ex. AObviousness Chart, and/or when combined with the knowledge of one of ordinary skill in the art. 

Motivations to combine may come from the knowledge of the person of ordinary skill themselves, or 

from the known problems and predictable solutions as embodied in these references. Further 

motivations to combine references and additional details may be found in the Cover Pleading and 

First Supplemental Ex. A-Obviousness Chart.

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Claim 17 of the ’802 Patent Prior Art Reference – Jäntti

[17.4] a second digital-toanalog converter for receiving 

the second digital signal and 

converting the second digital 

signal into a second analog 

signal, the second analog 

signal carrying the second 

data across a second 

frequency range;

Jäntti discloses “a second digital-to-analog converter for receiving the second digital signal and 

converting the second digital signal into a second analog signal, the second analog signal carrying the 

second data across a second frequency range.” 

Furthermore, this claim element is obvious in light of Jäntti itself, when combined with any of the 

other references as charted for this claim element in Exs. A-1–A-31, First Supplemental Ex. AObviousness Chart, and/or when combined with the knowledge of one of ordinary skill in the art. 

Motivations to combine may come from the knowledge of the person of ordinary skill themselves, or 

from the known problems and predictable solutions as embodied in these reference s. Further 

motivations to combine references and additional details may be found in the Cover Pleading and 

First Supplemental Ex. A-Obviousness Chart.

[17.5] a first up-converter 

circuit having a first input 

coupled to receive the first 

analog signal and a second 

input coupled to receive a first 

modulation signal having a 

first RF frequency, wherein 

the first up-converter outputs 

a first up-converted analog 

signal comprising a first upconverted frequency range 

from the first RF frequency 

minus one-half the first 

frequency range to the first 

RF frequency plus one-half 

the first frequency range;

Jäntti discloses “a first up-converter circuit having a first input coupled to receive the first analog 

signal and a second input coupled to receive a first modulation signal having a first RF frequency, 

wherein the first up-converter outputs a first up-converted analog signal comprising a first upconverted frequency range from the first RF frequency minus one-half the first frequency range to the 

first RF frequency plus one-half the first frequency range.” 

Furthermore, this claim element is obvious in light of Jäntti itself, when combined with any of the 

other references as charted for this claim element in Exs. A-1–A-31, First Supplemental Ex. AObviousness Chart, and/or when combined with the knowledge of one of ordinary skill in the art. 

Motivations to combine may come from the knowledge of the person of ordinary skill themselves, or 

from the known problems and predictable solutions as embodied in these references. Further 

motivations to combine references and additional details may be found in the Cover Pleading and 

First Supplemental Ex. A-Obviousness Chart.

[17.6] a second up-converter 

circuit having a first input 

coupled to receive the second 

analog signal and a second 

Jäntti discloses “a second up-converter circuit having a first input coupled to receive the second 

analog signal and a second input coupled to receive a second modulation signal having a se cond RF 

frequency, wherein the second up-converter outputs a second up-converted analog signal comprising 

a second up-converted frequency range from the second RF frequency minus one-half the second 

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Claim 17 of the ’802 Patent Prior Art Reference – Jäntti

input coupled to receive a 

second modulation signal 

having a second RF 

frequency, wherein the second 

up-converter outputs a second 

up-converted analog signal 

comprising a second upconverted frequency range 

from the second RF frequency 

minus one-half the second 

frequency range to the second 

RF frequency plus one-half 

the second frequency range, 

and wherein frequency 

difference between the first 

RF frequency and the second 

RF frequency is greater than 

the sum of one-half the first 

frequency range and one-half 

the second frequency range; 

and

frequency range to the second RF frequency plus one-half the second frequency range, and wherein 

frequency difference between the first RF frequency and the second RF frequency is greater than the 

sum of one-half the first frequency range and one-half the second frequency range.” 

Furthermore, this claim element is obvious in light of Jäntti itself, when combined with any of the 

other references as charted for this claim element in Exs. A-1–A-31, First Supplemental Ex. AObviousness Chart, and/or when combined with the knowledge of one of ordinary skill in the art. 

Motivations to combine may come from the knowledge of the person of ordinary skill themselves, or 

from the known problems and predictable solutions as embodied in these reference s. Further 

motivations to combine references and additional details may be found in the Cover Pleading and 

First Supplemental Ex. A-Obviousness Chart.

[17.7] a power amplifier 

coupled to receive the first 

and second up-converted 

analog signals, wherein the 

bandwidth of the power 

amplifier is greater than the 

difference between a lowest 

frequency in the first upconverted frequency range 

and a highest frequency in the 

Jäntti discloses “a power amplifier coupled to receive the first and second up-converted analog 

signals, wherein the bandwidth of the power amplifier is greater than the difference between a lowest 

frequency in the first up-converted frequency range and a highest frequency in the second upconverted frequency range.” See, e.g.: 

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Claim 17 of the ’802 Patent Prior Art Reference – Jäntti

second up-converted 

frequency range.

See, e.g., Jäntti at Figure 3.

The base stations in a mobile system are usually sectored to enhance transceiver operation. In 

accordance with prior art, the transmitter functions of two sectors having different carriers are 

implemented with different transmitters. Each sector-specific transmitter comprises a transmitter unit, 

a power amplifier and a filter unit, and cables between these units. The drawbacks of said separate 

structures include high costs due to the amounts of components and different cables called for by the 

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Claim 17 of the ’802 Patent Prior Art Reference – Jäntti

separate structures. The minimization of transmission losses requires large, and expensive, cables at 

the base station. Separate structures require relatively much space owing to the large size of the 

power amplifier, in particular. Radio systems based on the WCDMA technology require the use of 

expensive and complex linear amplifiers as power amplifiers in transmitter operation. The need for a 

separate linear amplifier for each transmitter is a significant drawback

See, e.g., Jäntti at 1:27-43.

In a first preferred embodiment of the invention, shown in FIG. 3, the transmitter operation of two 

sectors is arranged in a centralized manner. The signal block 100 comprises for different sectors two 

transmitter units 300, 302 for generating the signals to be transmitted. Said signals generated by the 

different transmitter units have different frequencies. These different frequencies are typically 

implemented by generating in each transmitter unit for the signal a carrier that is on a different 

frequency than a carrier generated by another transmitter unit. The carrier is a wave with which a 

signal is modulated. In the modulation, the signal to be transmitted, including information, is 

combined with the carrier is the transmitter unit. When carriers are at different frequencies, they are 

typically on entirely different frequency ranges, or frequency bands.

The method and arrangement of the invention typically utilizes the WCDMA technology, associated 

with which linear modulation is used in signal processing. Referring still to FIG. 3, the signals having 

different carrier frequencies and modulated by the transmitter units are combined in an adder in the 

transmitter block. The adder is typically of the Wilkinson type, such as a Wilkinson hybrid adder. 

After the combination, the signals are amplified in a multifrequency amplifier 304 acting as the 

power amplifier of the amplifier block 102. In a system according to the WCDMA technology, a 

linear amplifier is used as the power amplifier 306, which enables the simultaneous processing of 

several signals at different frequencies. Herein, simultaneity means that signals at different 

frequencies are combined into signals combined with for example the adder 304, as was described 

above. In a typical case according to the invention, the multifrequency amplifier thus simultaneously 

amplifies at least two combined signals at different carrier frequencies.

See, e.g., Jäntti at 4:62-5:27.

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Claim 17 of the ’802 Patent Prior Art Reference – Jäntti

Furthermore, this claim element is obvious in light of Jäntti itself, when combined with any of the 

other references as charted for this claim element in Exs. A-1–A-31, First Supplemental Ex. AObviousness Chart, and/or when combined with the knowledge of one of ordinary skill in the art. 

Motivations to combine may come from the knowledge of the person of ordinary skill themselves, or 

from the known problems and predictable solutions as embodied in these references. Further 

motivations to combine references and additional details may be found in the Cover Pleading and 

First Supplemental Ex. A-Obviousness Chart.

Claim 21 of the ’802 Patent Prior Art Reference – Jäntti

[21.1] The communication 

system of claim 17

Jäntti discloses all the elements of claim 17 for all the reasons provided above.

[21.2] wherein the first data of 

the first digital signal is 

encoded using a first wireless 

protocol and the first data of 

the second digital signal is 

encoded using a second 

wireless protocol.

Jäntti discloses “wherein the first data of the first digital signal is encoded using a first wireless 

protocol and the first data of the second digital signal is encoded using a second wireless protocol.” 

Furthermore, this claim element is obvious in light of Jäntti itself, when combined with any of the 

other references as charted for this claim element in Exs. A-1–A-31, First Supplemental Ex. AObviousness Chart, and/or when combined with the knowledge of one of ordinary skill in the art. 

Motivations to combine may come from the knowledge of the person of ordinary skill themselves, or 

from the known problems and predictable solutions as embodied in these references. Further 

motivations to combine references and additional details may be found in the Cover Pleading and 

First Supplemental Ex. A-Obviousness Chart.

Claim 22 of the ’802 Patent Prior Art Reference – Jäntti

[22.1] The communication 

system of claim 17

Jäntti discloses all the elements of claim 17 for all the reasons provided above.

[22.2] wherein the second 

data corresponds to the first 

data and wherein the power 

Jäntti discloses “wherein the second data corresponds to the first data and wherein the power 

amplifier outputs a third up-converted signal comprising the up-converted first analog signal and the 

up-converted second analog signal.” 

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Claim 22 of the ’802 Patent Prior Art Reference – Jäntti

amplifier outputs a third upconverted signal comprising 

the up-converted first analog 

signal and the up-converted 

second analog signal.

Furthermore, this claim element is obvious in light of Jäntti itself, when combined with any of the 

other references as charted for this claim element in Exs. A-1–A-31, First Supplemental Ex. AObviousness Chart, and/or when combined with the knowledge of one of ordinary skill in the art. 

Motivations to combine may come from the knowledge of the person of ordinary skill themselves, or 

from the known problems and predictable solutions as embodied in these references. Further 

motivations to combine references and additional details may be found in the Cover Pleading and 

First Supplemental Ex. A-Obviousness Chart.

Claim 23 of the ’802 Patent Prior Art Reference – Jäntti

[23.1] The communication 

system of claim 17

Jäntti discloses all the elements of claim 17 for all the reasons provided above.

[23.2] wherein first and 

second data to be transmitted 

comprise a plurality of OFDM 

symbols, wherein a first 

symbol is transmitted during a 

first time slot across the first 

up-converted frequency range 

and a second symbol is 

transmitted during the first 

time slot across the second 

up-converted frequency range, 

and wherein a third symbol is 

transmitted during a second 

time slot across the first upconverted frequency range 

and a fourth symbol is 

transmitted during the second 

Jäntti discloses “wherein first and second data to be transmitted comprise a plurality of OFDM 

symbols, wherein a first symbol is transmitted during a first time slot across the first up -converted 

frequency range and a second symbol is transmitted during the first time slot across the second upconverted frequency range, and wherein a third symbol is transmitted during a second time slot 

across the first up-converted frequency range and a fourth symbol is transmitted during the second 

time slot across a second up-converted frequency range.” 

Furthermore, this claim element is obvious in light of Jäntti itself, when combined with any of the 

other references as charted for this claim element in Exs. A-1–A-31, First Supplemental Ex. AObviousness Chart, and/or when combined with the knowledge of one of ordinary skill in the art. 

Motivations to combine may come from the knowledge of the person of ordinary skill themselves, or 

from the known problems and predictable solutions as embodied in these references. Further 

motivations to combine references and additional details may be found in the Cover Pleading and 

First Supplemental Ex. A-Obviousness Chart.

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Claim 23 of the ’802 Patent Prior Art Reference – Jäntti

time slot across a second upconverted frequency range.

Claim 24 of the ’802 Patent Prior Art Reference – Jäntti

[24.1] An electronic circuit 

comprising:

To the extent the preamble is limiting, Jäntti discloses “An electronic circuit comprising.” 

Furthermore, this claim element is obvious in light of Jäntti itself, when combined with any of the 

other references as charted for this claim element in Exs. A-1–A-31, First Supplemental Ex. AObviousness Chart, and/or when combined with the knowledge of one of ordinary skill in the art. 

Motivations to combine may come from the knowledge of the person of ordinary skill themselves, or 

from the known problems and predictable solutions as embodied in these references. Further 

motivations to combine references and additional details may be found in the Cover Pleading a nd 

First Supplemental Ex. A-Obviousness Chart.

[24.2] a first down-converter 

circuit having a first input 

coupled to receive a first upconverted signal, a second 

input coupled to receive a first 

demodulation signal having a 

first RF frequency, and an 

output, wherein the first 

down-converter circuit 

outputs a first down-converted 

signal on the first downconverter output;

Jäntti discloses “a first down-converter circuit having a first input coupled to receive a first upconverted signal, a second input coupled to receive a first demodulation signal having a first RF 

frequency, and an output, wherein the first down-converter circuit outputs a first down-converted 

signal on the first down-converter output.” 

Furthermore, this claim element is obvious in light of Jäntti itself, when combined with any of the 

other references as charted for this claim element in Exs. A-1–A-31, First Supplemental Ex. AObviousness Chart, and/or when combined with the knowledge of one of ordinary skill in the art. 

Motivations to combine may come from the knowledge of the person of ordinary skill themselves, or 

from the known problems and predictable solutions as embodied in these references. Further 

motivations to combine references and additional details may be found in the Cover Pleading and 

First Supplemental Ex. A-Obviousness Chart.

[24.3] a second downconverter circuit having a first 

input coupled to receive the 

Jäntti discloses “a second down-converter circuit having a first input coupled to receive the first upconverted signal, a second input coupled to receive a second demodulation signal having a second RF 

frequency different than the first RF frequency, and an output, wherein the second down -converter 

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Claim 24 of the ’802 Patent Prior Art Reference – Jäntti

first up-converted signal, a 

second input coupled to 

receive a second 

demodulation signal having a 

second RF frequency different 

than the first RF frequency, 

and an output, wherein the 

second down-converter 

outputs a second downconverted signal on the 

second down-converter 

output, wherein the first upconverted signal comprises a 

first signal modulated at the 

first RF frequency and a 

second signal modulated at 

the second RF frequency; and

outputs a second down-converted signal on the second down-converter output, wherein the first upconverted signal comprises a first signal modulated at the first RF frequency and a second signal 

modulated at the second RF frequency.” 

Furthermore, this claim element is obvious in light of Jäntti itself, when combined with any of the 

other references as charted for this claim element in Exs. A-1–A-31, First Supplemental Ex. AObviousness Chart, and/or when combined with the knowledge of one of ordinary skill in the art. 

Motivations to combine may come from the knowledge of the person of ordinary skill themselves, or 

from the known problems and predictable solutions as embodied in these references. Further 

motivations to combine references and additional details may be found in the Cover Pleading and 

First Supplemental Ex. A-Obviousness Chart.

[24.4] a filter having an input 

coupled to the output of the 

first down-converter and the 

output of the second downconverter, and in accordance 

therewith, the filter receives 

the first and second downconverted signals.

Jäntti discloses “a filter having an input coupled to the output of the first down-converter and the 

output of the second down-converter, and in accordance therewith, the filter receives the first and 

second down-converted signals.” 

Furthermore, this claim element is obvious in light of Jäntti itself, when combined with any of the 

other references as charted for this claim element in Exs. A-1–A-31, First Supplemental Ex. AObviousness Chart, and/or when combined with the knowledge of one of ordinary skill in the art. 

Motivations to combine may come from the knowledge of the person of ordinary skill themselves, or 

from the known problems and predictable solutions as embodied in these references. Further 

motivations to combine references and additional details may be found in the Cover Pleading and 

First Supplemental Ex. A-Obviousness Chart.

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