EXHIBIT M

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 1 of 946 PageID #:

4105
1

Exhibit A-31

Invalidity Claim Chart for U.S. Patent No. 7,924,802 vs. IEEE Std. 802.11-2007

IEEE Standard 802.11-2007 (“802.11-2007”) was completed in March 2007 and published in June 2007. 802.11-2007 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. 802.11-

2007 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 802.11-2007 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 o f the ’802

Patent to modify 802.11-2007 and/or to combine the teachings of 802.11-2007 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 ince ntives 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 comb ine the 

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. 

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 2 of 946 PageID #:

4106
2

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 ab ove. 

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 during discovery as the case progresses. 

Claim 1 of the ’802 Patent Prior Art Reference – 802.11-2007

[1.1] A method of 

transmitting information in a 

wireless communication 

channel comprising:

To the extent the preamble is limiting, 802.11-2007 discloses “A method of transmitting information 

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

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 3 of 946 PageID #:

4107
3

Claim 1 of the ’802 Patent Prior Art Reference – 802.11-2007

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 4 of 946 PageID #:

4108
4

See, e.g., 802.11-2007 § 17.3.3

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 5 of 946 PageID #:

4109
5

Claim 1 of the ’802 Patent Prior Art Reference – 802.11-2007

Furthermore, this claim element is obvious in light of 802.11-2007 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.

[1.2] 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; and

802.11-2007 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.: 

1.1 Scope

The scope of this standard is to define one medium access control (MAC) and several physical layer (PHY)

specifications for wireless connectivity for fixed, portable, and moving stations (STAs) within a loca l area.

See, e.g., 802.11-2007 § 1.1

5.1.1 How WLAN systems are different

Wireless networks have fundamental characteristics that make them significantly different from traditional

wired LANs. Some countries impose specific requirements for radio equipment in addition to those

specified in this standard. This standard does not provide information to meet these country -specific radio

regulations.

5.1.1.1 Destination address does not equal destination location

In wired LANs, an address is equivalent to a physical location. This is implicitly assumed in the design of

wired LANs. In IEEE Std 802.11, the addressable unit is a station (STA). The STA is a message destination,

but not (in general) a fixed location.

5.1.1.2 Media impact on design and performance

The PHYs used in IEEE Std 802.11 are fundamentally different from wired media. Thus IEEE 802.11 PHYs

a) Use a medium that has neither absolute nor readily observable boundaries outside of which STAs

with conformant PHY transceivers are known to be unable to receive network frames

b) Are unprotected from other signals that may be sharing the medium

c) Communicate over a medium significantly less reliable than wired PHYs

d) Have dynamic topologies

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 6 of 946 PageID #:

4110
6

Claim 1 of the ’802 Patent Prior Art Reference – 802.11-2007

e) Lack full connectivity, and therefore the assumption normally made that every STA can hear every

other STA is invalid (i.e., STAs may be “hidden” from each other)

f) Have time-varying and asymmetric propagation properties

g) May experience interference from logically disjoint IEEE 802.11 networks operating in overlapping

areas

Because of limitations on wireless PHY ranges, WLANs intended to cover reasonable geographic distances

may be built from basic coverage building blocks. When providing QoS services it should be understood

that the MAC endeavors to provide QoS “service guarantees” within the limitations of the medium

properties identified above. In other words, particularly in unlicensed spectrum, true guarantees are often not

possible. However, gradations of service are always possible; and in sufficiently controlled environments,

QoS guarantees can truly be made.

5.1.1.3 The impact of handling mobile STAs

One of the requirements of IEEE Std 802.11 is to handle mobile as well as portable STAs. A portable STA

is one that is moved from location to location, but that is only used while at a fixed location. Mobile STAs

actually access the LAN while in motion.

For technical reasons, it is not sufficient to handle only portable STAs. Propagation effects blur the

distinction between portable and mobile STAs; stationary STAs often appear to be mobile due to

propagation effects.

Another aspect of mobile STAs is that they may often be battery powered. Hence power management is

an important consideration. For example, it cannot be presumed that a STA’s receiver will always be

powered on.

See, e.g., 802.11-2007 § 5.1.1 - § 5.1.1.3

5.2 Components of the IEEE 802.11 architecture

The IEEE 802.11 architecture consists of several components that interact to provide a WLAN that supports

STA mobility transparently to upper layers.

The basic service set (BSS) is the basic building block of an IEEE 802.11 LAN. Figure 5 -1 shows two BSSs,

each of which has two STAs that are members of the BSS.

It is useful to think of the ovals used to depict a BSS as the coverage area within which the member STAs of

the BSS may remain in communication. (The concept of area, while not precise, is often good enough.) This

area is called the Basic Service Area (BSA). If a STA moves out of its BSA, it can no longer directly

communicate with other STAs present in the BSA.

See, e.g., 802.11-2007 § 5.2

5.2.3 Distribution system (DS) concepts

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 7 of 946 PageID #:

4111
7

Claim 1 of the ’802 Patent Prior Art Reference – 802.11-2007

PHY limitations determine the direct station-to-station distance that may be supported. For some networks

this distance is sufficient; for other networks, increased coverage is required.

Instead of existing independently, a BSS may also form a component of an extended form of network that is

built with multiple BSSs. The architectural component used to interconnect BSSs is the DS.

IEEE Std 802.11 logically separates the WM from the distribution system medium (DSM). Each logical

medium is used for different purposes, by a different component of the architecture. The IEEE 802.11

definitions neither preclude, nor demand, that the multiple media be either the same or different.

Recognizing that the multiple media are logically different is key to understanding the flexibility of the

architecture. The IEEE 802.11 LAN architecture is specified independently of the physical characteristics of

any specific implementation.

The DS enables mobile device support by providing the logical services necessary to handle address to

destination mapping and seamless integration of multiple BSSs.

An access point (AP) is any entity that has STA functionality and enables access to the DS, via the WM for

associated STAs.

See, e.g., 802.11-2007 § 5.2.3

5.3.2 DSS

The service provided by the DS is known as the DSS.

This service is represented in the IEEE 802.11 architecture by arrows within the APs, indicating that the

service is used to cross media and possibly address space logical boundaries. An AP is a logical entity, and

the functions described may be shared by one or more physical entities.

The services that comprise the DSS are as follows:

a) Association

b) Disassociation

c) Distribution

d) Integration

e) Reassociation

f) QoS traffic scheduling (QoS facility only)

DSSs are specified for use by MAC sublayer entities.

Figure 5-7 combines the components from previous figures with both types of services to show the complete

IEEE 802.11 architecture.

See, e.g., 802.11-2007 § 5.3.2

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 8 of 946 PageID #:

4112
8

Claim 1 of the ’802 Patent Prior Art Reference – 802.11-2007

5.4.4.1 TPC

Radio regulations may require radio local area networks (RLANs) operating in the 5 GHz band to use

transmitter power control, involving specification of a regulatory maximum transmit power and a mitigation

requirement for each allowed channel, to reduce interference with satellite services. The TPC service is used

to satisfy this regulatory requirement.

The TPC service provides for the following:

— Association of STAs with an AP in a BSS based on the STAs’ power capability.

— Specification of regulatory and local maximum transmit power levels for the current channel.

— Selection of a transmit power for each transmission in a channel within constraints imposed by

regulatory requirements.

— Adaptation of transmit power based on a range of information, including path loss and link margin

estimates.

See, e.g., 802.11-2007 § 5.4.4.1

7.3.2.20 Channel Switch Announcement element

The Channel Switch Announcement element is used by an AP in a BSS or a STA in an IBSS to advertise

when it is changing to a new channel and the channel number of the new channel. The format of the Channel

Switch Announcement element is shown in Figure 7-57.

See, e.g., 802.11-2007 § 7.3.2.20

10.3.11 Spectrum management protocol layer model

The layer management extensions for measurement and channel switching assume a certain partition

of spectrum management functionality between the MLME and SME. This partitioning assumes that

policy decisions (e.g., regarding measurement and channel switching) reside in the SME, while the protocol

for measurement, switch timing, and the associated frame exchanges resides within the MLME (see

Figure 10-2).

...

The informative diagrams within this subclause further illustrate the spectrum management protocol model

adopted. Figure 10-3 and Figure 10-4 depict the measurement process for a peer STA to accept and reject a

measurement request, respectively. Figure 10-5 illustrates the TPC adaptation process. Lastly, Figure 10-6

depicts the management process for a channel switch using a Channel Switch Announcement frame.

See, e.g., 802.11-2007 § 10.3.11

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 9 of 946 PageID #:

4113
9

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 10 of 946 PageID #:

4114
10

Claim 1 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 § 10.4.3.2

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 11 of 946 PageID #:

4115
11

Claim 1 of the ’802 Patent Prior Art Reference – 802.11-2007

17.1 Introduction

This clause specifies the PHY entity for an orthogonal frequency division multiplexing (OFDM) system.

The OFDM system provides a WLAN with data payload communication capabilities of 6, 9, 12, 18, 24, 36,

48, and 54 Mb/s. The support of transmitting and receiving at data rates of 6, 12, and 24 Mb/s is mandatory.

The system uses 52 subcarriers that are modulated using binary or quadrature phase shift keying (BPSK or

QPSK) or using 16- or 64-quadrature amplitude modulation (16-QAM or 64-QAM). Forward error

correction coding (convolutional coding) is used with a coding rate of 1/2, 2/3, or 3/4.

The OFDM system also provides a “half-clocked” operation using 10 MHz channel spacings with data

communications capabilities of 3, 4.5, 6, 9, 12, 18, 24, and 27 Mb/s. The support of transmitting and

receiving at data rates of 3, 6, and 12 Mb/s is mandatory when using 10 MHz channel spacing. The halfclocked

operation doubles symbol times and clear channel assessment (CCA) times when using 10 MHz

channel spacing. The regulatory requirements and information regarding use of this OFDM system in

4.9 GHz and 5 GHz bands is in Annex I and Annex J.

The OFDM system also provides a “quarter-clocked” operation using 5 MHz channel spacing with data

communication capabilities of 1.5, 2.25, 3, 4.5, 6, 9, 12, and 13.5 Mb/s. The support of transmitting and

receiving at data rates of 1.5, 3, and 6 Mb/s is mandatory when using 5 MHz channel spacing. The quarterclocked

operation quadruples symbol times and CCA times when using 5 MHz channel spacing. The

regulatory requirements and information regarding use of this OFDM system in the 4.9 GHz band is in

Annex I and Annex J.

See, e.g., 802.11-2007 § 17.1

17.3.2.1 Overview of the PPDU encoding process

The encoding process is composed of many detailed steps, which are described fully in later subclauses, as

noted below. The following overview intends to facilitate understanding the details of the convergence

procedure:

a) Produce the PLCP Preamble field, composed of 10 repetitions of a “short training sequence” (used

for AGC convergence, diversity selection, timing acquisition, and coarse frequency acquisition in

the receiver) and two repetitions of a “long training sequence” (used for channel estimation and fine

frequency acquisition in the receiver), preceded by a guard interval (GI). Refer to 17.3.3 for details.

b) Produce the PLCP header field from the RATE, LENGTH, and SERVICE fields of the

TXVECTOR by filling the appropriate bit fields. The RATE and LENGTH fields of the PLCP

header are encoded by a convolutional code at a rate of R = 1/2, and are subsequently mapped onto a

single BPSK encoded OFDM symbol, denoted as the SIGNAL symbol. In order to facilitate a

reliable and timely detection of the RATE and LENGTH fields, 6 zero tail bits are inserted into the

PLCP header. The encoding of the SIGNAL field into an OFDM symbol follows the same steps for

convolutional encoding, interleaving, BPSK modulation, pilot insertion, Fourier transform, and

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 12 of 946 PageID #:

4116
12

Claim 1 of the ’802 Patent Prior Art Reference – 802.11-2007

prepending a GI as described subsequently for data transmission with BPSK-OFDM modulated at

coding rate 1/2. The contents of the SIGNAL field are not scrambled. Refer to 17.3.4 for details.

c) Calculate from RATE field of the TXVECTOR the number of data bits per OFDM symbol (NDBPS),

the coding rate (R), the number of bits in each OFDM subcarrier (NBPSC), and the number of coded

bits per OFDM symbol (NCBPS). Refer to 17.3.2.2 for details.

d) Append the PSDU to the SERVICE field of the TXVECTOR. Extend the resulting bit string with

zero bits (at least 6 bits) so that the resulting length will be a multiple of NDBPS. The resulting bit

string constitutes the DATA part of the packet. Refer to 17.3.5.3 for details.

e) Initiate the scrambler with a pseudo-random nonzero seed, generate a scrambling sequence, and

XOR it with the extended string of data bits. Refer to 17.3.5.4 for details.

f) Replace the six scrambled zero bits following the data with six nonscrambled zero bits. (Those bits

return the convolutional encoder to the zero state and are denoted as tail bits.) Refer to 17.3.5.2 for

details.

g) Encode the extended, scrambled data string with a convolutional encoder (R = 1/2). Omit (puncture)

some of the encoder output string (chosen according to “puncturing pattern”) to reach the desired

“coding rate.” Refer to 17.3.5.5 for details.

h) Divide the encoded bit string into groups of NCBPS bits. Within each group, perform an

“interleaving” (reordering) of the bits according to a rule corresponding to the desired RATE. Refer

to 17.3.5.6 for details.

i) Divide the resulting coded and interleaved data string into groups of NCBPS bits. For each of the bit

groups, convert the bit group into a complex number according to the modulation encoding tables.

Refer to 17.3.5.7 for details.

j) Divide the complex number string into groups of 48 complex numbers. Each such group will be

associated with one OFDM symbol. In each group, the complex numbers will be numbered 0 to 47

and mapped hereafter into OFDM subcarriers numbered –26 to –22, –20 to –8, –6 to –1, 1 to 6,

8 to 20, and 22 to 26. The subcarriers –21, –7, 7, and 21 are skipped and, subsequently, used for

inserting pilot subcarriers. The 0 subcarrier, associated with center frequency, is omitted and filled

with zero value. Refer to 17.3.5.9 for details.

k) Four subcarriers are inserted as pilots into positions –21, –7, 7, and 21. The total number of the

subcarriers is 52 (48 + 4). Refer to 17.3.5.8 for details.

l) For each group of subcarriers –26 to 26, convert the subcarriers to time domain using inverse

Fourier transform. Prepend to the Fourier-transformed waveform a circular extension of itself thus

forming a GI, and truncate the resulting periodic waveform to a single OFDM symbol length by

applying time domain windowing. Refer to 17.3.5.9 for details.

m) Append the OFDM symbols one after another, starting after the SIGNAL symbol describing the

RATE and LENGTH fields. Refer to 17.3.5.9 for details.

n) Up-convert the resulting “complex baseband” waveform to an RF according to the cen ter frequency

of the desired channel and transmit. Refer to 17.3.2.4 and 17.3.8.1 for details.

An illustration of the transmitted frame and its parts appears in Figure 17-4 (in 17.3.3).

See, e.g., 802.11-2007 § 17.3.2.1

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 13 of 946 PageID #:

4117
13

Claim 1 of the ’802 Patent Prior Art Reference – 802.11-2007

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 14 of 946 PageID #:

4118
14

Claim 1 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 § 17.3.2.3

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 15 of 946 PageID #:

4119
15

Claim 1 of the ’802 Patent Prior Art Reference – 802.11-2007

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 16 of 946 PageID #:

4120
16

Claim 1 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 § 17.3.2.4 Eq. (17-1)

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 17 of 946 PageID #:

4121
17

Claim 1 of the ’802 Patent Prior Art Reference – 802.11-2007

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 18 of 946 PageID #:

4122
18

Claim 1 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 § 17.3.2.5

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 19 of 946 PageID #:

4123
19

Claim 1 of the ’802 Patent Prior Art Reference – 802.11-2007

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 20 of 946 PageID #:

4124
20

See, e.g., 802.11-2007 § 17.3.3

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 21 of 946 PageID #:

4125
21

Claim 1 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 § 17.3.5.7

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 22 of 946 PageID #:

4126
22

Claim 1 of the ’802 Patent Prior Art Reference – 802.11-2007

17.3.5.8 Pilot subcarriers

In each OFDM symbol, four of the subcarriers are dedicated to pilot signals in order to make the coherent

detection robust against frequency offsets and phase noise. These pilot signals shall be put in subcarriers

–21, –7, 7, and 21. The pilots shall be BPSK modulated by a pseudo-binary sequence to prevent the

generation of spectral lines. The contribution of the pilot subcarriers to each OFDM symbol is described in

17.3.5.9.

See, e.g., 802.11-2007 § 17.3.5.8

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 23 of 946 PageID #:

4127
23

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 24 of 946 PageID #:

4128
24

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 25 of 946 PageID #:

4129
25

Claim 1 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 § 17.3.5.9

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 26 of 946 PageID #:

4130
26

Claim 1 of the ’802 Patent Prior Art Reference – 802.11-2007

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 27 of 946 PageID #:

4131
27

Claim 1 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 § 17.3.8.1

17.3.8.3.1 Operating frequency range

The OFDM PHY shall operate in the 5 GHz band, as allocated by a regulatory body in its operational region.

Spectrum allocation in the 5 GHz band is subject to authorities responsible for geographic-specific

regulatory domains (e.g., global, regional, and national). The particular channelization to be used for this

standard is dependent on such allocation, as well as the associated regulations for use of the allocations.

These regulations are subject to revision, or may be superseded.

In some regulatory domains, several frequency bands may be available for OFDM PHY-based WLANs.

These bands may be contiguous or not, and different regulatory limits may be applicable. A compliant

OFDM PHY shall support at least one frequency band in at least one regulatory domain. The support of

specific regulatory domains, and bands within the domains, shall be indicated by PLME attributes

dot11RegDomainsSupported and dot11FrequencyBandsSupported.

See, e.g., 802.11-2007 § 17.3.8.3.1

17.3.9.1 Transmit power levels

The maximum allowable transmit power by regulatory domain is defined in Annex I.

See, e.g., 802.11-2007 § 17.3.9.1

17.3.9.6.2 Transmitter spectral flatness

The average energy of the constellations in each of the spectral lines –16.. –1 and +1.. +16 will deviate no

more than ± 2 dB from their average energy. The average energy of the constellations in each of the spectral

lines –26.. –17 and +17.. +26 will deviate no more than +2/–4 dB from the average energy of spectral lines

–16.. –1 and +1.. +16. The data for this test shall be derived from the channel estimation step.

See, e.g., 802.11-2007 § 17.3.9.6.2

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 28 of 946 PageID #:

4132
28

Claim 1 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 § I.2.2

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 29 of 946 PageID #:

4133
29

Claim 1 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 § I.2.3

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 30 of 946 PageID #:

4134
30

Claim 1 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 Figure 5-7

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 31 of 946 PageID #:

4135
31

Claim 1 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 Figure 10-6

Furthermore, this claim element is obvious in light of 802.11-2007 itself, when combined with any of 

the other references as charted for this claim element in Exs. A-1–A-31, First Supplemental Ex. ACase 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 32 of 946 PageID #:

4136
32

Claim 1 of the ’802 Patent Prior Art Reference – 802.11-2007

Obviousness 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.

[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.

802.11-2007 discloses “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.” See, e.g.: 

1.1 Scope

The scope of this standard is to define one medium access control (MAC) and several physical layer (PHY)

specifications for wireless connectivity for fixed, portable, and moving stations (STAs) within a local area.

See, e.g., 802.11-2007 § 1.1

5.1.1 How WLAN systems are different

Wireless networks have fundamental characteristics that make them significantly different from traditional

wired LANs. Some countries impose specific requirements for radio equipment in addition to those

specified in this standard. This standard does not provide information to meet these country-specific radio

regulations.

5.1.1.1 Destination address does not equal destination location

In wired LANs, an address is equivalent to a physical location. This is implicitly assumed in the design of

wired LANs. In IEEE Std 802.11, the addressable unit is a station (STA). The STA is a message destination,

but not (in general) a fixed location.

5.1.1.2 Media impact on design and performance

The PHYs used in IEEE Std 802.11 are fundamentally different from wired media. Thu s IEEE 802.11 PHYs

a) Use a medium that has neither absolute nor readily observable boundaries outside of which STAs

with conformant PHY transceivers are known to be unable to receive network frames

b) Are unprotected from other signals that may be sharing the medium

c) Communicate over a medium significantly less reliable than wired PHYs

d) Have dynamic topologies

e) Lack full connectivity, and therefore the assumption normally made that every STA can hear every

other STA is invalid (i.e., STAs may be “hidden” from each other)

f) Have time-varying and asymmetric propagation properties

g) May experience interference from logically disjoint IEEE 802.11 networks operating in overlapping

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 33 of 946 PageID #:

4137
33

Claim 1 of the ’802 Patent Prior Art Reference – 802.11-2007

areas

Because of limitations on wireless PHY ranges, WLANs intended to cover reasonable geographic distances

may be built from basic coverage building blocks. When providing QoS services it should be understood

that the MAC endeavors to provide QoS “service guarantees” within the limitations of the medium

properties identified above. In other words, particularly in unlicensed spectrum, true guarantees are often not

possible. However, gradations of service are always possible; and in sufficiently controlled environments,

QoS guarantees can truly be made.

5.1.1.3 The impact of handling mobile STAs

One of the requirements of IEEE Std 802.11 is to handle mobile as well as portable STAs. A portable STA

is one that is moved from location to location, but that is only used while at a fixed location. Mobile STAs

actually access the LAN while in motion.

For technical reasons, it is not sufficient to handle only portable STAs. Propagation effects blur the

distinction between portable and mobile STAs; stationary STAs often appear to be mobile due to

propagation effects.

Another aspect of mobile STAs is that they may often be battery powered. Hence power management is

an important consideration. For example, it cannot be presumed that a STA’s receiver will always be

powered on.

See, e.g., 802.11-2007 § 5.1.1 - § 5.1.1.3

5.2 Components of the IEEE 802.11 architecture

The IEEE 802.11 architecture consists of several components that interact to provide a WLAN that supports

STA mobility transparently to upper layers.

The basic service set (BSS) is the basic building block of an IEEE 802.11 LAN. Figure 5 -1 shows two BSSs,

each of which has two STAs that are members of the BSS.

It is useful to think of the ovals used to depict a BSS as the coverage area within which the member STAs of

the BSS may remain in communication. (The concept of area, while not precise, is often good enough.) This

area is called the Basic Service Area (BSA). If a STA moves out of its BSA, it can no longer directly

communicate with other STAs present in the BSA.

See, e.g., 802.11-2007 § 5.2

5.2.3 Distribution system (DS) concepts

PHY limitations determine the direct station-to-station distance that may be supported. For some networks

this distance is sufficient; for other networks, increased coverage is required.

Instead of existing independently, a BSS may also form a component of an extended form of network that is

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 34 of 946 PageID #:

4138
34

Claim 1 of the ’802 Patent Prior Art Reference – 802.11-2007

built with multiple BSSs. The architectural component used to interconnect BSSs is the DS.

IEEE Std 802.11 logically separates the WM from the distribution system medium (DSM). Each logical

medium is used for different purposes, by a different component of the architecture. The IEEE 802.11

definitions neither preclude, nor demand, that the multiple media be either the same or different.

Recognizing that the multiple media are logically different is key to understanding the flexibility of the

architecture. The IEEE 802.11 LAN architecture is specified independently of the physical characteristics of

any specific implementation.

The DS enables mobile device support by providing the logical services necessary to handle address to

destination mapping and seamless integration of multiple BSSs.

An access point (AP) is any entity that has STA functionality and enables access to the DS, via the WM for

associated STAs.

See, e.g., 802.11-2007 § 5.2.3

5.3.2 DSS

The service provided by the DS is known as the DSS.

This service is represented in the IEEE 802.11 architecture by arrows within the APs, indicating that the

service is used to cross media and possibly address space logical boundaries. An AP is a logical entity, and

the functions described may be shared by one or more physical entities.

The services that comprise the DSS are as follows:

a) Association

b) Disassociation

c) Distribution

d) Integration

e) Reassociation

f) QoS traffic scheduling (QoS facility only)

DSSs are specified for use by MAC sublayer entities.

Figure 5-7 combines the components from previous figures with both types of services to show the complete

IEEE 802.11 architecture.

See, e.g., 802.11-2007 § 5.3.2

5.4.4.1 TPC

Radio regulations may require radio local area networks (RLANs) operating in the 5 GHz band to use

transmitter power control, involving specification of a regulatory maximum transmit power and a mitigation

requirement for each allowed channel, to reduce interference with satellite services. The TPC service is used

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 35 of 946 PageID #:

4139
35

Claim 1 of the ’802 Patent Prior Art Reference – 802.11-2007

to satisfy this regulatory requirement.

The TPC service provides for the following:

— Association of STAs with an AP in a BSS based on the STAs’ power capability.

— Specification of regulatory and local maximum transmit power levels for the current channel.

— Selection of a transmit power for each transmission in a channel within constraints imposed by

regulatory requirements.

— Adaptation of transmit power based on a range of information, including path loss and link margin

estimates.

See, e.g., 802.11-2007 § 5.4.4.1

7.3.2.20 Channel Switch Announcement element

The Channel Switch Announcement element is used by an AP in a BSS or a STA in an IBSS to advertise

when it is changing to a new channel and the channel number of the new channel. The format of the Channel

Switch Announcement element is shown in Figure 7-57.

See, e.g., 802.11-2007 § 7.3.2.20

10.3.11 Spectrum management protocol layer model

The layer management extensions for measurement and channel switching assume a certain partition

of spectrum management functionality between the MLME and SME. This partitioning assumes that

policy decisions (e.g., regarding measurement and channel switching) reside in the SME, while the protocol

for measurement, switch timing, and the associated frame exchanges resides within the MLME (see

Figure 10-2).

...

The informative diagrams within this subclause further illustrate the spectrum management protocol model

adopted. Figure 10-3 and Figure 10-4 depict the measurement process for a peer STA to accept and reject a

measurement request, respectively. Figure 10-5 illustrates the TPC adaptation process. Lastly, Figure 10-6

depicts the management process for a channel switch using a Channel Switch Announcement frame.

See, e.g., 802.11-2007 § 10.3.11

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 36 of 946 PageID #:

4140
36

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 37 of 946 PageID #:

4141
37

Claim 1 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 § 10.4.3.2

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 38 of 946 PageID #:

4142
38

Claim 1 of the ’802 Patent Prior Art Reference – 802.11-2007

17.1 Introduction

This clause specifies the PHY entity for an orthogonal frequency division multiplexing (OFDM) system.

The OFDM system provides a WLAN with data payload communication capabilities of 6, 9, 12, 18, 24, 36,

48, and 54 Mb/s. The support of transmitting and receiving at data rates of 6, 12, and 24 Mb/s is mandatory.

The system uses 52 subcarriers that are modulated using binary or quadrature phase shift keying (BPSK or

QPSK) or using 16- or 64-quadrature amplitude modulation (16-QAM or 64-QAM). Forward error

correction coding (convolutional coding) is used with a coding rate of 1/2, 2/3, or 3/4.

The OFDM system also provides a “half-clocked” operation using 10 MHz channel spacings with data

communications capabilities of 3, 4.5, 6, 9, 12, 18, 24, and 27 Mb/s. The support of transmitting and

receiving at data rates of 3, 6, and 12 Mb/s is mandatory when using 10 MHz channel spacing. The halfclocked

operation doubles symbol times and clear channel assessment (CCA) times when using 10 MHz

channel spacing. The regulatory requirements and information regarding use of this OFDM system in

4.9 GHz and 5 GHz bands is in Annex I and Annex J.

The OFDM system also provides a “quarter-clocked” operation using 5 MHz channel spacing with data

communication capabilities of 1.5, 2.25, 3, 4.5, 6, 9, 12, and 13.5 Mb/s. The support of transmitting and

receiving at data rates of 1.5, 3, and 6 Mb/s is mandatory when using 5 MHz channel spacing. The quarterclocked

operation quadruples symbol times and CCA times when using 5 MHz channel spacing. The

regulatory requirements and information regarding use of this OFDM system in the 4.9 GHz band is in

Annex I and Annex J.

See, e.g., 802.11-2007 § 17.1

17.3.2.1 Overview of the PPDU encoding process

The encoding process is composed of many detailed steps, which are described fully in later subclauses, as

noted below. The following overview intends to facilitate understanding the details of the convergence

procedure:

a) Produce the PLCP Preamble field, composed of 10 repetitions of a “short training sequence” (used

for AGC convergence, diversity selection, timing acquisition, and coarse frequency acquisition in

the receiver) and two repetitions of a “long training sequence” (used for channel estimation and fine

frequency acquisition in the receiver), preceded by a guard interval (GI). Refer to 17.3.3 for details.

b) Produce the PLCP header field from the RATE, LENGTH, and SERVICE fields of the

TXVECTOR by filling the appropriate bit fields. The RATE and LENGTH fields of the PLCP

header are encoded by a convolutional code at a rate of R = 1/2, and are subsequently mapped onto a

single BPSK encoded OFDM symbol, denoted as the SIGNAL symbol. In order to facilitate a

reliable and timely detection of the RATE and LENGTH fields, 6 zero tail bits are inserted into the

PLCP header. The encoding of the SIGNAL field into an OFDM symbol follows the same steps for

convolutional encoding, interleaving, BPSK modulation, pilot insertion, Fourier transform, and

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 39 of 946 PageID #:

4143
39

Claim 1 of the ’802 Patent Prior Art Reference – 802.11-2007

prepending a GI as described subsequently for data transmission with BPSK-OFDM modulated at

coding rate 1/2. The contents of the SIGNAL field are not scrambled. Refer to 17.3.4 for details.

c) Calculate from RATE field of the TXVECTOR the number of data bits per OFDM symbol (NDBPS),

the coding rate (R), the number of bits in each OFDM subcarrier (NBPSC), and the number of coded

bits per OFDM symbol (NCBPS). Refer to 17.3.2.2 for details.

d) Append the PSDU to the SERVICE field of the TXVECTOR. Extend the resulting bit string with

zero bits (at least 6 bits) so that the resulting length will be a multiple of NDBPS. The resulting bit

string constitutes the DATA part of the packet. Refer to 17.3.5.3 for details.

e) Initiate the scrambler with a pseudo-random nonzero seed, generate a scrambling sequence, and

XOR it with the extended string of data bits. Refer to 17.3.5.4 for details.

f) Replace the six scrambled zero bits following the data with six nonscrambled zero bits. (Those bits

return the convolutional encoder to the zero state and are denoted as tail bits.) Refer to 17.3.5.2 for

details.

g) Encode the extended, scrambled data string with a convolutional encoder (R = 1/2). Omit (puncture)

some of the encoder output string (chosen according to “puncturing pattern”) to reach the desired

“coding rate.” Refer to 17.3.5.5 for details.

h) Divide the encoded bit string into groups of NCBPS bits. Within each group, perform an

“interleaving” (reordering) of the bits according to a rule corresponding to the desired RATE. Refer

to 17.3.5.6 for details.

i) Divide the resulting coded and interleaved data string into groups of NCBPS bits. For each of the bit

groups, convert the bit group into a complex number according to the modulation encoding tables.

Refer to 17.3.5.7 for details.

j) Divide the complex number string into groups of 48 complex numbers. Each such group will be

associated with one OFDM symbol. In each group, the complex numbers will be numbered 0 to 47

and mapped hereafter into OFDM subcarriers numbered –26 to –22, –20 to –8, –6 to –1, 1 to 6,

8 to 20, and 22 to 26. The subcarriers –21, –7, 7, and 21 are skipped and, subsequently, used for

inserting pilot subcarriers. The 0 subcarrier, associated with center frequency, is omitted and filled

with zero value. Refer to 17.3.5.9 for details.

k) Four subcarriers are inserted as pilots into positions –21, –7, 7, and 21. The total number of the

subcarriers is 52 (48 + 4). Refer to 17.3.5.8 for details.

l) For each group of subcarriers –26 to 26, convert the subcarriers to time domain using inverse

Fourier transform. Prepend to the Fourier-transformed waveform a circular extension of itself thus

forming a GI, and truncate the resulting periodic waveform to a single OFDM symbol length by

applying time domain windowing. Refer to 17.3.5.9 for details.

m) Append the OFDM symbols one after another, starting after the SIGNAL symbol describing the

RATE and LENGTH fields. Refer to 17.3.5.9 for details.

n) Up-convert the resulting “complex baseband” waveform to an RF according to the cen ter frequency

of the desired channel and transmit. Refer to 17.3.2.4 and 17.3.8.1 for details.

An illustration of the transmitted frame and its parts appears in Figure 17-4 (in 17.3.3).

See, e.g., 802.11-2007 § 17.3.2.1

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 40 of 946 PageID #:

4144
40

Claim 1 of the ’802 Patent Prior Art Reference – 802.11-2007

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 41 of 946 PageID #:

4145
41

Claim 1 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 § 17.3.2.3

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 42 of 946 PageID #:

4146
42

Claim 1 of the ’802 Patent Prior Art Reference – 802.11-2007

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 43 of 946 PageID #:

4147
43

Claim 1 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 § 17.3.2.4 Eq. (17-1)

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 44 of 946 PageID #:

4148
44

Claim 1 of the ’802 Patent Prior Art Reference – 802.11-2007

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 45 of 946 PageID #:

4149
45

Claim 1 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 § 17.3.2.5

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 46 of 946 PageID #:

4150
46

Claim 1 of the ’802 Patent Prior Art Reference – 802.11-2007

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 47 of 946 PageID #:

4151
47

See, e.g., 802.11-2007 § 17.3.3

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 48 of 946 PageID #:

4152
48

Claim 1 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 § 17.3.5.7

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 49 of 946 PageID #:

4153
49

Claim 1 of the ’802 Patent Prior Art Reference – 802.11-2007

17.3.5.8 Pilot subcarriers

In each OFDM symbol, four of the subcarriers are dedicated to pilot signals in order to make the coherent

detection robust against frequency offsets and phase noise. These pilot signals shall be put in subcarriers

–21, –7, 7, and 21. The pilots shall be BPSK modulated by a pseudo-binary sequence to prevent the

generation of spectral lines. The contribution of the pilot subcarriers to each OFDM symbol is described in

17.3.5.9.

See, e.g., 802.11-2007 § 17.3.5.8

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 50 of 946 PageID #:

4154
50

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 51 of 946 PageID #:

4155
51

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 52 of 946 PageID #:

4156
52

Claim 1 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 § 17.3.5.9

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 53 of 946 PageID #:

4157
53

Claim 1 of the ’802 Patent Prior Art Reference – 802.11-2007

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 54 of 946 PageID #:

4158
54

Claim 1 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 § 17.3.8.1

17.3.8.3.1 Operating frequency range

The OFDM PHY shall operate in the 5 GHz band, as allocated by a regulatory body in its operational region.

Spectrum allocation in the 5 GHz band is subject to authorities responsible for geographic-specific

regulatory domains (e.g., global, regional, and national). The particular channelization to be used for this

standard is dependent on such allocation, as well as the associated regulations for use of the allocations.

These regulations are subject to revision, or may be superseded.

In some regulatory domains, several frequency bands may be available for OFDM PHY-based WLANs.

These bands may be contiguous or not, and different regulatory limits may be applicable. A compliant

OFDM PHY shall support at least one frequency band in at least one regulatory domain. The support of

specific regulatory domains, and bands within the domains, shall be indicated by PLME attributes

dot11RegDomainsSupported and dot11FrequencyBandsSupported.

See, e.g., 802.11-2007 § 17.3.8.3.1

17.3.9.1 Transmit power levels

The maximum allowable transmit power by regulatory domain is defined in Annex I.

See, e.g., 802.11-2007 § 17.3.9.1

17.3.9.6.2 Transmitter spectral flatness

The average energy of the constellations in each of the spectral lines –16.. –1 and +1.. +16 will deviate no

more than ± 2 dB from their average energy. The average energy of the constellations in each of the spectral

lines –26.. –17 and +17.. +26 will deviate no more than +2/–4 dB from the average energy of spectral lines

–16.. –1 and +1.. +16. The data for this test shall be derived from the channel estimation step.

See, e.g., 802.11-2007 § 17.3.9.6.2

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 55 of 946 PageID #:

4159
55

Claim 1 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 § I.2.2

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 56 of 946 PageID #:

4160
56

Claim 1 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 § I.2.3

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 57 of 946 PageID #:

4161
57

Claim 1 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 Figure 5-7

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 58 of 946 PageID #:

4162
58

Claim 1 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 Figure 10-6

Furthermore, this claim element is obvious in light of 802.11-2007 itself, when combined with any of 

the other references as charted for this claim element in Exs. A-1–A-31, First Supplemental Ex. ACase 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 59 of 946 PageID #:

4163
59

Claim 1 of the ’802 Patent Prior Art Reference – 802.11-2007

Obviousness 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 – 802.11-2007

[2.1] The method of claim 1 802.11-2007 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.

802.11-2007 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.” See, e.g.: 

1.1 Scope

The scope of this standard is to define one medium access control (MAC) and several physical layer (PHY)

specifications for wireless connectivity for fixed, portable, and moving stations (STAs) within a local area.

See, e.g., 802.11-2007 § 1.1

5.1.1 How WLAN systems are different

Wireless networks have fundamental characteristics that make them significantly different from traditional

wired LANs. Some countries impose specific requirements for radio equipment in addition to those

specified in this standard. This standard does not provide information to meet these country-specific radio

regulations.

5.1.1.1 Destination address does not equal destination location

In wired LANs, an address is equivalent to a physical location. This is implicitly assumed in the design of

wired LANs. In IEEE Std 802.11, the addressable unit is a station (STA). The STA is a message destination,

but not (in general) a fixed location.

5.1.1.2 Media impact on design and performance

The PHYs used in IEEE Std 802.11 are fundamentally different from wired media. Thus IEEE 802.11 PHYs

a) Use a medium that has neither absolute nor readily observable boundaries outside of which STAs

with conformant PHY transceivers are known to be unable to receive network frames

b) Are unprotected from other signals that may be sharing the medium

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 60 of 946 PageID #:

4164
60

Claim 2 of the ’802 Patent Prior Art Reference – 802.11-2007

c) Communicate over a medium significantly less reliable than wired PHYs

d) Have dynamic topologies

e) Lack full connectivity, and therefore the assumption normally made that every STA can hear every

other STA is invalid (i.e., STAs may be “hidden” from each other)

f) Have time-varying and asymmetric propagation properties

g) May experience interference from logically disjoint IEEE 802.11 networks operating in overlapping

areas

Because of limitations on wireless PHY ranges, WLANs intended to cover reasonable geographic distances

may be built from basic coverage building blocks. When providing QoS services it should be understood

that the MAC endeavors to provide QoS “service guarantees” within the limitations of the medium

properties identified above. In other words, particularly in unlicensed spectrum, true guarantees are often not

possible. However, gradations of service are always possible; and in sufficiently controlled environments,

QoS guarantees can truly be made.

5.1.1.3 The impact of handling mobile STAs

One of the requirements of IEEE Std 802.11 is to handle mobile as well as portable STAs. A portable STA

is one that is moved from location to location, but that is only used while at a fixed location. Mobile STAs

actually access the LAN while in motion.

For technical reasons, it is not sufficient to handle only portable STAs. Propagation effects blur the

distinction between portable and mobile STAs; stationary STAs often appear to be mobile due to

propagation effects.

Another aspect of mobile STAs is that they may often be battery powered. Hence power management is

an important consideration. For example, it cannot be presumed that a STA’s receiver will always be

powered on.

See, e.g., 802.11-2007 § 5.1.1 - § 5.1.1.3

5.2 Components of the IEEE 802.11 architecture

The IEEE 802.11 architecture consists of several components that interact to provide a WLAN that supports

STA mobility transparently to upper layers.

The basic service set (BSS) is the basic building block of an IEEE 802.11 LAN. Figure 5-1 shows two BSSs,

each of which has two STAs that are members of the BSS.

It is useful to think of the ovals used to depict a BSS as the coverage area within which the member STAs of

the BSS may remain in communication. (The concept of area, while not precise, is often good enough.) This

area is called the Basic Service Area (BSA). If a STA moves out of its BSA, it can no longer directly

communicate with other STAs present in the BSA.

See, e.g., 802.11-2007 § 5.2

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 61 of 946 PageID #:

4165
61

Claim 2 of the ’802 Patent Prior Art Reference – 802.11-2007

5.2.3 Distribution system (DS) concepts

PHY limitations determine the direct station-to-station distance that may be supported. For some networks

this distance is sufficient; for other networks, increased coverage is required.

Instead of existing independently, a BSS may also form a component of an extended form of network that is

built with multiple BSSs. The architectural component used to interconnect BSSs is the DS.

IEEE Std 802.11 logically separates the WM from the distribution system medium (DSM). Each logical

medium is used for different purposes, by a different component of the architecture. The IEEE 802.11

definitions neither preclude, nor demand, that the multiple media be either the same or different.

Recognizing that the multiple media are logically different is key to understanding the flexibility of the

architecture. The IEEE 802.11 LAN architecture is specified independently of the physical characteristics of

any specific implementation.

The DS enables mobile device support by providing the logical services necessary to handle address to

destination mapping and seamless integration of multiple BSSs.

An access point (AP) is any entity that has STA functionality and enables access to the DS, via the WM for

associated STAs.

See, e.g., 802.11-2007 § 5.2.3

5.3.2 DSS

The service provided by the DS is known as the DSS.

This service is represented in the IEEE 802.11 architecture by arrows within the APs, indicating that the

service is used to cross media and possibly address space logical boundaries. An AP is a logical entity, and

the functions described may be shared by one or more physical entities.

The services that comprise the DSS are as follows:

a) Association

b) Disassociation

c) Distribution

d) Integration

e) Reassociation

f) QoS traffic scheduling (QoS facility only)

DSSs are specified for use by MAC sublayer entities.

Figure 5-7 combines the components from previous figures with both types of services to show the complete

IEEE 802.11 architecture.

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 62 of 946 PageID #:

4166
62

Claim 2 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 § 5.3.2

5.4.4.1 TPC

Radio regulations may require radio local area networks (RLANs) operating in the 5 GHz band to use

transmitter power control, involving specification of a regulatory maximum transmit power and a mitigation

requirement for each allowed channel, to reduce interference with satellite services. The TPC service is used

to satisfy this regulatory requirement.

The TPC service provides for the following:

— Association of STAs with an AP in a BSS based on the STAs’ power capability.

— Specification of regulatory and local maximum transmit power levels for the current channel.

— Selection of a transmit power for each transmission in a channel within constraints imposed by

regulatory requirements.

— Adaptation of transmit power based on a range of information, including path loss and link margin

estimates.

See, e.g., 802.11-2007 § 5.4.4.1

7.3.2.20 Channel Switch Announcement element

The Channel Switch Announcement element is used by an AP in a BSS or a STA in an IBSS to advertise

when it is changing to a new channel and the channel number of the new channel. The format of the Channel

Switch Announcement element is shown in Figure 7-57.

See, e.g., 802.11-2007 § 7.3.2.20

10.3.11 Spectrum management protocol layer model

The layer management extensions for measurement and channel switching assume a certain partition

of spectrum management functionality between the MLME and SME. This partitioning assumes that

policy decisions (e.g., regarding measurement and channel switching) reside in the SME, while the protocol

for measurement, switch timing, and the associated frame exchanges resides within the MLME (see

Figure 10-2).

...

The informative diagrams within this subclause further illustrate the spectrum management protocol model

adopted. Figure 10-3 and Figure 10-4 depict the measurement process for a peer STA to accept and reject a

measurement request, respectively. Figure 10-5 illustrates the TPC adaptation process. Lastly, Figure 10-6

depicts the management process for a channel switch using a Channel Switch Announcement frame.

See, e.g., 802.11-2007 § 10.3.11

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 63 of 946 PageID #:

4167
63

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 64 of 946 PageID #:

4168
64

Claim 2 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 § 10.4.3.2

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 65 of 946 PageID #:

4169
65

Claim 2 of the ’802 Patent Prior Art Reference – 802.11-2007

17.1 Introduction

This clause specifies the PHY entity for an orthogonal frequency division multiplexing (OFDM) system.

The OFDM system provides a WLAN with data payload communication capabilities of 6, 9, 12, 18, 24, 36,

48, and 54 Mb/s. The support of transmitting and receiving at data rates of 6, 12, and 24 Mb/s is mandatory.

The system uses 52 subcarriers that are modulated using binary or quadrature phase shift keying (BPSK or

QPSK) or using 16- or 64-quadrature amplitude modulation (16-QAM or 64-QAM). Forward error

correction coding (convolutional coding) is used with a coding rate of 1/2, 2/3, or 3/4.

The OFDM system also provides a “half-clocked” operation using 10 MHz channel spacings with data

communications capabilities of 3, 4.5, 6, 9, 12, 18, 24, and 27 Mb/s. The support of transmitting and

receiving at data rates of 3, 6, and 12 Mb/s is mandatory when using 10 MHz channel spacing. The halfclocked

operation doubles symbol times and clear channel assessment (CCA) times when using 10 MHz

channel spacing. The regulatory requirements and information regarding use of this OFDM system in

4.9 GHz and 5 GHz bands is in Annex I and Annex J.

The OFDM system also provides a “quarter-clocked” operation using 5 MHz channel spacing with data

communication capabilities of 1.5, 2.25, 3, 4.5, 6, 9, 12, and 13.5 Mb/s. The support of transmitting and

receiving at data rates of 1.5, 3, and 6 Mb/s is mandatory when using 5 MHz channel spacing. The quarterclocked

operation quadruples symbol times and CCA times when using 5 MHz channel spacing. The

regulatory requirements and information regarding use of this OFDM system in the 4.9 GHz band is in

Annex I and Annex J.

See, e.g., 802.11-2007 § 17.1

17.3.2.1 Overview of the PPDU encoding process

The encoding process is composed of many detailed steps, which are described fully in later subclauses, as

noted below. The following overview intends to facilitate understanding the details of the convergence

procedure:

a) Produce the PLCP Preamble field, composed of 10 repetitions of a “short training sequence” (used

for AGC convergence, diversity selection, timing acquisition, and coarse frequ ency acquisition in

the receiver) and two repetitions of a “long training sequence” (used for channel estimation and fine

frequency acquisition in the receiver), preceded by a guard interval (GI). Refer to 17.3.3 for details.

b) Produce the PLCP header field from the RATE, LENGTH, and SERVICE fields of the

TXVECTOR by filling the appropriate bit fields. The RATE and LENGTH fields of the PLCP

header are encoded by a convolutional code at a rate of R = 1/2, and are subsequently mapped onto a

single BPSK encoded OFDM symbol, denoted as the SIGNAL symbol. In order to facilitate a

reliable and timely detection of the RATE and LENGTH fields, 6 zero tail bits are inserted into the

PLCP header. The encoding of the SIGNAL field into an OFDM symbol follows the same steps for

convolutional encoding, interleaving, BPSK modulation, pilot insertion, Fourier transform, and

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 66 of 946 PageID #:

4170
66

Claim 2 of the ’802 Patent Prior Art Reference – 802.11-2007

prepending a GI as described subsequently for data transmission with BPSK-OFDM modulated at

coding rate 1/2. The contents of the SIGNAL field are not scrambled. Refer to 17.3.4 for details.

c) Calculate from RATE field of the TXVECTOR the number of data bits per OFDM symbol (NDBPS),

the coding rate (R), the number of bits in each OFDM subcarrier (NBPSC), and the number of coded

bits per OFDM symbol (NCBPS). Refer to 17.3.2.2 for details.

d) Append the PSDU to the SERVICE field of the TXVECTOR. Extend the resulting bit string with

zero bits (at least 6 bits) so that the resulting length will be a multiple of NDBPS. The resulting bit

string constitutes the DATA part of the packet. Refer to 17.3.5.3 for details.

e) Initiate the scrambler with a pseudo-random nonzero seed, generate a scrambling sequence, and

XOR it with the extended string of data bits. Refer to 17.3.5.4 for details.

f) Replace the six scrambled zero bits following the data with six nonscrambled zero bits. (Those bits

return the convolutional encoder to the zero state and are denoted as tail bits.) Refer to 17.3.5.2 for

details.

g) Encode the extended, scrambled data string with a convolutional encoder (R = 1/2). Omit (puncture)

some of the encoder output string (chosen according to “puncturing pattern”) to reach the desired

“coding rate.” Refer to 17.3.5.5 for details.

h) Divide the encoded bit string into groups of NCBPS bits. Within each group, perform an

“interleaving” (reordering) of the bits according to a rule corresponding to the desired RATE. Refer

to 17.3.5.6 for details.

i) Divide the resulting coded and interleaved data string into groups of NCBPS bits. For each of the bit

groups, convert the bit group into a complex number according to the modulation encoding tables.

Refer to 17.3.5.7 for details.

j) Divide the complex number string into groups of 48 complex numbers. Each such group will be

associated with one OFDM symbol. In each group, the complex numbers will be numbered 0 to 47

and mapped hereafter into OFDM subcarriers numbered –26 to –22, –20 to –8, –6 to –1, 1 to 6,

8 to 20, and 22 to 26. The subcarriers –21, –7, 7, and 21 are skipped and, subsequently, used for

inserting pilot subcarriers. The 0 subcarrier, associated with center frequency, is omitted and filled

with zero value. Refer to 17.3.5.9 for details.

k) Four subcarriers are inserted as pilots into positions –21, –7, 7, and 21. The total number of the

subcarriers is 52 (48 + 4). Refer to 17.3.5.8 for details.

l) For each group of subcarriers –26 to 26, convert the subcarriers to time domain using inverse

Fourier transform. Prepend to the Fourier-transformed waveform a circular extension of itself thus

forming a GI, and truncate the resulting periodic waveform to a single OFDM symbol length by

applying time domain windowing. Refer to 17.3.5.9 for details.

m) Append the OFDM symbols one after another, starting after the SIGNAL symbol describing the

RATE and LENGTH fields. Refer to 17.3.5.9 for details.

n) Up-convert the resulting “complex baseband” waveform to an RF according to the center frequency

of the desired channel and transmit. Refer to 17.3.2.4 and 17.3.8.1 for details.

An illustration of the transmitted frame and its parts appears in Figure 17-4 (in 17.3.3).

See, e.g., 802.11-2007 § 17.3.2.1

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 67 of 946 PageID #:

4171
67

Claim 2 of the ’802 Patent Prior Art Reference – 802.11-2007

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 68 of 946 PageID #:

4172
68

Claim 2 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 § 17.3.2.3

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 69 of 946 PageID #:

4173
69

Claim 2 of the ’802 Patent Prior Art Reference – 802.11-2007

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 70 of 946 PageID #:

4174
70

Claim 2 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 § 17.3.2.4 Eq. (17-1)

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 71 of 946 PageID #:

4175
71

Claim 2 of the ’802 Patent Prior Art Reference – 802.11-2007

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 72 of 946 PageID #:

4176
72

Claim 2 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 § 17.3.2.5

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 73 of 946 PageID #:

4177
73

Claim 2 of the ’802 Patent Prior Art Reference – 802.11-2007

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 74 of 946 PageID #:

4178
74

See, e.g., 802.11-2007 § 17.3.3

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 75 of 946 PageID #:

4179
75

Claim 2 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 § 17.3.5.7

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 76 of 946 PageID #:

4180
76

Claim 2 of the ’802 Patent Prior Art Reference – 802.11-2007

17.3.5.8 Pilot subcarriers

In each OFDM symbol, four of the subcarriers are dedicated to pilot signals in order to make the coherent

detection robust against frequency offsets and phase noise. These pilot signals shall be put in subcarriers

–21, –7, 7, and 21. The pilots shall be BPSK modulated by a pseudo-binary sequence to prevent the

generation of spectral lines. The contribution of the pilot subcarriers to each OFDM symbol is described in

17.3.5.9.

See, e.g., 802.11-2007 § 17.3.5.8

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 77 of 946 PageID #:

4181
77

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 78 of 946 PageID #:

4182
78

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 79 of 946 PageID #:

4183
79

Claim 2 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 § 17.3.5.9

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 80 of 946 PageID #:

4184
80

Claim 2 of the ’802 Patent Prior Art Reference – 802.11-2007

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 81 of 946 PageID #:

4185
81

Claim 2 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 § 17.3.8.1

17.3.8.3.1 Operating frequency range

The OFDM PHY shall operate in the 5 GHz band, as allocated by a regulatory body in its operational region.

Spectrum allocation in the 5 GHz band is subject to authorities responsible for geographic-specific

regulatory domains (e.g., global, regional, and national). The particular channelization to be used for this

standard is dependent on such allocation, as well as the associated regulations for use of the allocations.

These regulations are subject to revision, or may be superseded.

In some regulatory domains, several frequency bands may be available for OFDM PHY-based WLANs.

These bands may be contiguous or not, and different regulatory limits may be applicable. A compliant

OFDM PHY shall support at least one frequency band in at least one regulatory domain. The support of

specific regulatory domains, and bands within the domains, shall be indicated by PLME attributes

dot11RegDomainsSupported and dot11FrequencyBandsSupported.

See, e.g., 802.11-2007 § 17.3.8.3.1

17.3.9.1 Transmit power levels

The maximum allowable transmit power by regulatory domain is defined in Annex I.

See, e.g., 802.11-2007 § 17.3.9.1

17.3.9.6.2 Transmitter spectral flatness

The average energy of the constellations in each of the spectral lines –16.. –1 and +1.. +16 will deviate no

more than ± 2 dB from their average energy. The average energy of the constellations in each of the spectral

lines –26.. –17 and +17.. +26 will deviate no more than +2/–4 dB from the average energy of spectral lines

–16.. –1 and +1.. +16. The data for this test shall be derived from the channel estimation step.

See, e.g., 802.11-2007 § 17.3.9.6.2

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 82 of 946 PageID #:

4186
82

Claim 2 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 § I.2.2

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 83 of 946 PageID #:

4187
83

Claim 2 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 § I.2.3

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 84 of 946 PageID #:

4188
84

Claim 2 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 Figure 5-7

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 85 of 946 PageID #:

4189
85

Claim 2 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 Figure 10-6

Furthermore, this claim element is obvious in light of 802.11-2007 itself, when combined with any of 

the other references as charted for this claim element in Exs. A-1–A-31, First Supplemental Ex. ACase 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 86 of 946 PageID #:

4190
86

Claim 2 of the ’802 Patent Prior Art Reference – 802.11-2007

Obviousness 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 – 802.11-2007

[3.1] The method of claim 1 802.11-2007 discloses all the elements of claim 1 for all the reasons provided above.

[3.2] wherein the first and 

second information are 

transmitted using the same 

power amplifier in said 

wireless transmitter.

802.11-2007 discloses “wherein the first and second information are transmitted using the same 

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

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 87 of 946 PageID #:

4191
87

Claim 3 of the ’802 Patent Prior Art Reference – 802.11-2007

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 88 of 946 PageID #:

4192
88

Claim 3 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 § 17.3.8.1

17.3.2.1 Overview of the PPDU encoding process

The encoding process is composed of many detailed steps, which are described fully in later subclauses, as

noted below. The following overview intends to facilitate understanding the details of the convergence

procedure:

a) Produce the PLCP Preamble field, composed of 10 repetitions of a “short training sequence” (used

for AGC convergence, diversity selection, timing acquisition, and coarse freq uency acquisition in

the receiver) and two repetitions of a “long training sequence” (used for channel estimation and fine

frequency acquisition in the receiver), preceded by a guard interval (GI). Refer to 17.3.3 for details.

b) Produce the PLCP header field from the RATE, LENGTH, and SERVICE fields of the

TXVECTOR by filling the appropriate bit fields. The RATE and LENGTH fields of the PLCP

header are encoded by a convolutional code at a rate of R = 1/2, and are subsequently mapped onto a

single BPSK encoded OFDM symbol, denoted as the SIGNAL symbol. In order to facilitate a

reliable and timely detection of the RATE and LENGTH fields, 6 zero tail bits are inserted into the

PLCP header. The encoding of the SIGNAL field into an OFDM symbol follows the same steps for

convolutional encoding, interleaving, BPSK modulation, pilot insertion, Fourier transform, and

prepending a GI as described subsequently for data transmission with BPSK-OFDM modulated at

coding rate 1/2. The contents of the SIGNAL field are not scrambled. Refer to 17.3.4 for details.

c) Calculate from RATE field of the TXVECTOR the number of data bits per OFDM symbol (NDBPS),

the coding rate (R), the number of bits in each OFDM subcarrier (NBPSC), and the number of coded

bits per OFDM symbol (NCBPS). Refer to 17.3.2.2 for details.

d) Append the PSDU to the SERVICE field of the TXVECTOR. Extend the resulting bit string with

zero bits (at least 6 bits) so that the resulting length will be a multiple of NDBPS. The resulting bit

string constitutes the DATA part of the packet. Refer to 17.3.5.3 for details.

e) Initiate the scrambler with a pseudo-random nonzero seed, generate a scrambling sequence, and

XOR it with the extended string of data bits. Refer to 17.3.5.4 for details.

f) Replace the six scrambled zero bits following the data with six nonscrambled zero bits. (Those bits

return the convolutional encoder to the zero state and are denoted as tail bits.) Refer to 17.3.5.2 for

details.

g) Encode the extended, scrambled data string with a convolutional encoder (R = 1/2). Omit (puncture)

some of the encoder output string (chosen according to “puncturing pattern”) to reach the desired

“coding rate.” Refer to 17.3.5.5 for details.

h) Divide the encoded bit string into groups of NCBPS bits. Within each group, perform an

“interleaving” (reordering) of the bits according to a rule corresponding to the desired RATE. Refer

to 17.3.5.6 for details.

i) Divide the resulting coded and interleaved data string into groups of NCBPS bits. For each of the bit

groups, convert the bit group into a complex number according to the modulation encoding tables.

Refer to 17.3.5.7 for details.

j) Divide the complex number string into groups of 48 complex numbers. Each such group will be

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 89 of 946 PageID #:

4193
89

Claim 3 of the ’802 Patent Prior Art Reference – 802.11-2007

associated with one OFDM symbol. In each group, the complex numbers will be numbered 0 to 47

and mapped hereafter into OFDM subcarriers numbered –26 to –22, –20 to –8, –6 to –1, 1 to 6,

8 to 20, and 22 to 26. The subcarriers –21, –7, 7, and 21 are skipped and, subsequently, used for

inserting pilot subcarriers. The 0 subcarrier, associated with center frequency, is omitted and filled

with zero value. Refer to 17.3.5.9 for details.

k) Four subcarriers are inserted as pilots into positions –21, –7, 7, and 21. The total number of the

subcarriers is 52 (48 + 4). Refer to 17.3.5.8 for details.

l) For each group of subcarriers –26 to 26, convert the subcarriers to time domain using inverse

Fourier transform. Prepend to the Fourier-transformed waveform a circular extension of itself thus

forming a GI, and truncate the resulting periodic waveform to a single OFDM symbol length by

applying time domain windowing. Refer to 17.3.5.9 for details.

m) Append the OFDM symbols one after another, starting after the SIGNAL symbol describing the

RATE and LENGTH fields. Refer to 17.3.5.9 for details.

n) Up-convert the resulting “complex baseband” waveform to an RF according to the center frequency

of the desired channel and transmit. Refer to 17.3.2.4 and 17.3.8.1 for details.

An illustration of the transmitted frame and its parts appears in Figure 17-4 (in 17.3.3).

See, e.g., 802.11-2007 § 17.3.2.1

Furthermore, this claim element is obvious in light of 802.11-2007 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.

Claim 4 of the ’802 Patent Prior Art Reference – 802.11-2007

[4.1] The method of claim 3 802.11-2007 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 

802.11-2007 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.: 

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 90 of 946 PageID #:

4194
90

Claim 4 of the ’802 Patent Prior Art Reference – 802.11-2007

frequency and the second 

highest frequency.

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 91 of 946 PageID #:

4195
91

Claim 4 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 § 17.3.8.1

17.3.2.1 Overview of the PPDU encoding process

The encoding process is composed of many detailed steps, which are described fully in later subclauses, as

noted below. The following overview intends to facilitate understanding the details of the convergence

procedure:

a) Produce the PLCP Preamble field, composed of 10 repetitions of a “short training sequence” (used

for AGC convergence, diversity selection, timing acquisition, and coarse frequency acquisition in

the receiver) and two repetitions of a “long training sequence” (used for channel estimation and fine

frequency acquisition in the receiver), preceded by a guard interval (GI). Refer to 17.3.3 for details.

b) Produce the PLCP header field from the RATE, LENGTH, and SERVICE fields of the

TXVECTOR by filling the appropriate bit fields. The RATE and LENGTH fields of the PLCP

header are encoded by a convolutional code at a rate of R = 1/2, and are subsequently mapped onto a

single BPSK encoded OFDM symbol, denoted as the SIGNAL symbol. In order to facilitate a

reliable and timely detection of the RATE and LENGTH fields, 6 zero tail bits are inserted into the

PLCP header. The encoding of the SIGNAL field into an OFDM symbol follows the same steps for

convolutional encoding, interleaving, BPSK modulation, pilot insertion, Fourier transform, and

prepending a GI as described subsequently for data transmission with BPSK-OFDM modulated at

coding rate 1/2. The contents of the SIGNAL field are not scrambled. Refer to 17.3.4 for details.

c) Calculate from RATE field of the TXVECTOR the number of data bits per OFDM symbol (NDBPS),

the coding rate (R), the number of bits in each OFDM subcarrier (NBPSC), and the number of coded

bits per OFDM symbol (NCBPS). Refer to 17.3.2.2 for details.

d) Append the PSDU to the SERVICE field of the TXVECTOR. Extend the resulting bit string with

zero bits (at least 6 bits) so that the resulting length will be a multiple of NDBPS. The resulting bit

string constitutes the DATA part of the packet. Refer to 17.3.5.3 for details.

e) Initiate the scrambler with a pseudo-random nonzero seed, generate a scrambling sequence, and

XOR it with the extended string of data bits. Refer to 17.3.5.4 for details.

f) Replace the six scrambled zero bits following the data with six nonscrambled zero bits. (Those bits

return the convolutional encoder to the zero state and are denoted as tail bits.) Refer to 17.3.5.2 for

details.

g) Encode the extended, scrambled data string with a convolutional encoder (R = 1/2). Omit (puncture)

some of the encoder output string (chosen according to “puncturing pattern”) to reach the desired

“coding rate.” Refer to 17.3.5.5 for details.

h) Divide the encoded bit string into groups of NCBPS bits. Within each group, perform an

“interleaving” (reordering) of the bits according to a rule corresponding to the desired RATE. Refer

to 17.3.5.6 for details.

i) Divide the resulting coded and interleaved data string into groups of NCBPS bits. For each of the bit

groups, convert the bit group into a complex number according to the modulation encoding tables.

Refer to 17.3.5.7 for details.

j) Divide the complex number string into groups of 48 complex numbers. Each such group will be

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 92 of 946 PageID #:

4196
92

Claim 4 of the ’802 Patent Prior Art Reference – 802.11-2007

associated with one OFDM symbol. In each group, the complex numbers will be numbered 0 to 47

and mapped hereafter into OFDM subcarriers numbered –26 to –22, –20 to –8, –6 to –1, 1 to 6,

8 to 20, and 22 to 26. The subcarriers –21, –7, 7, and 21 are skipped and, subsequently, used for

inserting pilot subcarriers. The 0 subcarrier, associated with center frequency, is omitted and filled

with zero value. Refer to 17.3.5.9 for details.

k) Four subcarriers are inserted as pilots into positions –21, –7, 7, and 21. The total number of the

subcarriers is 52 (48 + 4). Refer to 17.3.5.8 for details.

l) For each group of subcarriers –26 to 26, convert the subcarriers to time domain using inverse

Fourier transform. Prepend to the Fourier-transformed waveform a circular extension of itself thus

forming a GI, and truncate the resulting periodic waveform to a single OFDM symbol length by

applying time domain windowing. Refer to 17.3.5.9 for details.

m) Append the OFDM symbols one after another, starting after the SIGNAL symbol describing the

RATE and LENGTH fields. Refer to 17.3.5.9 for details.

n) Up-convert the resulting “complex baseband” waveform to an RF according to the center frequency

of the desired channel and transmit. Refer to 17.3.2.4 and 17.3.8.1 for details.

An illustration of the transmitted frame and its parts appears in Figure 17-4 (in 17.3.3).

See, e.g., 802.11-2007 § 17.3.2.1

17.3.9.6.2 Transmitter spectral flatness

The average energy of the constellations in each of the spectral lines –16.. –1 and +1.. +16 will deviate no

more than ± 2 dB from their average energy. The average energy of the constellations in each of the spectral

lines –26.. –17 and +17.. +26 will deviate no more than +2/–4 dB from the average energy of spectral lines

–16.. –1 and +1.. +16. The data for this test shall be derived from the channel estimation step.

See, e.g., 802.11-2007 § 17.3.9.6.2

Furthermore, this claim element is obvious in light of 802.11-2007 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.

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 93 of 946 PageID #:

4197
93

Claim 6 of the ’802 Patent Prior Art Reference – 802.11-2007

[6.1] The method of claim 1 802.11-2007 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.

802.11-2007 discloses “wherein the first information corresponds to a first wireless protocol and the 

second information corresponds to a second wireless protocol.” See, e.g.: 

1.1 Scope

The scope of this standard is to define one medium access control (MAC) and several physical layer (PHY)

specifications for wireless connectivity for fixed, portable, and moving stations (STAs) within a local area.

See, e.g., 802.11-2007 § 1.1

5.1.1 How WLAN systems are different

Wireless networks have fundamental characteristics that make them significantly different from traditional

wired LANs. Some countries impose specific requirements for radio equipment in addition to those

specified in this standard. This standard does not provide information to meet these country -specific radio

regulations.

5.1.1.1 Destination address does not equal destination location

In wired LANs, an address is equivalent to a physical location. This is implicitly assumed in the design of

wired LANs. In IEEE Std 802.11, the addressable unit is a station (STA). The STA is a message destination,

but not (in general) a fixed location.

5.1.1.2 Media impact on design and performance

The PHYs used in IEEE Std 802.11 are fundamentally different from wired media. Thus IEEE 802.11 PHYs

a) Use a medium that has neither absolute nor readily observable boundaries outside of which STAs

with conformant PHY transceivers are known to be unable to receive network frames

b) Are unprotected from other signals that may be sharing the medium

c) Communicate over a medium significantly less reliable than wired PHYs

d) Have dynamic topologies

e) Lack full connectivity, and therefore the assumption normally made that every STA can hear every

other STA is invalid (i.e., STAs may be “hidden” from each other)

f) Have time-varying and asymmetric propagation properties

g) May experience interference from logically disjoint IEEE 802.11 networks operating in overlapping

areas

Because of limitations on wireless PHY ranges, WLANs intended to cover reasonable geographic distances

may be built from basic coverage building blocks. When providing QoS services it should be understood

that the MAC endeavors to provide QoS “service guarantees” within the limitations of the medium

properties identified above. In other words, particularly in unlicensed spectrum, true guarantees are often not

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 94 of 946 PageID #:

4198
94

Claim 6 of the ’802 Patent Prior Art Reference – 802.11-2007

possible. However, gradations of service are always possible; and in sufficiently controlled environments,

QoS guarantees can truly be made.

5.1.1.3 The impact of handling mobile STAs

One of the requirements of IEEE Std 802.11 is to handle mobile as well as portable STAs. A portable STA

is one that is moved from location to location, but that is only used while at a fixed location. Mobile STAs

actually access the LAN while in motion.

For technical reasons, it is not sufficient to handle only portable STAs. Propagation effects blur the

distinction between portable and mobile STAs; stationary STAs often appear to be mobile due to

propagation effects.

Another aspect of mobile STAs is that they may often be battery powered. Hence power management is

an important consideration. For example, it cannot be presumed that a STA’s receiver will always be

powered on.

See, e.g., 802.11-2007 § 5.1.1 - § 5.1.1.3

5.2 Components of the IEEE 802.11 architecture

The IEEE 802.11 architecture consists of several components that interact to provide a WLAN that supports

STA mobility transparently to upper layers.

The basic service set (BSS) is the basic building block of an IEEE 802.11 LAN. Figure 5 -1 shows two BSSs,

each of which has two STAs that are members of the BSS.

It is useful to think of the ovals used to depict a BSS as the coverage area within which the member STAs of

the BSS may remain in communication. (The concept of area, while not precise, is often good enough.) This

area is called the Basic Service Area (BSA). If a STA moves out of its BSA, it can no longer directly

communicate with other STAs present in the BSA.

See, e.g., 802.11-2007 § 5.2

5.2.3 Distribution system (DS) concepts

PHY limitations determine the direct station-to-station distance that may be supported. For some networks

this distance is sufficient; for other networks, increased coverage is required.

Instead of existing independently, a BSS may also form a component of an extended form of network that is

built with multiple BSSs. The architectural component used to interconnect BSSs is the DS.

IEEE Std 802.11 logically separates the WM from the distribution system medium (DSM). Each logical

medium is used for different purposes, by a different component of the architecture. The IEEE 802.11

definitions neither preclude, nor demand, that the multiple media be either the same or different.

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 95 of 946 PageID #:

4199
95

Claim 6 of the ’802 Patent Prior Art Reference – 802.11-2007

Recognizing that the multiple media are logically different is key to understanding the flexibility of the

architecture. The IEEE 802.11 LAN architecture is specified independently of the physical characteristics of

any specific implementation.

The DS enables mobile device support by providing the logical services necessary to handle address to

destination mapping and seamless integration of multiple BSSs.

An access point (AP) is any entity that has STA functionality and enables access to the DS, via the WM for

associated STAs.

See, e.g., 802.11-2007 § 5.2.3

5.3.2 DSS

The service provided by the DS is known as the DSS.

This service is represented in the IEEE 802.11 architecture by arrows within the APs, indicating that the

service is used to cross media and possibly address space logical boundaries. An AP is a logical entity, and

the functions described may be shared by one or more physical entities.

The services that comprise the DSS are as follows:

a) Association

b) Disassociation

c) Distribution

d) Integration

e) Reassociation

f) QoS traffic scheduling (QoS facility only)

DSSs are specified for use by MAC sublayer entities.

Figure 5-7 combines the components from previous figures with both types of services to show the complete

IEEE 802.11 architecture.

See, e.g., 802.11-2007 § 5.3.2

5.4.4.1 TPC

Radio regulations may require radio local area networks (RLANs) operating in the 5 GHz band to use

transmitter power control, involving specification of a regulatory maximum transmit power and a mitigation

requirement for each allowed channel, to reduce interference with satellite services. The TPC service is used

to satisfy this regulatory requirement.

The TPC service provides for the following:

— Association of STAs with an AP in a BSS based on the STAs’ power capability.

— Specification of regulatory and local maximum transmit power levels for the current channel.

— Selection of a transmit power for each transmission in a channel within constraints imposed by

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 96 of 946 PageID #:

4200
96

Claim 6 of the ’802 Patent Prior Art Reference – 802.11-2007

regulatory requirements.

— Adaptation of transmit power based on a range of information, including path loss and link margin

estimates.

See, e.g., 802.11-2007 § 5.4.4.1

7.3.2.20 Channel Switch Announcement element

The Channel Switch Announcement element is used by an AP in a BSS or a STA in an IBSS to advertise

when it is changing to a new channel and the channel number of the new channel. The format of the Channel

Switch Announcement element is shown in Figure 7-57.

See, e.g., 802.11-2007 § 7.3.2.20

10.3.11 Spectrum management protocol layer model

The layer management extensions for measurement and channel switching assume a certain partition

of spectrum management functionality between the MLME and SME. This partitioning assumes th at

policy decisions (e.g., regarding measurement and channel switching) reside in the SME, while the protocol

for measurement, switch timing, and the associated frame exchanges resides within the MLME (see

Figure 10-2).

...

The informative diagrams within this subclause further illustrate the spectrum management protocol model

adopted. Figure 10-3 and Figure 10-4 depict the measurement process for a peer STA to accept and reject a

measurement request, respectively. Figure 10-5 illustrates the TPC adaptation process. Lastly, Figure 10-6

depicts the management process for a channel switch using a Channel Switch Announcement frame.

See, e.g., 802.11-2007 § 10.3.11

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 97 of 946 PageID #:

4201
97

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 98 of 946 PageID #:

4202
98

Claim 6 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 § 10.4.3.2

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 99 of 946 PageID #:

4203
99

Claim 6 of the ’802 Patent Prior Art Reference – 802.11-2007

17.1 Introduction

This clause specifies the PHY entity for an orthogonal frequency division multiplexing (OFDM) system.

The OFDM system provides a WLAN with data payload communication capabilities of 6, 9, 12, 18, 24, 36,

48, and 54 Mb/s. The support of transmitting and receiving at data rates of 6, 12, and 24 Mb/s is mandatory.

The system uses 52 subcarriers that are modulated using binary or quadrature phase shift keying (BPSK or

QPSK) or using 16- or 64-quadrature amplitude modulation (16-QAM or 64-QAM). Forward error

correction coding (convolutional coding) is used with a coding rate of 1/2, 2/3, or 3/4.

The OFDM system also provides a “half-clocked” operation using 10 MHz channel spacings with data

communications capabilities of 3, 4.5, 6, 9, 12, 18, 24, and 27 Mb/s. The support of transmitting and

receiving at data rates of 3, 6, and 12 Mb/s is mandatory when using 10 MHz channel spacing. The halfclocked

operation doubles symbol times and clear channel assessment (CCA) times when using 10 MHz

channel spacing. The regulatory requirements and information regarding use of this OFDM system in

4.9 GHz and 5 GHz bands is in Annex I and Annex J.

The OFDM system also provides a “quarter-clocked” operation using 5 MHz channel spacing with data

communication capabilities of 1.5, 2.25, 3, 4.5, 6, 9, 12, and 13.5 Mb/s. The support of transmitting and

receiving at data rates of 1.5, 3, and 6 Mb/s is mandatory when using 5 MHz channel spacing. The quarterclocked

operation quadruples symbol times and CCA times when using 5 MHz channel spacing. The

regulatory requirements and information regarding use of this OFDM system in the 4.9 GHz band is in

Annex I and Annex J.

See, e.g., 802.11-2007 § 17.1

17.3.2.1 Overview of the PPDU encoding process

The encoding process is composed of many detailed steps, which are described fully in later subclauses, as

noted below. The following overview intends to facilitate understanding the details of the convergence

procedure:

a) Produce the PLCP Preamble field, composed of 10 repetitions of a “short training sequence” (used

for AGC convergence, diversity selection, timing acquisition, and coarse frequency acquisition in

the receiver) and two repetitions of a “long training sequence” (used for channel estimation and fine

frequency acquisition in the receiver), preceded by a guard interval (GI). Refer to 17.3.3 for details.

b) Produce the PLCP header field from the RATE, LENGTH, and SERVICE fields of the

TXVECTOR by filling the appropriate bit fields. The RATE and LENGTH fields of the PLCP

header are encoded by a convolutional code at a rate of R = 1/2, and are subsequently mapped onto a

single BPSK encoded OFDM symbol, denoted as the SIGNAL symbol. In order to facilitate a

reliable and timely detection of the RATE and LENGTH fields, 6 zero tail bits are inserted into the

PLCP header. The encoding of the SIGNAL field into an OFDM symbol follows the same steps for

convolutional encoding, interleaving, BPSK modulation, pilot insertion, Fourier transform, and

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 100 of 946 PageID #:

4204
100

Claim 6 of the ’802 Patent Prior Art Reference – 802.11-2007

prepending a GI as described subsequently for data transmission with BPSK-OFDM modulated at

coding rate 1/2. The contents of the SIGNAL field are not scrambled. Refer to 17.3.4 for details.

c) Calculate from RATE field of the TXVECTOR the number of data bits per OFDM symbol (NDBPS),

the coding rate (R), the number of bits in each OFDM subcarrier (NBPSC), and the number of coded

bits per OFDM symbol (NCBPS). Refer to 17.3.2.2 for details.

d) Append the PSDU to the SERVICE field of the TXVECTOR. Extend the resulting bit string with

zero bits (at least 6 bits) so that the resulting length will be a multiple of NDBPS. The resulting bit

string constitutes the DATA part of the packet. Refer to 17.3.5.3 for details.

e) Initiate the scrambler with a pseudo-random nonzero seed, generate a scrambling sequence, and

XOR it with the extended string of data bits. Refer to 17.3.5.4 for details.

f) Replace the six scrambled zero bits following the data with six nonscrambled zero bits. (Those bits

return the convolutional encoder to the zero state and are denoted as tail bits.) Refer to 17.3.5.2 for

details.

g) Encode the extended, scrambled data string with a convolutional encoder (R = 1/2). Omit (puncture)

some of the encoder output string (chosen according to “puncturing pattern”) to reach the desired

“coding rate.” Refer to 17.3.5.5 for details.

h) Divide the encoded bit string into groups of NCBPS bits. Within each group, perform an

“interleaving” (reordering) of the bits according to a rule corresponding to the desired RATE. Refer

to 17.3.5.6 for details.

i) Divide the resulting coded and interleaved data string into groups of NCBPS bits. For each of the bit

groups, convert the bit group into a complex number according to the modulation encoding tables.

Refer to 17.3.5.7 for details.

j) Divide the complex number string into groups of 48 complex numbers. Each such group will be

associated with one OFDM symbol. In each group, the complex numbers will be numbered 0 to 47

and mapped hereafter into OFDM subcarriers numbered –26 to –22, –20 to –8, –6 to –1, 1 to 6,

8 to 20, and 22 to 26. The subcarriers –21, –7, 7, and 21 are skipped and, subsequently, used for

inserting pilot subcarriers. The 0 subcarrier, associated with center frequency, is omitted and filled

with zero value. Refer to 17.3.5.9 for details.

k) Four subcarriers are inserted as pilots into positions –21, –7, 7, and 21. The total number of the

subcarriers is 52 (48 + 4). Refer to 17.3.5.8 for details.

l) For each group of subcarriers –26 to 26, convert the subcarriers to time domain using inverse

Fourier transform. Prepend to the Fourier-transformed waveform a circular extension of itself thus

forming a GI, and truncate the resulting periodic waveform to a single OFDM symbol length by

applying time domain windowing. Refer to 17.3.5.9 for details.

m) Append the OFDM symbols one after another, starting after the SIGNAL symbol describing the

RATE and LENGTH fields. Refer to 17.3.5.9 for details.

n) Up-convert the resulting “complex baseband” waveform to an RF according to the center frequency

of the desired channel and transmit. Refer to 17.3.2.4 and 17.3.8.1 for details.

An illustration of the transmitted frame and its parts appears in Figure 17-4 (in 17.3.3).

See, e.g., 802.11-2007 § 17.3.2.1

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 101 of 946 PageID #:

4205
101

Claim 6 of the ’802 Patent Prior Art Reference – 802.11-2007

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 102 of 946 PageID #:

4206
102

Claim 6 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 § 17.3.2.3

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 103 of 946 PageID #:

4207
103

Claim 6 of the ’802 Patent Prior Art Reference – 802.11-2007

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 104 of 946 PageID #:

4208
104

Claim 6 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 § 17.3.2.4 Eq. (17-1)

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 105 of 946 PageID #:

4209
105

Claim 6 of the ’802 Patent Prior Art Reference – 802.11-2007

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 106 of 946 PageID #:

4210
106

Claim 6 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 § 17.3.2.5

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 107 of 946 PageID #:

4211
107

Claim 6 of the ’802 Patent Prior Art Reference – 802.11-2007

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 108 of 946 PageID #:

4212
108

See, e.g., 802.11-2007 § 17.3.3

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 109 of 946 PageID #:

4213
109

Claim 6 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 § 17.3.5.7

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 110 of 946 PageID #:

4214
110

Claim 6 of the ’802 Patent Prior Art Reference – 802.11-2007

17.3.5.8 Pilot subcarriers

In each OFDM symbol, four of the subcarriers are dedicated to pilot signals in order to make the coherent

detection robust against frequency offsets and phase noise. These pilot signals shall be put in subcarriers

–21, –7, 7, and 21. The pilots shall be BPSK modulated by a pseudo-binary sequence to prevent the

generation of spectral lines. The contribution of the pilot subcarriers to each OFDM symbol is described in

17.3.5.9.

See, e.g., 802.11-2007 § 17.3.5.8

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 111 of 946 PageID #:

4215
111

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 112 of 946 PageID #:

4216
112

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 113 of 946 PageID #:

4217
113

Claim 6 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 § 17.3.5.9

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 114 of 946 PageID #:

4218
114

Claim 6 of the ’802 Patent Prior Art Reference – 802.11-2007

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 115 of 946 PageID #:

4219
115

Claim 6 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 § 17.3.8.1

17.3.8.3.1 Operating frequency range

The OFDM PHY shall operate in the 5 GHz band, as allocated by a regulatory body in its operational region.

Spectrum allocation in the 5 GHz band is subject to authorities responsible for geographic-specific

regulatory domains (e.g., global, regional, and national). The particular channelization to be used for this

standard is dependent on such allocation, as well as the associated regulations for use of the allocations.

These regulations are subject to revision, or may be superseded.

In some regulatory domains, several frequency bands may be available for OFDM PHY-based WLANs.

These bands may be contiguous or not, and different regulatory limits may be applicable. A compliant

OFDM PHY shall support at least one frequency band in at least one regulatory domain. The support of

specific regulatory domains, and bands within the domains, shall be indicated by PLME attributes

dot11RegDomainsSupported and dot11FrequencyBandsSupported.

See, e.g., 802.11-2007 § 17.3.8.3.1

17.3.9.1 Transmit power levels

The maximum allowable transmit power by regulatory domain is defined in Annex I.

See, e.g., 802.11-2007 § 17.3.9.1

17.3.9.6.2 Transmitter spectral flatness

The average energy of the constellations in each of the spectral lines –16.. –1 and +1.. +16 will deviate no

more than ± 2 dB from their average energy. The average energy of the constellations in each of the spectral

lines –26.. –17 and +17.. +26 will deviate no more than +2/–4 dB from the average energy of spectral lines

–16.. –1 and +1.. +16. The data for this test shall be derived from the channel estimation step.

See, e.g., 802.11-2007 § 17.3.9.6.2

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 116 of 946 PageID #:

4220
116

Claim 6 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 § I.2.2

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 117 of 946 PageID #:

4221
117

Claim 6 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 § I.2.3

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 118 of 946 PageID #:

4222
118

Claim 6 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 Figure 5-7

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 119 of 946 PageID #:

4223
119

Claim 6 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 Figure 10-6

Furthermore, this claim element is obvious in light of 802.11-2007 itself, when combined with any of 

the other references as charted for this claim element in Exs. A-1–A-31, First Supplemental Ex. ACase 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 120 of 946 PageID #:

4224
120

Claim 6 of the ’802 Patent Prior Art Reference – 802.11-2007

Obviousness 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 – 802.11-2007

[7.1] The method of claim 1 802.11-2007 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 

transmitted across two 

different frequencies.

802.11-2007 discloses “wherein the first information and the second information are the same data 

transmitted across two different frequencies.” See, e.g.: 

1.1 Scope

The scope of this standard is to define one medium access control (MAC) and several physical layer (PHY)

specifications for wireless connectivity for fixed, portable, and moving stations (STAs) within a local area.

See, e.g., 802.11-2007 § 1.1

5.1.1 How WLAN systems are different

Wireless networks have fundamental characteristics that make them significantly different from traditional

wired LANs. Some countries impose specific requirements for radio equipment in addition to those

specified in this standard. This standard does not provide information to meet these country -specific radio

regulations.

5.1.1.1 Destination address does not equal destination location

In wired LANs, an address is equivalent to a physical location. This is implicitly assumed in the design of

wired LANs. In IEEE Std 802.11, the addressable unit is a station (STA). The STA is a message destination,

but not (in general) a fixed location.

5.1.1.2 Media impact on design and performance

The PHYs used in IEEE Std 802.11 are fundamentally different from wired media. Thus IEEE 802.11 PHYs

a) Use a medium that has neither absolute nor readily observable boundaries outside of which STAs

with conformant PHY transceivers are known to be unable to receive network frames

b) Are unprotected from other signals that may be sharing the medium

c) Communicate over a medium significantly less reliable than wired PHYs

d) Have dynamic topologies

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 121 of 946 PageID #:

4225
121

Claim 7 of the ’802 Patent Prior Art Reference – 802.11-2007

e) Lack full connectivity, and therefore the assumption normally made that every STA can hear every

other STA is invalid (i.e., STAs may be “hidden” from each other)

f) Have time-varying and asymmetric propagation properties

g) May experience interference from logically disjoint IEEE 802.11 networks operating in overlapping

areas

Because of limitations on wireless PHY ranges, WLANs intended to cover reasonable geographic distances

may be built from basic coverage building blocks. When providing QoS services it should be understood

that the MAC endeavors to provide QoS “service guarantees” within the limitations of the medium

properties identified above. In other words, particularly in unlicensed spectrum, true guarantees are often not

possible. However, gradations of service are always possible; and in sufficiently controlled environments,

QoS guarantees can truly be made.

5.1.1.3 The impact of handling mobile STAs

One of the requirements of IEEE Std 802.11 is to handle mobile as well as portable STAs. A portable STA

is one that is moved from location to location, but that is only used while at a fixed location. Mobile STAs

actually access the LAN while in motion.

For technical reasons, it is not sufficient to handle only portable STAs. Propagation effects blur the

distinction between portable and mobile STAs; stationary STAs often appear to be mobile due to

propagation effects.

Another aspect of mobile STAs is that they may often be battery powered. Hence power management is

an important consideration. For example, it cannot be presumed that a STA’s receiver will always be

powered on.

See, e.g., 802.11-2007 § 5.1.1 - § 5.1.1.3

5.2 Components of the IEEE 802.11 architecture

The IEEE 802.11 architecture consists of several components that interact to provide a WLAN that supports

STA mobility transparently to upper layers.

The basic service set (BSS) is the basic building block of an IEEE 802.11 LAN. Figure 5 -1 shows two BSSs,

each of which has two STAs that are members of the BSS.

It is useful to think of the ovals used to depict a BSS as the coverage area within which the member STAs of

the BSS may remain in communication. (The concept of area, while not precise, is often good enough.) This

area is called the Basic Service Area (BSA). If a STA moves out of its BSA, it can no longer directly

communicate with other STAs present in the BSA.

See, e.g., 802.11-2007 § 5.2

5.2.3 Distribution system (DS) concepts

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 122 of 946 PageID #:

4226
122

Claim 7 of the ’802 Patent Prior Art Reference – 802.11-2007

PHY limitations determine the direct station-to-station distance that may be supported. For some networks

this distance is sufficient; for other networks, increased coverage is required.

Instead of existing independently, a BSS may also form a component of an extended form of network that is

built with multiple BSSs. The architectural component used to interconnect BSSs is the DS.

IEEE Std 802.11 logically separates the WM from the distribution system medium (DSM). Each logical

medium is used for different purposes, by a different component of the architecture. The IEEE 802.11

definitions neither preclude, nor demand, that the multiple media be either the same or different.

Recognizing that the multiple media are logically different is key to understanding the flexibility of the

architecture. The IEEE 802.11 LAN architecture is specified independently of the physical characteristics of

any specific implementation.

The DS enables mobile device support by providing the logical services necessary to handle address to

destination mapping and seamless integration of multiple BSSs.

An access point (AP) is any entity that has STA functionality and enables access to the DS, via the WM for

associated STAs.

See, e.g., 802.11-2007 § 5.2.3

5.3.2 DSS

The service provided by the DS is known as the DSS.

This service is represented in the IEEE 802.11 architecture by arrows within the APs, indicating that the

service is used to cross media and possibly address space logical boundaries. An AP is a logical entity, and

the functions described may be shared by one or more physical entities.

The services that comprise the DSS are as follows:

a) Association

b) Disassociation

c) Distribution

d) Integration

e) Reassociation

f) QoS traffic scheduling (QoS facility only)

DSSs are specified for use by MAC sublayer entities.

Figure 5-7 combines the components from previous figures with both types of services to show the complete

IEEE 802.11 architecture.

See, e.g., 802.11-2007 § 5.3.2

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 123 of 946 PageID #:

4227
123

Claim 7 of the ’802 Patent Prior Art Reference – 802.11-2007

5.4.4.1 TPC

Radio regulations may require radio local area networks (RLANs) operating in the 5 GHz band to use

transmitter power control, involving specification of a regulatory maximum transmit power and a mitigation

requirement for each allowed channel, to reduce interference with satellite services. The TPC service is used

to satisfy this regulatory requirement.

The TPC service provides for the following:

— Association of STAs with an AP in a BSS based on the STAs’ power capability.

— Specification of regulatory and local maximum transmit power levels for the current channel.

— Selection of a transmit power for each transmission in a channel within constraints imposed by

regulatory requirements.

— Adaptation of transmit power based on a range of information, including path loss and link margin

estimates.

See, e.g., 802.11-2007 § 5.4.4.1

7.3.2.20 Channel Switch Announcement element

The Channel Switch Announcement element is used by an AP in a BSS or a STA in an IBSS to advertise

when it is changing to a new channel and the channel number of the new channel. The format of the Channel

Switch Announcement element is shown in Figure 7-57.

See, e.g., 802.11-2007 § 7.3.2.20

10.3.11 Spectrum management protocol layer model

The layer management extensions for measurement and channel switching assume a certain partition

of spectrum management functionality between the MLME and SME. This partitioning assumes that

policy decisions (e.g., regarding measurement and channel switching) reside in the SME, while the protocol

for measurement, switch timing, and the associated frame exchanges resides within the MLME (see

Figure 10-2).

...

The informative diagrams within this subclause further illustrate the spectrum management protocol model

adopted. Figure 10-3 and Figure 10-4 depict the measurement process for a peer STA to accept and reject a

measurement request, respectively. Figure 10-5 illustrates the TPC adaptation process. Lastly, Figure 10-6

depicts the management process for a channel switch using a Channel Switch Announcement frame.

See, e.g., 802.11-2007 § 10.3.11

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 124 of 946 PageID #:

4228
124

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 125 of 946 PageID #:

4229
125

Claim 7 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 § 10.4.3.2

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 126 of 946 PageID #:

4230
126

Claim 7 of the ’802 Patent Prior Art Reference – 802.11-2007

17.1 Introduction

This clause specifies the PHY entity for an orthogonal frequency division multiplexing (OFDM) system.

The OFDM system provides a WLAN with data payload communication capabilities of 6, 9, 12, 18, 24, 36,

48, and 54 Mb/s. The support of transmitting and receiving at data rates of 6, 12, and 24 Mb/s is mandatory.

The system uses 52 subcarriers that are modulated using binary or quadrature phase shift keying (BPSK or

QPSK) or using 16- or 64-quadrature amplitude modulation (16-QAM or 64-QAM). Forward error

correction coding (convolutional coding) is used with a coding rate of 1/2, 2/3, or 3/4.

The OFDM system also provides a “half-clocked” operation using 10 MHz channel spacings with data

communications capabilities of 3, 4.5, 6, 9, 12, 18, 24, and 27 Mb/s. The support of transmitting and

receiving at data rates of 3, 6, and 12 Mb/s is mandatory when using 10 MHz channel spacing. The halfclocked

operation doubles symbol times and clear channel assessment (CCA) times when using 10 MHz

channel spacing. The regulatory requirements and information regarding use of this OFDM system in

4.9 GHz and 5 GHz bands is in Annex I and Annex J.

The OFDM system also provides a “quarter-clocked” operation using 5 MHz channel spacing with data

communication capabilities of 1.5, 2.25, 3, 4.5, 6, 9, 12, and 13.5 Mb/s. The support of transmitting and

receiving at data rates of 1.5, 3, and 6 Mb/s is mandatory when using 5 MHz channel spacing. The quarterclocked

operation quadruples symbol times and CCA times when using 5 MHz channel spacing. The

regulatory requirements and information regarding use of this OFDM system in the 4.9 GHz band is in

Annex I and Annex J.

See, e.g., 802.11-2007 § 17.1

17.3.2.1 Overview of the PPDU encoding process

The encoding process is composed of many detailed steps, which are described fully in later subclauses, as

noted below. The following overview intends to facilitate understanding the details of the convergence

procedure:

a) Produce the PLCP Preamble field, composed of 10 repetitions of a “short training sequence” (used

for AGC convergence, diversity selection, timing acquisition, and coarse frequency acquisition in

the receiver) and two repetitions of a “long training sequence” (used for channel estimation and fine

frequency acquisition in the receiver), preceded by a guard interval (GI). Refer to 17.3.3 for details.

b) Produce the PLCP header field from the RATE, LENGTH, and SERVICE fields of the

TXVECTOR by filling the appropriate bit fields. The RATE and LENGTH field s of the PLCP

header are encoded by a convolutional code at a rate of R = 1/2, and are subsequently mapped onto a

single BPSK encoded OFDM symbol, denoted as the SIGNAL symbol. In order to facilitate a

reliable and timely detection of the RATE and LENGTH fields, 6 zero tail bits are inserted into the

PLCP header. The encoding of the SIGNAL field into an OFDM symbol follows the same steps for

convolutional encoding, interleaving, BPSK modulation, pilot insertion, Fourier transform, and

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 127 of 946 PageID #:

4231
127

Claim 7 of the ’802 Patent Prior Art Reference – 802.11-2007

prepending a GI as described subsequently for data transmission with BPSK-OFDM modulated at

coding rate 1/2. The contents of the SIGNAL field are not scrambled. Refer to 17.3.4 for details.

c) Calculate from RATE field of the TXVECTOR the number of data bits per OFDM symbol (NDBPS),

the coding rate (R), the number of bits in each OFDM subcarrier (NBPSC), and the number of coded

bits per OFDM symbol (NCBPS). Refer to 17.3.2.2 for details.

d) Append the PSDU to the SERVICE field of the TXVECTOR. Extend the resulting bit string with

zero bits (at least 6 bits) so that the resulting length will be a multiple of NDBPS. The resulting bit

string constitutes the DATA part of the packet. Refer to 17.3.5.3 for details.

e) Initiate the scrambler with a pseudo-random nonzero seed, generate a scrambling sequence, and

XOR it with the extended string of data bits. Refer to 17.3.5.4 for details.

f) Replace the six scrambled zero bits following the data with six nonscrambled zero bits. (Those bits

return the convolutional encoder to the zero state and are denoted as tail bits.) Refer to 17.3.5.2 for

details.

g) Encode the extended, scrambled data string with a convolutional encoder (R = 1/2). Omit (puncture)

some of the encoder output string (chosen according to “puncturing pattern”) to r each the desired

“coding rate.” Refer to 17.3.5.5 for details.

h) Divide the encoded bit string into groups of NCBPS bits. Within each group, perform an

“interleaving” (reordering) of the bits according to a rule corresponding to the desired RATE. Refer

to 17.3.5.6 for details.

i) Divide the resulting coded and interleaved data string into groups of NCBPS bits. For each of the bit

groups, convert the bit group into a complex number according to the modulation encoding tables.

Refer to 17.3.5.7 for details.

j) Divide the complex number string into groups of 48 complex numbers. Each such group will be

associated with one OFDM symbol. In each group, the complex numbers will be numbered 0 to 47

and mapped hereafter into OFDM subcarriers numbered –26 to –22, –20 to –8, –6 to –1, 1 to 6,

8 to 20, and 22 to 26. The subcarriers –21, –7, 7, and 21 are skipped and, subsequently, used for

inserting pilot subcarriers. The 0 subcarrier, associated with center frequency, is omitted and filled

with zero value. Refer to 17.3.5.9 for details.

k) Four subcarriers are inserted as pilots into positions –21, –7, 7, and 21. The total number of the

subcarriers is 52 (48 + 4). Refer to 17.3.5.8 for details.

l) For each group of subcarriers –26 to 26, convert the subcarriers to time domain using inverse

Fourier transform. Prepend to the Fourier-transformed waveform a circular extension of itself thus

forming a GI, and truncate the resulting periodic waveform to a single OFDM symbol length by

applying time domain windowing. Refer to 17.3.5.9 for details.

m) Append the OFDM symbols one after another, starting after the SIGNAL symbol describing the

RATE and LENGTH fields. Refer to 17.3.5.9 for details.

n) Up-convert the resulting “complex baseband” waveform to an RF according to the center frequency

of the desired channel and transmit. Refer to 17.3.2.4 and 17.3.8.1 for details.

An illustration of the transmitted frame and its parts appears in Figure 17-4 (in 17.3.3).

See, e.g., 802.11-2007 § 17.3.2.1

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 128 of 946 PageID #:

4232
128

Claim 7 of the ’802 Patent Prior Art Reference – 802.11-2007

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 129 of 946 PageID #:

4233
129

Claim 7 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 § 17.3.2.3

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 130 of 946 PageID #:

4234
130

Claim 7 of the ’802 Patent Prior Art Reference – 802.11-2007

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 131 of 946 PageID #:

4235
131

Claim 7 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 § 17.3.2.4 Eq. (17-1)

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 132 of 946 PageID #:

4236
132

Claim 7 of the ’802 Patent Prior Art Reference – 802.11-2007

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 133 of 946 PageID #:

4237
133

Claim 7 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 § 17.3.2.5

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 134 of 946 PageID #:

4238
134

Claim 7 of the ’802 Patent Prior Art Reference – 802.11-2007

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 135 of 946 PageID #:

4239
135

See, e.g., 802.11-2007 § 17.3.3

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 136 of 946 PageID #:

4240
136

Claim 7 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 § 17.3.5.7

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 137 of 946 PageID #:

4241
137

Claim 7 of the ’802 Patent Prior Art Reference – 802.11-2007

17.3.5.8 Pilot subcarriers

In each OFDM symbol, four of the subcarriers are dedicated to pilot signals in order to make the coherent

detection robust against frequency offsets and phase noise. These pilot signals shall be put in subcarriers

–21, –7, 7, and 21. The pilots shall be BPSK modulated by a pseudo-binary sequence to prevent the

generation of spectral lines. The contribution of the pilot subcarriers to each OFDM symbol is described in

17.3.5.9.

See, e.g., 802.11-2007 § 17.3.5.8

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 138 of 946 PageID #:

4242
138

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 139 of 946 PageID #:

4243
139

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 140 of 946 PageID #:

4244
140

Claim 7 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 § 17.3.5.9

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 141 of 946 PageID #:

4245
141

Claim 7 of the ’802 Patent Prior Art Reference – 802.11-2007

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 142 of 946 PageID #:

4246
142

Claim 7 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 § 17.3.8.1

17.3.8.3.1 Operating frequency range

The OFDM PHY shall operate in the 5 GHz band, as allocated by a regulatory body in its operational region.

Spectrum allocation in the 5 GHz band is subject to authorities responsible for geographic-specific

regulatory domains (e.g., global, regional, and national). The particular channelization to be used for this

standard is dependent on such allocation, as well as the associated regulations for use of the allocations.

These regulations are subject to revision, or may be superseded.

In some regulatory domains, several frequency bands may be available for OFDM PHY-based WLANs.

These bands may be contiguous or not, and different regulatory limits may be applicable. A compliant

OFDM PHY shall support at least one frequency band in at least one regulatory domain. The support of

specific regulatory domains, and bands within the domains, shall be indicated by PLME attributes

dot11RegDomainsSupported and dot11FrequencyBandsSupported.

See, e.g., 802.11-2007 § 17.3.8.3.1

17.3.9.1 Transmit power levels

The maximum allowable transmit power by regulatory domain is defined in Annex I.

See, e.g., 802.11-2007 § 17.3.9.1

17.3.9.6.2 Transmitter spectral flatness

The average energy of the constellations in each of the spectral lines –16.. –1 and +1.. +16 will deviate no

more than ± 2 dB from their average energy. The average energy of the constellations in each of the spectral

lines –26.. –17 and +17.. +26 will deviate no more than +2/–4 dB from the average energy of spectral lines

–16.. –1 and +1.. +16. The data for this test shall be derived from the channel estimation step.

See, e.g., 802.11-2007 § 17.3.9.6.2

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 143 of 946 PageID #:

4247
143

Claim 7 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 § I.2.2

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 144 of 946 PageID #:

4248
144

Claim 7 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 § I.2.3

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 145 of 946 PageID #:

4249
145

Claim 7 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 Figure 5-7

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 146 of 946 PageID #:

4250
146

Claim 7 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 Figure 10-6

Furthermore, this claim element is obvious in light of 802.11-2007 itself, when combined with any of 

the other references as charted for this claim element in Exs. A-1–A-31, First Supplemental Ex. ACase 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 147 of 946 PageID #:

4251
147

Claim 7 of the ’802 Patent Prior Art Reference – 802.11-2007

Obviousness 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 – 802.11-2007

[8.1] The method of claim 1 802.11-2007 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.

802.11-2007 discloses “wherein the first information and the second information are from the same 

data stream.” See, e.g.: 

1.1 Scope

The scope of this standard is to define one medium access control (MAC) and s everal physical layer (PHY)

specifications for wireless connectivity for fixed, portable, and moving stations (STAs) within a local area.

See, e.g., 802.11-2007 § 1.1

5.1.1 How WLAN systems are different

Wireless networks have fundamental characteristics that make them significantly different from traditional

wired LANs. Some countries impose specific requirements for radio equipment in addition to those

specified in this standard. This standard does not provide information to meet these country-specific radio

regulations.

5.1.1.1 Destination address does not equal destination location

In wired LANs, an address is equivalent to a physical location. This is implicitly assumed in the design of

wired LANs. In IEEE Std 802.11, the addressable unit is a station (STA). The STA is a message destination,

but not (in general) a fixed location.

5.1.1.2 Media impact on design and performance

The PHYs used in IEEE Std 802.11 are fundamentally different from wired media. Thus IEEE 802.11 PHYs

a) Use a medium that has neither absolute nor readily observable boundaries outside of which STAs

with conformant PHY transceivers are known to be unable to receive network frames

b) Are unprotected from other signals that may be sharing the medium

c) Communicate over a medium significantly less reliable than wired PHYs

d) Have dynamic topologies

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 148 of 946 PageID #:

4252
148

Claim 8 of the ’802 Patent Prior Art Reference – 802.11-2007

e) Lack full connectivity, and therefore the assumption normally made that every STA can hear every

other STA is invalid (i.e., STAs may be “hidden” from each other)

f) Have time-varying and asymmetric propagation properties

g) May experience interference from logically disjoint IEEE 802.11 networks operating in overlapping

areas

Because of limitations on wireless PHY ranges, WLANs intended to cover reasonable geogr aphic distances

may be built from basic coverage building blocks. When providing QoS services it should be understood

that the MAC endeavors to provide QoS “service guarantees” within the limitations of the medium

properties identified above. In other words, particularly in unlicensed spectrum, true guarantees are often not

possible. However, gradations of service are always possible; and in sufficiently controlled environments,

QoS guarantees can truly be made.

5.1.1.3 The impact of handling mobile STAs

One of the requirements of IEEE Std 802.11 is to handle mobile as well as portable STAs. A portable STA

is one that is moved from location to location, but that is only used while at a fixed location. Mobile STAs

actually access the LAN while in motion.

For technical reasons, it is not sufficient to handle only portable STAs. Propagation effects blur the

distinction between portable and mobile STAs; stationary STAs often appear to be mobile due to

propagation effects.

Another aspect of mobile STAs is that they may often be battery powered. Hence power management is

an important consideration. For example, it cannot be presumed that a STA’s receiver will always be

powered on.

See, e.g., 802.11-2007 § 5.1.1 - § 5.1.1.3

5.2 Components of the IEEE 802.11 architecture

The IEEE 802.11 architecture consists of several components that interact to provide a WLAN that supports

STA mobility transparently to upper layers.

The basic service set (BSS) is the basic building block of an IEEE 802.11 LAN. Figure 5 -1 shows two BSSs,

each of which has two STAs that are members of the BSS.

It is useful to think of the ovals used to depict a BSS as the coverage area within which the member STAs of

the BSS may remain in communication. (The concept of area, while not precis e, is often good enough.) This

area is called the Basic Service Area (BSA). If a STA moves out of its BSA, it can no longer directly

communicate with other STAs present in the BSA.

See, e.g., 802.11-2007 § 5.2

5.2.3 Distribution system (DS) concepts

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 149 of 946 PageID #:

4253
149

Claim 8 of the ’802 Patent Prior Art Reference – 802.11-2007

PHY limitations determine the direct station-to-station distance that may be supported. For some networks

this distance is sufficient; for other networks, increased coverage is required.

Instead of existing independently, a BSS may also form a component of an extended form of network that is

built with multiple BSSs. The architectural component used to interconnect BSSs is the DS.

IEEE Std 802.11 logically separates the WM from the distribution system medium (DSM). Each logical

medium is used for different purposes, by a different component of the architecture. The IEEE 802.11

definitions neither preclude, nor demand, that the multiple media be either the same or different.

Recognizing that the multiple media are logically different is key to understanding the flexibility of the

architecture. The IEEE 802.11 LAN architecture is specified independently of the physical characteristics of

any specific implementation.

The DS enables mobile device support by providing the logical services necessary to handle address to

destination mapping and seamless integration of multiple BSSs.

An access point (AP) is any entity that has STA functionality and enables access to the DS, via the WM for

associated STAs.

See, e.g., 802.11-2007 § 5.2.3

5.3.2 DSS

The service provided by the DS is known as the DSS.

This service is represented in the IEEE 802.11 architecture by arrows within the APs, indicating that the

service is used to cross media and possibly address space logical boundaries. An AP is a logical entity, and

the functions described may be shared by one or more physical entities.

The services that comprise the DSS are as follows:

a) Association

b) Disassociation

c) Distribution

d) Integration

e) Reassociation

f) QoS traffic scheduling (QoS facility only)

DSSs are specified for use by MAC sublayer entities.

Figure 5-7 combines the components from previous figures with both types of services to show the complete

IEEE 802.11 architecture.

See, e.g., 802.11-2007 § 5.3.2

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 150 of 946 PageID #:

4254
150

Claim 8 of the ’802 Patent Prior Art Reference – 802.11-2007

5.4.4.1 TPC

Radio regulations may require radio local area networks (RLANs) operating in the 5 GHz band to use

transmitter power control, involving specification of a regulatory maximum transmit power and a mitigation

requirement for each allowed channel, to reduce interference with satellite services. The TPC service is used

to satisfy this regulatory requirement.

The TPC service provides for the following:

— Association of STAs with an AP in a BSS based on the STAs’ power capability.

— Specification of regulatory and local maximum transmit power levels for the current channel.

— Selection of a transmit power for each transmission in a channel within constraints imposed by

regulatory requirements.

— Adaptation of transmit power based on a range of information, including path loss and link margin

estimates.

See, e.g., 802.11-2007 § 5.4.4.1

7.3.2.20 Channel Switch Announcement element

The Channel Switch Announcement element is used by an AP in a BSS or a STA in an IBSS to advertise

when it is changing to a new channel and the channel number of the new channel. The format of the Channel

Switch Announcement element is shown in Figure 7-57.

See, e.g., 802.11-2007 § 7.3.2.20

10.3.11 Spectrum management protocol layer model

The layer management extensions for measurement and channel switching assume a certain partition

of spectrum management functionality between the MLME and SME. This partitioning assumes that

policy decisions (e.g., regarding measurement and channel switching) reside in the SME, while the protocol

for measurement, switch timing, and the associated frame exchanges resides within the MLME (see

Figure 10-2).

...

The informative diagrams within this subclause further illustrate the spectrum management protocol model

adopted. Figure 10-3 and Figure 10-4 depict the measurement process for a peer STA to accept and reject a

measurement request, respectively. Figure 10-5 illustrates the TPC adaptation process. Lastly, Figure 10-6

depicts the management process for a channel switch using a Channel Switch Annou ncement frame.

See, e.g., 802.11-2007 § 10.3.11

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 151 of 946 PageID #:

4255
151

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 152 of 946 PageID #:

4256
152

Claim 8 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 § 10.4.3.2

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 153 of 946 PageID #:

4257
153

Claim 8 of the ’802 Patent Prior Art Reference – 802.11-2007

17.1 Introduction

This clause specifies the PHY entity for an orthogonal frequency division multiplexing (OFDM) system.

The OFDM system provides a WLAN with data payload communication capabilities of 6, 9, 12, 18, 24, 36,

48, and 54 Mb/s. The support of transmitting and receiving at data rates of 6, 12, and 24 Mb/s is mandatory.

The system uses 52 subcarriers that are modulated using binary or quadrature phase shift keying (BPSK or

QPSK) or using 16- or 64-quadrature amplitude modulation (16-QAM or 64-QAM). Forward error

correction coding (convolutional coding) is used with a coding rate of 1/2, 2/3, or 3/4.

The OFDM system also provides a “half-clocked” operation using 10 MHz channel spacings with data

communications capabilities of 3, 4.5, 6, 9, 12, 18, 24, and 27 Mb/s. The support of transmitting and

receiving at data rates of 3, 6, and 12 Mb/s is mandatory when using 10 MHz channel spacing. The halfclocked

operation doubles symbol times and clear channel assessment (CCA) times when using 10 MHz

channel spacing. The regulatory requirements and information regarding use of this OFDM system in

4.9 GHz and 5 GHz bands is in Annex I and Annex J.

The OFDM system also provides a “quarter-clocked” operation using 5 MHz channel spacing with data

communication capabilities of 1.5, 2.25, 3, 4.5, 6, 9, 12, and 13.5 Mb/s. The support of transmitting and

receiving at data rates of 1.5, 3, and 6 Mb/s is mandatory when using 5 MHz channel spacing. The quarterclocked

operation quadruples symbol times and CCA times when using 5 MHz channel spacing. The

regulatory requirements and information regarding use of this OFDM system in the 4.9 GHz band is in

Annex I and Annex J.

See, e.g., 802.11-2007 § 17.1

17.3.2.1 Overview of the PPDU encoding process

The encoding process is composed of many detailed steps, which are described fully in later subclauses, as

noted below. The following overview intends to facilitate understanding the details of the convergence

procedure:

a) Produce the PLCP Preamble field, composed of 10 repetitions of a “short training sequence” (used

for AGC convergence, diversity selection, timing acquisition, and coarse frequency acquisition in

the receiver) and two repetitions of a “long training sequence” (used for channel estimation and fine

frequency acquisition in the receiver), preceded by a guard interval (GI). Refer to 17.3.3 for details.

b) Produce the PLCP header field from the RATE, LENGTH, and SERVICE fields of the

TXVECTOR by filling the appropriate bit fields. The RATE and LENGTH fields of the PLCP

header are encoded by a convolutional code at a rate of R = 1/2, and are subsequently mapped onto a

single BPSK encoded OFDM symbol, denoted as the SIGNAL symbol. In order to facilitate a

reliable and timely detection of the RATE and LENGTH fields, 6 zero tail bits are inserted into the

PLCP header. The encoding of the SIGNAL field into an OFDM symbol follows the same steps for

convolutional encoding, interleaving, BPSK modulation, pilot insertion, Fourier transform, and

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 154 of 946 PageID #:

4258
154

Claim 8 of the ’802 Patent Prior Art Reference – 802.11-2007

prepending a GI as described subsequently for data transmission with BPSK-OFDM modulated at

coding rate 1/2. The contents of the SIGNAL field are not scrambled. Refer to 17.3.4 for details.

c) Calculate from RATE field of the TXVECTOR the number of data bits per OFDM symbol (NDBPS),

the coding rate (R), the number of bits in each OFDM subcarrier (NBPSC), and the number of coded

bits per OFDM symbol (NCBPS). Refer to 17.3.2.2 for details.

d) Append the PSDU to the SERVICE field of the TXVECTOR. Extend the resulting bit string with

zero bits (at least 6 bits) so that the resulting length will be a multiple of NDBPS. The resulting bit

string constitutes the DATA part of the packet. Refer to 17.3.5.3 for details.

e) Initiate the scrambler with a pseudo-random nonzero seed, generate a scrambling sequence, and

XOR it with the extended string of data bits. Refer to 17.3.5.4 for details.

f) Replace the six scrambled zero bits following the data with six nonscrambled zero bits. (Those bits

return the convolutional encoder to the zero state and are denoted as tail bits.) Refer to 17.3.5.2 for

details.

g) Encode the extended, scrambled data string with a convolutional encoder (R = 1/2). Omit (punc ture)

some of the encoder output string (chosen according to “puncturing pattern”) to reach the desired

“coding rate.” Refer to 17.3.5.5 for details.

h) Divide the encoded bit string into groups of NCBPS bits. Within each group, perform an

“interleaving” (reordering) of the bits according to a rule corresponding to the desired RATE. Refer

to 17.3.5.6 for details.

i) Divide the resulting coded and interleaved data string into groups of NCBPS bits. For each of the bit

groups, convert the bit group into a complex number according to the modulation encoding tables.

Refer to 17.3.5.7 for details.

j) Divide the complex number string into groups of 48 complex numbers. Each such group will be

associated with one OFDM symbol. In each group, the complex numbers will b e numbered 0 to 47

and mapped hereafter into OFDM subcarriers numbered –26 to –22, –20 to –8, –6 to –1, 1 to 6,

8 to 20, and 22 to 26. The subcarriers –21, –7, 7, and 21 are skipped and, subsequently, used for

inserting pilot subcarriers. The 0 subcarrier, associated with center frequency, is omitted and filled

with zero value. Refer to 17.3.5.9 for details.

k) Four subcarriers are inserted as pilots into positions –21, –7, 7, and 21. The total number of the

subcarriers is 52 (48 + 4). Refer to 17.3.5.8 for details.

l) For each group of subcarriers –26 to 26, convert the subcarriers to time domain using inverse

Fourier transform. Prepend to the Fourier-transformed waveform a circular extension of itself thus

forming a GI, and truncate the resulting periodic waveform to a single OFDM symbol length by

applying time domain windowing. Refer to 17.3.5.9 for details.

m) Append the OFDM symbols one after another, starting after the SIGNAL symbol describing the

RATE and LENGTH fields. Refer to 17.3.5.9 for details.

n) Up-convert the resulting “complex baseband” waveform to an RF according to the center frequency

of the desired channel and transmit. Refer to 17.3.2.4 and 17.3.8.1 for details.

An illustration of the transmitted frame and its parts appears in Figure 17-4 (in 17.3.3).

See, e.g., 802.11-2007 § 17.3.2.1

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 155 of 946 PageID #:

4259
155

Claim 8 of the ’802 Patent Prior Art Reference – 802.11-2007

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 156 of 946 PageID #:

4260
156

Claim 8 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 § 17.3.2.3

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 157 of 946 PageID #:

4261
157

Claim 8 of the ’802 Patent Prior Art Reference – 802.11-2007

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 158 of 946 PageID #:

4262
158

Claim 8 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 § 17.3.2.4 Eq. (17-1)

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 159 of 946 PageID #:

4263
159

Claim 8 of the ’802 Patent Prior Art Reference – 802.11-2007

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 160 of 946 PageID #:

4264
160

Claim 8 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 § 17.3.2.5

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 161 of 946 PageID #:

4265
161

Claim 8 of the ’802 Patent Prior Art Reference – 802.11-2007

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 162 of 946 PageID #:

4266
162

See, e.g., 802.11-2007 § 17.3.3

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 163 of 946 PageID #:

4267
163

Claim 8 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 § 17.3.5.7

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 164 of 946 PageID #:

4268
164

Claim 8 of the ’802 Patent Prior Art Reference – 802.11-2007

17.3.5.8 Pilot subcarriers

In each OFDM symbol, four of the subcarriers are dedicated to pilot signals in order to make the coherent

detection robust against frequency offsets and phase noise. These pilot signals shall be put in su bcarriers

–21, –7, 7, and 21. The pilots shall be BPSK modulated by a pseudo-binary sequence to prevent the

generation of spectral lines. The contribution of the pilot subcarriers to each OFDM symbol is described in

17.3.5.9.

See, e.g., 802.11-2007 § 17.3.5.8

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 165 of 946 PageID #:

4269
165

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 166 of 946 PageID #:

4270
166

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 167 of 946 PageID #:

4271
167

Claim 8 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 § 17.3.5.9

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 168 of 946 PageID #:

4272
168

Claim 8 of the ’802 Patent Prior Art Reference – 802.11-2007

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 169 of 946 PageID #:

4273
169

Claim 8 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 § 17.3.8.1

17.3.8.3.1 Operating frequency range

The OFDM PHY shall operate in the 5 GHz band, as allocated by a regulatory body in its operational region.

Spectrum allocation in the 5 GHz band is subject to authorities responsible for geographic-specific

regulatory domains (e.g., global, regional, and national). The particular channelization to be used for this

standard is dependent on such allocation, as well as the associated regulations for use of the allocations.

These regulations are subject to revision, or may be superseded.

In some regulatory domains, several frequency bands may be available for OFDM PHY-based WLANs.

These bands may be contiguous or not, and different regulatory limits may be applicable. A compliant

OFDM PHY shall support at least one frequency band in at least one regulatory domain. The support of

specific regulatory domains, and bands within the domains, shall be indicated by PLME attributes

dot11RegDomainsSupported and dot11FrequencyBandsSupported.

See, e.g., 802.11-2007 § 17.3.8.3.1

17.3.9.1 Transmit power levels

The maximum allowable transmit power by regulatory domain is defined in Annex I.

See, e.g., 802.11-2007 § 17.3.9.1

17.3.9.6.2 Transmitter spectral flatness

The average energy of the constellations in each of the spectral lines –16.. –1 and +1.. +16 will deviate no

more than ± 2 dB from their average energy. The average energy of the constellations in each of the spectral

lines –26.. –17 and +17.. +26 will deviate no more than +2/–4 dB from the average energy of spectral lines

–16.. –1 and +1.. +16. The data for this test shall be derived from the channel estimation step.

See, e.g., 802.11-2007 § 17.3.9.6.2

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 170 of 946 PageID #:

4274
170

Claim 8 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 § I.2.2

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 171 of 946 PageID #:

4275
171

Claim 8 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 § I.2.3

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 172 of 946 PageID #:

4276
172

Claim 8 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 Figure 5-7

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 173 of 946 PageID #:

4277
173

Claim 8 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 Figure 10-6

Furthermore, this claim element is obvious in light of 802.11-2007 itself, when combined with any of 

the other references as charted for this claim element in Exs. A-1–A-31, First Supplemental Ex. ACase 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 174 of 946 PageID #:

4278
174

Claim 8 of the ’802 Patent Prior Art Reference – 802.11-2007

Obviousness 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 – 802.11-2007

[9.1] The method of claim 1 802.11-2007 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 

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.

802.11-2007 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 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.” See, e.g.: 

1.1 Scope

The scope of this standard is to define one medium access control (MAC) and several physical layer (PHY)

specifications for wireless connectivity for fixed, portable, and moving stations (STAs) within a local area.

See, e.g., 802.11-2007 § 1.1

5.1.1 How WLAN systems are different

Wireless networks have fundamental characteristics that make them significantly different from traditional

wired LANs. Some countries impose specific requirements for radio equipment in addition to those

specified in this standard. This standard does not provide information to meet these country-specific radio

regulations.

5.1.1.1 Destination address does not equal destination location

In wired LANs, an address is equivalent to a physical location. This is implicitly assumed in the design of

wired LANs. In IEEE Std 802.11, the addressable unit is a station (STA). The STA is a message destination,

but not (in general) a fixed location.

5.1.1.2 Media impact on design and performance

The PHYs used in IEEE Std 802.11 are fundamentally different from wired media. Thus IEEE 802.11 PHYs

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 175 of 946 PageID #:

4279
175

Claim 9 of the ’802 Patent Prior Art Reference – 802.11-2007

a) Use a medium that has neither absolute nor readily observable boundaries outside of which STAs

with conformant PHY transceivers are known to be unable to receive network frames

b) Are unprotected from other signals that may be sharing the medium

c) Communicate over a medium significantly less reliable than wired PHYs

d) Have dynamic topologies

e) Lack full connectivity, and therefore the assumption normally made that every STA can hear every

other STA is invalid (i.e., STAs may be “hidden” from each other)

f) Have time-varying and asymmetric propagation properties

g) May experience interference from logically disjoint IEEE 802.11 networks operating in overlapping

areas

Because of limitations on wireless PHY ranges, WLANs intended to cover reasonable geogr aphic distances

may be built from basic coverage building blocks. When providing QoS services it should be understood

that the MAC endeavors to provide QoS “service guarantees” within the limitations of the medium

properties identified above. In other words, particularly in unlicensed spectrum, true guarantees are often not

possible. However, gradations of service are always possible; and in sufficiently controlled environments,

QoS guarantees can truly be made.

5.1.1.3 The impact of handling mobile STAs

One of the requirements of IEEE Std 802.11 is to handle mobile as well as portable STAs. A portable STA

is one that is moved from location to location, but that is only used while at a fixed location. Mobile STAs

actually access the LAN while in motion.

For technical reasons, it is not sufficient to handle only portable STAs. Propagation effects blur the

distinction between portable and mobile STAs; stationary STAs often appear to be mobile due to

propagation effects.

Another aspect of mobile STAs is that they may often be battery powered. Hence power management is

an important consideration. For example, it cannot be presumed that a STA’s receiver will always be

powered on.

See, e.g., 802.11-2007 § 5.1.1 - § 5.1.1.3

5.2 Components of the IEEE 802.11 architecture

The IEEE 802.11 architecture consists of several components that interact to provide a WLAN that supports

STA mobility transparently to upper layers.

The basic service set (BSS) is the basic building block of an IEEE 802.11 LAN. Figure 5 -1 shows two BSSs,

each of which has two STAs that are members of the BSS.

It is useful to think of the ovals used to depict a BSS as the coverage area within which the member STAs of

the BSS may remain in communication. (The concept of area, while not precis e, is often good enough.) This

area is called the Basic Service Area (BSA). If a STA moves out of its BSA, it can no longer directly

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 176 of 946 PageID #:

4280
176

Claim 9 of the ’802 Patent Prior Art Reference – 802.11-2007

communicate with other STAs present in the BSA.

See, e.g., 802.11-2007 § 5.2

5.2.3 Distribution system (DS) concepts

PHY limitations determine the direct station-to-station distance that may be supported. For some networks

this distance is sufficient; for other networks, increased coverage is required.

Instead of existing independently, a BSS may also form a component of an extended form of network that is

built with multiple BSSs. The architectural component used to interconnect BSSs is the DS.

IEEE Std 802.11 logically separates the WM from the distribution system medium (DSM). Each logical

medium is used for different purposes, by a different component of the architecture. The IEEE 802.11

definitions neither preclude, nor demand, that the multiple media be either the same or different.

Recognizing that the multiple media are logically different is key to understanding the flexibility of the

architecture. The IEEE 802.11 LAN architecture is specified independently of the physical characteristics of

any specific implementation.

The DS enables mobile device support by providing the logical services necessary to handle address to

destination mapping and seamless integration of multiple BSSs.

An access point (AP) is any entity that has STA functionality and enables access to the DS, via the WM for

associated STAs.

See, e.g., 802.11-2007 § 5.2.3

5.3.2 DSS

The service provided by the DS is known as the DSS.

This service is represented in the IEEE 802.11 architecture by arrows within the APs, indicating that the

service is used to cross media and possibly address space logical boundaries. An AP is a logical entity, and

the functions described may be shared by one or more physical entities.

The services that comprise the DSS are as follows:

a) Association

b) Disassociation

c) Distribution

d) Integration

e) Reassociation

f) QoS traffic scheduling (QoS facility only)

DSSs are specified for use by MAC sublayer entities.

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 177 of 946 PageID #:

4281
177

Claim 9 of the ’802 Patent Prior Art Reference – 802.11-2007

Figure 5-7 combines the components from previous figures with both types of services to show the complete

IEEE 802.11 architecture.

See, e.g., 802.11-2007 § 5.3.2

5.4.4.1 TPC

Radio regulations may require radio local area networks (RLANs) operating in the 5 GHz band to use

transmitter power control, involving specification of a regulatory maximum transmit power and a mitigation

requirement for each allowed channel, to reduce interference with satellite services. The TPC service is used

to satisfy this regulatory requirement.

The TPC service provides for the following:

— Association of STAs with an AP in a BSS based on the STAs’ power capability.

— Specification of regulatory and local maximum transmit power levels for the current channel.

— Selection of a transmit power for each transmission in a channel within constraints imposed by

regulatory requirements.

— Adaptation of transmit power based on a range of information, including path loss and link margin

estimates.

See, e.g., 802.11-2007 § 5.4.4.1

7.3.2.20 Channel Switch Announcement element

The Channel Switch Announcement element is used by an AP in a BSS or a STA in an IBSS to advertise

when it is changing to a new channel and the channel number of the new channel. The format of the Channel

Switch Announcement element is shown in Figure 7-57.

See, e.g., 802.11-2007 § 7.3.2.20

10.3.11 Spectrum management protocol layer model

The layer management extensions for measurement and channel switching assume a certain partition

of spectrum management functionality between the MLME and SME. This partitioning assumes that

policy decisions (e.g., regarding measurement and channel switching) reside in the SME, while the pro tocol

for measurement, switch timing, and the associated frame exchanges resides within the MLME (see

Figure 10-2).

...

The informative diagrams within this subclause further illustrate the spectrum management protocol model

adopted. Figure 10-3 and Figure 10-4 depict the measurement process for a peer STA to accept and reject a

measurement request, respectively. Figure 10-5 illustrates the TPC adaptation process. Lastly, Figure 10-6

depicts the management process for a channel switch using a Channel Switch Announcement frame.

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 178 of 946 PageID #:

4282
178

Claim 9 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 § 10.3.11

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 179 of 946 PageID #:

4283
179

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 180 of 946 PageID #:

4284
180

Claim 9 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 § 10.4.3.2

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 181 of 946 PageID #:

4285
181

Claim 9 of the ’802 Patent Prior Art Reference – 802.11-2007

17.1 Introduction

This clause specifies the PHY entity for an orthogonal frequency division multiplexing (OFDM) system.

The OFDM system provides a WLAN with data payload communication capabilities of 6, 9, 12, 18, 24, 36,

48, and 54 Mb/s. The support of transmitting and receiving at data rates of 6, 12, and 24 Mb/s is mandatory.

The system uses 52 subcarriers that are modulated using binary or quadrature phase shift keying (BPSK or

QPSK) or using 16- or 64-quadrature amplitude modulation (16-QAM or 64-QAM). Forward error

correction coding (convolutional coding) is used with a coding rate of 1/2, 2/3, or 3/4.

The OFDM system also provides a “half-clocked” operation using 10 MHz channel spacings with data

communications capabilities of 3, 4.5, 6, 9, 12, 18, 24, and 27 Mb/s. The support of transmitting and

receiving at data rates of 3, 6, and 12 Mb/s is mandatory when using 10 MHz channel spacing. The halfclo cked

operation doubles symbol times and clear channel assessment (CCA) times when using 10 MHz

channel spacing. The regulatory requirements and information regarding use of this OFDM system in

4.9 GHz and 5 GHz bands is in Annex I and Annex J.

The OFDM system also provides a “quarter-clocked” operation using 5 MHz channel spacing with data

communication capabilities of 1.5, 2.25, 3, 4.5, 6, 9, 12, and 13.5 Mb/s. The support of transmitting and

receiving at data rates of 1.5, 3, and 6 Mb/s is mandatory when using 5 MHz channel spacing. The quarterclocked

operation quadruples symbol times and CCA times when using 5 MHz channel spacing. The

regulatory requirements and information regarding use of this OFDM system in the 4.9 GHz band is in

Annex I and Annex J.

See, e.g., 802.11-2007 § 17.1

17.3.2.1 Overview of the PPDU encoding process

The encoding process is composed of many detailed steps, which are described fully in later subclauses, as

noted below. The following overview intends to facilitate understanding the details of the convergence

procedure:

a) Produce the PLCP Preamble field, composed of 10 repetitions of a “short training sequence” (used

for AGC convergence, diversity selection, timing acquisition, and coarse frequency acquisition in

the receiver) and two repetitions of a “long training sequence” (used for channel estimation and fine

frequency acquisition in the receiver), preceded by a guard interval (GI). Refer to 17.3.3 for details.

b) Produce the PLCP header field from the RATE, LENGTH, and SERVICE fields of the

TXVECTOR by filling the appropriate bit fields. The RATE and LENGTH fields of the PLCP

header are encoded by a convolutional code at a rate of R = 1/2, and are subsequently mapped onto a

single BPSK encoded OFDM symbol, denoted as the SIGNAL symbol. In order to facilitate a

reliable and timely detection of the RATE and LENGTH fields, 6 zero tail bits are inserted into the

PLCP header. The encoding of the SIGNAL field into an OFDM symbol follows the same steps for

convolutional encoding, interleaving, BPSK modulation, pilot insertion, Fourier transform, and

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 182 of 946 PageID #:

4286
182

Claim 9 of the ’802 Patent Prior Art Reference – 802.11-2007

prepending a GI as described subsequently for data transmission with BPSK-OFDM modulated at

coding rate 1/2. The contents of the SIGNAL field are not scrambled. Refer to 17.3.4 for details.

c) Calculate from RATE field of the TXVECTOR the number of data bits per OFDM symbol (NDBPS),

the coding rate (R), the number of bits in each OFDM subcarrier (NBPSC), and the number of coded

bits per OFDM symbol (NCBPS). Refer to 17.3.2.2 for details.

d) Append the PSDU to the SERVICE field of the TXVECTOR. Extend the resulting bit string with

zero bits (at least 6 bits) so that the resulting length will be a multiple of NDBPS. The resulting bit

string constitutes the DATA part of the packet. Refer to 17.3.5.3 for details.

e) Initiate the scrambler with a pseudo-random nonzero seed, generate a scrambling sequence, and

XOR it with the extended string of data bits. Refer to 17.3.5.4 for details.

f) Replace the six scrambled zero bits following the data with six nonscrambled zero bits. (Those bits

return the convolutional encoder to the zero state and are denoted as tail bits.) Refer to 17.3.5.2 for

details.

g) Encode the extended, scrambled data string with a convolutional encoder (R = 1/2). Omit (puncture)

some of the encoder output string (chosen according to “puncturing pattern”) to reach the desired

“coding rate.” Refer to 17.3.5.5 for details.

h) Divide the encoded bit string into groups of NCBPS bits. Within each group, perform an

“interleaving” (reordering) of the bits according to a rule corresponding to the desired RATE. Refer

to 17.3.5.6 for details.

i) Divide the resulting coded and interleaved data string into groups of NCBPS bits. For each of the bit

groups, convert the bit group into a complex number according to the modulation encoding tables.

Refer to 17.3.5.7 for details.

j) Divide the complex number string into groups of 48 complex numbers. Each such group will be

associated with one OFDM symbol. In each group, the complex numbers will be numbered 0 to 47

and mapped hereafter into OFDM subcarriers numbered –26 to –22, –20 to –8, –6 to –1, 1 to 6,

8 to 20, and 22 to 26. The subcarriers –21, –7, 7, and 21 are skipped and, subsequently, used for

inserting pilot subcarriers. The 0 subcarrier, associated with center frequency, is omitted and filled

with zero value. Refer to 17.3.5.9 for details.

k) Four subcarriers are inserted as pilots into positions –21, –7, 7, and 21. The total number of the

subcarriers is 52 (48 + 4). Refer to 17.3.5.8 for details.

l) For each group of subcarriers –26 to 26, convert the subcarriers to time domain using inverse

Fourier transform. Prepend to the Fourier-transformed waveform a circular extension of itself thus

forming a GI, and truncate the resulting periodic waveform to a single OFDM symbol length by

applying time domain windowing. Refer to 17.3.5.9 for details.

m) Append the OFDM symbols one after another, starting after the SIGNAL symbol describing the

RATE and LENGTH fields. Refer to 17.3.5.9 for details.

n) Up-convert the resulting “complex baseband” waveform to an RF according to the center frequency

of the desired channel and transmit. Refer to 17.3.2.4 and 17.3.8.1 for details.

An illustration of the transmitted frame and its parts appears in Figure 17-4 (in 17.3.3).

See, e.g., 802.11-2007 § 17.3.2.1

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 183 of 946 PageID #:

4287
183

Claim 9 of the ’802 Patent Prior Art Reference – 802.11-2007

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 184 of 946 PageID #:

4288
184

Claim 9 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 § 17.3.2.3

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 185 of 946 PageID #:

4289
185

Claim 9 of the ’802 Patent Prior Art Reference – 802.11-2007

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 186 of 946 PageID #:

4290
186

Claim 9 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 § 17.3.2.4 Eq. (17-1)

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 187 of 946 PageID #:

4291
187

Claim 9 of the ’802 Patent Prior Art Reference – 802.11-2007

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 188 of 946 PageID #:

4292
188

Claim 9 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 § 17.3.2.5

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 189 of 946 PageID #:

4293
189

Claim 9 of the ’802 Patent Prior Art Reference – 802.11-2007

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 190 of 946 PageID #:

4294
190

See, e.g., 802.11-2007 § 17.3.3

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 191 of 946 PageID #:

4295
191

Claim 9 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 § 17.3.5.7

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 192 of 946 PageID #:

4296
192

Claim 9 of the ’802 Patent Prior Art Reference – 802.11-2007

17.3.5.8 Pilot subcarriers

In each OFDM symbol, four of the subcarriers are dedicated to pilot signals in order to make the coherent

detection robust against frequency offsets and phase noise. These pilot signals shall be put in su bcarriers

–21, –7, 7, and 21. The pilots shall be BPSK modulated by a pseudo-binary sequence to prevent the

generation of spectral lines. The contribution of the pilot subcarriers to each OFDM symbol is described in

17.3.5.9.

See, e.g., 802.11-2007 § 17.3.5.8

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 193 of 946 PageID #:

4297
193

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 194 of 946 PageID #:

4298
194

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 195 of 946 PageID #:

4299
195

Claim 9 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 § 17.3.5.9

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 196 of 946 PageID #:

4300
196

Claim 9 of the ’802 Patent Prior Art Reference – 802.11-2007

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 197 of 946 PageID #:

4301
197

Claim 9 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 § 17.3.8.1

17.3.8.3.1 Operating frequency range

The OFDM PHY shall operate in the 5 GHz band, as allocated by a regulatory body in its operational region.

Spectrum allocation in the 5 GHz band is subject to authorities responsible for geographic-specific

regulatory domains (e.g., global, regional, and national). The particular channelization to be used for this

standard is dependent on such allocation, as well as the associated regulations for use of the allocations.

These regulations are subject to revision, or may be superseded.

In some regulatory domains, several frequency bands may be available for OFDM PHY-based WLANs.

These bands may be contiguous or not, and different regulatory limits may be applicable. A compliant

OFDM PHY shall support at least one frequency band in at least one regulatory domain. The support of

specific regulatory domains, and bands within the domains, shall be indicated by PLME attributes

dot11RegDomainsSupported and dot11FrequencyBandsSupported.

See, e.g., 802.11-2007 § 17.3.8.3.1

17.3.9.1 Transmit power levels

The maximum allowable transmit power by regulatory domain is defined in Annex I.

See, e.g., 802.11-2007 § 17.3.9.1

17.3.9.6.2 Transmitter spectral flatness

The average energy of the constellations in each of the spectral lines –16.. –1 and +1.. +16 will deviate no

more than ± 2 dB from their average energy. The average energy of the constellations in each of the spectral

lines –26.. –17 and +17.. +26 will deviate no more than +2/–4 dB from the average energy of spectral lines

–16.. –1 and +1.. +16. The data for this test shall be derived from the channel estimation step.

See, e.g., 802.11-2007 § 17.3.9.6.2

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 198 of 946 PageID #:

4302
198

Claim 9 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 § I.2.2

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 199 of 946 PageID #:

4303
199

Claim 9 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 § I.2.3

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 200 of 946 PageID #:

4304
200

Claim 9 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 Figure 5-7

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 201 of 946 PageID #:

4305
201

Claim 9 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 Figure 10-6

Furthermore, this claim element is obvious in light of 802.11-2007 itself, when combined with any of 

the other references as charted for this claim element in Exs. A-1–A-31, First Supplemental Ex. ACase 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 202 of 946 PageID #:

4306
202

Claim 9 of the ’802 Patent Prior Art Reference – 802.11-2007

Obviousness 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 – 802.11-2007

[10.1] A method of 

transmitting information in a 

wireless communication 

channel comprising:

To the extent the preamble is limiting, 802.11-2007 discloses “A method of transmitting information 

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

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 203 of 946 PageID #:

4307
203

Claim 10 of the ’802 Patent Prior Art Reference – 802.11-2007

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 204 of 946 PageID #:

4308
204

See, e.g., 802.11-2007 § 17.3.3

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 205 of 946 PageID #:

4309
205

Claim 10 of the ’802 Patent Prior Art Reference – 802.11-2007

Furthermore, this claim element is obvious in light of 802.11-2007 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;

802.11-2007 discloses “receiving a first digital signal comprising first data to be transmitted.” See, 

e.g.: 

1.1 Scope

The scope of this standard is to define one medium access control (MAC) and several physical layer (PHY)

specifications for wireless connectivity for fixed, portable, and moving stations (STAs) within a local area.

See, e.g., 802.11-2007 § 1.1

5.1.1 How WLAN systems are different

Wireless networks have fundamental characteristics that make them significantly different from traditional

wired LANs. Some countries impose specific requirements for radio equipment in addition to those

specified in this standard. This standard does not provide information to meet these country -specific radio

regulations.

5.1.1.1 Destination address does not equal destination location

In wired LANs, an address is equivalent to a physical location. This is implicitly assumed in the design of

wired LANs. In IEEE Std 802.11, the addressable unit is a station (STA). The STA is a message destination,

but not (in general) a fixed location.

5.1.1.2 Media impact on design and performance

The PHYs used in IEEE Std 802.11 are fundamentally different from wired media. Thus IEEE 802.11 PHYs

a) Use a medium that has neither absolute nor readily observable boundaries outside of which STAs

with conformant PHY transceivers are known to be unable to receive network frames

b) Are unprotected from other signals that may be sharing the medium

c) Communicate over a medium significantly less reliable than wired PHYs

d) Have dynamic topologies

e) Lack full connectivity, and therefore the assumption normally made that every STA can hear every

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 206 of 946 PageID #:

4310
206

Claim 10 of the ’802 Patent Prior Art Reference – 802.11-2007

other STA is invalid (i.e., STAs may be “hidden” from each other)

f) Have time-varying and asymmetric propagation properties

g) May experience interference from logically disjoint IEEE 802.11 networks operating in overlapping

areas

Because of limitations on wireless PHY ranges, WLANs intended to cover reasonable geographic distances

may be built from basic coverage building blocks. When providing QoS services it should be understood

that the MAC endeavors to provide QoS “service guarantees” within the limitations of the medium

properties identified above. In other words, particularly in unlicensed spectrum, true guarantees are often not

possible. However, gradations of service are always possible; and in sufficiently controlled environments,

QoS guarantees can truly be made.

5.1.1.3 The impact of handling mobile STAs

One of the requirements of IEEE Std 802.11 is to handle mobile as well as portable STAs. A portable STA

is one that is moved from location to location, but that is only used while at a fixed location. Mobile STAs

actually access the LAN while in motion.

For technical reasons, it is not sufficient to handle only portable STAs. Propagation effects blur the

distinction between portable and mobile STAs; stationary STAs often appear to be mobile due to

propagation effects.

Another aspect of mobile STAs is that they may often be battery powered. Hence power management is

an important consideration. For example, it cannot be presumed that a STA’s receiver will always be

powered on.

See, e.g., 802.11-2007 § 5.1.1 - § 5.1.1.3

5.2 Components of the IEEE 802.11 architecture

The IEEE 802.11 architecture consists of several components that interact to provide a WLAN that supports

STA mobility transparently to upper layers.

The basic service set (BSS) is the basic building block of an IEEE 802.11 LAN. Figure 5 -1 shows two BSSs,

each of which has two STAs that are members of the BSS.

It is useful to think of the ovals used to depict a BSS as the coverage area within which the member STAs of

the BSS may remain in communication. (The concept of area, while not precise, is often good eno ugh.) This

area is called the Basic Service Area (BSA). If a STA moves out of its BSA, it can no longer directly

communicate with other STAs present in the BSA.

See, e.g., 802.11-2007 § 5.2

5.2.3 Distribution system (DS) concepts

PHY limitations determine the direct station-to-station distance that may be supported. For some networks

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 207 of 946 PageID #:

4311
207

Claim 10 of the ’802 Patent Prior Art Reference – 802.11-2007

this distance is sufficient; for other networks, increased coverage is required.

Instead of existing independently, a BSS may also form a component of an extended form of n etwork that is

built with multiple BSSs. The architectural component used to interconnect BSSs is the DS.

IEEE Std 802.11 logically separates the WM from the distribution system medium (DSM). Each logical

medium is used for different purposes, by a different component of the architecture. The IEEE 802.11

definitions neither preclude, nor demand, that the multiple media be either the same or different.

Recognizing that the multiple media are logically different is key to understanding the flexibility of the

architecture. The IEEE 802.11 LAN architecture is specified independently of the physical characteristics of

any specific implementation.

The DS enables mobile device support by providing the logical services necessary to handle address to

destination mapping and seamless integration of multiple BSSs.

An access point (AP) is any entity that has STA functionality and enables access to the DS, via the WM for

associated STAs.

See, e.g., 802.11-2007 § 5.2.3

5.3.2 DSS

The service provided by the DS is known as the DSS.

This service is represented in the IEEE 802.11 architecture by arrows within the APs, indicating that the

service is used to cross media and possibly address space logical boundaries. An AP is a logical entity, and

the functions described may be shared by one or more physical entities.

The services that comprise the DSS are as follows:

a) Association

b) Disassociation

c) Distribution

d) Integration

e) Reassociation

f) QoS traffic scheduling (QoS facility only)

DSSs are specified for use by MAC sublayer entities.

Figure 5-7 combines the components from previous figures with both types of services to show the complete

IEEE 802.11 architecture.

See, e.g., 802.11-2007 § 5.3.2

5.4.4.1 TPC

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 208 of 946 PageID #:

4312
208

Claim 10 of the ’802 Patent Prior Art Reference – 802.11-2007

Radio regulations may require radio local area networks (RLANs) operating in the 5 GHz band to use

transmitter power control, involving specification of a regulatory maximum transmit power and a mitigation

requirement for each allowed channel, to reduce interference with satellite services. The TPC service is used

to satisfy this regulatory requirement.

The TPC service provides for the following:

— Association of STAs with an AP in a BSS based on the STAs’ power capability.

— Specification of regulatory and local maximum transmit power levels for the current channel.

— Selection of a transmit power for each transmission in a channel within constraints imposed by

regulatory requirements.

— Adaptation of transmit power based on a range of information, including path loss and link margin

estimates.

See, e.g., 802.11-2007 § 5.4.4.1

7.3.2.20 Channel Switch Announcement element

The Channel Switch Announcement element is used by an AP in a BSS or a STA in an IBSS to advertise

when it is changing to a new channel and the channel number of the new ch annel. The format of the Channel

Switch Announcement element is shown in Figure 7-57.

See, e.g., 802.11-2007 § 7.3.2.20

10.3.11 Spectrum management protocol layer model

The layer management extensions for measurement and channel switching assume a certain partition

of spectrum management functionality between the MLME and SME. This partitioning assumes that

policy decisions (e.g., regarding measurement and channel switching) reside in the SME, while the protocol

for measurement, switch timing, and the associated frame exchanges resides within the MLME (see

Figure 10-2).

...

The informative diagrams within this subclause further illustrate the spectrum management protocol model

adopted. Figure 10-3 and Figure 10-4 depict the measurement process for a peer STA to accept and reject a

measurement request, respectively. Figure 10-5 illustrates the TPC adaptation process. Lastly, Figure 10-6

depicts the management process for a channel switch using a Channel Switch Announcement frame.

See, e.g., 802.11-2007 § 10.3.11

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 209 of 946 PageID #:

4313
209

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 210 of 946 PageID #:

4314
210

Claim 10 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 § 10.4.3.2

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 211 of 946 PageID #:

4315
211

Claim 10 of the ’802 Patent Prior Art Reference – 802.11-2007

17.1 Introduction

This clause specifies the PHY entity for an orthogonal frequency division multiplexing (OFDM) system.

The OFDM system provides a WLAN with data payload communication capabilities of 6, 9, 12, 18, 24, 36,

48, and 54 Mb/s. The support of transmitting and receiving at data rates of 6, 12, and 24 Mb/s is mandatory.

The system uses 52 subcarriers that are modulated using binary or quadrature phase shift keying (BPSK or

QPSK) or using 16- or 64-quadrature amplitude modulation (16-QAM or 64-QAM). Forward error

correction coding (convolutional coding) is used with a coding rate of 1/2, 2/3, or 3/4.

The OFDM system also provides a “half-clocked” operation using 10 MHz channel spacings with data

communications capabilities of 3, 4.5, 6, 9, 12, 18, 24, and 27 Mb/s. The support of transmitting and

receiving at data rates of 3, 6, and 12 Mb/s is mandatory when using 10 MHz channel spacing. The halfclocked

operation doubles symbol times and clear channel assessment (CCA) times when using 10 MHz

channel spacing. The regulatory requirements and information regarding use of this OFDM system in

4.9 GHz and 5 GHz bands is in Annex I and Annex J.

The OFDM system also provides a “quarter-clocked” operation using 5 MHz channel spacing with data

communication capabilities of 1.5, 2.25, 3, 4.5, 6, 9, 12, and 13.5 Mb/s. The support of transmitting and

receiving at data rates of 1.5, 3, and 6 Mb/s is mandatory when using 5 MHz channel spacing. Th e quarterclocked

operation quadruples symbol times and CCA times when using 5 MHz channel spacing. The

regulatory requirements and information regarding use of this OFDM system in the 4.9 GHz band is in

Annex I and Annex J.

See, e.g., 802.11-2007 § 17.1

17.3.2.1 Overview of the PPDU encoding process

The encoding process is composed of many detailed steps, which are described fully in later subclauses, as

noted below. The following overview intends to facilitate understanding the details of the convergence

procedure:

a) Produce the PLCP Preamble field, composed of 10 repetitions of a “short training sequence” (used

for AGC convergence, diversity selection, timing acquisition, and coarse frequency acquisition in

the receiver) and two repetitions of a “long training sequence” (used for channel estimation and fine

frequency acquisition in the receiver), preceded by a guard interval (GI). Refer to 17.3.3 for details.

b) Produce the PLCP header field from the RATE, LENGTH, and SERVICE fields of the

TXVECTOR by filling the appropriate bit fields. The RATE and LENGTH fields of the PLCP

header are encoded by a convolutional code at a rate of R = 1/2, and are subsequently mapped onto a

single BPSK encoded OFDM symbol, denoted as the SIGNAL symbol. In order to f acilitate a

reliable and timely detection of the RATE and LENGTH fields, 6 zero tail bits are inserted into the

PLCP header. The encoding of the SIGNAL field into an OFDM symbol follows the same steps for

convolutional encoding, interleaving, BPSK modulation, pilot insertion, Fourier transform, and

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 212 of 946 PageID #:

4316
212

Claim 10 of the ’802 Patent Prior Art Reference – 802.11-2007

prepending a GI as described subsequently for data transmission with BPSK-OFDM modulated at

coding rate 1/2. The contents of the SIGNAL field are not scrambled. Refer to 17.3.4 for details.

c) Calculate from RATE field of the TXVECTOR the number of data bits per OFDM symbol (NDBPS),

the coding rate (R), the number of bits in each OFDM subcarrier (NBPSC), and the number of coded

bits per OFDM symbol (NCBPS). Refer to 17.3.2.2 for details.

d) Append the PSDU to the SERVICE field of the TXVECTOR. Extend the resulting bit string with

zero bits (at least 6 bits) so that the resulting length will be a multiple of NDBPS. The resulting bit

string constitutes the DATA part of the packet. Refer to 17.3.5.3 for details.

e) Initiate the scrambler with a pseudo-random nonzero seed, generate a scrambling sequence, and

XOR it with the extended string of data bits. Refer to 17.3.5.4 for details.

f) Replace the six scrambled zero bits following the data with six nonscrambled zero bits. (Those bits

return the convolutional encoder to the zero state and are denoted as tail bits.) Refer to 17.3.5.2 for

details.

g) Encode the extended, scrambled data string with a convolutional encoder (R = 1/2). Omit (puncture)

some of the encoder output string (chosen according to “puncturing pattern”) to reach the desired

“coding rate.” Refer to 17.3.5.5 for details.

h) Divide the encoded bit string into groups of NCBPS bits. Within each group, perform an

“interleaving” (reordering) of the bits according to a rule corresponding to the desired RATE. Refer

to 17.3.5.6 for details.

i) Divide the resulting coded and interleaved data string into groups of NCBPS bits. For each of the bit

groups, convert the bit group into a complex number according to the modulation encoding tables.

Refer to 17.3.5.7 for details.

j) Divide the complex number string into groups of 48 complex numbers. Each such group will be

associated with one OFDM symbol. In each group, the complex numbers will be numbered 0 to 47

and mapped hereafter into OFDM subcarriers numbered –26 to –22, –20 to –8, –6 to –1, 1 to 6,

8 to 20, and 22 to 26. The subcarriers –21, –7, 7, and 21 are skipped and, subsequently, used for

inserting pilot subcarriers. The 0 subcarrier, associated with center frequency, is omitted and filled

with zero value. Refer to 17.3.5.9 for details.

k) Four subcarriers are inserted as pilots into positions –21, –7, 7, and 21. The total number of the

subcarriers is 52 (48 + 4). Refer to 17.3.5.8 for details.

l) For each group of subcarriers –26 to 26, convert the subcarriers to time domain using inverse

Fourier transform. Prepend to the Fourier-transformed waveform a circular extension of itself thus

forming a GI, and truncate the resulting periodic waveform to a single OFDM symbol length by

applying time domain windowing. Refer to 17.3.5.9 for details.

m) Append the OFDM symbols one after another, starting after the SIGNAL symbol describing the

RATE and LENGTH fields. Refer to 17.3.5.9 for details.

n) Up-convert the resulting “complex baseband” waveform to an RF according to the center frequency

of the desired channel and transmit. Refer to 17.3.2.4 and 17.3.8.1 for details.

An illustration of the transmitted frame and its parts appears in Figure 17-4 (in 17.3.3).

See, e.g., 802.11-2007 § 17.3.2.1

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 213 of 946 PageID #:

4317
213

Claim 10 of the ’802 Patent Prior Art Reference – 802.11-2007

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 214 of 946 PageID #:

4318
214

Claim 10 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 § 17.3.2.3

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 215 of 946 PageID #:

4319
215

Claim 10 of the ’802 Patent Prior Art Reference – 802.11-2007

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 216 of 946 PageID #:

4320
216

Claim 10 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 § 17.3.2.4 Eq. (17-1)

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 217 of 946 PageID #:

4321
217

Claim 10 of the ’802 Patent Prior Art Reference – 802.11-2007

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 218 of 946 PageID #:

4322
218

Claim 10 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 § 17.3.2.5

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 219 of 946 PageID #:

4323
219

Claim 10 of the ’802 Patent Prior Art Reference – 802.11-2007

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 220 of 946 PageID #:

4324
220

See, e.g., 802.11-2007 § 17.3.3

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 221 of 946 PageID #:

4325
221

Claim 10 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 § 17.3.5.7

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 222 of 946 PageID #:

4326
222

Claim 10 of the ’802 Patent Prior Art Reference – 802.11-2007

17.3.5.8 Pilot subcarriers

In each OFDM symbol, four of the subcarriers are dedicated to pilot signals in order to make the coherent

detection robust against frequency offsets and phase noise. These pilot signals shall be put in subcarriers

–21, –7, 7, and 21. The pilots shall be BPSK modulated by a pseudo-binary sequence to prevent the

generation of spectral lines. The contribution of the pilot subcarriers to each OFDM symbol is described in

17.3.5.9.

See, e.g., 802.11-2007 § 17.3.5.8

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 223 of 946 PageID #:

4327
223

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 224 of 946 PageID #:

4328
224

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 225 of 946 PageID #:

4329
225

Claim 10 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 § 17.3.5.9

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 226 of 946 PageID #:

4330
226

Claim 10 of the ’802 Patent Prior Art Reference – 802.11-2007

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 227 of 946 PageID #:

4331
227

Claim 10 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 § 17.3.8.1

17.3.8.3.1 Operating frequency range

The OFDM PHY shall operate in the 5 GHz band, as allocated by a regulatory body in its operational region.

Spectrum allocation in the 5 GHz band is subject to authorities responsible for geographic-specific

regulatory domains (e.g., global, regional, and national). The particular channelization to be used for this

standard is dependent on such allocation, as well as the associated regulations for use of the allocations.

These regulations are subject to revision, or may be superseded.

In some regulatory domains, several frequency bands may be available for OFDM PHY-based WLANs.

These bands may be contiguous or not, and different regulatory limits may be applicable. A comp liant

OFDM PHY shall support at least one frequency band in at least one regulatory domain. The support of

specific regulatory domains, and bands within the domains, shall be indicated by PLME attributes

dot11RegDomainsSupported and dot11FrequencyBandsSupported.

See, e.g., 802.11-2007 § 17.3.8.3.1

17.3.9.1 Transmit power levels

The maximum allowable transmit power by regulatory domain is defined in Annex I.

See, e.g., 802.11-2007 § 17.3.9.1

17.3.9.6.2 Transmitter spectral flatness

The average energy of the constellations in each of the spectral lines –16.. –1 and +1.. +16 will deviate no

more than ± 2 dB from their average energy. The average energy of the constellations in each of the spectral

lines –26.. –17 and +17.. +26 will deviate no more than +2/–4 dB from the average energy of spectral lines

–16.. –1 and +1.. +16. The data for this test shall be derived from the channel estimation step.

See, e.g., 802.11-2007 § 17.3.9.6.2

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 228 of 946 PageID #:

4332
228

Claim 10 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 § I.2.2

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 229 of 946 PageID #:

4333
229

Claim 10 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 § I.2.3

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 230 of 946 PageID #:

4334
230

Claim 10 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 Figure 5-7

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 231 of 946 PageID #:

4335
231

Claim 10 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 Figure 10-6

Furthermore, this claim element is obvious in light of 802.11-2007 itself, when combined with any of 

the other references as charted for this claim element in Exs. A-1–A-31, First Supplemental Ex. ACase 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 232 of 946 PageID #:

4336
232

Claim 10 of the ’802 Patent Prior Art Reference – 802.11-2007

Obviousness 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;

802.11-2007 discloses “receiving a second digital signal comprising second data to be transmitted.” 

See, e.g.: 

1.1 Scope

The scope of this standard is to define one medium access control (MAC) and several physical layer (PHY)

specifications for wireless connectivity for fixed, portable, and moving stations (STAs) within a local area.

See, e.g., 802.11-2007 § 1.1

5.1.1 How WLAN systems are different

Wireless networks have fundamental characteristics that make them significantly different from traditional

wired LANs. Some countries impose specific requirements for radio equipment in addition to those

specified in this standard. This standard does not provide information to meet these country-specific radio

regulations.

5.1.1.1 Destination address does not equal destination location

In wired LANs, an address is equivalent to a physical location. This is implicitly assumed in the design of

wired LANs. In IEEE Std 802.11, the addressable unit is a station (STA). The STA is a message destination,

but not (in general) a fixed location.

5.1.1.2 Media impact on design and performance

The PHYs used in IEEE Std 802.11 are fundamentally different from wired media. Thus IEEE 802.11 PHYs

a) Use a medium that has neither absolute nor readily observable boundaries outside of which STAs

with conformant PHY transceivers are known to be unable to receive network frames

b) Are unprotected from other signals that may be sharing the medium

c) Communicate over a medium significantly less reliable than wired PHYs

d) Have dynamic topologies

e) Lack full connectivity, and therefore the assumption normally made that every STA can hear every

other STA is invalid (i.e., STAs may be “hidden” from each other)

f) Have time-varying and asymmetric propagation properties

g) May experience interference from logically disjoint IEEE 802.11 networks operating in overlapping

areas

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 233 of 946 PageID #:

4337
233

Claim 10 of the ’802 Patent Prior Art Reference – 802.11-2007

Because of limitations on wireless PHY ranges, WLANs intended to cover reasonable geographic distances

may be built from basic coverage building blocks. When providing QoS services it should be understood

that the MAC endeavors to provide QoS “service guarantees” within the limitations of the medium

properties identified above. In other words, particularly in unlicensed spectrum, true guarantees are often not

possible. However, gradations of service are always possible; and in sufficiently controlled environments,

QoS guarantees can truly be made.

5.1.1.3 The impact of handling mobile STAs

One of the requirements of IEEE Std 802.11 is to handle mobile as well as portable STAs. A portable STA

is one that is moved from location to location, but that is only used while at a fixed location. Mobile STAs

actually access the LAN while in motion.

For technical reasons, it is not sufficient to handle only portable STAs. Propagation effects blur the

distinction between portable and mobile STAs; stationary STAs often appear to be mobile due to

propagation effects.

Another aspect of mobile STAs is that they may often be battery powered. Hence power management is

an important consideration. For example, it cannot be presumed that a STA’s receiver will always be

powered on.

See, e.g., 802.11-2007 § 5.1.1 - § 5.1.1.3

5.2 Components of the IEEE 802.11 architecture

The IEEE 802.11 architecture consists of several components that interact to provide a WLAN that supports

STA mobility transparently to upper layers.

The basic service set (BSS) is the basic building block of an IEEE 802.11 LAN. Figure 5-1 shows two BSSs,

each of which has two STAs that are members of the BSS.

It is useful to think of the ovals used to depict a BSS as the coverage area within which the member STAs of

the BSS may remain in communication. (The concept of area, while not precise, is often good enough.) This

area is called the Basic Service Area (BSA). If a STA moves out of its BSA, it can no longer directly

communicate with other STAs present in the BSA.

See, e.g., 802.11-2007 § 5.2

5.2.3 Distribution system (DS) concepts

PHY limitations determine the direct station-to-station distance that may be supported. For some networks

this distance is sufficient; for other networks, increased coverage is required.

Instead of existing independently, a BSS may also form a component of an extended form of network that is

built with multiple BSSs. The architectural component used to interconnect BSSs is the DS.

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 234 of 946 PageID #:

4338
234

Claim 10 of the ’802 Patent Prior Art Reference – 802.11-2007

IEEE Std 802.11 logically separates the WM from the distribution system medium (DSM). Each logical

medium is used for different purposes, by a different component of the architecture. The IEEE 802.11

definitions neither preclude, nor demand, that the multiple media be either the same or different.

Recognizing that the multiple media are logically different is key to understanding the flexibility of the

architecture. The IEEE 802.11 LAN architecture is specified independently of the physical characteristics of

any specific implementation.

The DS enables mobile device support by providing the logical services necessary to handle address to

destination mapping and seamless integration of multiple BSSs.

An access point (AP) is any entity that has STA functionality and enables access to the DS, via the WM for

associated STAs.

See, e.g., 802.11-2007 § 5.2.3

5.3.2 DSS

The service provided by the DS is known as the DSS.

This service is represented in the IEEE 802.11 architecture by arrows within the APs, indicating that the

service is used to cross media and possibly address space logical boundaries. An AP is a logical entity, and

the functions described may be shared by one or more physical entities.

The services that comprise the DSS are as follows:

a) Association

b) Disassociation

c) Distribution

d) Integration

e) Reassociation

f) QoS traffic scheduling (QoS facility only)

DSSs are specified for use by MAC sublayer entities.

Figure 5-7 combines the components from previous figures with both types of services to show the complete

IEEE 802.11 architecture.

See, e.g., 802.11-2007 § 5.3.2

5.4.4.1 TPC

Radio regulations may require radio local area networks (RLANs) operating in the 5 GHz band to use

transmitter power control, involving specification of a regulatory maximum transmit power and a mitigation

requirement for each allowed channel, to reduce interference with satellite services. The TPC service is used

to satisfy this regulatory requirement.

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 235 of 946 PageID #:

4339
235

Claim 10 of the ’802 Patent Prior Art Reference – 802.11-2007

The TPC service provides for the following:

— Association of STAs with an AP in a BSS based on the STAs’ power capability.

— Specification of regulatory and local maximum transmit power levels for the current channel.

— Selection of a transmit power for each transmission in a channel within constraints imposed by

regulatory requirements.

— Adaptation of transmit power based on a range of information, including path loss and link margin

estimates.

See, e.g., 802.11-2007 § 5.4.4.1

7.3.2.20 Channel Switch Announcement element

The Channel Switch Announcement element is used by an AP in a BSS or a STA in an IBSS to advertise

when it is changing to a new channel and the channel number of the new channel. The format of the Channel

Switch Announcement element is shown in Figure 7-57.

See, e.g., 802.11-2007 § 7.3.2.20

10.3.11 Spectrum management protocol layer model

The layer management extensions for measurement and channel switching assume a certain partition

of spectrum management functionality between the MLME and SME. This partitioning assumes that

policy decisions (e.g., regarding measurement and channel switching) reside in the SME, while the protocol

for measurement, switch timing, and the associated frame exchanges resides within the MLME (see

Figure 10-2).

...

The informative diagrams within this subclause further illustrate the spectrum management protocol model

adopted. Figure 10-3 and Figure 10-4 depict the measurement process for a peer STA to accept and reject a

measurement request, respectively. Figure 10-5 illustrates the TPC adaptation process. Lastly, Figure 10-6

depicts the management process for a channel switch using a Channel Switch Announcement frame.

See, e.g., 802.11-2007 § 10.3.11

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 236 of 946 PageID #:

4340
236

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 237 of 946 PageID #:

4341
237

Claim 10 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 § 10.4.3.2

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 238 of 946 PageID #:

4342
238

Claim 10 of the ’802 Patent Prior Art Reference – 802.11-2007

17.1 Introduction

This clause specifies the PHY entity for an orthogonal frequency division multiplex ing (OFDM) system.

The OFDM system provides a WLAN with data payload communication capabilities of 6, 9, 12, 18, 24, 36,

48, and 54 Mb/s. The support of transmitting and receiving at data rates of 6, 12, and 24 Mb/s is mandatory.

The system uses 52 subcarriers that are modulated using binary or quadrature phase shift keying (BPSK or

QPSK) or using 16- or 64-quadrature amplitude modulation (16-QAM or 64-QAM). Forward error

correction coding (convolutional coding) is used with a coding rate of 1/2, 2/3 , or 3/4.

The OFDM system also provides a “half-clocked” operation using 10 MHz channel spacings with data

communications capabilities of 3, 4.5, 6, 9, 12, 18, 24, and 27 Mb/s. The support of transmitting and

receiving at data rates of 3, 6, and 12 Mb/s is mandatory when using 10 MHz channel spacing. The halfclocked

operation doubles symbol times and clear channel assessment (CCA) times when using 10 MHz

channel spacing. The regulatory requirements and information regarding use of this OFDM system in

4.9 GHz and 5 GHz bands is in Annex I and Annex J.

The OFDM system also provides a “quarter-clocked” operation using 5 MHz channel spacing with data

communication capabilities of 1.5, 2.25, 3, 4.5, 6, 9, 12, and 13.5 Mb/s. The support of transmitting and

receiving at data rates of 1.5, 3, and 6 Mb/s is mandatory when using 5 MHz channel spacing. The quarterclocked

operation quadruples symbol times and CCA times when using 5 MHz channel spacing. The

regulatory requirements and information regarding use of this OFDM system in the 4.9 GHz band is in

Annex I and Annex J.

See, e.g., 802.11-2007 § 17.1

17.3.2.1 Overview of the PPDU encoding process

The encoding process is composed of many detailed steps, which are described fully in later subclauses, as

noted below. The following overview intends to facilitate understanding the details of the convergence

procedure:

a) Produce the PLCP Preamble field, composed of 10 repetitions of a “short training sequence” (used

for AGC convergence, diversity selection, timing acquisition, and coarse frequency acquisition in

the receiver) and two repetitions of a “long training sequence” (used for channel estimation and fine

frequency acquisition in the receiver), preceded by a guard interval (GI). Refer to 17.3.3 for details.

b) Produce the PLCP header field from the RATE, LENGTH, and SERVICE fields of the

TXVECTOR by filling the appropriate bit fields. The RATE and LENGTH fields of the PLCP

header are encoded by a convolutional code at a rate of R = 1/2, and are subsequently mapped onto a

single BPSK encoded OFDM symbol, denoted as the SIGNAL symbol. In order to facilitate a

reliable and timely detection of the RATE and LENGTH fields, 6 zero tail bits are inserted into the

PLCP header. The encoding of the SIGNAL field into an OFDM symbol follows the same steps for

convolutional encoding, interleaving, BPSK modulation, pilot insertion, Fourier transform, and

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 239 of 946 PageID #:

4343
239

Claim 10 of the ’802 Patent Prior Art Reference – 802.11-2007

prepending a GI as described subsequently for data transmission with BPSK-OFDM modulated at

coding rate 1/2. The contents of the SIGNAL field are not scrambled. Refer to 17.3.4 for details.

c) Calculate from RATE field of the TXVECTOR the number of data bits per OFDM symbol (NDBPS),

the coding rate (R), the number of bits in each OFDM subcarrier (NBPSC), and the number of coded

bits per OFDM symbol (NCBPS). Refer to 17.3.2.2 for details.

d) Append the PSDU to the SERVICE field of the TXVECTOR. Extend the resulting bit string with

zero bits (at least 6 bits) so that the resulting length will be a multiple of NDBPS. The resulting bit

string constitutes the DATA part of the packet. Refer to 17.3.5.3 for details.

e) Initiate the scrambler with a pseudo-random nonzero seed, generate a scrambling sequence, and

XOR it with the extended string of data bits. Refer to 17.3.5.4 for details.

f) Replace the six scrambled zero bits following the data with six nonscrambled zero bits. (Those bits

return the convolutional encoder to the zero state and are denoted as tail bits.) Refer to 17.3.5.2 for

details.

g) Encode the extended, scrambled data string with a convolutional encoder (R = 1/2). Omit (puncture)

some of the encoder output string (chosen according to “puncturing pattern”) to reach the desired

“coding rate.” Refer to 17.3.5.5 for details.

h) Divide the encoded bit string into groups of NCBPS bits. Within each group, perform an

“interleaving” (reordering) of the bits according to a rule corresponding to the desired RATE. Refer

to 17.3.5.6 for details.

i) Divide the resulting coded and interleaved data string into groups of NCBPS bits. For each of the bit

groups, convert the bit group into a complex number according to the modulation encoding tables.

Refer to 17.3.5.7 for details.

j) Divide the complex number string into groups of 48 complex numbers. Each such group will be

associated with one OFDM symbol. In each group, the complex numbers will be numbered 0 to 47

and mapped hereafter into OFDM subcarriers numbered –26 to –22, –20 to –8, –6 to –1, 1 to 6,

8 to 20, and 22 to 26. The subcarriers –21, –7, 7, and 21 are skipped and, subsequently, used for

inserting pilot subcarriers. The 0 subcarrier, associated with center frequency, is omitted and filled

with zero value. Refer to 17.3.5.9 for details.

k) Four subcarriers are inserted as pilots into positions –21, –7, 7, and 21. The total number of the

subcarriers is 52 (48 + 4). Refer to 17.3.5.8 for details.

l) For each group of subcarriers –26 to 26, convert the subcarriers to time domain using inverse

Fourier transform. Prepend to the Fourier-transformed waveform a circular extension of itself thus

forming a GI, and truncate the resulting periodic waveform to a single OFDM symbol length by

applying time domain windowing. Refer to 17.3.5.9 for details.

m) Append the OFDM symbols one after another, starting after the SIGNAL symbol describing the

RATE and LENGTH fields. Refer to 17.3.5.9 for details.

n) Up-convert the resulting “complex baseband” waveform to an RF according to the center frequency

of the desired channel and transmit. Refer to 17.3.2.4 and 17.3.8.1 for details.

An illustration of the transmitted frame and its parts appears in Figure 17-4 (in 17.3.3).

See, e.g., 802.11-2007 § 17.3.2.1

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 240 of 946 PageID #:

4344
240

Claim 10 of the ’802 Patent Prior Art Reference – 802.11-2007

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 241 of 946 PageID #:

4345
241

Claim 10 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 § 17.3.2.3

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 242 of 946 PageID #:

4346
242

Claim 10 of the ’802 Patent Prior Art Reference – 802.11-2007

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 243 of 946 PageID #:

4347
243

Claim 10 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 § 17.3.2.4 Eq. (17-1)

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 244 of 946 PageID #:

4348
244

Claim 10 of the ’802 Patent Prior Art Reference – 802.11-2007

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 245 of 946 PageID #:

4349
245

Claim 10 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 § 17.3.2.5

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 246 of 946 PageID #:

4350
246

Claim 10 of the ’802 Patent Prior Art Reference – 802.11-2007

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 247 of 946 PageID #:

4351
247

See, e.g., 802.11-2007 § 17.3.3

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 248 of 946 PageID #:

4352
248

Claim 10 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 § 17.3.5.7

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 249 of 946 PageID #:

4353
249

Claim 10 of the ’802 Patent Prior Art Reference – 802.11-2007

17.3.5.8 Pilot subcarriers

In each OFDM symbol, four of the subcarriers are dedicated to pilot signals in order to make the coherent

detection robust against frequency offsets and phase noise. These pilot signals shall be put in subcarriers

–21, –7, 7, and 21. The pilots shall be BPSK modulated by a pseudo-binary sequence to prevent the

generation of spectral lines. The contribution of the pilot subcarriers to each OFDM symbol is described in

17.3.5.9.

See, e.g., 802.11-2007 § 17.3.5.8

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 250 of 946 PageID #:

4354
250

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 251 of 946 PageID #:

4355
251

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 252 of 946 PageID #:

4356
252

Claim 10 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 § 17.3.5.9

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 253 of 946 PageID #:

4357
253

Claim 10 of the ’802 Patent Prior Art Reference – 802.11-2007

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 254 of 946 PageID #:

4358
254

Claim 10 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 § 17.3.8.1

17.3.8.3.1 Operating frequency range

The OFDM PHY shall operate in the 5 GHz band, as allocated by a regulatory body in its operational region.

Spectrum allocation in the 5 GHz band is subject to authorities responsible for geographic-specific

regulatory domains (e.g., global, regional, and national). The particular channelization to be used for this

standard is dependent on such allocation, as well as the associated regulations for use of the allocations.

These regulations are subject to revision, or may be superseded.

In some regulatory domains, several frequency bands may be available for OFDM PHY-based WLANs.

These bands may be contiguous or not, and different regulatory limits may be applicable. A compliant

OFDM PHY shall support at least one frequency band in at least one regulatory domain. The support of

specific regulatory domains, and bands within the domains, shall be indicated by PLME attributes

dot11RegDomainsSupported and dot11FrequencyBandsSupported.

See, e.g., 802.11-2007 § 17.3.8.3.1

17.3.9.1 Transmit power levels

The maximum allowable transmit power by regulatory domain is defined in Annex I.

See, e.g., 802.11-2007 § 17.3.9.1

17.3.9.6.2 Transmitter spectral flatness

The average energy of the constellations in each of the spectral lines –16.. –1 and +1.. +16 will deviate no

more than ± 2 dB from their average energy. The average energy of the constellations in each of the spectral

lines –26.. –17 and +17.. +26 will deviate no more than +2/–4 dB from the average energy of spectral lines

–16.. –1 and +1.. +16. The data for this test shall be derived from the channel estimation step.

See, e.g., 802.11-2007 § 17.3.9.6.2

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 255 of 946 PageID #:

4359
255

Claim 10 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 § I.2.2

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 256 of 946 PageID #:

4360
256

Claim 10 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 § I.2.3

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 257 of 946 PageID #:

4361
257

Claim 10 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 Figure 5-7

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 258 of 946 PageID #:

4362
258

Claim 10 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 Figure 10-6

Furthermore, this claim element is obvious in light of 802.11-2007 itself, when combined with any of 

the other references as charted for this claim element in Exs. A-1–A-31, First Supplemental Ex. ACase 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 259 of 946 PageID #:

4363
259

Claim 10 of the ’802 Patent Prior Art Reference – 802.11-2007

Obviousness 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;.

802.11-2007 discloses “converting the first digital signal into a first analog signal using a first digitalto-analog converter, the first analog signal carrying the first data across a first frequency range.” See, 

e.g.: 

1.1 Scope

The scope of this standard is to define one medium access control (MAC) and several physical layer (PHY)

specifications for wireless connectivity for fixed, portable, and moving stations (STAs) within a local area.

See, e.g., 802.11-2007 § 1.1

5.1.1 How WLAN systems are different

Wireless networks have fundamental characteristics that make them significantly different from traditional

wired LANs. Some countries impose specific requirements for radio equipment in addition to those

specified in this standard. This standard does not provide information to meet these country-specific radio

regulations.

5.1.1.1 Destination address does not equal destination location

In wired LANs, an address is equivalent to a physical location. This is implicitly assumed in the design of

wired LANs. In IEEE Std 802.11, the addressable unit is a station (STA). The STA is a message destination,

but not (in general) a fixed location.

5.1.1.2 Media impact on design and performance

The PHYs used in IEEE Std 802.11 are fundamentally different from wired media. Thus IEEE 802.11 PHYs

a) Use a medium that has neither absolute nor readily observable boundaries outside of which STAs

with conformant PHY transceivers are known to be unable to receive network frames

b) Are unprotected from other signals that may be sharing the medium

c) Communicate over a medium significantly less reliable than wired PHYs

d) Have dynamic topologies

e) Lack full connectivity, and therefore the assumption normally made that every STA can hear every

other STA is invalid (i.e., STAs may be “hidden” from each other)

f) Have time-varying and asymmetric propagation properties

g) May experience interference from logically disjoint IEEE 802.11 networks operating in overlapping

areas

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 260 of 946 PageID #:

4364
260

Claim 10 of the ’802 Patent Prior Art Reference – 802.11-2007

Because of limitations on wireless PHY ranges, WLANs intended to cover reasonable geographic distances

may be built from basic coverage building blocks. When providing QoS services it should be understood

that the MAC endeavors to provide QoS “service guarantees” within the limitations of the medium

properties identified above. In other words, particularly in unlicensed spectrum, true guarantees are often not

possible. However, gradations of service are always possible; and in sufficiently controlled environments,

QoS guarantees can truly be made.

5.1.1.3 The impact of handling mobile STAs

One of the requirements of IEEE Std 802.11 is to handle mobile as well as portable STAs. A portable STA

is one that is moved from location to location, but that is only used while at a fixed location. Mobile STAs

actually access the LAN while in motion.

For technical reasons, it is not sufficient to handle only portable STAs. Propagation effects blur the

distinction between portable and mobile STAs; stationary STAs often appear to be mobile due to

propagation effects.

Another aspect of mobile STAs is that they may often be battery powered. Hence power management is

an important consideration. For example, it cannot be presumed that a STA’s receiver will always be

powered on.

See, e.g., 802.11-2007 § 5.1.1 - § 5.1.1.3

5.2 Components of the IEEE 802.11 architecture

The IEEE 802.11 architecture consists of several components that interact to provide a WLAN that supports

STA mobility transparently to upper layers.

The basic service set (BSS) is the basic building block of an IEEE 802.11 LAN. Figure 5-1 shows two BSSs,

each of which has two STAs that are members of the BSS.

It is useful to think of the ovals used to depict a BSS as the coverage area within which the member STAs of

the BSS may remain in communication. (The concept of area, while not pr ecise, is often good enough.) This

area is called the Basic Service Area (BSA). If a STA moves out of its BSA, it can no longer directly

communicate with other STAs present in the BSA.

See, e.g., 802.11-2007 § 5.2

5.2.3 Distribution system (DS) concepts

PHY limitations determine the direct station-to-station distance that may be supported. For some networks

this distance is sufficient; for other networks, increased coverage is required.

Instead of existing independently, a BSS may also form a component of an extended form of network that is

built with multiple BSSs. The architectural component used to interconnect BSSs is the DS.

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 261 of 946 PageID #:

4365
261

Claim 10 of the ’802 Patent Prior Art Reference – 802.11-2007

IEEE Std 802.11 logically separates the WM from the distribution system medium (DSM). Each logical

medium is used for different purposes, by a different component of the architecture. The IEEE 802.11

definitions neither preclude, nor demand, that the multiple media be either the same or different.

Recognizing that the multiple media are logically different is key to understanding the flexibility of the

architecture. The IEEE 802.11 LAN architecture is specified independently of the physical characteristics of

any specific implementation.

The DS enables mobile device support by providing the logical services necessary to handle address to

destination mapping and seamless integration of multiple BSSs.

An access point (AP) is any entity that has STA functionality and enables access to the DS, via the WM for

associated STAs.

See, e.g., 802.11-2007 § 5.2.3

5.3.2 DSS

The service provided by the DS is known as the DSS.

This service is represented in the IEEE 802.11 architecture by arrows within the APs, indicating that the

service is used to cross media and possibly address space logical boundaries. An AP is a logical entity, and

the functions described may be shared by one or more physical entities.

The services that comprise the DSS are as follows:

a) Association

b) Disassociation

c) Distribution

d) Integration

e) Reassociation

f) QoS traffic scheduling (QoS facility only)

DSSs are specified for use by MAC sublayer entities.

Figure 5-7 combines the components from previous figures with both types of services to show the complete

IEEE 802.11 architecture.

See, e.g., 802.11-2007 § 5.3.2

5.4.4.1 TPC

Radio regulations may require radio local area networks (RLANs) operating in the 5 GHz band to use

transmitter power control, involving specification of a regulatory maximum transmit power and a mitigation

requirement for each allowed channel, to reduce interference with satellite services. The TPC service is used

to satisfy this regulatory requirement.

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 262 of 946 PageID #:

4366
262

Claim 10 of the ’802 Patent Prior Art Reference – 802.11-2007

The TPC service provides for the following:

— Association of STAs with an AP in a BSS based on the STAs’ power capability.

— Specification of regulatory and local maximum transmit power levels for the current channel.

— Selection of a transmit power for each transmission in a channel within constraints imposed by

regulatory requirements.

— Adaptation of transmit power based on a range of information, including path loss and link margin

estimates.

See, e.g., 802.11-2007 § 5.4.4.1

7.3.2.20 Channel Switch Announcement element

The Channel Switch Announcement element is used by an AP in a BSS or a STA in an IBSS to advertise

when it is changing to a new channel and the channel number of the new channel. The format of the Channel

Switch Announcement element is shown in Figure 7-57.

See, e.g., 802.11-2007 § 7.3.2.20

10.3.11 Spectrum management protocol layer model

The layer management extensions for measurement and channel switching assume a certain partition

of spectrum management functionality between the MLME and SME. This partitioning assumes that

policy decisions (e.g., regarding measurement and channel switching) reside in the SME, while the pro tocol

for measurement, switch timing, and the associated frame exchanges resides within the MLME (see

Figure 10-2).

...

The informative diagrams within this subclause further illustrate the spectrum management protocol model

adopted. Figure 10-3 and Figure 10-4 depict the measurement process for a peer STA to accept and reject a

measurement request, respectively. Figure 10-5 illustrates the TPC adaptation process. Lastly, Figure 10-6

depicts the management process for a channel switch using a Channel Switch Announcement frame.

See, e.g., 802.11-2007 § 10.3.11

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 263 of 946 PageID #:

4367
263

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 264 of 946 PageID #:

4368
264

Claim 10 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 § 10.4.3.2

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 265 of 946 PageID #:

4369
265

Claim 10 of the ’802 Patent Prior Art Reference – 802.11-2007

17.1 Introduction

This clause specifies the PHY entity for an orthogonal frequency division multiplexing (OFDM) system.

The OFDM system provides a WLAN with data payload communication capabilities of 6, 9, 12, 18, 24, 36,

48, and 54 Mb/s. The support of transmitting and receiving at data rates of 6, 12, and 24 Mb/s is mandatory.

The system uses 52 subcarriers that are modulated using binary or quadrature phase shift keying (BPSK or

QPSK) or using 16- or 64-quadrature amplitude modulation (16-QAM or 64-QAM). Forward error

correction coding (convolutional coding) is used with a coding rate of 1/2, 2/3, or 3/4.

The OFDM system also provides a “half-clocked” operation using 10 MHz channel spacings with data

communications capabilities of 3, 4.5, 6, 9, 12, 18, 24, and 27 Mb/s. The support of transmitting and

receiving at data rates of 3, 6, and 12 Mb/s is mandatory when using 10 MHz channel spacing. The halfclo cked

operation doubles symbol times and clear channel assessment (CCA) times when using 10 MHz

channel spacing. The regulatory requirements and information regarding use of this OFDM system in

4.9 GHz and 5 GHz bands is in Annex I and Annex J.

The OFDM system also provides a “quarter-clocked” operation using 5 MHz channel spacing with data

communication capabilities of 1.5, 2.25, 3, 4.5, 6, 9, 12, and 13.5 Mb/s. The support of transmitting and

receiving at data rates of 1.5, 3, and 6 Mb/s is mandatory when using 5 MHz channel spacing. The quarterclocked

operation quadruples symbol times and CCA times when using 5 MHz channel spacing. The

regulatory requirements and information regarding use of this OFDM system in the 4.9 GHz band is in

Annex I and Annex J.

See, e.g., 802.11-2007 § 17.1

17.3.2.1 Overview of the PPDU encoding process

The encoding process is composed of many detailed steps, which are described fully in later subclauses, as

noted below. The following overview intends to facilitate understanding the details of the convergence

procedure:

a) Produce the PLCP Preamble field, composed of 10 repetitions of a “short training sequence” (used

for AGC convergence, diversity selection, timing acquisition, and coarse frequency acquisition in

the receiver) and two repetitions of a “long training sequence” (used for channel estimation and fine

frequency acquisition in the receiver), preceded by a guard interval (GI). Refer to 17.3.3 for details.

b) Produce the PLCP header field from the RATE, LENGTH, and SERVICE fields of the

TXVECTOR by filling the appropriate bit fields. The RATE and LENGTH fields of the PLCP

header are encoded by a convolutional code at a rate of R = 1/2, and are subsequently mapped onto a

single BPSK encoded OFDM symbol, denoted as the SIGNAL symbol. In order to facilitate a

reliable and timely detection of the RATE and LENGTH fields, 6 zero tail bits are inserted into the

PLCP header. The encoding of the SIGNAL field into an OFDM symbol follows the same steps for

convolutional encoding, interleaving, BPSK modulation, pilot insertion, Fourier transform, and

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 266 of 946 PageID #:

4370
266

Claim 10 of the ’802 Patent Prior Art Reference – 802.11-2007

prepending a GI as described subsequently for data transmission with BPSK-OFDM modulated at

coding rate 1/2. The contents of the SIGNAL field are not scrambled. Refer to 17.3.4 for details.

c) Calculate from RATE field of the TXVECTOR the number of data bits per OFDM symbol (NDBPS),

the coding rate (R), the number of bits in each OFDM subcarrier (NBPSC), and the number of coded

bits per OFDM symbol (NCBPS). Refer to 17.3.2.2 for details.

d) Append the PSDU to the SERVICE field of the TXVECTOR. Extend the resulting bit string with

zero bits (at least 6 bits) so that the resulting length will be a multiple of NDBPS. The resulting bit

string constitutes the DATA part of the packet. Refer to 17.3.5.3 for details.

e) Initiate the scrambler with a pseudo-random nonzero seed, generate a scrambling sequence, and

XOR it with the extended string of data bits. Refer to 17.3.5.4 for details.

f) Replace the six scrambled zero bits following the data with six nonscrambled zero bits. (Those bits

return the convolutional encoder to the zero state and are denoted as tail bits.) Refer to 17.3.5.2 for

details.

g) Encode the extended, scrambled data string with a convolutional encoder (R = 1/2). Omit ( puncture)

some of the encoder output string (chosen according to “puncturing pattern”) to reach the desired

“coding rate.” Refer to 17.3.5.5 for details.

h) Divide the encoded bit string into groups of NCBPS bits. Within each group, perform an

“interleaving” (reordering) of the bits according to a rule corresponding to the desired RATE. Refer

to 17.3.5.6 for details.

i) Divide the resulting coded and interleaved data string into groups of NCBPS bits. For each of the bit

groups, convert the bit group into a complex number according to the modulation encoding tables.

Refer to 17.3.5.7 for details.

j) Divide the complex number string into groups of 48 complex numbers. Each such group will be

associated with one OFDM symbol. In each group, the complex numbers will be numbered 0 to 47

and mapped hereafter into OFDM subcarriers numbered –26 to –22, –20 to –8, –6 to –1, 1 to 6,

8 to 20, and 22 to 26. The subcarriers –21, –7, 7, and 21 are skipped and, subsequently, used for

inserting pilot subcarriers. The 0 subcarrier, associated with center frequency, is omitted and filled

with zero value. Refer to 17.3.5.9 for details.

k) Four subcarriers are inserted as pilots into positions –21, –7, 7, and 21. The total number of the

subcarriers is 52 (48 + 4). Refer to 17.3.5.8 for details.

l) For each group of subcarriers –26 to 26, convert the subcarriers to time domain using inverse

Fourier transform. Prepend to the Fourier-transformed waveform a circular extension of itself thus

forming a GI, and truncate the resulting periodic waveform to a single OFDM symbol length by

applying time domain windowing. Refer to 17.3.5.9 for details.

m) Append the OFDM symbols one after another, starting after the SIGNAL symbol describing the

RATE and LENGTH fields. Refer to 17.3.5.9 for details.

n) Up-convert the resulting “complex baseband” waveform to an RF according to the center frequency

of the desired channel and transmit. Refer to 17.3.2.4 and 17.3.8.1 for details.

An illustration of the transmitted frame and its parts appears in Figure 17-4 (in 17.3.3).

See, e.g., 802.11-2007 § 17.3.2.1

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 267 of 946 PageID #:

4371
267

Claim 10 of the ’802 Patent Prior Art Reference – 802.11-2007

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 268 of 946 PageID #:

4372
268

Claim 10 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 § 17.3.2.3

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 269 of 946 PageID #:

4373
269

Claim 10 of the ’802 Patent Prior Art Reference – 802.11-2007

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 270 of 946 PageID #:

4374
270

Claim 10 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 § 17.3.2.4 Eq. (17-1)

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 271 of 946 PageID #:

4375
271

Claim 10 of the ’802 Patent Prior Art Reference – 802.11-2007

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 272 of 946 PageID #:

4376
272

Claim 10 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 § 17.3.2.5

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 273 of 946 PageID #:

4377
273

Claim 10 of the ’802 Patent Prior Art Reference – 802.11-2007

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 274 of 946 PageID #:

4378
274

See, e.g., 802.11-2007 § 17.3.3

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 275 of 946 PageID #:

4379
275

Claim 10 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 § 17.3.5.7

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 276 of 946 PageID #:

4380
276

Claim 10 of the ’802 Patent Prior Art Reference – 802.11-2007

17.3.5.8 Pilot subcarriers

In each OFDM symbol, four of the subcarriers are dedicated to pilot signals in order to make the coherent

detection robust against frequency offsets and phase noise. These pilot signals shall be put in subcarriers

–21, –7, 7, and 21. The pilots shall be BPSK modulated by a pseudo-binary sequence to prevent the

generation of spectral lines. The contribution of the pilot subcarriers to each OFDM symbol is described in

17.3.5.9.

See, e.g., 802.11-2007 § 17.3.5.8

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 277 of 946 PageID #:

4381
277

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 278 of 946 PageID #:

4382
278

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 279 of 946 PageID #:

4383
279

Claim 10 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 § 17.3.5.9

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 280 of 946 PageID #:

4384
280

Claim 10 of the ’802 Patent Prior Art Reference – 802.11-2007

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 281 of 946 PageID #:

4385
281

Claim 10 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 § 17.3.8.1

17.3.8.3.1 Operating frequency range

The OFDM PHY shall operate in the 5 GHz band, as allocated by a regulatory body in its operational region.

Spectrum allocation in the 5 GHz band is subject to authorities responsible for geographic-specific

regulatory domains (e.g., global, regional, and national). The particular channelization to be used for this

standard is dependent on such allocation, as well as the associated regulations for use of the allocations.

These regulations are subject to revision, or may be superseded.

In some regulatory domains, several frequency bands may be available for OFDM PHY-based WLANs.

These bands may be contiguous or not, and different regulatory limits may be applicable. A compliant

OFDM PHY shall support at least one frequency band in at least one regulatory domain. The support of

specific regulatory domains, and bands within the domains, shall be indicated by PLME attributes

dot11RegDomainsSupported and dot11FrequencyBandsSupported.

See, e.g., 802.11-2007 § 17.3.8.3.1

17.3.9.1 Transmit power levels

The maximum allowable transmit power by regulatory domain is defined in Annex I.

See, e.g., 802.11-2007 § 17.3.9.1

17.3.9.6.2 Transmitter spectral flatness

The average energy of the constellations in each of the spectral lines –16.. –1 and +1.. +16 will deviate no

more than ± 2 dB from their average energy. The average energy of the constellations in each of the spectral

lines –26.. –17 and +17.. +26 will deviate no more than +2/–4 dB from the average energy of spectral lines

–16.. –1 and +1.. +16. The data for this test shall be derived from the channel estimation step.

See, e.g., 802.11-2007 § 17.3.9.6.2

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 282 of 946 PageID #:

4386
282

Claim 10 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 § I.2.2

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 283 of 946 PageID #:

4387
283

Claim 10 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 § I.2.3

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 284 of 946 PageID #:

4388
284

Claim 10 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 Figure 5-7

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 285 of 946 PageID #:

4389
285

Claim 10 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 Figure 10-6

Furthermore, this claim element is obvious in light of 802.11-2007 itself, when combined with any of 

the other references as charted for this claim element in Exs. A-1–A-31, First Supplemental Ex. ACase 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 286 of 946 PageID #:

4390
286

Claim 10 of the ’802 Patent Prior Art Reference – 802.11-2007

Obviousness 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.

[10.5] 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;

802.11-2007 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.” See, e.g.: 

1.1 Scope

The scope of this standard is to define one medium access control (MAC) and several physical layer (PHY)

specifications for wireless connectivity for fixed, portable, and moving stations (STAs) within a local area.

See, e.g., 802.11-2007 § 1.1

5.1.1 How WLAN systems are different

Wireless networks have fundamental characteristics that make them significantly different from traditional

wired LANs. Some countries impose specific requirements for radio equipment in addition to those

specified in this standard. This standard does not provide information to meet these country-specific radio

regulations.

5.1.1.1 Destination address does not equal destination location

In wired LANs, an address is equivalent to a physical location. This is implicitly assumed in the design of

wired LANs. In IEEE Std 802.11, the addressable unit is a station (STA). The STA is a message destination,

but not (in general) a fixed location.

5.1.1.2 Media impact on design and performance

The PHYs used in IEEE Std 802.11 are fundamentally different from wired media. Thus IEEE 802.11 PHYs

a) Use a medium that has neither absolute nor readily observable boundaries outside of which STAs

with conformant PHY transceivers are known to be unable to receive network frames

b) Are unprotected from other signals that may be sharing the medium

c) Communicate over a medium significantly less reliable than wired PHYs

d) Have dynamic topologies

e) Lack full connectivity, and therefore the assumption normally made that every STA can hear every

other STA is invalid (i.e., STAs may be “hidden” from each other)

f) Have time-varying and asymmetric propagation properties

g) May experience interference from logically disjoint IEEE 802.11 networks operating in overlapping

areas

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 287 of 946 PageID #:

4391
287

Claim 10 of the ’802 Patent Prior Art Reference – 802.11-2007

Because of limitations on wireless PHY ranges, WLANs intended to cover reasonable geographic distances

may be built from basic coverage building blocks. When providing QoS services it should be understood

that the MAC endeavors to provide QoS “service guarantees” within the limitations of the medium

properties identified above. In other words, particularly in unlicensed spectrum, true guarantees are often not

possible. However, gradations of service are always possible; and in sufficiently controlled environments,

QoS guarantees can truly be made.

5.1.1.3 The impact of handling mobile STAs

One of the requirements of IEEE Std 802.11 is to handle mobile as well as portable STAs. A portable STA

is one that is moved from location to location, but that is only used while at a fixed location. Mobile STAs

actually access the LAN while in motion.

For technical reasons, it is not sufficient to handle only portable STAs. Propagation effects blur the

distinction between portable and mobile STAs; stationary STAs often appear to be mobile due to

propagation effects.

Another aspect of mobile STAs is that they may often be battery powered. Hence power management is

an important consideration. For example, it cannot be presumed that a STA’s receiver will always be

powered on.

See, e.g., 802.11-2007 § 5.1.1 - § 5.1.1.3

5.2 Components of the IEEE 802.11 architecture

The IEEE 802.11 architecture consists of several components that interact to provide a WLAN that supports

STA mobility transparently to upper layers.

The basic service set (BSS) is the basic building block of an IEEE 802.11 LAN. Figure 5-1 shows two BSSs,

each of which has two STAs that are members of the BSS.

It is useful to think of the ovals used to depict a BSS as the coverage area within which the member STAs of

the BSS may remain in communication. (The concept of area, while not precise, is often good enough.) This

area is called the Basic Service Area (BSA). If a STA moves out of its BSA, it can no longer directly

communicate with other STAs present in the BSA.

See, e.g., 802.11-2007 § 5.2

5.2.3 Distribution system (DS) concepts

PHY limitations determine the direct station-to-station distance that may be supported. For some networks

this distance is sufficient; for other networks, increased coverage is required.

Instead of existing independently, a BSS may also form a component of an extended form of network that is

built with multiple BSSs. The architectural component used to interconnect BSSs is the DS.

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 288 of 946 PageID #:

4392
288

Claim 10 of the ’802 Patent Prior Art Reference – 802.11-2007

IEEE Std 802.11 logically separates the WM from the distribution system medium (DSM). Each logical

medium is used for different purposes, by a different component of the architecture. The IEEE 802.11

definitions neither preclude, nor demand, that the multiple media be either the same or different.

Recognizing that the multiple media are logically different is key to understanding the flexibility of the

architecture. The IEEE 802.11 LAN architecture is specified independently of the physical characteristics of

any specific implementation.

The DS enables mobile device support by providing the logical services necessary to handle address to

destination mapping and seamless integration of multiple BSSs.

An access point (AP) is any entity that has STA functionality and enables access to the DS, via the WM for

associated STAs.

See, e.g., 802.11-2007 § 5.2.3

5.3.2 DSS

The service provided by the DS is known as the DSS.

This service is represented in the IEEE 802.11 architecture by arrows within the APs, indicating that the

service is used to cross media and possibly address space logical boundaries. An AP is a logical entity, and

the functions described may be shared by one or more physical entities.

The services that comprise the DSS are as follows:

a) Association

b) Disassociation

c) Distribution

d) Integration

e) Reassociation

f) QoS traffic scheduling (QoS facility only)

DSSs are specified for use by MAC sublayer entities.

Figure 5-7 combines the components from previous figures with both types of services to show the complete

IEEE 802.11 architecture.

See, e.g., 802.11-2007 § 5.3.2

5.4.4.1 TPC

Radio regulations may require radio local area networks (RLANs) operating in the 5 GHz band to use

transmitter power control, involving specification of a regulatory maximum transmit power and a mitigation

requirement for each allowed channel, to reduce interference with satellite services. The TPC service is used

to satisfy this regulatory requirement.

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 289 of 946 PageID #:

4393
289

Claim 10 of the ’802 Patent Prior Art Reference – 802.11-2007

The TPC service provides for the following:

— Association of STAs with an AP in a BSS based on the STAs’ power capability.

— Specification of regulatory and local maximum transmit power levels for the current channel.

— Selection of a transmit power for each transmission in a channel within constraints imposed by

regulatory requirements.

— Adaptation of transmit power based on a range of information, including path loss and link margin

estimates.

See, e.g., 802.11-2007 § 5.4.4.1

7.3.2.20 Channel Switch Announcement element

The Channel Switch Announcement element is used by an AP in a BSS or a STA in an IBSS to advertise

when it is changing to a new channel and the channel number of the new channel. The format of the Channel

Switch Announcement element is shown in Figure 7-57.

See, e.g., 802.11-2007 § 7.3.2.20

10.3.11 Spectrum management protocol layer model

The layer management extensions for measurement and channel switching assume a certain partition

of spectrum management functionality between the MLME and SME. This partitioning assumes that

policy decisions (e.g., regarding measurement and channel switching) reside in the SME, while the pro tocol

for measurement, switch timing, and the associated frame exchanges resides within the MLME (see

Figure 10-2).

...

The informative diagrams within this subclause further illustrate the spectrum management protocol model

adopted. Figure 10-3 and Figure 10-4 depict the measurement process for a peer STA to accept and reject a

measurement request, respectively. Figure 10-5 illustrates the TPC adaptation process. Lastly, Figure 10-6

depicts the management process for a channel switch using a Channel Switch Announcement frame.

See, e.g., 802.11-2007 § 10.3.11

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 290 of 946 PageID #:

4394
290

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 291 of 946 PageID #:

4395
291

Claim 10 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 § 10.4.3.2

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 292 of 946 PageID #:

4396
292

Claim 10 of the ’802 Patent Prior Art Reference – 802.11-2007

17.1 Introduction

This clause specifies the PHY entity for an orthogonal frequency division multiplexing (OFDM) system.

The OFDM system provides a WLAN with data payload communication capabilities of 6, 9, 12, 18, 24, 36,

48, and 54 Mb/s. The support of transmitting and receiving at data rates of 6, 12, and 24 Mb/s is mandatory.

The system uses 52 subcarriers that are modulated using binary or quadrature phase shift keying (BPSK or

QPSK) or using 16- or 64-quadrature amplitude modulation (16-QAM or 64-QAM). Forward error

correction coding (convolutional coding) is used with a coding rate of 1/2, 2/3, or 3/4.

The OFDM system also provides a “half-clocked” operation using 10 MHz channel spacings with data

communications capabilities of 3, 4.5, 6, 9, 12, 18, 24, and 27 Mb/s. The support of transmitting and

receiving at data rates of 3, 6, and 12 Mb/s is mandatory when using 10 MHz channel spacing. The halfclo cked

operation doubles symbol times and clear channel assessment (CCA) times when using 10 MHz

channel spacing. The regulatory requirements and information regarding use of this OFDM system in

4.9 GHz and 5 GHz bands is in Annex I and Annex J.

The OFDM system also provides a “quarter-clocked” operation using 5 MHz channel spacing with data

communication capabilities of 1.5, 2.25, 3, 4.5, 6, 9, 12, and 13.5 Mb/s. The support of transmitting and

receiving at data rates of 1.5, 3, and 6 Mb/s is mandatory when using 5 MHz channel spacing. The quarterclocked

operation quadruples symbol times and CCA times when using 5 MHz channel spacing. The

regulatory requirements and information regarding use of this OFDM system in the 4.9 GHz band is in

Annex I and Annex J.

See, e.g., 802.11-2007 § 17.1

17.3.2.1 Overview of the PPDU encoding process

The encoding process is composed of many detailed steps, which are described fully in later subclauses, as

noted below. The following overview intends to facilitate understanding the details of the convergence

procedure:

a) Produce the PLCP Preamble field, composed of 10 repetitions of a “short training sequence” (used

for AGC convergence, diversity selection, timing acquisition, and coarse frequency acquisition in

the receiver) and two repetitions of a “long training sequence” (used for channel estimation and fine

frequency acquisition in the receiver), preceded by a guard interval (GI). Refer to 17.3.3 for details.

b) Produce the PLCP header field from the RATE, LENGTH, and SERVICE fields of the

TXVECTOR by filling the appropriate bit fields. The RATE and LENGTH fields of the PLCP

header are encoded by a convolutional code at a rate of R = 1/2, and are subsequently mapped onto a

single BPSK encoded OFDM symbol, denoted as the SIGNAL symbol. In order to facilitate a

reliable and timely detection of the RATE and LENGTH fields, 6 zero tail bits are inserted into the

PLCP header. The encoding of the SIGNAL field into an OFDM symbol follows the same steps for

convolutional encoding, interleaving, BPSK modulation, pilot insertion, Fourier transform, and

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 293 of 946 PageID #:

4397
293

Claim 10 of the ’802 Patent Prior Art Reference – 802.11-2007

prepending a GI as described subsequently for data transmission with BPSK-OFDM modulated at

coding rate 1/2. The contents of the SIGNAL field are not scrambled. Refer to 17.3.4 for details.

c) Calculate from RATE field of the TXVECTOR the number of data bits per OFDM symbol (NDBPS),

the coding rate (R), the number of bits in each OFDM subcarrier (NBPSC), and the number of coded

bits per OFDM symbol (NCBPS). Refer to 17.3.2.2 for details.

d) Append the PSDU to the SERVICE field of the TXVECTOR. Extend the resulting bit string with

zero bits (at least 6 bits) so that the resulting length will be a multiple of NDBPS. The resulting bit

string constitutes the DATA part of the packet. Refer to 17.3.5.3 for details.

e) Initiate the scrambler with a pseudo-random nonzero seed, generate a scrambling sequence, and

XOR it with the extended string of data bits. Refer to 17.3.5.4 for details.

f) Replace the six scrambled zero bits following the data with six nonscrambled zero bits. (Those bits

return the convolutional encoder to the zero state and are denoted as tail bits.) Refer to 17.3.5.2 for

details.

g) Encode the extended, scrambled data string with a convolutional encoder (R = 1/2). Omit ( puncture)

some of the encoder output string (chosen according to “puncturing pattern”) to reach the desired

“coding rate.” Refer to 17.3.5.5 for details.

h) Divide the encoded bit string into groups of NCBPS bits. Within each group, perform an

“interleaving” (reordering) of the bits according to a rule corresponding to the desired RATE. Refer

to 17.3.5.6 for details.

i) Divide the resulting coded and interleaved data string into groups of NCBPS bits. For each of the bit

groups, convert the bit group into a complex number according to the modulation encoding tables.

Refer to 17.3.5.7 for details.

j) Divide the complex number string into groups of 48 complex numbers. Each such group will be

associated with one OFDM symbol. In each group, the complex numbers will be numbered 0 to 47

and mapped hereafter into OFDM subcarriers numbered –26 to –22, –20 to –8, –6 to –1, 1 to 6,

8 to 20, and 22 to 26. The subcarriers –21, –7, 7, and 21 are skipped and, subsequently, used for

inserting pilot subcarriers. The 0 subcarrier, associated with center frequency, is omitted and filled

with zero value. Refer to 17.3.5.9 for details.

k) Four subcarriers are inserted as pilots into positions –21, –7, 7, and 21. The total number of the

subcarriers is 52 (48 + 4). Refer to 17.3.5.8 for details.

l) For each group of subcarriers –26 to 26, convert the subcarriers to time domain using inverse

Fourier transform. Prepend to the Fourier-transformed waveform a circular extension of itself thus

forming a GI, and truncate the resulting periodic waveform to a single OFDM symbol length by

applying time domain windowing. Refer to 17.3.5.9 for details.

m) Append the OFDM symbols one after another, starting after the SIGNAL symbol describing the

RATE and LENGTH fields. Refer to 17.3.5.9 for details.

n) Up-convert the resulting “complex baseband” waveform to an RF according to the center frequency

of the desired channel and transmit. Refer to 17.3.2.4 and 17.3.8.1 for details.

An illustration of the transmitted frame and its parts appears in Figure 17-4 (in 17.3.3).

See, e.g., 802.11-2007 § 17.3.2.1

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 294 of 946 PageID #:

4398
294

Claim 10 of the ’802 Patent Prior Art Reference – 802.11-2007

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 295 of 946 PageID #:

4399
295

Claim 10 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 § 17.3.2.3

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 296 of 946 PageID #:

4400
296

Claim 10 of the ’802 Patent Prior Art Reference – 802.11-2007

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 297 of 946 PageID #:

4401
297

Claim 10 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 § 17.3.2.4 Eq. (17-1)

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 298 of 946 PageID #:

4402
298

Claim 10 of the ’802 Patent Prior Art Reference – 802.11-2007

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 299 of 946 PageID #:

4403
299

Claim 10 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 § 17.3.2.5

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 300 of 946 PageID #:

4404
300

Claim 10 of the ’802 Patent Prior Art Reference – 802.11-2007

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 301 of 946 PageID #:

4405
301

See, e.g., 802.11-2007 § 17.3.3

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 302 of 946 PageID #:

4406
302

Claim 10 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 § 17.3.5.7

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 303 of 946 PageID #:

4407
303

Claim 10 of the ’802 Patent Prior Art Reference – 802.11-2007

17.3.5.8 Pilot subcarriers

In each OFDM symbol, four of the subcarriers are dedicated to pilot signals in order to make the coherent

detection robust against frequency offsets and phase noise. These pilot signals shall be put in subcarriers

–21, –7, 7, and 21. The pilots shall be BPSK modulated by a pseudo-binary sequence to prevent the

generation of spectral lines. The contribution of the pilot subcarriers to each OFDM symbol is described in

17.3.5.9.

See, e.g., 802.11-2007 § 17.3.5.8

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 304 of 946 PageID #:

4408
304

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 305 of 946 PageID #:

4409
305

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 306 of 946 PageID #:

4410
306

Claim 10 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 § 17.3.5.9

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 307 of 946 PageID #:

4411
307

Claim 10 of the ’802 Patent Prior Art Reference – 802.11-2007

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 308 of 946 PageID #:

4412
308

Claim 10 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 § 17.3.8.1

17.3.8.3.1 Operating frequency range

The OFDM PHY shall operate in the 5 GHz band, as allocated by a regulatory body in its operational region.

Spectrum allocation in the 5 GHz band is subject to authorities responsible for geographic-specific

regulatory domains (e.g., global, regional, and national). The particular channelization to be used for this

standard is dependent on such allocation, as well as the associated regulations for use of the allocations.

These regulations are subject to revision, or may be superseded.

In some regulatory domains, several frequency bands may be available for OFDM PHY-based WLANs.

These bands may be contiguous or not, and different regulatory limits may be applicable. A compliant

OFDM PHY shall support at least one frequency band in at least one regulatory domain. The support of

specific regulatory domains, and bands within the domains, shall be indicated by PLME attributes

dot11RegDomainsSupported and dot11FrequencyBandsSupported.

See, e.g., 802.11-2007 § 17.3.8.3.1

17.3.9.1 Transmit power levels

The maximum allowable transmit power by regulatory domain is defined in Annex I.

See, e.g., 802.11-2007 § 17.3.9.1

17.3.9.6.2 Transmitter spectral flatness

The average energy of the constellations in each of the spectral lines –16.. –1 and +1.. +16 will deviate no

more than ± 2 dB from their average energy. The average energy of the constellations in each of the spectral

lines –26.. –17 and +17.. +26 will deviate no more than +2/–4 dB from the average energy of spectral lines

–16.. –1 and +1.. +16. The data for this test shall be derived from the channel estimation step.

See, e.g., 802.11-2007 § 17.3.9.6.2

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 309 of 946 PageID #:

4413
309

Claim 10 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 § I.2.2

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 310 of 946 PageID #:

4414
310

Claim 10 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 § I.2.3

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 311 of 946 PageID #:

4415
311

Claim 10 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 Figure 5-7

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 312 of 946 PageID #:

4416
312

Claim 10 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 Figure 10-6

Furthermore, this claim element is obvious in light of 802.11-2007 itself, when combined with any of 

the other references as charted for this claim element in Exs. A-1–A-31, First Supplemental Ex. ACase 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 313 of 946 PageID #:

4417
313

Claim 10 of the ’802 Patent Prior Art Reference – 802.11-2007

Obviousness 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;

802.11-2007 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.” See, e.g.: 

1.1 Scope

The scope of this standard is to define one medium access control (MAC) and several physical layer (PHY)

specifications for wireless connectivity for fixed, portable, and moving stations (STAs) within a local area.

See, e.g., 802.11-2007 § 1.1

5.1.1 How WLAN systems are different

Wireless networks have fundamental characteristics that make them significantly different from traditional

wired LANs. Some countries impose specific requirements for radio equipment in addition to those

specified in this standard. This standard does not provide information to meet these country -specific radio

regulations.

5.1.1.1 Destination address does not equal destination location

In wired LANs, an address is equivalent to a physical location. This is implicitly assumed in the design of

wired LANs. In IEEE Std 802.11, the addressable unit is a station (STA). The STA is a message destination,

but not (in general) a fixed location.

5.1.1.2 Media impact on design and performance

The PHYs used in IEEE Std 802.11 are fundamentally different from wired media. Thus IEEE 802.11 PHYs

a) Use a medium that has neither absolute nor readily observable boundaries outside of which STAs

with conformant PHY transceivers are known to be unable to receive network frames

b) Are unprotected from other signals that may be sharing the medium

c) Communicate over a medium significantly less reliable than wired PHYs

d) Have dynamic topologies

e) Lack full connectivity, and therefore the assumption normally made th at every STA can hear every

other STA is invalid (i.e., STAs may be “hidden” from each other)

f) Have time-varying and asymmetric propagation properties

g) May experience interference from logically disjoint IEEE 802.11 networks operating in overlapping

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 314 of 946 PageID #:

4418
314

Claim 10 of the ’802 Patent Prior Art Reference – 802.11-2007

areas

Because of limitations on wireless PHY ranges, WLANs intended to cover reasonable geographic distances

may be built from basic coverage building blocks. When providing QoS services it should be understood

that the MAC endeavors to provide QoS “service guarantees” within the limitations of the medium

properties identified above. In other words, particularly in unlicensed spectrum, true guarantees are often not

possible. However, gradations of service are always possible; and in sufficiently controlled environments,

QoS guarantees can truly be made.

5.1.1.3 The impact of handling mobile STAs

One of the requirements of IEEE Std 802.11 is to handle mobile as well as portable STAs. A portable STA

is one that is moved from location to location, but that is only used while at a fixed location. Mobile STAs

actually access the LAN while in motion.

For technical reasons, it is not sufficient to handle only portable STAs. Propagation effects blur the

distinction between portable and mobile STAs; stationary STAs often appear to be mobile due to

propagation effects.

Another aspect of mobile STAs is that they may often be battery powered. Hence power management is

an important consideration. For example, it cannot be presumed that a STA’s receiver will always be

powered on.

See, e.g., 802.11-2007 § 5.1.1 - § 5.1.1.3

5.2 Components of the IEEE 802.11 architecture

The IEEE 802.11 architecture consists of several components that interact to provide a WLAN that supports

STA mobility transparently to upper layers.

The basic service set (BSS) is the basic building block of an IEEE 802.11 LAN. Figure 5 -1 shows two BSSs,

each of which has two STAs that are members of the BSS.

It is useful to think of the ovals used to depict a BSS as the coverage area within which the member STAs of

the BSS may remain in communication. (The concept of area, while not precise, is often good enough.) This

area is called the Basic Service Area (BSA). If a STA moves out of its BSA, it can no longer directly

communicate with other STAs present in the BSA.

See, e.g., 802.11-2007 § 5.2

5.2.3 Distribution system (DS) concepts

PHY limitations determine the direct station-to-station distance that may be supported. For some networks

this distance is sufficient; for other networks, increased coverage is required.

Instead of existing independently, a BSS may also form a component of an extended form of network that is

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 315 of 946 PageID #:

4419
315

Claim 10 of the ’802 Patent Prior Art Reference – 802.11-2007

built with multiple BSSs. The architectural component used to interconnect BSSs is the DS.

IEEE Std 802.11 logically separates the WM from the distribution system medium (DSM). Each logical

medium is used for different purposes, by a different component of the architecture. The IEEE 802.11

definitions neither preclude, nor demand, that the multiple media be either the same or different.

Recognizing that the multiple media are logically different is key to understanding the flexibility of the

architecture. The IEEE 802.11 LAN architecture is specified independently of the physical characteristics of

any specific implementation.

The DS enables mobile device support by providing the logical services necessary to handle address to

destination mapping and seamless integration of multiple BSSs.

An access point (AP) is any entity that has STA functionality and enables access to the DS, via the WM for

associated STAs.

See, e.g., 802.11-2007 § 5.2.3

5.3.2 DSS

The service provided by the DS is known as the DSS.

This service is represented in the IEEE 802.11 architecture by arrows within the APs, indicating that the

service is used to cross media and possibly address space logical boundaries. An AP is a logical entity, and

the functions described may be shared by one or more physical entities.

The services that comprise the DSS are as follows:

a) Association

b) Disassociation

c) Distribution

d) Integration

e) Reassociation

f) QoS traffic scheduling (QoS facility only)

DSSs are specified for use by MAC sublayer entities.

Figure 5-7 combines the components from previous figures with both types of services to show the complete

IEEE 802.11 architecture.

See, e.g., 802.11-2007 § 5.3.2

5.4.4.1 TPC

Radio regulations may require radio local area networks (RLANs) operating in the 5 GHz band to use

transmitter power control, involving specification of a regulatory maximum transmit power and a mitigation

requirement for each allowed channel, to reduce interference with satellite services. The TPC service is used

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 316 of 946 PageID #:

4420
316

Claim 10 of the ’802 Patent Prior Art Reference – 802.11-2007

to satisfy this regulatory requirement.

The TPC service provides for the following:

— Association of STAs with an AP in a BSS bas ed on the STAs’ power capability.

— Specification of regulatory and local maximum transmit power levels for the current channel.

— Selection of a transmit power for each transmission in a channel within constraints imposed by

regulatory requirements.

— Adaptation of transmit power based on a range of information, including path loss and link margin

estimates.

See, e.g., 802.11-2007 § 5.4.4.1

7.3.2.20 Channel Switch Announcement element

The Channel Switch Announcement element is used by an AP in a BSS or a STA in an IBSS to advertise

when it is changing to a new channel and the channel number of the new channel. The format of the Channel

Switch Announcement element is shown in Figure 7-57.

See, e.g., 802.11-2007 § 7.3.2.20

10.3.11 Spectrum management protocol layer model

The layer management extensions for measurement and channel switching assume a certain partition

of spectrum management functionality between the MLME and SME. This partitioning assumes that

policy decisions (e.g., regarding measurement and channel switching) reside in the SME, while the protocol

for measurement, switch timing, and the associated frame exchanges resides within the MLME (see

Figure 10-2).

...

The informative diagrams within this subclause further illustrate the spectrum management protocol model

adopted. Figure 10-3 and Figure 10-4 depict the measurement process for a peer STA to accept and reject a

measurement request, respectively. Figure 10-5 illustrates the TPC adaptation process. Lastly, Figure 10-6

depicts the management process for a channel switch using a Channel Switch Announcement frame.

See, e.g., 802.11-2007 § 10.3.11

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 317 of 946 PageID #:

4421
317

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 318 of 946 PageID #:

4422
318

Claim 10 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 § 10.4.3.2

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 319 of 946 PageID #:

4423
319

Claim 10 of the ’802 Patent Prior Art Reference – 802.11-2007

17.1 Introduction

This clause specifies the PHY entity for an orthogonal frequency division multiplexing (OFDM) system.

The OFDM system provides a WLAN with data payload communication capabilities of 6, 9, 12, 18, 24, 36,

48, and 54 Mb/s. The support of transmitting and receiving at data rates of 6, 12, and 24 Mb/s is mandatory .

The system uses 52 subcarriers that are modulated using binary or quadrature phase shift keying (BPSK or

QPSK) or using 16- or 64-quadrature amplitude modulation (16-QAM or 64-QAM). Forward error

correction coding (convolutional coding) is used with a coding rate of 1/2, 2/3, or 3/4.

The OFDM system also provides a “half-clocked” operation using 10 MHz channel spacings with data

communications capabilities of 3, 4.5, 6, 9, 12, 18, 24, and 27 Mb/s. The support of transmitting and

receiving at data rates of 3, 6, and 12 Mb/s is mandatory when using 10 MHz channel spacing. The halfclocked

operation doubles symbol times and clear channel assessment (CCA) times when using 10 MHz

channel spacing. The regulatory requirements and information regarding use of this OFDM system in

4.9 GHz and 5 GHz bands is in Annex I and Annex J.

The OFDM system also provides a “quarter-clocked” operation using 5 MHz channel spacing with data

communication capabilities of 1.5, 2.25, 3, 4.5, 6, 9, 12, and 13.5 Mb/s. The support of transmitting and

receiving at data rates of 1.5, 3, and 6 Mb/s is mandatory when using 5 MHz channel spacing. The quarterclocked

operation quadruples symbol times and CCA times when using 5 MHz channel spacing. The

regulatory requirements and information regarding use of this OFDM system in the 4.9 GHz band is in

Annex I and Annex J.

See, e.g., 802.11-2007 § 17.1

17.3.2.1 Overview of the PPDU encoding process

The encoding process is composed of many detailed steps, which are described fully in later subclauses, as

noted below. The following overview intends to facilitate understanding the details of the convergence

procedure:

a) Produce the PLCP Preamble field, composed of 10 repetitions of a “short training sequence” (used

for AGC convergence, diversity selection, timing acquisition, and coarse frequency acquisition in

the receiver) and two repetitions of a “long training sequence” (used for channel estimation and fine

frequency acquisition in the receiver), preceded by a guard interval (GI). Refer to 17.3.3 for details.

b) Produce the PLCP header field from the RATE, LENGTH, and SERVICE fields of the

TXVECTOR by filling the appropriate bit fields. The RATE and LENGTH fields of the PLCP

header are encoded by a convolutional code at a rate of R = 1/2, and are subsequently mapped onto a

single BPSK encoded OFDM symbol, denoted as the SIGNAL symbol. In order to facilitate a

reliable and timely detection of the RATE and LENGTH fields, 6 zero tail bits are inserted into the

PLCP header. The encoding of the SIGNAL field into an OFDM symbol follows the same steps for

convolutional encoding, interleaving, BPSK modulation, pilot insertion, Fourier transform, and

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 320 of 946 PageID #:

4424
320

Claim 10 of the ’802 Patent Prior Art Reference – 802.11-2007

prepending a GI as described subsequently for data transmission with BPSK-OFDM modulated at

coding rate 1/2. The contents of the SIGNAL field are not scrambled. Refer to 17.3.4 for details.

c) Calculate from RATE field of the TXVECTOR the number of data bits per OFDM symbol (NDBPS),

the coding rate (R), the number of bits in each OFDM subcarrier (NBPSC), and the number of coded

bits per OFDM symbol (NCBPS). Refer to 17.3.2.2 for details.

d) Append the PSDU to the SERVICE field of the TXVECTOR. Extend the resulting bit string with

zero bits (at least 6 bits) so that the resulting length will be a multiple of NDBPS. The resulting bit

string constitutes the DATA part of the packet. Refer to 17.3.5.3 for details.

e) Initiate the scrambler with a pseudo-random nonzero seed, generate a scrambling sequence, and

XOR it with the extended string of data bits. Refer to 17.3.5.4 for details.

f) Replace the six scrambled zero bits following the data with six nonscrambled zero bits. (Those bits

return the convolutional encoder to the zero state and are denoted as tail bits.) Refer to 17.3.5.2 for

details.

g) Encode the extended, scrambled data string with a convolutional encoder (R = 1/2). Omit (puncture)

some of the encoder output string (chosen according to “puncturing pattern”) to reach the desired

“coding rate.” Refer to 17.3.5.5 for details.

h) Divide the encoded bit string into groups of NCBPS bits. Within each group, perform an

“interleaving” (reordering) of the bits according to a rule corresponding to the desired RATE. Refer

to 17.3.5.6 for details.

i) Divide the resulting coded and interleaved data string into groups of NCBPS bits. For each of the bit

groups, convert the bit group into a complex number according to the modulation encoding tables.

Refer to 17.3.5.7 for details.

j) Divide the complex number string into groups of 48 complex numbers. Each such group will be

associated with one OFDM symbol. In each group, the complex numbers will be numbered 0 to 47

and mapped hereafter into OFDM subcarriers numbered –26 to –22, –20 to –8, –6 to –1, 1 to 6,

8 to 20, and 22 to 26. The subcarriers –21, –7, 7, and 21 are skipped and, subsequently, used for

inserting pilot subcarriers. The 0 subcarrier, associated with center frequency, is omitted and filled

with zero value. Refer to 17.3.5.9 for details.

k) Four subcarriers are inserted as pilots into positions –21, –7, 7, and 21. The total number of the

subcarriers is 52 (48 + 4). Refer to 17.3.5.8 for details.

l) For each group of subcarriers –26 to 26, convert the subcarriers to time domain using inverse

Fourier transform. Prepend to the Fourier-transformed waveform a circular extension of itself thus

forming a GI, and truncate the resulting periodic waveform to a single OFDM symbol length by

applying time domain windowing. Refer to 17.3.5.9 for details.

m) Append the OFDM symbols one after another, starting after the SIGNAL symbol describing the

RATE and LENGTH fields. Refer to 17.3.5.9 for details.

n) Up-convert the resulting “complex baseband” waveform to an RF according to the center frequency

of the desired channel and transmit. Refer to 17.3.2.4 and 17.3.8.1 for details.

An illustration of the transmitted frame and its parts appears in Figure 17-4 (in 17.3.3).

See, e.g., 802.11-2007 § 17.3.2.1

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 321 of 946 PageID #:

4425
321

Claim 10 of the ’802 Patent Prior Art Reference – 802.11-2007

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 322 of 946 PageID #:

4426
322

Claim 10 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 § 17.3.2.3

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 323 of 946 PageID #:

4427
323

Claim 10 of the ’802 Patent Prior Art Reference – 802.11-2007

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 324 of 946 PageID #:

4428
324

Claim 10 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 § 17.3.2.4 Eq. (17-1)

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 325 of 946 PageID #:

4429
325

Claim 10 of the ’802 Patent Prior Art Reference – 802.11-2007

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 326 of 946 PageID #:

4430
326

Claim 10 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 § 17.3.2.5

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 327 of 946 PageID #:

4431
327

Claim 10 of the ’802 Patent Prior Art Reference – 802.11-2007

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 328 of 946 PageID #:

4432
328

See, e.g., 802.11-2007 § 17.3.3

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 329 of 946 PageID #:

4433
329

Claim 10 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 § 17.3.5.7

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 330 of 946 PageID #:

4434
330

Claim 10 of the ’802 Patent Prior Art Reference – 802.11-2007

17.3.5.8 Pilot subcarriers

In each OFDM symbol, four of the subcarriers are dedicated to pilot signals in order to make the coherent

detection robust against frequency offsets and phase noise. These pilot signals shall be put in subcarriers

–21, –7, 7, and 21. The pilots shall be BPSK modulated by a pseudo-binary sequence to prevent the

generation of spectral lines. The contribution of the pilot subcarriers to each OFDM symbol is described in

17.3.5.9.

See, e.g., 802.11-2007 § 17.3.5.8

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 331 of 946 PageID #:

4435
331

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 332 of 946 PageID #:

4436
332

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 333 of 946 PageID #:

4437
333

Claim 10 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 § 17.3.5.9

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 334 of 946 PageID #:

4438
334

Claim 10 of the ’802 Patent Prior Art Reference – 802.11-2007

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 335 of 946 PageID #:

4439
335

Claim 10 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 § 17.3.8.1

17.3.8.3.1 Operating frequency range

The OFDM PHY shall operate in the 5 GHz band, as allocated by a regulatory body in its operational region.

Spectrum allocation in the 5 GHz band is subject to authorities responsible for geographic-specific

regulatory domains (e.g., global, regional, and national). The particular channelization to be used for this

standard is dependent on such allocation, as well as the associated regulations for use of the allocations.

These regulations are subject to revision, or may be superseded.

In some regulatory domains, several frequency bands may be available for OFDM PHY-based WLANs.

These bands may be contiguous or not, and different regulatory limits may be applicable. A compliant

OFDM PHY shall support at least one frequency band in at least one regulatory domain. The support of

specific regulatory domains, and bands within the domains, shall be indicated by PLME attributes

dot11RegDomainsSupported and dot11FrequencyBandsSupported.

See, e.g., 802.11-2007 § 17.3.8.3.1

17.3.9.1 Transmit power levels

The maximum allowable transmit power by regulatory domain is defined in Annex I.

See, e.g., 802.11-2007 § 17.3.9.1

17.3.9.6.2 Transmitter spectral flatness

The average energy of the constellations in each of the spectral lines –16.. –1 and +1.. +16 will deviate no

more than ± 2 dB from their average energy. The average energy of the constellations in each of the spectral

lines –26.. –17 and +17.. +26 will deviate no more than +2/–4 dB from the average energy of spectral lines

–16.. –1 and +1.. +16. The data for this test shall be derived from the channel estimation step.

See, e.g., 802.11-2007 § 17.3.9.6.2

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 336 of 946 PageID #:

4440
336

Claim 10 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 § I.2.2

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 337 of 946 PageID #:

4441
337

Claim 10 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 § I.2.3

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 338 of 946 PageID #:

4442
338

Claim 10 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 Figure 5-7

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 339 of 946 PageID #:

4443
339

Claim 10 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 Figure 10-6

Furthermore, this claim element is obvious in light of 802.11-2007 itself, when combined with any of 

the other references as charted for this claim element in Exs. A-1–A-31, First Supplemental Ex. ACase 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 340 of 946 PageID #:

4444
340

Claim 10 of the ’802 Patent Prior Art Reference – 802.11-2007

Obviousness 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 

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;

802.11-2007 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 up-converted 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 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 one-half the second frequency range.” See, e.g.: 

1.1 Scope

The scope of this standard is to define one medium access control (MAC) and several physical layer (PHY)

specifications for wireless connectivity for fixed, portable, and moving stations (STAs) within a local area.

See, e.g., 802.11-2007 § 1.1

5.1.1 How WLAN systems are different

Wireless networks have fundamental characteristics that make them significantly different from traditional

wired LANs. Some countries impose specific requirements for radio equipment in addition to those

specified in this standard. This standard does not provide information to meet these country -specific radio

regulations.

5.1.1.1 Destination address does not equal destination location

In wired LANs, an address is equivalent to a physical location. This is implicitly assumed in the design of

wired LANs. In IEEE Std 802.11, the addressable unit is a station (STA). The STA is a message destination,

but not (in general) a fixed location.

5.1.1.2 Media impact on design and performance

The PHYs used in IEEE Std 802.11 are fundamentally different from wired media. Thus IEEE 802.11 PHYs

a) Use a medium that has neither absolute nor readily observable boundaries outside of which STAs

with conformant PHY transceivers are known to be unable to receive network frames

b) Are unprotected from other signals that may be sharing the medium

c) Communicate over a medium significantly less reliable than wired PHYs

d) Have dynamic topologies

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 341 of 946 PageID #:

4445
341

Claim 10 of the ’802 Patent Prior Art Reference – 802.11-2007

e) Lack full connectivity, and therefore the assumption normally made that every STA can hear every

other STA is invalid (i.e., STAs may be “hidden” from each other)

f) Have time-varying and asymmetric propagation properties

g) May experience interference from logically disjoint IEEE 802.11 networks operating in overlapping

areas

Because of limitations on wireless PHY ranges, WLANs intended to cover reasonable geographic distances

may be built from basic coverage building blocks. When providing QoS services it should be understood

that the MAC endeavors to provide QoS “service guarantees” within the limitations of the medium

properties identified above. In other words, particularly in unlicensed spectrum, true guarantees are often not

possible. However, gradations of service are always possible; and in sufficiently controlled environments,

QoS guarantees can truly be made.

5.1.1.3 The impact of handling mobile STAs

One of the requirements of IEEE Std 802.11 is to handle mobile as well as portable STAs. A portable STA

is one that is moved from location to location, but that is only used while at a fixed location. Mobile STAs

actually access the LAN while in motion.

For technical reasons, it is not sufficient to handle only portable STAs. Propagation effects blur the

distinction between portable and mobile STAs; stationary STAs often appear to be mobile due to

propagation effects.

Another aspect of mobile STAs is that they may often be battery powered. Hence power management is

an important consideration. For example, it cannot be presumed that a STA’s receiver will always be

powered on.

See, e.g., 802.11-2007 § 5.1.1 - § 5.1.1.3

5.2 Components of the IEEE 802.11 architecture

The IEEE 802.11 architecture consists of several components that interact to provide a WLAN that supports

STA mobility transparently to upper layers.

The basic service set (BSS) is the basic building block of an IEEE 802.11 LAN. Figure 5 -1 shows two BSSs,

each of which has two STAs that are members of the BSS.

It is useful to think of the ovals used to depict a BSS as the coverage area within which the member STAs of

the BSS may remain in communication. (The concept of area, while not precise, is often good enough.) This

area is called the Basic Service Area (BSA). If a STA moves out of its BSA, it can no longer directly

communicate with other STAs present in the BSA.

See, e.g., 802.11-2007 § 5.2

5.2.3 Distribution system (DS) concepts

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 342 of 946 PageID #:

4446
342

Claim 10 of the ’802 Patent Prior Art Reference – 802.11-2007

PHY limitations determine the direct station-to-station distance that may be supported. For some networks

this distance is sufficient; for other networks, increased coverage is required.

Instead of existing independently, a BSS may also form a component of an extended form of network that is

built with multiple BSSs. The architectural component used to interconnect BSSs is the DS.

IEEE Std 802.11 logically separates the WM from the distribution system medium (DSM). Each logical

medium is used for different purposes, by a different component of the architecture. The IEEE 802.11

definitions neither preclude, nor demand, that the multiple media be either the same or different.

Recognizing that the multiple media are logically different is key to understanding the flexibility of the

architecture. The IEEE 802.11 LAN architecture is specified independently of the physical characteristics of

any specific implementation.

The DS enables mobile device support by providing the logical services necessary to handle address to

destination mapping and seamless integration of multiple BSSs.

An access point (AP) is any entity that has STA functionality and enables access to the DS, via the WM for

associated STAs.

See, e.g., 802.11-2007 § 5.2.3

5.3.2 DSS

The service provided by the DS is known as the DSS.

This service is represented in the IEEE 802.11 architecture by arrows within the APs, indicating that the

service is used to cross media and possibly address space logical boundaries. An AP is a logical entity, and

the functions described may be shared by one or more physical entities.

The services that comprise the DSS are as follows:

a) Association

b) Disassociation

c) Distribution

d) Integration

e) Reassociation

f) QoS traffic scheduling (QoS facility only)

DSSs are specified for use by MAC sublayer entities.

Figure 5-7 combines the components from previous figures with both types of services to show the complete

IEEE 802.11 architecture.

See, e.g., 802.11-2007 § 5.3.2

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 343 of 946 PageID #:

4447
343

Claim 10 of the ’802 Patent Prior Art Reference – 802.11-2007

5.4.4.1 TPC

Radio regulations may require radio local area networks (RLANs) operating in the 5 GHz band to use

transmitter power control, involving specification of a regulatory maximum tr ansmit power and a mitigation

requirement for each allowed channel, to reduce interference with satellite services. The TPC service is used

to satisfy this regulatory requirement.

The TPC service provides for the following:

— Association of STAs with an AP in a BSS based on the STAs’ power capability.

— Specification of regulatory and local maximum transmit power levels for the current channel.

— Selection of a transmit power for each transmission in a channel within constraints imposed by

regulatory requirements.

— Adaptation of transmit power based on a range of information, including path loss and link margin

estimates.

See, e.g., 802.11-2007 § 5.4.4.1

7.3.2.20 Channel Switch Announcement element

The Channel Switch Announcement element is used by an AP in a BSS or a STA in an IBSS to advertise

when it is changing to a new channel and the channel number of the new channel. The format of the Channel

Switch Announcement element is shown in Figure 7-57.

See, e.g., 802.11-2007 § 7.3.2.20

10.3.11 Spectrum management protocol layer model

The layer management extensions for measurement and channel switching assume a certain partition

of spectrum management functionality between the MLME and SME. This partitioning assumes that

policy decisions (e.g., regarding measurement and channel switching) reside in the SME, while the protocol

for measurement, switch timing, and the associated frame exchanges resides within the MLME (see

Figure 10-2).

...

The informative diagrams within this subclause further illustrate the spectrum management protocol model

adopted. Figure 10-3 and Figure 10-4 depict the measurement process for a peer STA to accept and reject a

measurement request, respectively. Figure 10-5 illustrates the TPC adaptation process. Lastly, Figure 10-6

depicts the management process for a channel switch using a Channel Switch Announcement frame.

See, e.g., 802.11-2007 § 10.3.11

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 344 of 946 PageID #:

4448
344

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 345 of 946 PageID #:

4449
345

Claim 10 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 § 10.4.3.2

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 346 of 946 PageID #:

4450
346

Claim 10 of the ’802 Patent Prior Art Reference – 802.11-2007

17.1 Introduction

This clause specifies the PHY entity for an orthogonal frequency division multiplexing (OFDM) system.

The OFDM system provides a WLAN with data payload communication capabilities of 6, 9, 12, 18, 24, 36,

48, and 54 Mb/s. The support of transmitting and receiving at data rates of 6, 12, and 24 Mb/s is mandatory.

The system uses 52 subcarriers that are modulated using binary or quadrature phase shift keying (BPSK or

QPSK) or using 16- or 64-quadrature amplitude modulation (16-QAM or 64-QAM). Forward error

correction coding (convolutional coding) is used with a coding rate of 1/2, 2/3, or 3/4.

The OFDM system also provides a “half-clocked” operation using 10 MHz channel spacings with data

communications capabilities of 3, 4.5, 6, 9, 12, 18, 24, and 27 Mb/s. The support of transmitting and

receiving at data rates of 3, 6, and 12 Mb/s is mandatory when using 10 MHz channel spacing. The halfclocked

operation doubles symbol times and clear channel assessment (CCA) times when using 10 MHz

channel spacing. The regulatory requirements and information regarding use of this OFDM system in

4.9 GHz and 5 GHz bands is in Annex I and Annex J.

The OFDM system also provides a “quarter-clocked” operation using 5 MHz channel spacing with data

communication capabilities of 1.5, 2.25, 3, 4.5, 6, 9, 12, and 13.5 Mb/s. The s upport of transmitting and

receiving at data rates of 1.5, 3, and 6 Mb/s is mandatory when using 5 MHz channel spacing. The quarterclocked

operation quadruples symbol times and CCA times when using 5 MHz channel spacing. The

regulatory requirements and information regarding use of this OFDM system in the 4.9 GHz band is in

Annex I and Annex J.

See, e.g., 802.11-2007 § 17.1

17.3.2.1 Overview of the PPDU encoding process

The encoding process is composed of many detailed steps, which are described fully in later subclauses, as

noted below. The following overview intends to facilitate understanding the details of the convergence

procedure:

a) Produce the PLCP Preamble field, composed of 10 repetitions of a “short training sequence” (used

for AGC convergence, diversity selection, timing acquisition, and coarse frequency acquisition in

the receiver) and two repetitions of a “long training sequence” (used for channel estimation and fine

frequency acquisition in the receiver), preceded by a guard interval (GI). Refer to 17.3.3 for details.

b) Produce the PLCP header field from the RATE, LENGTH, and SERVICE fields of the

TXVECTOR by filling the appropriate bit fields. The RATE and LENGTH fields of the PLCP

header are encoded by a convolutional code at a rate of R = 1/2, and are subsequently mapped onto a

single BPSK encoded OFDM symbol, denoted as the SIGNAL symbol. In order to facilitate a

reliable and timely detection of the RATE and LENGTH fields, 6 zero tail bits are inserted into the

PLCP header. The encoding of the SIGNAL field into an OFDM symbol follows the same steps for

convolutional encoding, interleaving, BPSK modulation, pilot insertion, Fourier transform, and

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 347 of 946 PageID #:

4451
347

Claim 10 of the ’802 Patent Prior Art Reference – 802.11-2007

prepending a GI as described subsequently for data transmission with BPSK-OFDM modulated at

coding rate 1/2. The contents of the SIGNAL field are not scrambled. Refer to 17.3.4 for details.

c) Calculate from RATE field of the TXVECTOR the number of data bits per OFDM symbol (NDBPS),

the coding rate (R), the number of bits in each OFDM subcarrier (NBPSC), and the number of coded

bits per OFDM symbol (NCBPS). Refer to 17.3.2.2 for details.

d) Append the PSDU to the SERVICE field of the TXVECTOR. Extend the resulting bit string with

zero bits (at least 6 bits) so that the resulting length will be a multiple of NDBPS. The resulting bit

string constitutes the DATA part of the packet. Refer to 17.3.5.3 for details.

e) Initiate the scrambler with a pseudo-random nonzero seed, generate a scrambling sequence, and

XOR it with the extended string of data bits. Refer to 17.3.5.4 for details.

f) Replace the six scrambled zero bits following the data with six nonscrambled zero bits. (Those bits

return the convolutional encoder to the zero state and are denoted as tail bits.) Refer to 17.3.5.2 for

details.

g) Encode the extended, scrambled data string with a convolutional encoder (R = 1/2). Omit (puncture)

some of the encoder output string (chosen according to “puncturing pattern”) to reach the desired

“coding rate.” Refer to 17.3.5.5 for details.

h) Divide the encoded bit string into groups of NCBPS bits. Within each group, perform an

“interleaving” (reordering) of the bits according to a rule corresponding to the desired RATE. Refer

to 17.3.5.6 for details.

i) Divide the resulting coded and interleaved data string into groups of NCBPS bits. For each of the bit

groups, convert the bit group into a complex number according to the modulation encoding tables.

Refer to 17.3.5.7 for details.

j) Divide the complex number string into groups of 48 complex numbers. Each such group will be

associated with one OFDM symbol. In each group, the complex numbers will be numbered 0 to 47

and mapped hereafter into OFDM subcarriers numbered –26 to –22, –20 to –8, –6 to –1, 1 to 6,

8 to 20, and 22 to 26. The subcarriers –21, –7, 7, and 21 are skipped and, subsequently, used for

inserting pilot subcarriers. The 0 subcarrier, associated with center frequency, is omitted and filled

with zero value. Refer to 17.3.5.9 for details.

k) Four subcarriers are inserted as pilots into positions –21, –7, 7, and 21. The total number of the

subcarriers is 52 (48 + 4). Refer to 17.3.5.8 for details.

l) For each group of subcarriers –26 to 26, convert the subcarriers to time domain using inverse

Fourier transform. Prepend to the Fourier-transformed waveform a circular extension of itself thus

forming a GI, and truncate the resulting periodic waveform to a single OFDM symbol length by

applying time domain windowing. Refer to 17.3.5.9 for details.

m) Append the OFDM symbols one after another, starting after the SIGNAL symbol describing the

RATE and LENGTH fields. Refer to 17.3.5.9 for details.

n) Up-convert the resulting “complex baseband” waveform to an RF according to the center frequency

of the desired channel and transmit. Refer to 17.3.2.4 and 17.3.8.1 for details.

An illustration of the transmitted frame and its parts appears in Figure 17-4 (in 17.3.3).

See, e.g., 802.11-2007 § 17.3.2.1

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 348 of 946 PageID #:

4452
348

Claim 10 of the ’802 Patent Prior Art Reference – 802.11-2007

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 349 of 946 PageID #:

4453
349

Claim 10 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 § 17.3.2.3

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 350 of 946 PageID #:

4454
350

Claim 10 of the ’802 Patent Prior Art Reference – 802.11-2007

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 351 of 946 PageID #:

4455
351

Claim 10 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 § 17.3.2.4 Eq. (17-1)

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 352 of 946 PageID #:

4456
352

Claim 10 of the ’802 Patent Prior Art Reference – 802.11-2007

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 353 of 946 PageID #:

4457
353

Claim 10 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 § 17.3.2.5

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 354 of 946 PageID #:

4458
354

Claim 10 of the ’802 Patent Prior Art Reference – 802.11-2007

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 355 of 946 PageID #:

4459
355

See, e.g., 802.11-2007 § 17.3.3

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 356 of 946 PageID #:

4460
356

Claim 10 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 § 17.3.5.7

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 357 of 946 PageID #:

4461
357

Claim 10 of the ’802 Patent Prior Art Reference – 802.11-2007

17.3.5.8 Pilot subcarriers

In each OFDM symbol, four of the subcarriers are dedicated to pilot signals in order to make the coherent

detection robust against frequency offsets and phase noise. These pilot signals shall be put in subcarriers

–21, –7, 7, and 21. The pilots shall be BPSK modulated by a pseudo-binary sequence to prevent the

generation of spectral lines. The contribution of the pilot subcarriers to each OFDM symbol is described in

17.3.5.9.

See, e.g., 802.11-2007 § 17.3.5.8

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 358 of 946 PageID #:

4462
358

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 359 of 946 PageID #:

4463
359

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 360 of 946 PageID #:

4464
360

Claim 10 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 § 17.3.5.9

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 361 of 946 PageID #:

4465
361

Claim 10 of the ’802 Patent Prior Art Reference – 802.11-2007

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 362 of 946 PageID #:

4466
362

Claim 10 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 § 17.3.8.1

17.3.8.3.1 Operating frequency range

The OFDM PHY shall operate in the 5 GHz band, as allocated by a regulatory body in its operational region.

Spectrum allocation in the 5 GHz band is subject to authorities responsible for geographic-specific

regulatory domains (e.g., global, regional, and national). The particular channelization to be used for this

standard is dependent on such allocation, as well as the associated regulations for use of the allocations.

These regulations are subject to revision, or may be superseded.

In some regulatory domains, several frequency bands may be available for OFDM PHY-based WLANs.

These bands may be contiguous or not, and different regulatory limits may be applicable. A compliant

OFDM PHY shall support at least one frequency band in at least one regulatory domain. The support of

specific regulatory domains, and bands within the domains, shall be indicated by PLME attributes

dot11RegDomainsSupported and dot11FrequencyBandsSupported.

See, e.g., 802.11-2007 § 17.3.8.3.1

17.3.9.1 Transmit power levels

The maximum allowable transmit power by regulatory domain is defined in Annex I.

See, e.g., 802.11-2007 § 17.3.9.1

17.3.9.6.2 Transmitter spectral flatness

The average energy of the constellations in each of the spectral lines –16.. –1 and +1.. +16 will deviate no

more than ± 2 dB from their average energy. The average energy of the constellations in each of the spectral

lines –26.. –17 and +17.. +26 will deviate no more than +2/–4 dB from the average energy of spectral lines

–16.. –1 and +1.. +16. The data for this test shall be derived from the channel estimation step.

See, e.g., 802.11-2007 § 17.3.9.6.2

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 363 of 946 PageID #:

4467
363

Claim 10 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 § I.2.2

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 364 of 946 PageID #:

4468
364

Claim 10 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 § I.2.3

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 365 of 946 PageID #:

4469
365

Claim 10 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 Figure 5-7

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 366 of 946 PageID #:

4470
366

Claim 10 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 Figure 10-6

Furthermore, this claim element is obvious in light of 802.11-2007 itself, when combined with any of 

the other references as charted for this claim element in Exs. A-1–A-31, First Supplemental Ex. ACase 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 367 of 946 PageID #:

4471
367

Claim 10 of the ’802 Patent Prior Art Reference – 802.11-2007

Obviousness 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.

[10.8] combining the first upconverted analog signal and 

the second up-converted 

analog signal to produce a 

combined up-converted 

signal;

802.11-2007 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.: 

1.1 Scope

The scope of this standard is to define one medium access control (MAC) and several physical layer (PHY)

specifications for wireless connectivity for fixed, portable, and moving stations (STAs) within a local area.

See, e.g., 802.11-2007 § 1.1

5.1.1 How WLAN systems are different

Wireless networks have fundamental characteristics that make them significantly different from traditional

wired LANs. Some countries impose specific requirements for radio equipment in addition to those

specified in this standard. This standard does not provide information to meet these country -specific radio

regulations.

5.1.1.1 Destination address does not equal destination location

In wired LANs, an address is equivalent to a physical location. This is implicitly assumed in the design of

wired LANs. In IEEE Std 802.11, the addressable unit is a station (STA). The STA is a message destination,

but not (in general) a fixed location.

5.1.1.2 Media impact on design and performance

The PHYs used in IEEE Std 802.11 are fundamentally different from wired media. Thus IEEE 802.11 PHYs

a) Use a medium that has neither absolute nor readily observable boundaries outside of which STAs

with conformant PHY transceivers are known to be unable to receive network frames

b) Are unprotected from other signals that may be sharing the medium

c) Communicate over a medium significantly less reliable than wired PHYs

d) Have dynamic topologies

e) Lack full connectivity, and therefore the assumption normally made that every STA can hear every

other STA is invalid (i.e., STAs may be “hidden” from each other)

f) Have time-varying and asymmetric propagation properties

g) May experience interference from logically disjoint IEEE 802.11 networks operating in overlapping

areas

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 368 of 946 PageID #:

4472
368

Claim 10 of the ’802 Patent Prior Art Reference – 802.11-2007

Because of limitations on wireless PHY ranges, WLANs intended to cover reasonable geographic distances

may be built from basic coverage building blocks. When providing QoS services it should be understood

that the MAC endeavors to provide QoS “service guarantees” within the limitations of the medium

properties identified above. In other words, particularly in unlicensed spectrum, true guarantees are often not

possible. However, gradations of service are always possible; and in sufficiently controlled environments,

QoS guarantees can truly be made.

5.1.1.3 The impact of handling mobile STAs

One of the requirements of IEEE Std 802.11 is to handle mobile as well as portable STAs. A portable STA

is one that is moved from location to location, but that is only used while at a fixed location. Mobile STAs

actually access the LAN while in motion.

For technical reasons, it is not sufficient to handle only portable STAs. Propagation effects blur the

distinction between portable and mobile STAs; stationary STAs often appear to be mobile due to

propagation effects.

Another aspect of mobile STAs is that they may often be battery powered. Hence power management is

an important consideration. For example, it cannot be presumed that a STA’s receiver will always be

powered on.

See, e.g., 802.11-2007 § 5.1.1 - § 5.1.1.3

5.2 Components of the IEEE 802.11 architecture

The IEEE 802.11 architecture consists of several components that interact to provid e a WLAN that supports

STA mobility transparently to upper layers.

The basic service set (BSS) is the basic building block of an IEEE 802.11 LAN. Figure 5 -1 shows two BSSs,

each of which has two STAs that are members of the BSS.

It is useful to think of the ovals used to depict a BSS as the coverage area within which the member STAs of

the BSS may remain in communication. (The concept of area, while not precise, is often good enough.) This

area is called the Basic Service Area (BSA). If a STA moves out of its BSA, it can no longer directly

communicate with other STAs present in the BSA.

See, e.g., 802.11-2007 § 5.2

5.2.3 Distribution system (DS) concepts

PHY limitations determine the direct station-to-station distance that may be supported. For some networks

this distance is sufficient; for other networks, increased coverage is required.

Instead of existing independently, a BSS may also form a component of an extended form of network that is

built with multiple BSSs. The architectural component used to interconnect BSSs is the DS.

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 369 of 946 PageID #:

4473
369

Claim 10 of the ’802 Patent Prior Art Reference – 802.11-2007

IEEE Std 802.11 logically separates the WM from the distribution system medium (DSM). Each logical

medium is used for different purposes, by a different component of the architecture. The IEEE 802.11

definitions neither preclude, nor demand, that the multiple media be either the same or different.

Recognizing that the multiple media are logically different is key to understanding the flexibility of the

architecture. The IEEE 802.11 LAN architecture is specified independently of the physical characteristics of

any specific implementation.

The DS enables mobile device support by providing the logical services necessary to handle address to

destination mapping and seamless integration of multiple BSSs.

An access point (AP) is any entity that has STA functionality and enables access to the DS, via the WM for

associated STAs.

See, e.g., 802.11-2007 § 5.2.3

5.3.2 DSS

The service provided by the DS is known as the DSS.

This service is represented in the IEEE 802.11 architecture by arrows within the APs, indicating that the

service is used to cross media and possibly address space logical boundaries. An AP is a logical entity, and

the functions described may be shared by one or more physical entities.

The services that comprise the DSS are as follows:

a) Association

b) Disassociation

c) Distribution

d) Integration

e) Reassociation

f) QoS traffic scheduling (QoS facility only)

DSSs are specified for use by MAC sublayer entities.

Figure 5-7 combines the components from previous figures with both types of services to show the complete

IEEE 802.11 architecture.

See, e.g., 802.11-2007 § 5.3.2

5.4.4.1 TPC

Radio regulations may require radio local area networks (RLANs) operating in the 5 GHz band to use

transmitter power control, involving specification of a regulatory maximum transmit power and a mitigation

requirement for each allowed channel, to reduce interference with satellite services. The TPC service is used

to satisfy this regulatory requirement.

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 370 of 946 PageID #:

4474
370

Claim 10 of the ’802 Patent Prior Art Reference – 802.11-2007

The TPC service provides for the following:

— Association of STAs with an AP in a BSS based on the STAs’ power capability.

— Specification of regulatory and local maximum transmit power levels for the current channel.

— Selection of a transmit power for each transmission in a channel within constraints imposed by

regulatory requirements.

— Adaptation of transmit power based on a range of information, including path loss and link margin

estimates.

See, e.g., 802.11-2007 § 5.4.4.1

7.3.2.20 Channel Switch Announcement element

The Channel Switch Announcement element is used by an AP in a BSS or a STA in an IBSS to advertise

when it is changing to a new channel and the channel number of the new channel. The format of the Channel

Switch Announcement element is shown in Figure 7-57.

See, e.g., 802.11-2007 § 7.3.2.20

10.3.11 Spectrum management protocol layer model

The layer management extensions for measurement and channel switching assume a certain partition

of spectrum management functionality between the MLME and SME. This partitioning assumes that

policy decisions (e.g., regarding measurement and channel switching) reside in the SME, while the protocol

for measurement, switch timing, and the associated frame exchanges resides within the MLME (see

Figure 10-2).

...

The informative diagrams within this subclause further illustrate the spectrum management protocol model

adopted. Figure 10-3 and Figure 10-4 depict the measurement process for a peer STA to accept and reject a

measurement request, respectively. Figure 10-5 illustrates the TPC adaptation process. Lastly, Figure 10-6

depicts the management process for a channel switch using a Channel Switch Announcement frame.

See, e.g., 802.11-2007 § 10.3.11

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 371 of 946 PageID #:

4475
371

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 372 of 946 PageID #:

4476
372

Claim 10 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 § 10.4.3.2

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 373 of 946 PageID #:

4477
373

Claim 10 of the ’802 Patent Prior Art Reference – 802.11-2007

17.1 Introduction

This clause specifies the PHY entity for an orthogonal frequency division multiplexing (OFDM) system.

The OFDM system provides a WLAN with data payload communication capabilities of 6, 9, 12, 18, 24, 36,

48, and 54 Mb/s. The support of transmitting and receiving at data rates of 6, 12, and 24 Mb/s is mandatory.

The system uses 52 subcarriers that are modulated using binary or quadrature phase shift keying (BPSK or

QPSK) or using 16- or 64-quadrature amplitude modulation (16-QAM or 64-QAM). Forward error

correction coding (convolutional coding) is used with a coding rate of 1/2, 2/3, or 3/4.

The OFDM system also provides a “half-clocked” operation using 10 MHz channel spacings with data

communications capabilities of 3, 4.5, 6, 9, 12, 18, 24, and 27 Mb/s. The support of transmitting and

receiving at data rates of 3, 6, and 12 Mb/s is mandatory when using 10 MHz channel spacing. The halfclocked

operation doubles symbol times and clear channel assessment (CCA) times when using 10 MHz

channel spacing. The regulatory requirements and information regarding use of this OFDM system in

4.9 GHz and 5 GHz bands is in Annex I and Annex J.

The OFDM system also provides a “quarter-clocked” operation using 5 MHz channel spacing with data

communication capabilities of 1.5, 2.25, 3, 4.5, 6, 9, 12, and 13.5 Mb/s. The support of transmitting and

receiving at data rates of 1.5, 3, and 6 Mb/s is mandatory when using 5 MHz channel spacing. The quarterclocked

operation quadruples symbol times and CCA times when using 5 MHz channel spacing. The

regulatory requirements and information regarding use of this OFDM system in the 4.9 GHz band is in

Annex I and Annex J.

See, e.g., 802.11-2007 § 17.1

17.3.2.1 Overview of the PPDU encoding process

The encoding process is composed of many detailed steps, which are described fully in later subclauses, as

noted below. The following overview intends to facilitate understanding the details of the convergence

procedure:

a) Produce the PLCP Preamble field, composed of 10 repetitions of a “short training sequence” (used

for AGC convergence, diversity selection, timing acquisition, and coarse frequency acquisition in

the receiver) and two repetitions of a “long training sequence” (used for channel estimation and fine

frequency acquisition in the receiver), preceded by a guard interval (GI). Refer to 17.3.3 for details.

b) Produce the PLCP header field from the RATE, LENGTH, and SERVICE fields of the

TXVECTOR by filling the appropriate bit fields. The RATE and LENGTH fields of the PLCP

header are encoded by a convolutional code at a rate of R = 1/2, and are subsequently mapped onto a

single BPSK encoded OFDM symbol, denoted as the SIGNAL symbol. In order to facilitate a

reliable and timely detection of the RATE and LENGTH fields, 6 zero tail bits are inserted into the

PLCP header. The encoding of the SIGNAL field into an OFDM symbol follows the same steps for

convolutional encoding, interleaving, BPSK modulation, pilot insertion, Fourier transform, and

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 374 of 946 PageID #:

4478
374

Claim 10 of the ’802 Patent Prior Art Reference – 802.11-2007

prepending a GI as described subsequently for data transmission with BPSK-OFDM modulated at

coding rate 1/2. The contents of the SIGNAL field are not scrambled. Refer to 17.3.4 for details.

c) Calculate from RATE field of the TXVECTOR the number of data bits per OFDM symbol (NDBPS),

the coding rate (R), the number of bits in each OFDM subcarrier (NBPSC), and the number of coded

bits per OFDM symbol (NCBPS). Refer to 17.3.2.2 for details.

d) Append the PSDU to the SERVICE field of the TXVECTOR. Extend the resulting bit string with

zero bits (at least 6 bits) so that the resulting length will be a multiple of NDBPS. The resulting bit

string constitutes the DATA part of the packet. Refer to 17.3.5.3 for details.

e) Initiate the scrambler with a pseudo-random nonzero seed, generate a scrambling sequence, and

XOR it with the extended string of data bits. Refer to 17.3.5.4 for details.

f) Replace the six scrambled zero bits following the data with six nonscrambled zero bits. (Those bits

return the convolutional encoder to the zero state and are denoted as tail bits.) Refer to 17.3.5.2 for

details.

g) Encode the extended, scrambled data string with a convolutional encoder (R = 1/2). Omit (puncture)

some of the encoder output string (chosen according to “puncturing pattern”) to reach the desired

“coding rate.” Refer to 17.3.5.5 for details.

h) Divide the encoded bit string into groups of NCBPS bits. Within each group, perform an

“interleaving” (reordering) of the bits according to a rule corresponding to the desired RATE. Refer

to 17.3.5.6 for details.

i) Divide the resulting coded and interleaved data string into groups of NCBPS bits. For each of the bit

groups, convert the bit group into a complex number according to the modulation encoding tables.

Refer to 17.3.5.7 for details.

j) Divide the complex number string into groups of 48 complex numbers. Each such group will be

associated with one OFDM symbol. In each group, the complex numbers will be numbered 0 to 47

and mapped hereafter into OFDM subcarriers numbered –26 to –22, –20 to –8, –6 to –1, 1 to 6,

8 to 20, and 22 to 26. The subcarriers –21, –7, 7, and 21 are skipped and, subsequently, used for

inserting pilot subcarriers. The 0 subcarrier, associated with center frequency, is omitted and filled

with zero value. Refer to 17.3.5.9 for details.

k) Four subcarriers are inserted as pilots into positions –21, –7, 7, and 21. The total number of the

subcarriers is 52 (48 + 4). Refer to 17.3.5.8 for details.

l) For each group of subcarriers –26 to 26, convert the subcarriers to time domain using inverse

Fourier transform. Prepend to the Fourier-transformed waveform a circular extension of itself thus

forming a GI, and truncate the resulting periodic waveform to a single OFDM symbol length by

applying time domain windowing. Refer to 17.3.5.9 for details.

m) Append the OFDM symbols one after another, starting after the SIGNAL symbol describing the

RATE and LENGTH fields. Refer to 17.3.5.9 for details.

n) Up-convert the resulting “complex baseband” waveform to an RF according to the center frequency

of the desired channel and transmit. Refer to 17.3.2.4 and 17.3.8.1 for details.

An illustration of the transmitted frame and its parts appears in Figure 17-4 (in 17.3.3).

See, e.g., 802.11-2007 § 17.3.2.1

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 375 of 946 PageID #:

4479
375

Claim 10 of the ’802 Patent Prior Art Reference – 802.11-2007

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 376 of 946 PageID #:

4480
376

Claim 10 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 § 17.3.2.3

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 377 of 946 PageID #:

4481
377

Claim 10 of the ’802 Patent Prior Art Reference – 802.11-2007

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 378 of 946 PageID #:

4482
378

Claim 10 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 § 17.3.2.4 Eq. (17-1)

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 379 of 946 PageID #:

4483
379

Claim 10 of the ’802 Patent Prior Art Reference – 802.11-2007

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 380 of 946 PageID #:

4484
380

Claim 10 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 § 17.3.2.5

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 381 of 946 PageID #:

4485
381

Claim 10 of the ’802 Patent Prior Art Reference – 802.11-2007

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 382 of 946 PageID #:

4486
382

See, e.g., 802.11-2007 § 17.3.3

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 383 of 946 PageID #:

4487
383

Claim 10 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 § 17.3.5.7

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 384 of 946 PageID #:

4488
384

Claim 10 of the ’802 Patent Prior Art Reference – 802.11-2007

17.3.5.8 Pilot subcarriers

In each OFDM symbol, four of the subcarriers are dedicated to pilot signals in order to make the coherent

detection robust against frequency offsets and phase noise. These pilot signals shall be put in subcarriers

–21, –7, 7, and 21. The pilots shall be BPSK modulated by a pseudo-binary sequence to prevent the

generation of spectral lines. The contribution of the pilot subcarriers to each OFDM symbol is described in

17.3.5.9.

See, e.g., 802.11-2007 § 17.3.5.8

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 385 of 946 PageID #:

4489
385

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 386 of 946 PageID #:

4490
386

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 387 of 946 PageID #:

4491
387

Claim 10 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 § 17.3.5.9

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 388 of 946 PageID #:

4492
388

Claim 10 of the ’802 Patent Prior Art Reference – 802.11-2007

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 389 of 946 PageID #:

4493
389

Claim 10 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 § 17.3.8.1

17.3.8.3.1 Operating frequency range

The OFDM PHY shall operate in the 5 GHz band, as allocated by a regulatory body in its operational region.

Spectrum allocation in the 5 GHz band is subject to authorities responsible for geographic-specific

regulatory domains (e.g., global, regional, and national). The particular channelization to be used for this

standard is dependent on such allocation, as well as the associated regulations for use of the allocations.

These regulations are subject to revision, or may be superseded.

In some regulatory domains, several frequency bands may be available for OFDM PHY-based WLANs.

These bands may be contiguous or not, and different regulatory limits may be applicable. A compliant

OFDM PHY shall support at least one frequency band in at least one regulatory domain. The support of

specific regulatory domains, and bands within the domains, shall be indicated by PLME attributes

dot11RegDomainsSupported and dot11FrequencyBandsSupported.

See, e.g., 802.11-2007 § 17.3.8.3.1

17.3.9.1 Transmit power levels

The maximum allowable transmit power by regulatory domain is defined in Annex I.

See, e.g., 802.11-2007 § 17.3.9.1

17.3.9.6.2 Transmitter spectral flatness

The average energy of the constellations in each of the spectral lines –16.. –1 and +1.. +16 will deviate no

more than ± 2 dB from their average energy. The average energy of the constellations in each of the spectral

lines –26.. –17 and +17.. +26 will deviate no more than +2/–4 dB from the average energy of spectral lines

–16.. –1 and +1.. +16. The data for this test shall be derived from the channel estimation step.

See, e.g., 802.11-2007 § 17.3.9.6.2

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 390 of 946 PageID #:

4494
390

Claim 10 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 § I.2.2

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 391 of 946 PageID #:

4495
391

Claim 10 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 § I.2.3

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 392 of 946 PageID #:

4496
392

Claim 10 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 Figure 5-7

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 393 of 946 PageID #:

4497
393

Claim 10 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 Figure 10-6

Furthermore, this claim element is obvious in light of 802.11-2007 itself, when combined with any of 

the other references as charted for this claim element in Exs. A-1–A-31, First Supplemental Ex. ACase 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 394 of 946 PageID #:

4498
394

Claim 10 of the ’802 Patent Prior Art Reference – 802.11-2007

Obviousness 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.

[10.9] amplifying the 

combined up-converted signal 

in a power amplifier resulting 

in an amplified combined upconverted signal; and

802.11-2007 discloses “amplifying the combined up-converted signal in a power amplifier resulting 

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

1.1 Scope

The scope of this standard is to define one medium access control (MAC) and several physical layer (PHY)

specifications for wireless connectivity for fixed, portable, and moving stations (STAs) within a local area.

See, e.g., 802.11-2007 § 1.1

5.1.1 How WLAN systems are different

Wireless networks have fundamental characteristics that make them significantly different from traditional

wired LANs. Some countries impose specific requirements for radio equipment in addition to those

specified in this standard. This standard does not provide information to meet these country -specific radio

regulations.

5.1.1.1 Destination address does not equal destination location

In wired LANs, an address is equivalent to a physical location. This is implicitly assumed in the design of

wired LANs. In IEEE Std 802.11, the addressable unit is a station (STA). The STA is a message destination,

but not (in general) a fixed location.

5.1.1.2 Media impact on design and performance

The PHYs used in IEEE Std 802.11 are fundamentally different from wired media. Thus IEEE 802.11 PHYs

a) Use a medium that has neither absolute nor readily observable boundaries outside of which STAs

with conformant PHY transceivers are known to be unable to receive network frames

b) Are unprotected from other signals that may be sharing the medium

c) Communicate over a medium significantly less reliable than wired PHYs

d) Have dynamic topologies

e) Lack full connectivity, and therefore the assumption normally made that every STA can hear every

other STA is invalid (i.e., STAs may be “hidden” from each other)

f) Have time-varying and asymmetric propagation properties

g) May experience interference from logically disjoint IEEE 802.11 networks operating in overlapping

areas

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 395 of 946 PageID #:

4499
395

Claim 10 of the ’802 Patent Prior Art Reference – 802.11-2007

Because of limitations on wireless PHY ranges, WLANs intended to cover reasonable geographic distances

may be built from basic coverage building blocks. When providing QoS services it should be understood

that the MAC endeavors to provide QoS “service guarantees” within the limitations of the medium

properties identified above. In other words, particularly in unlicensed spectrum, true guarantees are often not

possible. However, gradations of service are always possible; and in sufficiently controlled environments,

QoS guarantees can truly be made.

5.1.1.3 The impact of handling mobile STAs

One of the requirements of IEEE Std 802.11 is to handle mobile as well as portable STAs. A portable STA

is one that is moved from location to location, but that is only used while at a fixed location. Mobile STAs

actually access the LAN while in motion.

For technical reasons, it is not sufficient to handle only portable STAs. Propagation effects blur the

distinction between portable and mobile STAs; stationary STAs often appear to be mobile due to

propagation effects.

Another aspect of mobile STAs is that they may often be battery powered. Hence power management is

an important consideration. For example, it cannot be presumed that a STA’s receiver will always be

powered on.

See, e.g., 802.11-2007 § 5.1.1 - § 5.1.1.3

5.2 Components of the IEEE 802.11 architecture

The IEEE 802.11 architecture consists of several components that interact to provide a WLAN that supports

STA mobility transparently to upper layers.

The basic service set (BSS) is the basic building block of an IEEE 802.11 LAN. Figure 5 -1 shows two BSSs,

each of which has two STAs that are members of the BSS.

It is useful to think of the ovals used to depict a BSS as the coverage area within which the member STAs of

the BSS may remain in communication. (The concept of area, while not precise, is often good enough.) This

area is called the Basic Service Area (BSA). If a STA moves out of its BSA, it can no longer directly

communicate with other STAs present in the BSA.

See, e.g., 802.11-2007 § 5.2

5.2.3 Distribution system (DS) concepts

PHY limitations determine the direct station-to-station distance that may be supported. For some networks

this distance is sufficient; for other networks, increased coverage is required.

Instead of existing independently, a BSS may also form a component of an extended form of network that is

built with multiple BSSs. The architectural component used to interconnect BSSs is the DS.

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 396 of 946 PageID #:

4500
396

Claim 10 of the ’802 Patent Prior Art Reference – 802.11-2007

IEEE Std 802.11 logically separates the WM from the distribution system medium (DSM). Each logical

medium is used for different purposes, by a different component of the architecture. The IEEE 802.11

definitions neither preclude, nor demand, that the multiple media be either the same or different.

Recognizing that the multiple media are logically different is key to understanding the flexibility of the

architecture. The IEEE 802.11 LAN architecture is specified independently of the physical charac teristics of

any specific implementation.

The DS enables mobile device support by providing the logical services necessary to handle address to

destination mapping and seamless integration of multiple BSSs.

An access point (AP) is any entity that has STA functionality and enables access to the DS, via the WM for

associated STAs.

See, e.g., 802.11-2007 § 5.2.3

5.3.2 DSS

The service provided by the DS is known as the DSS.

This service is represented in the IEEE 802.11 architecture by arrows within the APs, indicating that the

service is used to cross media and possibly address space logical boundaries. An AP is a logical entity, and

the functions described may be shared by one or more physical entities.

The services that comprise the DSS are as follows:

a) Association

b) Disassociation

c) Distribution

d) Integration

e) Reassociation

f) QoS traffic scheduling (QoS facility only)

DSSs are specified for use by MAC sublayer entities.

Figure 5-7 combines the components from previous figures with both types of services to show the complete

IEEE 802.11 architecture.

See, e.g., 802.11-2007 § 5.3.2

5.4.4.1 TPC

Radio regulations may require radio local area networks (RLANs) operating in the 5 GHz band to use

transmitter power control, involving specification of a regulatory maximum transmit power and a mitigation

requirement for each allowed channel, to reduce interference with satellite services. The TPC service is used

to satisfy this regulatory requirement.

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 397 of 946 PageID #:

4501
397

Claim 10 of the ’802 Patent Prior Art Reference – 802.11-2007

The TPC service provides for the following:

— Association of STAs with an AP in a BSS based on the STAs’ power capability.

— Specification of regulatory and local maximum transmit power levels for the current channel.

— Selection of a transmit power for each transmission in a channel within constrain ts imposed by

regulatory requirements.

— Adaptation of transmit power based on a range of information, including path loss and link margin

estimates.

See, e.g., 802.11-2007 § 5.4.4.1

7.3.2.20 Channel Switch Announcement element

The Channel Switch Announcement element is used by an AP in a BSS or a STA in an IBSS to advertise

when it is changing to a new channel and the channel number of the new channel. The format of the Channel

Switch Announcement element is shown in Figure 7-57.

See, e.g., 802.11-2007 § 7.3.2.20

10.3.11 Spectrum management protocol layer model

The layer management extensions for measurement and channel switching assume a certain partition

of spectrum management functionality between the MLME and SME. This partitioning assumes that

policy decisions (e.g., regarding measurement and channel switching) reside in the SME, while the protocol

for measurement, switch timing, and the associated frame exchanges resides within the MLME (see

Figure 10-2).

...

The informative diagrams within this subclause further illustrate the spectrum management protocol model

adopted. Figure 10-3 and Figure 10-4 depict the measurement process for a peer STA to accept and reject a

measurement request, respectively. Figure 10-5 illustrates the TPC adaptation process. Lastly, Figure 10-6

depicts the management process for a channel switch using a Channel Switch Announcement frame.

See, e.g., 802.11-2007 § 10.3.11

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 398 of 946 PageID #:

4502
398

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 399 of 946 PageID #:

4503
399

Claim 10 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 § 10.4.3.2

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 400 of 946 PageID #:

4504
400

Claim 10 of the ’802 Patent Prior Art Reference – 802.11-2007

17.1 Introduction

This clause specifies the PHY entity for an orthogonal frequency division multiplexing (OFDM) system.

The OFDM system provides a WLAN with data payload communication capabilities of 6, 9, 12, 18, 24, 36,

48, and 54 Mb/s. The support of transmitting and receiving at data rates of 6, 12, and 24 Mb/s is mandatory.

The system uses 52 subcarriers that are modulated using binary or quadrature phase shift keying (BPSK or

QPSK) or using 16- or 64-quadrature amplitude modulation (16-QAM or 64-QAM). Forward error

correction coding (convolutional coding) is used with a coding rate of 1/2, 2/3, or 3/4.

The OFDM system also provides a “half-clocked” operation using 10 MHz channel spacings with data

communications capabilities of 3, 4.5, 6, 9, 12, 18, 24, and 27 Mb/s. The support of transmitting and

receiving at data rates of 3, 6, and 12 Mb/s is mandatory when using 10 MHz channel spacing. The halfclocked

operation doubles symbol times and clear channel assessment (CCA) times when using 10 MHz

channel spacing. The regulatory requirements and information regarding use of this OFDM system in

4.9 GHz and 5 GHz bands is in Annex I and Annex J.

The OFDM system also provides a “quarter-clocked” operation using 5 MHz channel spacing with data

communication capabilities of 1.5, 2.25, 3, 4.5, 6, 9, 12, and 13.5 Mb/s. The support of transmitting and

receiving at data rates of 1.5, 3, and 6 Mb/s is mandatory when using 5 MHz channel spacing. The quarterclocked

operation quadruples symbol times and CCA times when using 5 MHz channel spacing. The

regulatory requirements and information regarding use of this OFDM system in the 4.9 GHz band is in

Annex I and Annex J.

See, e.g., 802.11-2007 § 17.1

17.3.2.1 Overview of the PPDU encoding process

The encoding process is composed of many detailed steps, which are described fully in later subclauses, as

noted below. The following overview intends to facilitate understanding the details of the convergence

procedure:

a) Produce the PLCP Preamble field, composed of 10 repetitions of a “short training sequence” (used

for AGC convergence, diversity selection, timing acquisition, and coarse frequency acquisition in

the receiver) and two repetitions of a “long training sequence” (used for channel estimation and fine

frequency acquisition in the receiver), preceded by a guard interval (GI). Refer to 17.3.3 for details.

b) Produce the PLCP header field from the RATE, LENGTH, and SERVICE fields of the

TXVECTOR by filling the appropriate bit fields. The RATE and LENGTH fields of the PLCP

header are encoded by a convolutional code at a rate of R = 1/2, and are subsequently mapped onto a

single BPSK encoded OFDM symbol, denoted as the SIGNAL symbol. In order to facilitate a

reliable and timely detection of the RATE and LENGTH fields, 6 zero tail bits are inserted into the

PLCP header. The encoding of the SIGNAL field into an OFDM symbol follows the same steps for

convolutional encoding, interleaving, BPSK modulation, pilot insertion, Fourier transform, and

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 401 of 946 PageID #:

4505
401

Claim 10 of the ’802 Patent Prior Art Reference – 802.11-2007

prepending a GI as described subsequently for data transmission with BPSK-OFDM modulated at

coding rate 1/2. The contents of the SIGNAL field are not scrambled. Refer to 17.3.4 for details.

c) Calculate from RATE field of the TXVECTOR the number of data bits per OFDM symbol (NDBPS),

the coding rate (R), the number of bits in each OFDM subcarrier (NBPSC), and the number of coded

bits per OFDM symbol (NCBPS). Refer to 17.3.2.2 for details.

d) Append the PSDU to the SERVICE field of the TXVECTOR. Extend the resulting bit string with

zero bits (at least 6 bits) so that the resulting length will be a multiple of NDBPS. The resulting bit

string constitutes the DATA part of the packet. Refer to 17.3.5.3 for details.

e) Initiate the scrambler with a pseudo-random nonzero seed, generate a scrambling sequence, and

XOR it with the extended string of data bits. Refer to 17.3.5.4 for details.

f) Replace the six scrambled zero bits following the data with six nonscrambled zero bits. (Those bits

return the convolutional encoder to the zero state and are denoted as tail bits.) Refer to 17.3.5 .2 for

details.

g) Encode the extended, scrambled data string with a convolutional encoder (R = 1/2). Omit (puncture)

some of the encoder output string (chosen according to “puncturing pattern”) to reach the desired

“coding rate.” Refer to 17.3.5.5 for details.

h) Divide the encoded bit string into groups of NCBPS bits. Within each group, perform an

“interleaving” (reordering) of the bits according to a rule corresponding to the desired RATE. Refer

to 17.3.5.6 for details.

i) Divide the resulting coded and interleaved data string into groups of NCBPS bits. For each of the bit

groups, convert the bit group into a complex number according to the modulation encoding tables.

Refer to 17.3.5.7 for details.

j) Divide the complex number string into groups of 48 complex numbers. Each such group will be

associated with one OFDM symbol. In each group, the complex numbers will be numbered 0 to 47

and mapped hereafter into OFDM subcarriers numbered –26 to –22, –20 to –8, –6 to –1, 1 to 6,

8 to 20, and 22 to 26. The subcarriers –21, –7, 7, and 21 are skipped and, subsequently, used for

inserting pilot subcarriers. The 0 subcarrier, associated with center frequency, is omitted and filled

with zero value. Refer to 17.3.5.9 for details.

k) Four subcarriers are inserted as pilots into positions –21, –7, 7, and 21. The total number of the

subcarriers is 52 (48 + 4). Refer to 17.3.5.8 for details.

l) For each group of subcarriers –26 to 26, convert the subcarriers to time domain using inverse

Fourier transform. Prepend to the Fourier-transformed waveform a circular extension of itself thus

forming a GI, and truncate the resulting periodic waveform to a single OFDM symbol length by

applying time domain windowing. Refer to 17.3.5.9 for details.

m) Append the OFDM symbols one after another, starting after the SIGNAL symbol describing the

RATE and LENGTH fields. Refer to 17.3.5.9 for details.

n) Up-convert the resulting “complex baseband” waveform to an RF according to the center frequency

of the desired channel and transmit. Refer to 17.3.2.4 and 17.3.8.1 for details.

An illustration of the transmitted frame and its parts appears in Figure 17-4 (in 17.3.3).

See, e.g., 802.11-2007 § 17.3.2.1

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 402 of 946 PageID #:

4506
402

Claim 10 of the ’802 Patent Prior Art Reference – 802.11-2007

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 403 of 946 PageID #:

4507
403

Claim 10 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 § 17.3.2.3

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 404 of 946 PageID #:

4508
404

Claim 10 of the ’802 Patent Prior Art Reference – 802.11-2007

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 405 of 946 PageID #:

4509
405

Claim 10 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 § 17.3.2.4 Eq. (17-1)

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 406 of 946 PageID #:

4510
406

Claim 10 of the ’802 Patent Prior Art Reference – 802.11-2007

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 407 of 946 PageID #:

4511
407

Claim 10 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 § 17.3.2.5

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 408 of 946 PageID #:

4512
408

Claim 10 of the ’802 Patent Prior Art Reference – 802.11-2007

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 409 of 946 PageID #:

4513
409

See, e.g., 802.11-2007 § 17.3.3

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 410 of 946 PageID #:

4514
410

Claim 10 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 § 17.3.5.7

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 411 of 946 PageID #:

4515
411

Claim 10 of the ’802 Patent Prior Art Reference – 802.11-2007

17.3.5.8 Pilot subcarriers

In each OFDM symbol, four of the subcarriers are dedicated to pilot signals in order to make the coherent

detection robust against frequency offsets and phase noise. These pilot signals shall be put in subcarriers

–21, –7, 7, and 21. The pilots shall be BPSK modulated by a pseudo-binary sequence to prevent the

generation of spectral lines. The contribution of the pilot subcarriers to each OFDM symbol is described in

17.3.5.9.

See, e.g., 802.11-2007 § 17.3.5.8

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 412 of 946 PageID #:

4516
412

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 413 of 946 PageID #:

4517
413

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 414 of 946 PageID #:

4518
414

Claim 10 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 § 17.3.5.9

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 415 of 946 PageID #:

4519
415

Claim 10 of the ’802 Patent Prior Art Reference – 802.11-2007

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 416 of 946 PageID #:

4520
416

Claim 10 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 § 17.3.8.1

17.3.8.3.1 Operating frequency range

The OFDM PHY shall operate in the 5 GHz band, as allocated by a regulatory body in its operational region.

Spectrum allocation in the 5 GHz band is subject to authorities responsible for geographic-specific

regulatory domains (e.g., global, regional, and national). The particular channelization to be used for this

standard is dependent on such allocation, as well as the associated regulations for use of the allocations.

These regulations are subject to revision, or may be superseded.

In some regulatory domains, several frequency bands may be available for OFDM PHY-based WLANs.

These bands may be contiguous or not, and different regulatory limits may be applicable. A compliant

OFDM PHY shall support at least one frequency band in at least one regulatory domain. The support of

specific regulatory domains, and bands within the domains, shall be indicated by PLME attributes

dot11RegDomainsSupported and dot11FrequencyBandsSupported.

See, e.g., 802.11-2007 § 17.3.8.3.1

17.3.9.1 Transmit power levels

The maximum allowable transmit power by regulatory domain is defined in Annex I.

See, e.g., 802.11-2007 § 17.3.9.1

17.3.9.6.2 Transmitter spectral flatness

The average energy of the constellations in each of the spectral lines –16.. –1 and +1.. +16 will deviate no

more than ± 2 dB from their average energy. The average energy of the constellations in each of the spectral

lines –26.. –17 and +17.. +26 will deviate no more than +2/–4 dB from the average energy of spectral lines

–16.. –1 and +1.. +16. The data for this test shall be derived from the channel estimation step.

See, e.g., 802.11-2007 § 17.3.9.6.2

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 417 of 946 PageID #:

4521
417

Claim 10 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 § I.2.2

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 418 of 946 PageID #:

4522
418

Claim 10 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 § I.2.3

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 419 of 946 PageID #:

4523
419

Claim 10 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 Figure 5-7

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 420 of 946 PageID #:

4524
420

Claim 10 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 Figure 10-6

Furthermore, this claim element is obvious in light of 802.11-2007 itself, when combined with any of 

the other references as charted for this claim element in Exs. A-1–A-31, First Supplemental Ex. ACase 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 421 of 946 PageID #:

4525
421

Claim 10 of the ’802 Patent Prior Art Reference – 802.11-2007

Obviousness 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,

802.11-2007 discloses “transmitting the amplified combined up-converted signal on a first antenna.” 

See, e.g.: 

1.1 Scope

The scope of this standard is to define one medium access control (MAC) and several physical layer (PHY)

specifications for wireless connectivity for fixed, portable, and moving stations (STAs) within a local area.

See, e.g., 802.11-2007 § 1.1

5.1.1 How WLAN systems are different

Wireless networks have fundamental characteristics that make them significantly different from traditional

wired LANs. Some countries impose specific requirements for radio equipment in addition to those

specified in this standard. This standard does not provide information to meet these country-specific radio

regulations.

5.1.1.1 Destination address does not equal destination location

In wired LANs, an address is equivalent to a physical location. This is implicitly assumed in the design of

wired LANs. In IEEE Std 802.11, the addressable unit is a station (STA). The STA is a message destination,

but not (in general) a fixed location.

5.1.1.2 Media impact on design and performance

The PHYs used in IEEE Std 802.11 are fundamentally different from wired media. Thus IEEE 802.11 PHYs

a) Use a medium that has neither absolute nor readily observable boundaries outside of which STAs

with conformant PHY transceivers are known to be unable to receive network frames

b) Are unprotected from other signals that may be sharing the medium

c) Communicate over a medium significantly less reliable than wired PHYs

d) Have dynamic topologies

e) Lack full connectivity, and therefore the assumption normally made that every STA can hear every

other STA is invalid (i.e., STAs may be “hidden” from each other)

f) Have time-varying and asymmetric propagation properties

g) May experience interference from logically disjoint IEEE 802.11 networks operating in overlapping

areas

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 422 of 946 PageID #:

4526
422

Claim 10 of the ’802 Patent Prior Art Reference – 802.11-2007

Because of limitations on wireless PHY ranges, WLANs intended to cover reasonable geographic distances

may be built from basic coverage building blocks. When providing QoS services it should be understood

that the MAC endeavors to provide QoS “service guarantees” within the limitations of the medium

properties identified above. In other words, particularly in unlicensed spectrum, true guarantees are often not

possible. However, gradations of service are always possible; and in sufficiently controlled environments,

QoS guarantees can truly be made.

5.1.1.3 The impact of handling mobile STAs

One of the requirements of IEEE Std 802.11 is to handle mobile as well as portable STAs. A portable STA

is one that is moved from location to location, but that is only used while at a fixed location. Mobile STAs

actually access the LAN while in motion.

For technical reasons, it is not sufficient to handle only portable STAs. Propagation effects blur the

distinction between portable and mobile STAs; stationary STAs often appear to be mobile due to

propagation effects.

Another aspect of mobile STAs is that they may often be battery powered. Hence power management is

an important consideration. For example, it cannot be presumed that a STA’s receiver will always be

powered on.

See, e.g., 802.11-2007 § 5.1.1 - § 5.1.1.3

5.2 Components of the IEEE 802.11 architecture

The IEEE 802.11 architecture consists of several components that interact to provide a WLAN that supports

STA mobility transparently to upper layers.

The basic service set (BSS) is the basic building block of an IEEE 802.11 LAN. Figure 5-1 shows two BSSs,

each of which has two STAs that are members of the BSS.

It is useful to think of the ovals used to depict a BSS as the coverage area within which the member STAs of

the BSS may remain in communication. (The concept of area, while not precise, is often good enough.) This

area is called the Basic Service Area (BSA). If a STA moves out of its BSA, it can no longer directly

communicate with other STAs present in the BSA.

See, e.g., 802.11-2007 § 5.2

5.2.3 Distribution system (DS) concepts

PHY limitations determine the direct station-to-station distance that may be supported. For some networks

this distance is sufficient; for other networks, increased coverage is required.

Instead of existing independently, a BSS may also form a component of an extended form of network that is

built with multiple BSSs. The architectural component used to interconnect BSSs is the DS.

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 423 of 946 PageID #:

4527
423

Claim 10 of the ’802 Patent Prior Art Reference – 802.11-2007

IEEE Std 802.11 logically separates the WM from the distribution system medium (DSM). Each logical

medium is used for different purposes, by a different component of the architecture. The IEEE 802.11

definitions neither preclude, nor demand, that the multiple media be either the same or different.

Recognizing that the multiple media are logically different is key to understanding the flexibility of the

architecture. The IEEE 802.11 LAN architecture is specified independently of the physical characteristics of

any specific implementation.

The DS enables mobile device support by providing the logical services necessary to handle address to

destination mapping and seamless integration of multiple BSSs.

An access point (AP) is any entity that has STA functionality and enables access to the DS, via the WM for

associated STAs.

See, e.g., 802.11-2007 § 5.2.3

5.3.2 DSS

The service provided by the DS is known as the DSS.

This service is represented in the IEEE 802.11 architecture by arrows within the APs, indicating that the

service is used to cross media and possibly address space logical boundaries. An AP is a logical entity, and

the functions described may be shared by one or more physical entities.

The services that comprise the DSS are as follows:

a) Association

b) Disassociation

c) Distribution

d) Integration

e) Reassociation

f) QoS traffic scheduling (QoS facility only)

DSSs are specified for use by MAC sublayer entities.

Figure 5-7 combines the components from previous figures with both types of services to show the complete

IEEE 802.11 architecture.

See, e.g., 802.11-2007 § 5.3.2

5.4.4.1 TPC

Radio regulations may require radio local area networks (RLANs) operating in the 5 GHz band to use

transmitter power control, involving specification of a regulatory maximum transmit power and a mitigation

requirement for each allowed channel, to reduce interference with satellite services. The TPC service is used

to satisfy this regulatory requirement.

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 424 of 946 PageID #:

4528
424

Claim 10 of the ’802 Patent Prior Art Reference – 802.11-2007

The TPC service provides for the following:

— Association of STAs with an AP in a BSS based on the STAs’ power capability.

— Specification of regulatory and local maximum transmit power levels for the current channel.

— Selection of a transmit power for each transmission in a channel within constraints imposed by

regulatory requirements.

— Adaptation of transmit power based on a range of information, including path loss and link margin

estimates.

See, e.g., 802.11-2007 § 5.4.4.1

7.3.2.20 Channel Switch Announcement element

The Channel Switch Announcement element is used by an AP in a BSS or a STA in an IBSS to advertise

when it is changing to a new channel and the channel number of the new channel. The format of the Channel

Switch Announcement element is shown in Figure 7-57.

See, e.g., 802.11-2007 § 7.3.2.20

10.3.11 Spectrum management protocol layer model

The layer management extensions for measurement and channel switching assume a certain partition

of spectrum management functionality between the MLME and SME. This partitioning assumes that

policy decisions (e.g., regarding measurement and channel switching) reside in the SME, while the protocol

for measurement, switch timing, and the associated frame exchanges resides within the MLME (see

Figure 10-2).

...

The informative diagrams within this subclause further illustrate the spectrum management protocol model

adopted. Figure 10-3 and Figure 10-4 depict the measurement process for a peer STA to accept and reject a

measurement request, respectively. Figure 10-5 illustrates the TPC adaptation process. Lastly, Figure 10-6

depicts the management process for a channel switch using a Channel Switch Announcement frame.

See, e.g., 802.11-2007 § 10.3.11

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 425 of 946 PageID #:

4529
425

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 426 of 946 PageID #:

4530
426

Claim 10 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 § 10.4.3.2

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 427 of 946 PageID #:

4531
427

Claim 10 of the ’802 Patent Prior Art Reference – 802.11-2007

17.1 Introduction

This clause specifies the PHY entity for an orthogonal frequency division multiplexing (OFDM) system.

The OFDM system provides a WLAN with data payload communication capabilities of 6, 9, 12, 18, 24, 36,

48, and 54 Mb/s. The support of transmitting and receiving at data rates of 6, 12, and 24 Mb/s is mandatory.

The system uses 52 subcarriers that are modulated using binary or quadrature phase shift keying (BPSK or

QPSK) or using 16- or 64-quadrature amplitude modulation (16-QAM or 64-QAM). Forward error

correction coding (convolutional coding) is used with a coding rate of 1/2, 2 /3, or 3/4.

The OFDM system also provides a “half-clocked” operation using 10 MHz channel spacings with data

communications capabilities of 3, 4.5, 6, 9, 12, 18, 24, and 27 Mb/s. The support of transmitting and

receiving at data rates of 3, 6, and 12 Mb/s is mandatory when using 10 MHz channel spacing. The halfclocked

operation doubles symbol times and clear channel assessment (CCA) times when using 10 MHz

channel spacing. The regulatory requirements and information regarding use of this OFDM system in

4.9 GHz and 5 GHz bands is in Annex I and Annex J.

The OFDM system also provides a “quarter-clocked” operation using 5 MHz channel spacing with data

communication capabilities of 1.5, 2.25, 3, 4.5, 6, 9, 12, and 13.5 Mb/s. The support of transmitting and

receiving at data rates of 1.5, 3, and 6 Mb/s is mandatory when using 5 MHz channel spacing. The quarterclocked

operation quadruples symbol times and CCA times when using 5 MHz channel spacing. The

regulatory requirements and information regarding use of this OFDM system in the 4.9 GHz band is in

Annex I and Annex J.

See, e.g., 802.11-2007 § 17.1

17.3.2.1 Overview of the PPDU encoding process

The encoding process is composed of many detailed steps, which are described fully in later subclauses, as

noted below. The following overview intends to facilitate understanding the details of the convergence

procedure:

a) Produce the PLCP Preamble field, composed of 10 repetitions of a “short training sequence” (used

for AGC convergence, diversity selection, timing acquisition, and coarse frequency acquisition in

the receiver) and two repetitions of a “long training sequence” (used for channel estimation and fine

frequency acquisition in the receiver), preceded by a guard interval (GI). Refer to 17.3.3 for details.

b) Produce the PLCP header field from the RATE, LENGTH, and SERVICE fields of the

TXVECTOR by filling the appropriate bit fields. The RATE and LENGTH fields of the PLCP

header are encoded by a convolutional code at a rate of R = 1/2, and are subsequently mapped onto a

single BPSK encoded OFDM symbol, denoted as the SIGNAL symbol. In order to facilitate a

reliable and timely detection of the RATE and LENGTH fields, 6 zero tail bits are inserted into the

PLCP header. The encoding of the SIGNAL field into an OFDM symbol follows the same steps for

convolutional encoding, interleaving, BPSK modulation, pilot insertion, Fourier transform, and

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 428 of 946 PageID #:

4532
428

Claim 10 of the ’802 Patent Prior Art Reference – 802.11-2007

prepending a GI as described subsequently for data transmission with BPSK-OFDM modulated at

coding rate 1/2. The contents of the SIGNAL field are not scrambled. Refer to 17.3.4 for details.

c) Calculate from RATE field of the TXVECTOR the number of data bits per OFDM symbol (NDBPS),

the coding rate (R), the number of bits in each OFDM subcarrier (NBPSC), and the number of coded

bits per OFDM symbol (NCBPS). Refer to 17.3.2.2 for details.

d) Append the PSDU to the SERVICE field of the TXVECTOR. Extend the resulting bit string with

zero bits (at least 6 bits) so that the resulting length will be a multiple of NDBPS. The resulting bit

string constitutes the DATA part of the packet. Refer to 17.3.5.3 for details.

e) Initiate the scrambler with a pseudo-random nonzero seed, generate a scrambling sequence, and

XOR it with the extended string of data bits. Refer to 17.3.5.4 for details.

f) Replace the six scrambled zero bits following the data with six nonscrambled zero bits. (Those bits

return the convolutional encoder to the zero state and are denoted as tail bits.) Refer to 17.3.5.2 for

details.

g) Encode the extended, scrambled data string with a convolutional encoder (R = 1/2). Omit (puncture)

some of the encoder output string (chosen according to “puncturing pattern”) to reach the desired

“coding rate.” Refer to 17.3.5.5 for details.

h) Divide the encoded bit string into groups of NCBPS bits. Within each group, perform an

“interleaving” (reordering) of the bits according to a rule corresponding to the desired RATE. Refer

to 17.3.5.6 for details.

i) Divide the resulting coded and interleaved data string into groups of NCBPS bits. For each of the bit

groups, convert the bit group into a complex number according to the modulation encoding tables.

Refer to 17.3.5.7 for details.

j) Divide the complex number string into groups of 48 complex numbers. Each such group will be

associated with one OFDM symbol. In each group, the complex numbers will be numbered 0 to 47

and mapped hereafter into OFDM subcarriers numbered –26 to –22, –20 to –8, –6 to –1, 1 to 6,

8 to 20, and 22 to 26. The subcarriers –21, –7, 7, and 21 are skipped and, subsequently, used for

inserting pilot subcarriers. The 0 subcarrier, associated with center frequency, is omitted and filled

with zero value. Refer to 17.3.5.9 for details.

k) Four subcarriers are inserted as pilots into positions –21, –7, 7, and 21. The total number of the

subcarriers is 52 (48 + 4). Refer to 17.3.5.8 for details.

l) For each group of subcarriers –26 to 26, convert the subcarriers to time domain using inverse

Fourier transform. Prepend to the Fourier-transformed waveform a circular extension of itself thus

forming a GI, and truncate the resulting periodic waveform to a single OFDM symbol length by

applying time domain windowing. Refer to 17.3.5.9 for details.

m) Append the OFDM symbols one after another, starting after the SIGNAL symbol describing the

RATE and LENGTH fields. Refer to 17.3.5.9 for details.

n) Up-convert the resulting “complex baseband” waveform to an RF according to the center frequency

of the desired channel and transmit. Refer to 17.3.2.4 and 17.3.8.1 for details.

An illustration of the transmitted frame and its parts appears in Figure 17-4 (in 17.3.3).

See, e.g., 802.11-2007 § 17.3.2.1

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 429 of 946 PageID #:

4533
429

Claim 10 of the ’802 Patent Prior Art Reference – 802.11-2007

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 430 of 946 PageID #:

4534
430

Claim 10 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 § 17.3.2.3

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 431 of 946 PageID #:

4535
431

Claim 10 of the ’802 Patent Prior Art Reference – 802.11-2007

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 432 of 946 PageID #:

4536
432

Claim 10 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 § 17.3.2.4 Eq. (17-1)

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 433 of 946 PageID #:

4537
433

Claim 10 of the ’802 Patent Prior Art Reference – 802.11-2007

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 434 of 946 PageID #:

4538
434

Claim 10 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 § 17.3.2.5

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 435 of 946 PageID #:

4539
435

Claim 10 of the ’802 Patent Prior Art Reference – 802.11-2007

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 436 of 946 PageID #:

4540
436

See, e.g., 802.11-2007 § 17.3.3

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 437 of 946 PageID #:

4541
437

Claim 10 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 § 17.3.5.7

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 438 of 946 PageID #:

4542
438

Claim 10 of the ’802 Patent Prior Art Reference – 802.11-2007

17.3.5.8 Pilot subcarriers

In each OFDM symbol, four of the subcarriers are dedicated to pilot signals in order to make the coherent

detection robust against frequency offsets and phase noise. These pilot signals shall be put in subcarriers

–21, –7, 7, and 21. The pilots shall be BPSK modulated by a pseudo-binary sequence to prevent the

generation of spectral lines. The contribution of the pilot subcarriers to each OFDM symbol is described in

17.3.5.9.

See, e.g., 802.11-2007 § 17.3.5.8

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 439 of 946 PageID #:

4543
439

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 440 of 946 PageID #:

4544
440

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 441 of 946 PageID #:

4545
441

Claim 10 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 § 17.3.5.9

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 442 of 946 PageID #:

4546
442

Claim 10 of the ’802 Patent Prior Art Reference – 802.11-2007

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 443 of 946 PageID #:

4547
443

Claim 10 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 § 17.3.8.1

17.3.8.3.1 Operating frequency range

The OFDM PHY shall operate in the 5 GHz band, as allocated by a regulatory body in its operational region.

Spectrum allocation in the 5 GHz band is subject to authorities responsible for geographic-specific

regulatory domains (e.g., global, regional, and national). The particular channelization to be used for this

standard is dependent on such allocation, as well as the associated regulations for use of the allocations.

These regulations are subject to revision, or may be superseded.

In some regulatory domains, several frequency bands may be available for OFDM PHY-based WLANs.

These bands may be contiguous or not, and different regulatory limits may be applicable. A compliant

OFDM PHY shall support at least one frequency band in at least one regulatory domain. The support of

specific regulatory domains, and bands within the domains, shall be indicated by PLME attributes

dot11RegDomainsSupported and dot11FrequencyBandsSupported.

See, e.g., 802.11-2007 § 17.3.8.3.1

17.3.9.1 Transmit power levels

The maximum allowable transmit power by regulatory domain is defined in Annex I.

See, e.g., 802.11-2007 § 17.3.9.1

17.3.9.6.2 Transmitter spectral flatness

The average energy of the constellations in each of the spectral lines –16.. –1 and +1.. +16 will deviate no

more than ± 2 dB from their average energy. The average energy of the constellations in each of the spectral

lines –26.. –17 and +17.. +26 will deviate no more than +2/–4 dB from the average energy of spectral lines

–16.. –1 and +1.. +16. The data for this test shall be derived from the channel estimation step.

See, e.g., 802.11-2007 § 17.3.9.6.2

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 444 of 946 PageID #:

4548
444

Claim 10 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 § I.2.2

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 445 of 946 PageID #:

4549
445

Claim 10 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 § I.2.3

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 446 of 946 PageID #:

4550
446

Claim 10 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 Figure 5-7

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 447 of 946 PageID #:

4551
447

Claim 10 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 Figure 10-6

Furthermore, this claim element is obvious in light of 802.11-2007 itself, when combined with any of 

the other references as charted for this claim element in Exs. A-1–A-31, First Supplemental Ex. ACase 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 448 of 946 PageID #:

4552
448

Claim 10 of the ’802 Patent Prior Art Reference – 802.11-2007

Obviousness 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.

802.11-2007 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 59-13 Filed 07/11/24 Page 449 of 946 PageID #:

4553
449

Claim 10 of the ’802 Patent Prior Art Reference – 802.11-2007

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 450 of 946 PageID #:

4554
450

Claim 10 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 § 17.3.8.1

17.3.2.1 Overview of the PPDU encoding process

The encoding process is composed of many detailed steps, which are described fully in later subclauses, as

noted below. The following overview intends to facilitate understanding the details of the convergence

procedure:

a) Produce the PLCP Preamble field, composed of 10 repetitions of a “short training sequence” (used

for AGC convergence, diversity selection, timing acquisition, and coarse frequency acquisition in

the receiver) and two repetitions of a “long training sequence” (used for channel estimation and fine

frequency acquisition in the receiver), preceded by a guard interval (GI). Refer to 17.3.3 for details.

b) Produce the PLCP header field from the RATE, LENGTH, and SERVICE fields of the

TXVECTOR by filling the appropriate bit fields. The RATE and LENGTH fields of the PLCP

header are encoded by a convolutional code at a rate of R = 1/2, and are subsequently mapped onto a

single BPSK encoded OFDM symbol, denoted as the SIGNAL symbol. In order to facilitate a

reliable and timely detection of the RATE and LENGTH fields, 6 zero tail bits are inserted into the

PLCP header. The encoding of the SIGNAL field into an OFDM symbol follows the same steps for

convolutional encoding, interleaving, BPSK modulation, pilot insertion, Fourier transform, and

prepending a GI as described subsequently for data transmission with BPSK-OFDM modulated at

coding rate 1/2. The contents of the SIGNAL field are not scrambled. Refer to 17.3 .4 for details.

c) Calculate from RATE field of the TXVECTOR the number of data bits per OFDM symbol (NDBPS),

the coding rate (R), the number of bits in each OFDM subcarrier (NBPSC), and the number of coded

bits per OFDM symbol (NCBPS). Refer to 17.3.2.2 for details.

d) Append the PSDU to the SERVICE field of the TXVECTOR. Extend the resulting bit string with

zero bits (at least 6 bits) so that the resulting length will be a multiple of NDBPS. The resulting bit

string constitutes the DATA part of the packet. Refer to 17.3.5.3 for details.

e) Initiate the scrambler with a pseudo-random nonzero seed, generate a scrambling sequence, and

XOR it with the extended string of data bits. Refer to 17.3.5.4 for details.

f) Replace the six scrambled zero bits following the data with six nonscrambled zero bits. (Those bits

return the convolutional encoder to the zero state and are denoted as tail bits.) Refer to 17.3.5.2 for

details.

g) Encode the extended, scrambled data string with a convolutional encoder (R = 1/2). Omit (puncture)

some of the encoder output string (chosen according to “puncturing pattern”) to reach the desired

“coding rate.” Refer to 17.3.5.5 for details.

h) Divide the encoded bit string into groups of NCBPS bits. Within each group, perform an

“interleaving” (reordering) of the bits according to a rule corresponding to the desired RATE. Refer

to 17.3.5.6 for details.

i) Divide the resulting coded and interleaved data string into groups of NCBPS bits. For each of the bit

groups, convert the bit group into a complex number according to the modulation encoding tables.

Refer to 17.3.5.7 for details.

j) Divide the complex number string into groups of 48 complex numbers. Each such group will be

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 451 of 946 PageID #:

4555
451

Claim 10 of the ’802 Patent Prior Art Reference – 802.11-2007

associated with one OFDM symbol. In each group, the complex numbers will be numbered 0 to 47

and mapped hereafter into OFDM subcarriers numbered –26 to –22, –20 to –8, –6 to –1, 1 to 6,

8 to 20, and 22 to 26. The subcarriers –21, –7, 7, and 21 are skipped and, subsequently, used for

inserting pilot subcarriers. The 0 subcarrier, associated with center frequency, is omitted and filled

with zero value. Refer to 17.3.5.9 for details.

k) Four subcarriers are inserted as pilots into positions –21, –7, 7, and 21. The total number of the

subcarriers is 52 (48 + 4). Refer to 17.3.5.8 for details.

l) For each group of subcarriers –26 to 26, convert the subcarriers to time domain using inverse

Fourier transform. Prepend to the Fourier-transformed waveform a circular extension of itself thus

forming a GI, and truncate the resulting periodic waveform to a single OFDM symbol length by

applying time domain windowing. Refer to 17.3.5.9 for details.

m) Append the OFDM symbols one after another, starting after the SIGNAL symbol describing the

RATE and LENGTH fields. Refer to 17.3.5.9 for details.

n) Up-convert the resulting “complex baseband” waveform to an RF according to the center frequency

of the desired channel and transmit. Refer to 17.3.2.4 and 17.3.8.1 for details.

An illustration of the transmitted frame and its parts appears in Figure 17-4 (in 17.3.3).

See, e.g., 802.11-2007 § 17.3.2.1

17.3.9.6.2 Transmitter spectral flatness

The average energy of the constellations in each of the spectral lines –16.. –1 and +1.. +16 will deviate no

more than ± 2 dB from their average energy. The average energy of the constellations in each of the spectral

lines –26.. –17 and +17.. +26 will deviate no more than +2/–4 dB from the average energy of spectral lines

–16.. –1 and +1.. +16. The data for this test shall be derived from the channel estimation step.

See, e.g., 802.11-2007 § 17.3.9.6.2

Furthermore, this claim element is obvious in light of 802.11-2007 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.

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 452 of 946 PageID #:

4556
452

Claim 13 of the ’802 Patent Prior Art Reference – 802.11-2007

[13.1] The method of claim 10 802.11-2007 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.

802.11-2007 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.” See, e.g.: 

1.1 Scope

The scope of this standard is to define one medium access control (MAC) and s everal physical layer (PHY)

specifications for wireless connectivity for fixed, portable, and moving stations (STAs) within a local area.

See, e.g., 802.11-2007 § 1.1

5.1.1 How WLAN systems are different

Wireless networks have fundamental characteristics that make them significantly different from traditional

wired LANs. Some countries impose specific requirements for radio equipment in addition to those

specified in this standard. This standard does not provide information to meet these co untry-specific radio

regulations.

5.1.1.1 Destination address does not equal destination location

In wired LANs, an address is equivalent to a physical location. This is implicitly assumed in the design of

wired LANs. In IEEE Std 802.11, the addressable unit is a station (STA). The STA is a message destination,

but not (in general) a fixed location.

5.1.1.2 Media impact on design and performance

The PHYs used in IEEE Std 802.11 are fundamentally different from wired media. Thus IEEE 802.11 PHYs

a) Use a medium that has neither absolute nor readily observable boundaries outside of which STAs

with conformant PHY transceivers are known to be unable to receive network frames

b) Are unprotected from other signals that may be sharing the medium

c) Communicate over a medium significantly less reliable than wired PHYs

d) Have dynamic topologies

e) Lack full connectivity, and therefore the assumption normally made that every STA can hear every

other STA is invalid (i.e., STAs may be “hidden” from each other)

f) Have time-varying and asymmetric propagation properties

g) May experience interference from logically disjoint IEEE 802.11 networks operating in overlapping

areas

Because of limitations on wireless PHY ranges, WLANs intended to cover reasonable geographic distances

may be built from basic coverage building blocks. When providing QoS services it should be understood

that the MAC endeavors to provide QoS “service guarantees” within the limitations of the medium

properties identified above. In other words, particularly in unlicensed spectrum, true guarantees are often not

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 453 of 946 PageID #:

4557
453

Claim 13 of the ’802 Patent Prior Art Reference – 802.11-2007

possible. However, gradations of service are always possible; and in sufficiently controlled environments,

QoS guarantees can truly be made.

5.1.1.3 The impact of handling mobile STAs

One of the requirements of IEEE Std 802.11 is to handle mobile as well as portable STAs. A portable STA

is one that is moved from location to location, but that is only used while at a fixed location. Mobile STAs

actually access the LAN while in motion.

For technical reasons, it is not sufficient to handle only portable STAs. Propagation effects blur the

distinction between portable and mobile STAs; stationary STAs often appear to be mobile due to

propagation effects.

Another aspect of mobile STAs is that they may often be battery powered. Hence power management is

an important consideration. For example, it cannot be presumed that a STA’s receiver will always be

powered on.

See, e.g., 802.11-2007 § 5.1.1 - § 5.1.1.3

5.2 Components of the IEEE 802.11 architecture

The IEEE 802.11 architecture consists of several components that interact to provide a WLAN that supports

STA mobility transparently to upper layers.

The basic service set (BSS) is the basic building block of an IEEE 802.11 LAN. Figure 5 -1 shows two BSSs,

each of which has two STAs that are members of the BSS.

It is useful to think of the ovals used to depict a BSS as the coverage area within which the member STAs of

the BSS may remain in communication. (The concept of area, while not precise, is often good enough.) This

area is called the Basic Service Area (BSA). If a STA moves out of its BSA, it can no longer directly

communicate with other STAs present in the BSA.

See, e.g., 802.11-2007 § 5.2

5.2.3 Distribution system (DS) concepts

PHY limitations determine the direct station-to-station distance that may be supported. For some networks

this distance is sufficient; for other networks, increased coverage is required.

Instead of existing independently, a BSS may also form a component of an extended form of network that is

built with multiple BSSs. The architectural component used to interconnect BSSs is the DS.

IEEE Std 802.11 logically separates the WM from the distribution system medium (DSM). Each logical

medium is used for different purposes, by a different component of the architecture. The IEEE 802.11

definitions neither preclude, nor demand, that the multiple media be either the same or different.

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 454 of 946 PageID #:

4558
454

Claim 13 of the ’802 Patent Prior Art Reference – 802.11-2007

Recognizing that the multiple media are logically different is key to understanding the flexibility of the

architecture. The IEEE 802.11 LAN architecture is specified independently of the physical characteristics of

any specific implementation.

The DS enables mobile device support by providing the logical services necessary to handle address to

destination mapping and seamless integration of multiple BSSs.

An access point (AP) is any entity that has STA functionality and enables access to the DS, via the WM for

associated STAs.

See, e.g., 802.11-2007 § 5.2.3

5.3.2 DSS

The service provided by the DS is known as the DSS.

This service is represented in the IEEE 802.11 architecture by arrows within the APs, indicating that the

service is used to cross media and possibly address space logical boundaries. An AP is a logical entity, and

the functions described may be shared by one or more physical entities.

The services that comprise the DSS are as follows:

a) Association

b) Disassociation

c) Distribution

d) Integration

e) Reassociation

f) QoS traffic scheduling (QoS facility only)

DSSs are specified for use by MAC sublayer entities.

Figure 5-7 combines the components from previous figures with both types of services to show the complete

IEEE 802.11 architecture.

See, e.g., 802.11-2007 § 5.3.2

5.4.4.1 TPC

Radio regulations may require radio local area networks (RLANs) operating in the 5 GHz band to use

transmitter power control, involving specification of a regulatory maximum transmit power and a mitigation

requirement for each allowed channel, to reduce interference with satellite services. The TPC service is used

to satisfy this regulatory requirement.

The TPC service provides for the following:

— Association of STAs with an AP in a BSS based on the STAs’ power capability.

— Specification of regulatory and local maximum transmit power levels for the current channel.

— Selection of a transmit power for each transmission in a channel within constraints imposed by

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 455 of 946 PageID #:

4559
455

Claim 13 of the ’802 Patent Prior Art Reference – 802.11-2007

regulatory requirements.

— Adaptation of transmit power based on a range of information, including path loss and link margin

estimates.

See, e.g., 802.11-2007 § 5.4.4.1

7.3.2.20 Channel Switch Announcement element

The Channel Switch Announcement element is used by an AP in a BSS or a STA in an IBSS to advertise

when it is changing to a new channel and the channel number of the new channel. The format of the Channel

Switch Announcement element is shown in Figure 7-57.

See, e.g., 802.11-2007 § 7.3.2.20

10.3.11 Spectrum management protocol layer model

The layer management extensions for measurement and channel switching assume a certain partition

of spectrum management functionality between the MLME and SME. This partitioning assumes that

policy decisions (e.g., regarding measurement and channel switching) reside in the SME, while the protocol

for measurement, switch timing, and the associated frame exchanges resides within the MLME (see

Figure 10-2).

...

The informative diagrams within this subclause further illustrate the spectrum management protocol model

adopted. Figure 10-3 and Figure 10-4 depict the measurement process for a peer STA to accept and reject a

measurement request, respectively. Figure 10-5 illustrates the TPC adaptation process. Lastly, Figure 10-6

depicts the management process for a channel switch using a Channel Switch Announcement frame.

See, e.g., 802.11-2007 § 10.3.11

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 456 of 946 PageID #:

4560
456

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 457 of 946 PageID #:

4561
457

Claim 13 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 § 10.4.3.2

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 458 of 946 PageID #:

4562
458

Claim 13 of the ’802 Patent Prior Art Reference – 802.11-2007

17.1 Introduction

This clause specifies the PHY entity for an orthogonal frequency division multiplexing (OFDM) system.

The OFDM system provides a WLAN with data payload communication capabilities of 6, 9, 12, 18, 24, 36,

48, and 54 Mb/s. The support of transmitting and receiving at data rates of 6, 12, and 24 Mb/s is mandatory.

The system uses 52 subcarriers that are modulated using binary or quadrature phase shift keying (BPSK or

QPSK) or using 16- or 64-quadrature amplitude modulation (16-QAM or 64-QAM). Forward error

correction coding (convolutional coding) is used with a coding rate of 1/2, 2/3, or 3/4.

The OFDM system also provides a “half-clocked” operation using 10 MHz channel spacings with data

communications capabilities of 3, 4.5, 6, 9, 12, 18, 24, and 27 Mb/s. The support of transmitting and

receiving at data rates of 3, 6, and 12 Mb/s is mandatory when using 10 MHz channel spacing. The halfclocked

operation doubles symbol times and clear channel assessment (CCA) times when using 10 MHz

channel spacing. The regulatory requirements and information regarding use of this OFDM system in

4.9 GHz and 5 GHz bands is in Annex I and Annex J.

The OFDM system also provides a “quarter-clocked” operation using 5 MHz channel spacing with data

communication capabilities of 1.5, 2.25, 3, 4.5, 6, 9, 12, and 13.5 Mb/s. The support of transmitting and

receiving at data rates of 1.5, 3, and 6 Mb/s is mandatory when using 5 MHz channel spacing. The quarterclocked

operation quadruples symbol times and CCA times when using 5 MHz channel spacing. The

regulatory requirements and information regarding use of this OFDM system in the 4.9 GHz band is in

Annex I and Annex J.

See, e.g., 802.11-2007 § 17.1

17.3.2.1 Overview of the PPDU encoding process

The encoding process is composed of many detailed steps, which are described fully in later subclauses, as

noted below. The following overview intends to facilitate understanding the details of the convergence

procedure:

a) Produce the PLCP Preamble field, composed of 10 repetitions of a “short training sequence” (used

for AGC convergence, diversity selection, timing acquisition, and coarse frequency acquisition in

the receiver) and two repetitions of a “long training sequence” (used for channel estimation and fine

frequency acquisition in the receiver), preceded by a guard interval (GI). Refer to 17.3.3 for details.

b) Produce the PLCP header field from the RATE, LENGTH, and SERVICE field s of the

TXVECTOR by filling the appropriate bit fields. The RATE and LENGTH fields of the PLCP

header are encoded by a convolutional code at a rate of R = 1/2, and are subsequently mapped onto a

single BPSK encoded OFDM symbol, denoted as the SIGNAL symbol. In order to facilitate a

reliable and timely detection of the RATE and LENGTH fields, 6 zero tail bits are inserted into the

PLCP header. The encoding of the SIGNAL field into an OFDM symbol follows the same steps for

convolutional encoding, interleaving, BPSK modulation, pilot insertion, Fourier transform, and

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 459 of 946 PageID #:

4563
459

Claim 13 of the ’802 Patent Prior Art Reference – 802.11-2007

prepending a GI as described subsequently for data transmission with BPSK-OFDM modulated at

coding rate 1/2. The contents of the SIGNAL field are not scrambled. Refer to 17.3.4 for deta ils.

c) Calculate from RATE field of the TXVECTOR the number of data bits per OFDM symbol (NDBPS),

the coding rate (R), the number of bits in each OFDM subcarrier (NBPSC), and the number of coded

bits per OFDM symbol (NCBPS). Refer to 17.3.2.2 for details.

d) Append the PSDU to the SERVICE field of the TXVECTOR. Extend the resulting bit string with

zero bits (at least 6 bits) so that the resulting length will be a multiple of NDBPS. The resulting bit

string constitutes the DATA part of the packet. Refer to 17.3.5.3 for details.

e) Initiate the scrambler with a pseudo-random nonzero seed, generate a scrambling sequence, and

XOR it with the extended string of data bits. Refer to 17.3.5.4 for details.

f) Replace the six scrambled zero bits following the data with six nonscrambled zero bits. (Those bits

return the convolutional encoder to the zero state and are denoted as tail bits.) Refer to 17.3.5.2 for

details.

g) Encode the extended, scrambled data string with a convolutional encoder (R = 1/2). Omit (puncture )

some of the encoder output string (chosen according to “puncturing pattern”) to reach the desired

“coding rate.” Refer to 17.3.5.5 for details.

h) Divide the encoded bit string into groups of NCBPS bits. Within each group, perform an

“interleaving” (reordering) of the bits according to a rule corresponding to the desired RATE. Refer

to 17.3.5.6 for details.

i) Divide the resulting coded and interleaved data string into groups of NCBPS bits. For each of the bit

groups, convert the bit group into a complex number according to the modulation encoding tables.

Refer to 17.3.5.7 for details.

j) Divide the complex number string into groups of 48 complex numbers. Each such group will be

associated with one OFDM symbol. In each group, the complex numbers will be numbered 0 to 47

and mapped hereafter into OFDM subcarriers numbered –26 to –22, –20 to –8, –6 to –1, 1 to 6,

8 to 20, and 22 to 26. The subcarriers –21, –7, 7, and 21 are skipped and, subsequently, used for

inserting pilot subcarriers. The 0 subcarrier, associated with center frequency, is omitted and filled

with zero value. Refer to 17.3.5.9 for details.

k) Four subcarriers are inserted as pilots into positions –21, –7, 7, and 21. The total number of the

subcarriers is 52 (48 + 4). Refer to 17.3.5.8 for details.

l) For each group of subcarriers –26 to 26, convert the subcarriers to time domain using inverse

Fourier transform. Prepend to the Fourier-transformed waveform a circular extension of itself thus

forming a GI, and truncate the resulting periodic waveform to a single OFDM symbol length by

applying time domain windowing. Refer to 17.3.5.9 for details.

m) Append the OFDM symbols one after another, starting after the SIGNAL symbol describing the

RATE and LENGTH fields. Refer to 17.3.5.9 for details.

n) Up-convert the resulting “complex baseband” waveform to an RF according to the center frequency

of the desired channel and transmit. Refer to 17.3.2.4 and 17.3.8.1 for details.

An illustration of the transmitted frame and its parts appears in Figure 17-4 (in 17.3.3).

See, e.g., 802.11-2007 § 17.3.2.1

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 460 of 946 PageID #:

4564
460

Claim 13 of the ’802 Patent Prior Art Reference – 802.11-2007

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 461 of 946 PageID #:

4565
461

Claim 13 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 § 17.3.2.3

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 462 of 946 PageID #:

4566
462

Claim 13 of the ’802 Patent Prior Art Reference – 802.11-2007

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 463 of 946 PageID #:

4567
463

Claim 13 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 § 17.3.2.4 Eq. (17-1)

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 464 of 946 PageID #:

4568
464

Claim 13 of the ’802 Patent Prior Art Reference – 802.11-2007

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 465 of 946 PageID #:

4569
465

Claim 13 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 § 17.3.2.5

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 466 of 946 PageID #:

4570
466

Claim 13 of the ’802 Patent Prior Art Reference – 802.11-2007

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 467 of 946 PageID #:

4571
467

See, e.g., 802.11-2007 § 17.3.3

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 468 of 946 PageID #:

4572
468

Claim 13 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 § 17.3.5.7

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 469 of 946 PageID #:

4573
469

Claim 13 of the ’802 Patent Prior Art Reference – 802.11-2007

17.3.5.8 Pilot subcarriers

In each OFDM symbol, four of the subcarriers are dedicated to pilot signals in order to make the coherent

detection robust against frequency offsets and phase noise. These pilot signals shall be put in su bcarriers

–21, –7, 7, and 21. The pilots shall be BPSK modulated by a pseudo-binary sequence to prevent the

generation of spectral lines. The contribution of the pilot subcarriers to each OFDM symbol is described in

17.3.5.9.

See, e.g., 802.11-2007 § 17.3.5.8

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 470 of 946 PageID #:

4574
470

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 471 of 946 PageID #:

4575
471

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 472 of 946 PageID #:

4576
472

Claim 13 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 § 17.3.5.9

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 473 of 946 PageID #:

4577
473

Claim 13 of the ’802 Patent Prior Art Reference – 802.11-2007

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 474 of 946 PageID #:

4578
474

Claim 13 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 § 17.3.8.1

17.3.8.3.1 Operating frequency range

The OFDM PHY shall operate in the 5 GHz band, as allocated by a regulatory body in its operational region.

Spectrum allocation in the 5 GHz band is subject to authorities responsible for geographic-specific

regulatory domains (e.g., global, regional, and national). The particular channelization to be used for this

standard is dependent on such allocation, as well as the associated regulations for use of the allocations.

These regulations are subject to revision, or may be superseded.

In some regulatory domains, several frequency bands may be available for OFDM PHY-based WLANs.

These bands may be contiguous or not, and different regulatory limits may be applicable. A compliant

OFDM PHY shall support at least one frequency band in at least one regulatory domain. The support of

specific regulatory domains, and bands within the domains, shall be indicated by PLME attributes

dot11RegDomainsSupported and dot11FrequencyBandsSupported.

See, e.g., 802.11-2007 § 17.3.8.3.1

17.3.9.1 Transmit power levels

The maximum allowable transmit power by regulatory domain is defined in Annex I.

See, e.g., 802.11-2007 § 17.3.9.1

17.3.9.6.2 Transmitter spectral flatness

The average energy of the constellations in each of the spectral lines –16.. –1 and +1.. +16 will deviate no

more than ± 2 dB from their average energy. The average energy of the constellations in each of the spectral

lines –26.. –17 and +17.. +26 will deviate no more than +2/–4 dB from the average energy of spectral lines

–16.. –1 and +1.. +16. The data for this test shall be derived from the channel estimation step.

See, e.g., 802.11-2007 § 17.3.9.6.2

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 475 of 946 PageID #:

4579
475

Claim 13 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 § I.2.2

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 476 of 946 PageID #:

4580
476

Claim 13 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 § I.2.3

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 477 of 946 PageID #:

4581
477

Claim 13 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 Figure 5-7

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 478 of 946 PageID #:

4582
478

Claim 13 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 Figure 10-6

Furthermore, this claim element is obvious in light of 802.11-2007 itself, when combined with any of 

the other references as charted for this claim element in Exs. A-1–A-31, First Supplemental Ex. ACase 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 479 of 946 PageID #:

4583
479

Claim 13 of the ’802 Patent Prior Art Reference – 802.11-2007

Obviousness 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 – 802.11-2007

[14.1] The method of claim 10 802.11-2007 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 

data, the method further 

comprising:

802.11-2007 discloses “wherein the second data is the same as the first data, the method further 

comprising.” See, e.g.: 

1.1 Scope

The scope of this standard is to define one medium access control (MAC) and several physical layer (PHY)

specifications for wireless connectivity for fixed, portable, and moving stations (STAs) within a local area.

See, e.g., 802.11-2007 § 1.1

5.1.1 How WLAN systems are different

Wireless networks have fundamental characteristics that make them significantly different from traditional

wired LANs. Some countries impose specific requirements for radio equipment in addition to those

specified in this standard. This standard does not provide information to meet these co untry-specific radio

regulations.

5.1.1.1 Destination address does not equal destination location

In wired LANs, an address is equivalent to a physical location. This is implicitly assumed in the design of

wired LANs. In IEEE Std 802.11, the addressable unit is a station (STA). The STA is a message destination,

but not (in general) a fixed location.

5.1.1.2 Media impact on design and performance

The PHYs used in IEEE Std 802.11 are fundamentally different from wired media. Thus IEEE 802.11 PHYs

a) Use a medium that has neither absolute nor readily observable boundaries outside of which STAs

with conformant PHY transceivers are known to be unable to receive network frames

b) Are unprotected from other signals that may be sharing the medium

c) Communicate over a medium significantly less reliable than wired PHYs

d) Have dynamic topologies

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 480 of 946 PageID #:

4584
480

Claim 14 of the ’802 Patent Prior Art Reference – 802.11-2007

e) Lack full connectivity, and therefore the assumption normally made that every STA can hear every

other STA is invalid (i.e., STAs may be “hidden” from each other)

f) Have time-varying and asymmetric propagation properties

g) May experience interference from logically disjoint IEEE 802.11 networks operating in overlapping

areas

Because of limitations on wireless PHY ranges, WLANs intended to cover reasonable geographic distances

may be built from basic coverage building blocks. When providing QoS services it should be understood

that the MAC endeavors to provide QoS “service guarantees” within the limitations of the medium

properties identified above. In other words, particularly in unlicensed spectrum, true guarantees are often not

possible. However, gradations of service are always possible; and in sufficiently controlled environments,

QoS guarantees can truly be made.

5.1.1.3 The impact of handling mobile STAs

One of the requirements of IEEE Std 802.11 is to handle mobile as well as portable STAs. A portable STA

is one that is moved from location to location, but that is only used while at a fixed location. Mobile STAs

actually access the LAN while in motion.

For technical reasons, it is not sufficient to handle only portable STAs. Propagation effects blur the

distinction between portable and mobile STAs; stationary STAs often appear to be mobile due to

propagation effects.

Another aspect of mobile STAs is that they may often be battery powered. Hence power management is

an important consideration. For example, it cannot be presumed that a STA’s receiver will always be

powered on.

See, e.g., 802.11-2007 § 5.1.1 - § 5.1.1.3

5.2 Components of the IEEE 802.11 architecture

The IEEE 802.11 architecture consists of several components that interact to provide a WLAN that supports

STA mobility transparently to upper layers.

The basic service set (BSS) is the basic building block of an IEEE 802.11 LAN. Figure 5 -1 shows two BSSs,

each of which has two STAs that are members of the BSS.

It is useful to think of the ovals used to depict a BSS as the coverage area within which the member STAs of

the BSS may remain in communication. (The concept of area, while not precise, is often good enough.) This

area is called the Basic Service Area (BSA). If a STA moves out of its BSA, it can no longer directly

communicate with other STAs present in the BSA.

See, e.g., 802.11-2007 § 5.2

5.2.3 Distribution system (DS) concepts

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 481 of 946 PageID #:

4585
481

Claim 14 of the ’802 Patent Prior Art Reference – 802.11-2007

PHY limitations determine the direct station-to-station distance that may be supported. For some networks

this distance is sufficient; for other networks, increased coverage is required.

Instead of existing independently, a BSS may also form a component of an extended form of network that is

built with multiple BSSs. The architectural component used to interconnect BSSs is the DS.

IEEE Std 802.11 logically separates the WM from the distribution system medium (DSM). Each logical

medium is used for different purposes, by a different component of the architecture. The IEEE 802.11

definitions neither preclude, nor demand, that the multiple media be either the same or different.

Recognizing that the multiple media are logically different is key to understanding the flexibility of the

architecture. The IEEE 802.11 LAN architecture is specified independently of the physical characteristics of

any specific implementation.

The DS enables mobile device support by providing the logical services necessary to handle address to

destination mapping and seamless integration of multiple BSSs.

An access point (AP) is any entity that has STA functionality and enables access to the DS, via the WM for

associated STAs.

See, e.g., 802.11-2007 § 5.2.3

5.3.2 DSS

The service provided by the DS is known as the DSS.

This service is represented in the IEEE 802.11 architecture by arrows within the APs, indicating that the

service is used to cross media and possibly address space logical boundaries. An AP is a logical entity, and

the functions described may be shared by one or more physical entities.

The services that comprise the DSS are as follows:

a) Association

b) Disassociation

c) Distribution

d) Integration

e) Reassociation

f) QoS traffic scheduling (QoS facility only)

DSSs are specified for use by MAC sublayer entities.

Figure 5-7 combines the components from previous figures with both types of services to show the complete

IEEE 802.11 architecture.

See, e.g., 802.11-2007 § 5.3.2

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 482 of 946 PageID #:

4586
482

Claim 14 of the ’802 Patent Prior Art Reference – 802.11-2007

5.4.4.1 TPC

Radio regulations may require radio local area networks (RLANs) operating in the 5 GHz band to use

transmitter power control, involving specification of a regulatory maximum transmit power and a mitigation

requirement for each allowed channel, to reduce interference with satellite services. The TPC service is used

to satisfy this regulatory requirement.

The TPC service provides for the following:

— Association of STAs with an AP in a BSS based on the STAs’ power capability.

— Specification of regulatory and local maximum transmit power levels for the current channel.

— Selection of a transmit power for each transmission in a channel within constraints imposed by

regulatory requirements.

— Adaptation of transmit power based on a range of information, including path loss and link margin

estimates.

See, e.g., 802.11-2007 § 5.4.4.1

7.3.2.20 Channel Switch Announcement element

The Channel Switch Announcement element is used by an AP in a BSS or a STA in an IBSS to advertise

when it is changing to a new channel and the channel number of the new channel. The format of the Channel

Switch Announcement element is shown in Figure 7-57.

See, e.g., 802.11-2007 § 7.3.2.20

10.3.11 Spectrum management protocol layer model

The layer management extensions for measurement and channel switching assume a certain partition

of spectrum management functionality between the MLME and SME. This partitioning assumes that

policy decisions (e.g., regarding measurement and channel switching) reside in the SME, while the protocol

for measurement, switch timing, and the associated frame exchanges resides within the MLME (see

Figure 10-2).

...

The informative diagrams within this subclause further illustrate the spectrum management protocol model

adopted. Figure 10-3 and Figure 10-4 depict the measurement process for a peer STA to accept and reject a

measurement request, respectively. Figure 10-5 illustrates the TPC adaptation process. Lastly, Figure 10-6

depicts the management process for a channel switch using a Channel Switch Announcement frame.

See, e.g., 802.11-2007 § 10.3.11

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 483 of 946 PageID #:

4587
483

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 484 of 946 PageID #:

4588
484

Claim 14 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 § 10.4.3.2

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 485 of 946 PageID #:

4589
485

Claim 14 of the ’802 Patent Prior Art Reference – 802.11-2007

17.1 Introduction

This clause specifies the PHY entity for an orthogonal frequency division multiplexing (OFDM) system.

The OFDM system provides a WLAN with data payload communication capabilities of 6, 9, 12, 18, 24, 36,

48, and 54 Mb/s. The support of transmitting and receiving at data rates of 6, 12, and 24 Mb/s is mandatory.

The system uses 52 subcarriers that are modulated using binary or quadrature phase shift keying (BPSK or

QPSK) or using 16- or 64-quadrature amplitude modulation (16-QAM or 64-QAM). Forward error

correction coding (convolutional coding) is used with a coding rate of 1/2, 2/3, or 3/4.

The OFDM system also provides a “half-clocked” operation using 10 MHz channel spacings with data

communications capabilities of 3, 4.5, 6, 9, 12, 18, 24, and 27 Mb/s. The support of transmitting and

receiving at data rates of 3, 6, and 12 Mb/s is mandatory when using 10 MHz channel spacing. The halfclocked

operation doubles symbol times and clear channel assessment (CCA) times when using 10 MHz

channel spacing. The regulatory requirements and information regarding use of this OFDM system in

4.9 GHz and 5 GHz bands is in Annex I and Annex J.

The OFDM system also provides a “quarter-clocked” operation using 5 MHz channel spacing with data

communication capabilities of 1.5, 2.25, 3, 4.5, 6, 9, 12, and 13.5 Mb/s. The support of transmitting and

receiving at data rates of 1.5, 3, and 6 Mb/s is mandatory when using 5 MHz ch annel spacing. The quarterclocked

operation quadruples symbol times and CCA times when using 5 MHz channel spacing. The

regulatory requirements and information regarding use of this OFDM system in the 4.9 GHz band is in

Annex I and Annex J.

See, e.g., 802.11-2007 § 17.1

17.3.2.1 Overview of the PPDU encoding process

The encoding process is composed of many detailed steps, which are described fully in later subclauses, as

noted below. The following overview intends to facilitate understanding the details o f the convergence

procedure:

a) Produce the PLCP Preamble field, composed of 10 repetitions of a “short training sequence” (used

for AGC convergence, diversity selection, timing acquisition, and coarse frequency acquisition in

the receiver) and two repetitions of a “long training sequence” (used for channel estimation and fine

frequency acquisition in the receiver), preceded by a guard interval (GI). Refer to 17.3.3 for details.

b) Produce the PLCP header field from the RATE, LENGTH, and SERVICE fields of the

TXVECTOR by filling the appropriate bit fields. The RATE and LENGTH fields of the PLCP

header are encoded by a convolutional code at a rate of R = 1/2, and are subsequently mapped onto a

single BPSK encoded OFDM symbol, denoted as the SIGNAL symbol. In order to facilitate a

reliable and timely detection of the RATE and LENGTH fields, 6 zero tail bits are inserted into the

PLCP header. The encoding of the SIGNAL field into an OFDM symbol follows the same steps for

convolutional encoding, interleaving, BPSK modulation, pilot insertion, Fourier transform, and

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 486 of 946 PageID #:

4590
486

Claim 14 of the ’802 Patent Prior Art Reference – 802.11-2007

prepending a GI as described subsequently for data transmission with BPSK-OFDM modulated at

coding rate 1/2. The contents of the SIGNAL field are not scrambled. Refer to 17.3.4 for deta ils.

c) Calculate from RATE field of the TXVECTOR the number of data bits per OFDM symbol (NDBPS),

the coding rate (R), the number of bits in each OFDM subcarrier (NBPSC), and the number of coded

bits per OFDM symbol (NCBPS). Refer to 17.3.2.2 for details.

d) Append the PSDU to the SERVICE field of the TXVECTOR. Extend the resulting bit string with

zero bits (at least 6 bits) so that the resulting length will be a multiple of NDBPS. The resulting bit

string constitutes the DATA part of the packet. Refer to 17.3.5.3 for details.

e) Initiate the scrambler with a pseudo-random nonzero seed, generate a scrambling sequence, and

XOR it with the extended string of data bits. Refer to 17.3.5.4 for details.

f) Replace the six scrambled zero bits following the data with six nonscrambled zero bits. (Those bits

return the convolutional encoder to the zero state and are denoted as tail bits.) Refer to 17.3.5.2 for

details.

g) Encode the extended, scrambled data string with a convolutional encoder (R = 1/2). Omit (puncture )

some of the encoder output string (chosen according to “puncturing pattern”) to reach the desired

“coding rate.” Refer to 17.3.5.5 for details.

h) Divide the encoded bit string into groups of NCBPS bits. Within each group, perform an

“interleaving” (reordering) of the bits according to a rule corresponding to the desired RATE. Refer

to 17.3.5.6 for details.

i) Divide the resulting coded and interleaved data string into groups of NCBPS bits. For each of the bit

groups, convert the bit group into a complex number according to the modulation encoding tables.

Refer to 17.3.5.7 for details.

j) Divide the complex number string into groups of 48 complex numbers. Each such group will be

associated with one OFDM symbol. In each group, the complex numbers will be numbered 0 to 47

and mapped hereafter into OFDM subcarriers numbered –26 to –22, –20 to –8, –6 to –1, 1 to 6,

8 to 20, and 22 to 26. The subcarriers –21, –7, 7, and 21 are skipped and, subsequently, used for

inserting pilot subcarriers. The 0 subcarrier, associated with center frequency, is omitted and filled

with zero value. Refer to 17.3.5.9 for details.

k) Four subcarriers are inserted as pilots into positions –21, –7, 7, and 21. The total number of the

subcarriers is 52 (48 + 4). Refer to 17.3.5.8 for details.

l) For each group of subcarriers –26 to 26, convert the subcarriers to time domain using inverse

Fourier transform. Prepend to the Fourier-transformed waveform a circular extension of itself thus

forming a GI, and truncate the resulting periodic waveform to a single OFDM symbol length by

applying time domain windowing. Refer to 17.3.5.9 for details.

m) Append the OFDM symbols one after another, starting after the SIGNAL symbol describing the

RATE and LENGTH fields. Refer to 17.3.5.9 for details.

n) Up-convert the resulting “complex baseband” waveform to an RF according to the center frequency

of the desired channel and transmit. Refer to 17.3.2.4 and 17.3.8.1 for details.

An illustration of the transmitted frame and its parts appears in Figure 17-4 (in 17.3.3).

See, e.g., 802.11-2007 § 17.3.2.1

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 487 of 946 PageID #:

4591
487

Claim 14 of the ’802 Patent Prior Art Reference – 802.11-2007

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 488 of 946 PageID #:

4592
488

Claim 14 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 § 17.3.2.3

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 489 of 946 PageID #:

4593
489

Claim 14 of the ’802 Patent Prior Art Reference – 802.11-2007

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 490 of 946 PageID #:

4594
490

Claim 14 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 § 17.3.2.4 Eq. (17-1)

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 491 of 946 PageID #:

4595
491

Claim 14 of the ’802 Patent Prior Art Reference – 802.11-2007

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 492 of 946 PageID #:

4596
492

Claim 14 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 § 17.3.2.5

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 493 of 946 PageID #:

4597
493

Claim 14 of the ’802 Patent Prior Art Reference – 802.11-2007

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 494 of 946 PageID #:

4598
494

See, e.g., 802.11-2007 § 17.3.3

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 495 of 946 PageID #:

4599
495

Claim 14 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 § 17.3.5.7

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 496 of 946 PageID #:

4600
496

Claim 14 of the ’802 Patent Prior Art Reference – 802.11-2007

17.3.5.8 Pilot subcarriers

In each OFDM symbol, four of the subcarriers are dedicated to pilot signals in order to make the coherent

detection robust against frequency offsets and phase noise. These pilot signals shall be put in su bcarriers

–21, –7, 7, and 21. The pilots shall be BPSK modulated by a pseudo-binary sequence to prevent the

generation of spectral lines. The contribution of the pilot subcarriers to each OFDM symbol is described in

17.3.5.9.

See, e.g., 802.11-2007 § 17.3.5.8

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 497 of 946 PageID #:

4601
497

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 498 of 946 PageID #:

4602
498

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 499 of 946 PageID #:

4603
499

Claim 14 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 § 17.3.5.9

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 500 of 946 PageID #:

4604
500

Claim 14 of the ’802 Patent Prior Art Reference – 802.11-2007

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 501 of 946 PageID #:

4605
501

Claim 14 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 § 17.3.8.1

17.3.8.3.1 Operating frequency range

The OFDM PHY shall operate in the 5 GHz band, as allocated by a regulatory body in its operational region.

Spectrum allocation in the 5 GHz band is subject to authorities responsible for geographic-specific

regulatory domains (e.g., global, regional, and national). The particular channelization to be used for this

standard is dependent on such allocation, as well as the associated regulations for use of the allocations.

These regulations are subject to revision, or may be superseded.

In some regulatory domains, several frequency bands may be available for OFDM PHY-based WLANs.

These bands may be contiguous or not, and different regulatory limits may be applicable. A compliant

OFDM PHY shall support at least one frequency band in at least one regulatory domain. The support of

specific regulatory domains, and bands within the domains, shall be indicated by PLME attributes

dot11RegDomainsSupported and dot11FrequencyBandsSupported.

See, e.g., 802.11-2007 § 17.3.8.3.1

17.3.9.1 Transmit power levels

The maximum allowable transmit power by regulatory domain is defined in Annex I.

See, e.g., 802.11-2007 § 17.3.9.1

17.3.9.6.2 Transmitter spectral flatness

The average energy of the constellations in each of the spectral lines –16.. –1 and +1.. +16 will deviate no

more than ± 2 dB from their average energy. The average energy of the constellations in each of the spectral

lines –26.. –17 and +17.. +26 will deviate no more than +2/–4 dB from the average energy of spectral lines

–16.. –1 and +1.. +16. The data for this test shall be derived from the channel estimation step.

See, e.g., 802.11-2007 § 17.3.9.6.2

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 502 of 946 PageID #:

4606
502

Claim 14 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 § I.2.2

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 503 of 946 PageID #:

4607
503

Claim 14 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 § I.2.3

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 504 of 946 PageID #:

4608
504

Claim 14 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 Figure 5-7

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 505 of 946 PageID #:

4609
505

Claim 14 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 Figure 10-6

Furthermore, this claim element is obvious in light of 802.11-2007 itself, when combined with any of 

the other references as charted for this claim element in Exs. A-1–A-31, First Supplemental Ex. ACase 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 506 of 946 PageID #:

4610
506

Claim 14 of the ’802 Patent Prior Art Reference – 802.11-2007

Obviousness 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;

802.11-2007 discloses “receiving the transmitted signal on a second antenna.” See, e.g.: 

1.1 Scope

The scope of this standard is to define one medium access control (MAC) and several physical layer (PHY)

specifications for wireless connectivity for fixed, portable, and moving stations (STAs) within a local area.

See, e.g., 802.11-2007 § 1.1

5.1.1 How WLAN systems are different

Wireless networks have fundamental characteristics that make them significantly different from traditional

wired LANs. Some countries impose specific requirements for radio equipment in addition to those

specified in this standard. This standard does not provide information to meet these co untry-specific radio

regulations.

5.1.1.1 Destination address does not equal destination location

In wired LANs, an address is equivalent to a physical location. This is implicitly assumed in the design of

wired LANs. In IEEE Std 802.11, the addressable unit is a station (STA). The STA is a message destination,

but not (in general) a fixed location.

5.1.1.2 Media impact on design and performance

The PHYs used in IEEE Std 802.11 are fundamentally different from wired media. Thus IEEE 802.11 PHYs

a) Use a medium that has neither absolute nor readily observable boundaries outside of which STAs

with conformant PHY transceivers are known to be unable to receive network frames

b) Are unprotected from other signals that may be sharing the medium

c) Communicate over a medium significantly less reliable than wired PHYs

d) Have dynamic topologies

e) Lack full connectivity, and therefore the assumption normally made that every STA can hear every

other STA is invalid (i.e., STAs may be “hidden” from each other)

f) Have time-varying and asymmetric propagation properties

g) May experience interference from logically disjoint IEEE 802.11 networks operating in overlapping

areas

Because of limitations on wireless PHY ranges, WLANs intended to cover reasonable geographic distances

may be built from basic coverage building blocks. When providing QoS services it should be understood

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 507 of 946 PageID #:

4611
507

Claim 14 of the ’802 Patent Prior Art Reference – 802.11-2007

that the MAC endeavors to provide QoS “service guarantees” within the limitations of the medium

properties identified above. In other words, particularly in unlicensed spectrum, true guarantees are often not

possible. However, gradations of service are always possible; and in sufficiently controlled environments,

QoS guarantees can truly be made.

5.1.1.3 The impact of handling mobile STAs

One of the requirements of IEEE Std 802.11 is to handle mobile as well as portable STAs. A portable STA

is one that is moved from location to location, but that is only used while at a fixed location. Mobile STAs

actually access the LAN while in motion.

For technical reasons, it is not sufficient to handle only portable STAs. Propagation effects blur the

distinction between portable and mobile STAs; stationary STAs often appear to be mobile due to

propagation effects.

Another aspect of mobile STAs is that they may often be battery powered. Hence power management is

an important consideration. For example, it cannot be presumed that a STA’s receiver will always be

powered on.

See, e.g., 802.11-2007 § 5.1.1 - § 5.1.1.3

5.2 Components of the IEEE 802.11 architecture

The IEEE 802.11 architecture consists of several components that interact to provide a WLAN that supports

STA mobility transparently to upper layers.

The basic service set (BSS) is the basic building block of an IEEE 802.11 LAN. Figure 5 -1 shows two BSSs,

each of which has two STAs that are members of the BSS.

It is useful to think of the ovals used to depict a BSS as the coverage area within which the member STAs of

the BSS may remain in communication. (The concept of area, while not precise, is often good enough.) This

area is called the Basic Service Area (BSA). If a STA moves out of its BSA, it can no longer directly

communicate with other STAs present in the BSA.

See, e.g., 802.11-2007 § 5.2

5.2.3 Distribution system (DS) concepts

PHY limitations determine the direct station-to-station distance that may be supported. For some networks

this distance is sufficient; for other networks, increased coverage is required.

Instead of existing independently, a BSS may also form a component of an extended form of network that is

built with multiple BSSs. The architectural component used to interconnect BSSs is the DS.

IEEE Std 802.11 logically separates the WM from the distribution system medium (DSM). Each logical

medium is used for different purposes, by a different component of the architecture. The IEEE 802.11

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 508 of 946 PageID #:

4612
508

Claim 14 of the ’802 Patent Prior Art Reference – 802.11-2007

definitions neither preclude, nor demand, that the multiple media be either the same or different.

Recognizing that the multiple media are logically different is key to understanding the flexibility of the

architecture. The IEEE 802.11 LAN architecture is specified independently of the physical characteristics of

any specific implementation.

The DS enables mobile device support by providing the logical services necessary to handle address to

destination mapping and seamless integration of multiple BSSs.

An access point (AP) is any entity that has STA functionality and enables access to the DS, via the WM for

associated STAs.

See, e.g., 802.11-2007 § 5.2.3

5.3.2 DSS

The service provided by the DS is known as the DSS.

This service is represented in the IEEE 802.11 architecture by arrows within the APs, indicating that the

service is used to cross media and possibly address space logical boundaries. An AP is a logical entity, and

the functions described may be shared by one or more physical entities.

The services that comprise the DSS are as follows:

a) Association

b) Disassociation

c) Distribution

d) Integration

e) Reassociation

f) QoS traffic scheduling (QoS facility only)

DSSs are specified for use by MAC sublayer entities.

Figure 5-7 combines the components from previous figures with both types of services to show the complete

IEEE 802.11 architecture.

See, e.g., 802.11-2007 § 5.3.2

5.4.4.1 TPC

Radio regulations may require radio local area networks (RLANs) operating in the 5 GHz band to use

transmitter power control, involving specification of a regulatory maximum transmit power and a mitigation

requirement for each allowed channel, to reduce interference with satellite services. The TPC service is used

to satisfy this regulatory requirement.

The TPC service provides for the following:

— Association of STAs with an AP in a BSS based on the STAs’ power capability.

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 509 of 946 PageID #:

4613
509

Claim 14 of the ’802 Patent Prior Art Reference – 802.11-2007

— Specification of regulatory and local maximum transmit power levels for the current channel.

— Selection of a transmit power for each transmission in a channel within constraints imposed by

regulatory requirements.

— Adaptation of transmit power based on a range of information, including path loss and link margin

estimates.

See, e.g., 802.11-2007 § 5.4.4.1

7.3.2.20 Channel Switch Announcement element

The Channel Switch Announcement element is used by an AP in a BSS or a STA in an IBSS to advertise

when it is changing to a new channel and the channel number of the new channel. The format of the Channel

Switch Announcement element is shown in Figure 7-57.

See, e.g., 802.11-2007 § 7.3.2.20

10.3.11 Spectrum management protocol layer model

The layer management extensions for measurement and channel switching assume a certain partition

of spectrum management functionality between the MLME and SME. This partitioning assumes that

policy decisions (e.g., regarding measurement and channel switching) reside in the SME, while the protocol

for measurement, switch timing, and the associated frame exchanges resides within the MLME (see

Figure 10-2).

...

The informative diagrams within this subclause further illustrate the spectrum management protocol model

adopted. Figure 10-3 and Figure 10-4 depict the measurement process for a peer STA to accept and reject a

measurement request, respectively. Figure 10-5 illustrates the TPC adaptation process. Lastly, Figure 10-6

depicts the management process for a channel switch using a Channel Switch Announcement frame.

See, e.g., 802.11-2007 § 10.3.11

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 510 of 946 PageID #:

4614
510

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 511 of 946 PageID #:

4615
511

Claim 14 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 § 10.4.3.2

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 512 of 946 PageID #:

4616
512

Claim 14 of the ’802 Patent Prior Art Reference – 802.11-2007

17.1 Introduction

This clause specifies the PHY entity for an orthogonal frequency division multiplexing (OFDM) system.

The OFDM system provides a WLAN with data payload communication capabilities of 6, 9, 12, 18, 24, 36,

48, and 54 Mb/s. The support of transmitting and receiving at data rates of 6, 12, and 24 Mb/s is mandatory.

The system uses 52 subcarriers that are modulated using binary or quadrature phase shift keying (BPSK or

QPSK) or using 16- or 64-quadrature amplitude modulation (16-QAM or 64-QAM). Forward error

correction coding (convolutional coding) is used with a coding rate of 1/2, 2/3, or 3/4.

The OFDM system also provides a “half-clocked” operation using 10 MHz channel spacings with data

communications capabilities of 3, 4.5, 6, 9, 12, 18, 24, and 27 Mb/s. The support of transmitting and

receiving at data rates of 3, 6, and 12 Mb/s is mandatory when using 10 MHz channel spacing. The halfclocked

operation doubles symbol times and clear channel assessment (CCA) times when using 10 MHz

channel spacing. The regulatory requirements and information regarding use of this OFDM system in

4.9 GHz and 5 GHz bands is in Annex I and Annex J.

The OFDM system also provides a “quarter-clocked” operation using 5 MHz channel spacing with data

communication capabilities of 1.5, 2.25, 3, 4.5, 6, 9, 12, and 13.5 Mb/s. The support of transmitting and

receiving at data rates of 1.5, 3, and 6 Mb/s is mandatory when using 5 MHz ch annel spacing. The quarterclocked

operation quadruples symbol times and CCA times when using 5 MHz channel spacing. The

regulatory requirements and information regarding use of this OFDM system in the 4.9 GHz band is in

Annex I and Annex J.

See, e.g., 802.11-2007 § 17.1

17.3.2.1 Overview of the PPDU encoding process

The encoding process is composed of many detailed steps, which are described fully in later subclauses, as

noted below. The following overview intends to facilitate understanding the details o f the convergence

procedure:

a) Produce the PLCP Preamble field, composed of 10 repetitions of a “short training sequence” (used

for AGC convergence, diversity selection, timing acquisition, and coarse frequency acquisition in

the receiver) and two repetitions of a “long training sequence” (used for channel estimation and fine

frequency acquisition in the receiver), preceded by a guard interval (GI). Refer to 17.3.3 for details.

b) Produce the PLCP header field from the RATE, LENGTH, and SERVICE fields of the

TXVECTOR by filling the appropriate bit fields. The RATE and LENGTH fields of the PLCP

header are encoded by a convolutional code at a rate of R = 1/2, and are subsequently mapped onto a

single BPSK encoded OFDM symbol, denoted as the SIGNAL symbol. In order to facilitate a

reliable and timely detection of the RATE and LENGTH fields, 6 zero tail bits are inserted into the

PLCP header. The encoding of the SIGNAL field into an OFDM symbol follows the same steps for

convolutional encoding, interleaving, BPSK modulation, pilot insertion, Fourier transform, and

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 513 of 946 PageID #:

4617
513

Claim 14 of the ’802 Patent Prior Art Reference – 802.11-2007

prepending a GI as described subsequently for data transmission with BPSK-OFDM modulated at

coding rate 1/2. The contents of the SIGNAL field are not scrambled. Refer to 17.3.4 for deta ils.

c) Calculate from RATE field of the TXVECTOR the number of data bits per OFDM symbol (NDBPS),

the coding rate (R), the number of bits in each OFDM subcarrier (NBPSC), and the number of coded

bits per OFDM symbol (NCBPS). Refer to 17.3.2.2 for details.

d) Append the PSDU to the SERVICE field of the TXVECTOR. Extend the resulting bit string with

zero bits (at least 6 bits) so that the resulting length will be a multiple of NDBPS. The resulting bit

string constitutes the DATA part of the packet. Refer to 17.3.5.3 for details.

e) Initiate the scrambler with a pseudo-random nonzero seed, generate a scrambling sequence, and

XOR it with the extended string of data bits. Refer to 17.3.5.4 for details.

f) Replace the six scrambled zero bits following the data with six nonscrambled zero bits. (Those bits

return the convolutional encoder to the zero state and are denoted as tail bits.) Refer to 17.3.5.2 for

details.

g) Encode the extended, scrambled data string with a convolutional encoder (R = 1/2). Omit (puncture )

some of the encoder output string (chosen according to “puncturing pattern”) to reach the desired

“coding rate.” Refer to 17.3.5.5 for details.

h) Divide the encoded bit string into groups of NCBPS bits. Within each group, perform an

“interleaving” (reordering) of the bits according to a rule corresponding to the desired RATE. Refer

to 17.3.5.6 for details.

i) Divide the resulting coded and interleaved data string into groups of NCBPS bits. For each of the bit

groups, convert the bit group into a complex number according to the modulation encoding tables.

Refer to 17.3.5.7 for details.

j) Divide the complex number string into groups of 48 complex numbers. Each such group will be

associated with one OFDM symbol. In each group, the complex numbers will be numbered 0 to 47

and mapped hereafter into OFDM subcarriers numbered –26 to –22, –20 to –8, –6 to –1, 1 to 6,

8 to 20, and 22 to 26. The subcarriers –21, –7, 7, and 21 are skipped and, subsequently, used for

inserting pilot subcarriers. The 0 subcarrier, associated with center frequency, is omitted and filled

with zero value. Refer to 17.3.5.9 for details.

k) Four subcarriers are inserted as pilots into positions –21, –7, 7, and 21. The total number of the

subcarriers is 52 (48 + 4). Refer to 17.3.5.8 for details.

l) For each group of subcarriers –26 to 26, convert the subcarriers to time domain using inverse

Fourier transform. Prepend to the Fourier-transformed waveform a circular extension of itself thus

forming a GI, and truncate the resulting periodic waveform to a single OFDM symbol length by

applying time domain windowing. Refer to 17.3.5.9 for details.

m) Append the OFDM symbols one after another, starting after the SIGNAL symbol describing the

RATE and LENGTH fields. Refer to 17.3.5.9 for details.

n) Up-convert the resulting “complex baseband” waveform to an RF according to the center frequency

of the desired channel and transmit. Refer to 17.3.2.4 and 17.3.8.1 for details.

An illustration of the transmitted frame and its parts appears in Figure 17-4 (in 17.3.3).

See, e.g., 802.11-2007 § 17.3.2.1

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 514 of 946 PageID #:

4618
514

Claim 14 of the ’802 Patent Prior Art Reference – 802.11-2007

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 515 of 946 PageID #:

4619
515

Claim 14 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 § 17.3.2.3

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 516 of 946 PageID #:

4620
516

Claim 14 of the ’802 Patent Prior Art Reference – 802.11-2007

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 517 of 946 PageID #:

4621
517

Claim 14 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 § 17.3.2.4 Eq. (17-1)

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 518 of 946 PageID #:

4622
518

Claim 14 of the ’802 Patent Prior Art Reference – 802.11-2007

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 519 of 946 PageID #:

4623
519

Claim 14 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 § 17.3.2.5

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 520 of 946 PageID #:

4624
520

Claim 14 of the ’802 Patent Prior Art Reference – 802.11-2007

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 521 of 946 PageID #:

4625
521

See, e.g., 802.11-2007 § 17.3.3

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 522 of 946 PageID #:

4626
522

Claim 14 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 § 17.3.5.7

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 523 of 946 PageID #:

4627
523

Claim 14 of the ’802 Patent Prior Art Reference – 802.11-2007

17.3.5.8 Pilot subcarriers

In each OFDM symbol, four of the subcarriers are dedicated to pilot signals in order to make the coherent

detection robust against frequency offsets and phase noise. These pilot signals shall be put in su bcarriers

–21, –7, 7, and 21. The pilots shall be BPSK modulated by a pseudo-binary sequence to prevent the

generation of spectral lines. The contribution of the pilot subcarriers to each OFDM symbol is described in

17.3.5.9.

See, e.g., 802.11-2007 § 17.3.5.8

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 524 of 946 PageID #:

4628
524

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 525 of 946 PageID #:

4629
525

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 526 of 946 PageID #:

4630
526

Claim 14 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 § 17.3.5.9

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 527 of 946 PageID #:

4631
527

Claim 14 of the ’802 Patent Prior Art Reference – 802.11-2007

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 528 of 946 PageID #:

4632
528

Claim 14 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 § 17.3.8.1

17.3.8.3.1 Operating frequency range

The OFDM PHY shall operate in the 5 GHz band, as allocated by a regulatory body in its operational region.

Spectrum allocation in the 5 GHz band is subject to authorities responsible for geographic-specific

regulatory domains (e.g., global, regional, and national). The particular channelization to be used for this

standard is dependent on such allocation, as well as the associated regulations for use of the allocations.

These regulations are subject to revision, or may be superseded.

In some regulatory domains, several frequency bands may be available for OFDM PHY-based WLANs.

These bands may be contiguous or not, and different regulatory limits may be applicable. A compliant

OFDM PHY shall support at least one frequency band in at least one regulatory domain. The support of

specific regulatory domains, and bands within the domains, shall be indicated by PLME attributes

dot11RegDomainsSupported and dot11FrequencyBandsSupported.

See, e.g., 802.11-2007 § 17.3.8.3.1

17.3.9.1 Transmit power levels

The maximum allowable transmit power by regulatory domain is defined in Annex I.

See, e.g., 802.11-2007 § 17.3.9.1

17.3.9.6.2 Transmitter spectral flatness

The average energy of the constellations in each of the spectral lines –16.. –1 and +1.. +16 will deviate no

more than ± 2 dB from their average energy. The average energy of the constellations in each of the spectral

lines –26.. –17 and +17.. +26 will deviate no more than +2/–4 dB from the average energy of spectral lines

–16.. –1 and +1.. +16. The data for this test shall be derived from the channel estimation step.

See, e.g., 802.11-2007 § 17.3.9.6.2

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 529 of 946 PageID #:

4633
529

Claim 14 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 § I.2.2

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 530 of 946 PageID #:

4634
530

Claim 14 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 § I.2.3

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 531 of 946 PageID #:

4635
531

Claim 14 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 Figure 5-7

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 532 of 946 PageID #:

4636
532

Claim 14 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 Figure 10-6

Furthermore, this claim element is obvious in light of 802.11-2007 itself, when combined with any of 

the other references as charted for this claim element in Exs. A-1–A-31, First Supplemental Ex. ACase 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 533 of 946 PageID #:

4637
533

Claim 14 of the ’802 Patent Prior Art Reference – 802.11-2007

Obviousness 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;

802.11-2007 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.” See, e.g.: 

1.1 Scope

The scope of this standard is to define one medium access control (MAC) and several physical layer (PHY)

specifications for wireless connectivity for fixed, portable, and moving stations (STAs) within a local area.

See, e.g., 802.11-2007 § 1.1

5.1.1 How WLAN systems are different

Wireless networks have fundamental characteristics that make them significantly different from traditional

wired LANs. Some countries impose specific requirements for radio equipment in addition to those

specified in this standard. This standard does not provide information to meet these country-specific radio

regulations.

5.1.1.1 Destination address does not equal destination location

In wired LANs, an address is equivalent to a physical location. This is implicitly assumed in the design of

wired LANs. In IEEE Std 802.11, the addressable unit is a station (STA). The STA is a message destination,

but not (in general) a fixed location.

5.1.1.2 Media impact on design and performance

The PHYs used in IEEE Std 802.11 are fundamentally different from wired media. Thus IEEE 802.11 PHYs

a) Use a medium that has neither absolute nor readily observable boundaries outside of which STAs

with conformant PHY transceivers are known to be unable to receive network frames

b) Are unprotected from other signals that may be sharing the medium

c) Communicate over a medium significantly less reliable than wired PHYs

d) Have dynamic topologies

e) Lack full connectivity, and therefore the assumption normally made that every STA can hear every

other STA is invalid (i.e., STAs may be “hidden” from each other)

f) Have time-varying and asymmetric propagation properties

g) May experience interference from logically disjoint IEEE 802.11 networks operating in overlapping

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 534 of 946 PageID #:

4638
534

Claim 14 of the ’802 Patent Prior Art Reference – 802.11-2007

areas

Because of limitations on wireless PHY ranges, WLANs intended to cover reasonable geographic distances

may be built from basic coverage building blocks. When providing QoS services it should be understood

that the MAC endeavors to provide QoS “service guarantees” within the limitations of the medium

properties identified above. In other words, particularly in unlicensed spectrum, true guarantees are often not

possible. However, gradations of service are always possible; and in sufficiently controlled environments,

QoS guarantees can truly be made.

5.1.1.3 The impact of handling mobile STAs

One of the requirements of IEEE Std 802.11 is to handle mobile as well as portable STAs. A portable STA

is one that is moved from location to location, but that is only used while at a fixed location. Mobile STAs

actually access the LAN while in motion.

For technical reasons, it is not sufficient to handle only portable STAs. Propagation effects blur the

distinction between portable and mobile STAs; stationary STAs often appear to be mobile due to

propagation effects.

Another aspect of mobile STAs is that they may often be battery powered. Hence power management is

an important consideration. For example, it cannot be presumed that a STA’s receiver will always be

powered on.

See, e.g., 802.11-2007 § 5.1.1 - § 5.1.1.3

5.2 Components of the IEEE 802.11 architecture

The IEEE 802.11 architecture consists of several components that interact to provide a WLAN that supports

STA mobility transparently to upper layers.

The basic service set (BSS) is the basic building block of an IEEE 802.11 LAN. Figure 5-1 shows two BSSs,

each of which has two STAs that are members of the BSS.

It is useful to think of the ovals used to depict a BSS as the coverage area within which the member STAs of

the BSS may remain in communication. (The concept of area, while not precise, is often good enough.) This

area is called the Basic Service Area (BSA). If a STA moves out of its BSA, it can no longer directly

communicate with other STAs present in the BSA.

See, e.g., 802.11-2007 § 5.2

5.2.3 Distribution system (DS) concepts

PHY limitations determine the direct station-to-station distance that may be supported. For some networks

this distance is sufficient; for other networks, increased coverage is required.

Instead of existing independently, a BSS may also form a component of an extended form of network that is

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 535 of 946 PageID #:

4639
535

Claim 14 of the ’802 Patent Prior Art Reference – 802.11-2007

built with multiple BSSs. The architectural component used to interconnect BSSs is the DS.

IEEE Std 802.11 logically separates the WM from the distribution system medium (DSM). Each logical

medium is used for different purposes, by a different component of the architecture. The IEEE 802.11

definitions neither preclude, nor demand, that the multiple media be either the same or different.

Recognizing that the multiple media are logically different is key to understanding the flexibility of the

architecture. The IEEE 802.11 LAN architecture is specified independently of the physical characteristics of

any specific implementation.

The DS enables mobile device support by providing the logical services necessary to handle address to

destination mapping and seamless integration of multiple BSSs.

An access point (AP) is any entity that has STA functionality and enables access to the DS, via the WM for

associated STAs.

See, e.g., 802.11-2007 § 5.2.3

5.3.2 DSS

The service provided by the DS is known as the DSS.

This service is represented in the IEEE 802.11 architecture by arrows within the APs, indicating that the

service is used to cross media and possibly address space logical boundaries. An AP is a logical entity, and

the functions described may be shared by one or more physical entities.

The services that comprise the DSS are as follows:

a) Association

b) Disassociation

c) Distribution

d) Integration

e) Reassociation

f) QoS traffic scheduling (QoS facility only)

DSSs are specified for use by MAC sublayer entities.

Figure 5-7 combines the components from previous figures with both types of services to show the complete

IEEE 802.11 architecture.

See, e.g., 802.11-2007 § 5.3.2

5.4.4.1 TPC

Radio regulations may require radio local area networks (RLANs) operating in the 5 GHz band to use

transmitter power control, involving specification of a regulatory maximum transmit power and a mitigation

requirement for each allowed channel, to reduce interference with satellite services. The TPC service is used

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 536 of 946 PageID #:

4640
536

Claim 14 of the ’802 Patent Prior Art Reference – 802.11-2007

to satisfy this regulatory requirement.

The TPC service provides for the following:

— Association of STAs with an AP in a BSS based on the STAs’ power capability.

— Specification of regulatory and local maximum transmit power levels for the current channel.

— Selection of a transmit power for each transmission in a channel within constraints imposed by

regulatory requirements.

— Adaptation of transmit power based on a range of information, including path loss and link margin

estimates.

See, e.g., 802.11-2007 § 5.4.4.1

7.3.2.20 Channel Switch Announcement element

The Channel Switch Announcement element is used by an AP in a BSS or a STA in an IBSS to advertise

when it is changing to a new channel and the channel number of the new channel. The format of the Channel

Switch Announcement element is shown in Figure 7-57.

See, e.g., 802.11-2007 § 7.3.2.20

10.3.11 Spectrum management protocol layer model

The layer management extensions for measurement and channel switching assume a certain partition

of spectrum management functionality between the MLME and SME. This partitioning assumes that

policy decisions (e.g., regarding measurement and channel switching) reside in the SME, while the protocol

for measurement, switch timing, and the associated frame exchanges resides within the MLME (see

Figure 10-2).

...

The informative diagrams within this subclause further illustrate the spectrum management protocol model

adopted. Figure 10-3 and Figure 10-4 depict the measurement process for a peer STA to accept and reject a

measurement request, respectively. Figure 10-5 illustrates the TPC adaptation process. Lastly, Figure 10-6

depicts the management process for a channel switch using a Channel Switch Announcement frame.

See, e.g., 802.11-2007 § 10.3.11

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 537 of 946 PageID #:

4641
537

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 538 of 946 PageID #:

4642
538

Claim 14 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 § 10.4.3.2

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 539 of 946 PageID #:

4643
539

Claim 14 of the ’802 Patent Prior Art Reference – 802.11-2007

17.1 Introduction

This clause specifies the PHY entity for an orthogonal frequency division multiplexing (OFDM) system.

The OFDM system provides a WLAN with data payload communication capabilities of 6, 9, 12, 18, 24, 36,

48, and 54 Mb/s. The support of transmitting and receiving at data rates of 6, 12, and 24 Mb/s is mandatory.

The system uses 52 subcarriers that are modulated using binary or quadrature phase shift keying (BPSK or

QPSK) or using 16- or 64-quadrature amplitude modulation (16-QAM or 64-QAM). Forward error

correction coding (convolutional coding) is used with a coding rate of 1/2, 2/3, or 3/4.

The OFDM system also provides a “half-clocked” operation using 10 MHz channel spacings with data

communications capabilities of 3, 4.5, 6, 9, 12, 18, 24, and 27 Mb/s. The support of transmitting and

receiving at data rates of 3, 6, and 12 Mb/s is mandatory when using 10 MHz channel spacing. The halfclocked

operation doubles symbol times and clear channel assessment (CCA) times when using 10 MHz

channel spacing. The regulatory requirements and information regarding use of this OFDM system in

4.9 GHz and 5 GHz bands is in Annex I and Annex J.

The OFDM system also provides a “quarter-clocked” operation using 5 MHz channel spacing with data

communication capabilities of 1.5, 2.25, 3, 4.5, 6, 9, 12, and 13.5 Mb/s. The support of transmitting and

receiving at data rates of 1.5, 3, and 6 Mb/s is mandatory when using 5 MHz channel spacing. The quarterclocked

operation quadruples symbol times and CCA times when using 5 MHz channel spacing. The

regulatory requirements and information regarding use of this OFDM system in the 4.9 GHz band is in

Annex I and Annex J.

See, e.g., 802.11-2007 § 17.1

17.3.2.1 Overview of the PPDU encoding process

The encoding process is composed of many detailed steps, which are described fully in later subclauses, as

noted below. The following overview intends to facilitate understanding the details of the convergence

procedure:

a) Produce the PLCP Preamble field, composed of 10 repetitions of a “short training sequence” (used

for AGC convergence, diversity selection, timing acquisition, and coarse frequ ency acquisition in

the receiver) and two repetitions of a “long training sequence” (used for channel estimation and fine

frequency acquisition in the receiver), preceded by a guard interval (GI). Refer to 17.3.3 for details.

b) Produce the PLCP header field from the RATE, LENGTH, and SERVICE fields of the

TXVECTOR by filling the appropriate bit fields. The RATE and LENGTH fields of the PLCP

header are encoded by a convolutional code at a rate of R = 1/2, and are subsequently mapped onto a

single BPSK encoded OFDM symbol, denoted as the SIGNAL symbol. In order to facilitate a

reliable and timely detection of the RATE and LENGTH fields, 6 zero tail bits are inserted into the

PLCP header. The encoding of the SIGNAL field into an OFDM symbol follows the same steps for

convolutional encoding, interleaving, BPSK modulation, pilot insertion, Fourier transform, and

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 540 of 946 PageID #:

4644
540

Claim 14 of the ’802 Patent Prior Art Reference – 802.11-2007

prepending a GI as described subsequently for data transmission with BPSK-OFDM modulated at

coding rate 1/2. The contents of the SIGNAL field are not scrambled. Refer to 17.3.4 for details.

c) Calculate from RATE field of the TXVECTOR the number of data bits per OFDM symbol (NDBPS),

the coding rate (R), the number of bits in each OFDM subcarrier (NBPSC), and the number of coded

bits per OFDM symbol (NCBPS). Refer to 17.3.2.2 for details.

d) Append the PSDU to the SERVICE field of the TXVECTOR. Extend the resulting bit string with

zero bits (at least 6 bits) so that the resulting length will be a multiple of NDBPS. The resulting bit

string constitutes the DATA part of the packet. Refer to 17.3.5.3 for details.

e) Initiate the scrambler with a pseudo-random nonzero seed, generate a scrambling sequence, and

XOR it with the extended string of data bits. Refer to 17.3.5.4 for details.

f) Replace the six scrambled zero bits following the data with six nonscrambled zero bits. (Those bits

return the convolutional encoder to the zero state and are denoted as tail bits.) Refer to 17.3.5.2 for

details.

g) Encode the extended, scrambled data string with a convolutional encoder (R = 1/2). Omit (puncture)

some of the encoder output string (chosen according to “puncturing pattern”) to reach the desired

“coding rate.” Refer to 17.3.5.5 for details.

h) Divide the encoded bit string into groups of NCBPS bits. Within each group, perform an

“interleaving” (reordering) of the bits according to a rule corresponding to the desired RATE. Refer

to 17.3.5.6 for details.

i) Divide the resulting coded and interleaved data string into groups of NCBPS bits. For each of the bit

groups, convert the bit group into a complex number according to the modulation encoding tables.

Refer to 17.3.5.7 for details.

j) Divide the complex number string into groups of 48 complex numbers. Each such group will be

associated with one OFDM symbol. In each group, the complex numbers will be numbered 0 to 47

and mapped hereafter into OFDM subcarriers numbered –26 to –22, –20 to –8, –6 to –1, 1 to 6,

8 to 20, and 22 to 26. The subcarriers –21, –7, 7, and 21 are skipped and, subsequently, used for

inserting pilot subcarriers. The 0 subcarrier, associated with center frequency, is omitted and filled

with zero value. Refer to 17.3.5.9 for details.

k) Four subcarriers are inserted as pilots into positions –21, –7, 7, and 21. The total number of the

subcarriers is 52 (48 + 4). Refer to 17.3.5.8 for details.

l) For each group of subcarriers –26 to 26, convert the subcarriers to time domain using inverse

Fourier transform. Prepend to the Fourier-transformed waveform a circular extension of itself thus

forming a GI, and truncate the resulting periodic waveform to a single OFDM symbol length by

applying time domain windowing. Refer to 17.3.5.9 for details.

m) Append the OFDM symbols one after another, starting after the SIGNAL symbol describing the

RATE and LENGTH fields. Refer to 17.3.5.9 for details.

n) Up-convert the resulting “complex baseband” waveform to an RF according to the center frequency

of the desired channel and transmit. Refer to 17.3.2.4 and 17.3.8.1 for details.

An illustration of the transmitted frame and its parts appears in Figure 17-4 (in 17.3.3).

See, e.g., 802.11-2007 § 17.3.2.1

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 541 of 946 PageID #:

4645
541

Claim 14 of the ’802 Patent Prior Art Reference – 802.11-2007

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 542 of 946 PageID #:

4646
542

Claim 14 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 § 17.3.2.3

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 543 of 946 PageID #:

4647
543

Claim 14 of the ’802 Patent Prior Art Reference – 802.11-2007

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 544 of 946 PageID #:

4648
544

Claim 14 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 § 17.3.2.4 Eq. (17-1)

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 545 of 946 PageID #:

4649
545

Claim 14 of the ’802 Patent Prior Art Reference – 802.11-2007

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 546 of 946 PageID #:

4650
546

Claim 14 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 § 17.3.2.5

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 547 of 946 PageID #:

4651
547

Claim 14 of the ’802 Patent Prior Art Reference – 802.11-2007

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 548 of 946 PageID #:

4652
548

See, e.g., 802.11-2007 § 17.3.3

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 549 of 946 PageID #:

4653
549

Claim 14 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 § 17.3.5.7

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 550 of 946 PageID #:

4654
550

Claim 14 of the ’802 Patent Prior Art Reference – 802.11-2007

17.3.5.8 Pilot subcarriers

In each OFDM symbol, four of the subcarriers are dedicated to pilot signals in order to make the coherent

detection robust against frequency offsets and phase noise. These pilot signals shall be put in subcarriers

–21, –7, 7, and 21. The pilots shall be BPSK modulated by a pseudo-binary sequence to prevent the

generation of spectral lines. The contribution of the pilot subcarriers to each OFDM symbol is described in

17.3.5.9.

See, e.g., 802.11-2007 § 17.3.5.8

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 551 of 946 PageID #:

4655
551

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 552 of 946 PageID #:

4656
552

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 553 of 946 PageID #:

4657
553

Claim 14 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 § 17.3.5.9

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 554 of 946 PageID #:

4658
554

Claim 14 of the ’802 Patent Prior Art Reference – 802.11-2007

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 555 of 946 PageID #:

4659
555

Claim 14 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 § 17.3.8.1

17.3.8.3.1 Operating frequency range

The OFDM PHY shall operate in the 5 GHz band, as allocated by a regulatory body in its operational region.

Spectrum allocation in the 5 GHz band is subject to authorities responsible for geographic-specific

regulatory domains (e.g., global, regional, and national). The particular channelization to be used for this

standard is dependent on such allocation, as well as the associated regulations for use of the allocations.

These regulations are subject to revision, or may be superseded.

In some regulatory domains, several frequency bands may be available for OFDM PHY-based WLANs.

These bands may be contiguous or not, and different regulatory limits may be applicable. A compliant

OFDM PHY shall support at least one frequency band in at least one regulatory domain. The support of

specific regulatory domains, and bands within the domains, shall be indicated by PLME attributes

dot11RegDomainsSupported and dot11FrequencyBandsSupported.

See, e.g., 802.11-2007 § 17.3.8.3.1

17.3.9.1 Transmit power levels

The maximum allowable transmit power by regulatory domain is defined in Annex I.

See, e.g., 802.11-2007 § 17.3.9.1

17.3.9.6.2 Transmitter spectral flatness

The average energy of the constellations in each of the spectral lines –16.. –1 and +1.. +16 will deviate no

more than ± 2 dB from their average energy. The average energy of the constellations in each of the spectral

lines –26.. –17 and +17.. +26 will deviate no more than +2/–4 dB from the average energy of spectral lines

–16.. –1 and +1.. +16. The data for this test shall be derived from the channel estimation step.

See, e.g., 802.11-2007 § 17.3.9.6.2

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 556 of 946 PageID #:

4660
556

Claim 14 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 § I.2.2

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 557 of 946 PageID #:

4661
557

Claim 14 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 § I.2.3

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 558 of 946 PageID #:

4662
558

Claim 14 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 Figure 5-7

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 559 of 946 PageID #:

4663
559

Claim 14 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 Figure 10-6

Furthermore, this claim element is obvious in light of 802.11-2007 itself, when combined with any of 

the other references as charted for this claim element in Exs. A-1–A-31, First Supplemental Ex. ACase 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 560 of 946 PageID #:

4664
560

Claim 14 of the ’802 Patent Prior Art Reference – 802.11-2007

Obviousness 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.

[14.5] down-converting the 

amplified received upconverted signal using a first 

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

802.11-2007 discloses “down-converting the amplified received up-converted signal using a first 

down-converter and a signal corresponding to the first RF center frequency to produce a fourth 

analog signal corresponding to the first analog signal.” See, e.g.: 

1.1 Scope

The scope of this standard is to define one medium access control (MAC) and several physical layer (PHY)

specifications for wireless connectivity for fixed, portable, and moving stations (STAs) within a local area.

See, e.g., 802.11-2007 § 1.1

5.1.1 How WLAN systems are different

Wireless networks have fundamental characteristics that make them significantly different from traditional

wired LANs. Some countries impose specific requirements for radio equipment in addition to those

specified in this standard. This standard does not provide information to meet these country -specific radio

regulations.

5.1.1.1 Destination address does not equal destination location

In wired LANs, an address is equivalent to a physical location. This is implicitly assumed in the design of

wired LANs. In IEEE Std 802.11, the addressable unit is a station (STA). The STA is a message destination,

but not (in general) a fixed location.

5.1.1.2 Media impact on design and performance

The PHYs used in IEEE Std 802.11 are fundamentally different from wired media. Thus IEEE 802.11 PHYs

a) Use a medium that has neither absolute nor readily observable boun daries outside of which STAs

with conformant PHY transceivers are known to be unable to receive network frames

b) Are unprotected from other signals that may be sharing the medium

c) Communicate over a medium significantly less reliable than wired PHYs

d) Have dynamic topologies

e) Lack full connectivity, and therefore the assumption normally made that every STA can hear every

other STA is invalid (i.e., STAs may be “hidden” from each other)

f) Have time-varying and asymmetric propagation properties

g) May experience interference from logically disjoint IEEE 802.11 networks operating in overlapping

areas

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 561 of 946 PageID #:

4665
561

Claim 14 of the ’802 Patent Prior Art Reference – 802.11-2007

Because of limitations on wireless PHY ranges, WLANs intended to cover reasonable geographic distances

may be built from basic coverage building blocks. When providing QoS services it should be understood

that the MAC endeavors to provide QoS “service guarantees” within the limitations of the medium

properties identified above. In other words, particularly in unlicensed spectrum, true guarantees are often not

possible. However, gradations of service are always possible; and in sufficiently controlled environments,

QoS guarantees can truly be made.

5.1.1.3 The impact of handling mobile STAs

One of the requirements of IEEE Std 802.11 is to handle mobile as well as portable STAs. A portable STA

is one that is moved from location to location, but that is only used while at a fixed location. Mobile STAs

actually access the LAN while in motion.

For technical reasons, it is not sufficient to handle only portable STAs. Propagation effects blur the

distinction between portable and mobile STAs; stationary STAs often appear to be mobile due to

propagation effects.

Another aspect of mobile STAs is that they may often be battery powered. Hence power management is

an important consideration. For example, it cannot be presumed that a STA’s receiver will always be

powered on.

See, e.g., 802.11-2007 § 5.1.1 - § 5.1.1.3

5.2 Components of the IEEE 802.11 architecture

The IEEE 802.11 architecture consists of several components that interact to provide a WLAN that supports

STA mobility transparently to upper layers.

The basic service set (BSS) is the basic building block of an IEEE 802.11 LAN. Figure 5 -1 shows two BSSs,

each of which has two STAs that are members of the BSS.

It is useful to think of the ovals used to depict a BSS as the coverage area within which the member STAs of

the BSS may remain in communication. (The concept of area, while not precise, is often good enough.) This

area is called the Basic Service Area (BSA). If a STA moves out of its BSA, it can no longer directly

communicate with other STAs present in the BSA.

See, e.g., 802.11-2007 § 5.2

5.2.3 Distribution system (DS) concepts

PHY limitations determine the direct station-to-station distance that may be supported. For some networks

this distance is sufficient; for other networks, increased coverage is required.

Instead of existing independently, a BSS may also form a component of an extended form of network that is

built with multiple BSSs. The architectural component used to interconnect BSSs is the DS.

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 562 of 946 PageID #:

4666
562

Claim 14 of the ’802 Patent Prior Art Reference – 802.11-2007

IEEE Std 802.11 logically separates the WM from the distribution system medium (DSM). Each logical

medium is used for different purposes, by a different component of the architecture. The IEEE 802.11

definitions neither preclude, nor demand, that the multiple media be either the same or different.

Recognizing that the multiple media are logically different is key to understanding the flexibility of the

architecture. The IEEE 802.11 LAN architecture is specified independently of the physical characteristics of

any specific implementation.

The DS enables mobile device support by providing the logical services necessary to handle address to

destination mapping and seamless integration of multiple BSSs.

An access point (AP) is any entity that has STA functionality and enables access to the DS, via the WM for

associated STAs.

See, e.g., 802.11-2007 § 5.2.3

5.3.2 DSS

The service provided by the DS is known as the DSS.

This service is represented in the IEEE 802.11 architecture by arrows within the APs, indicating that the

service is used to cross media and possibly address space logical boundaries. An AP is a logical entity, and

the functions described may be shared by one or more physical entities.

The services that comprise the DSS are as follows:

a) Association

b) Disassociation

c) Distribution

d) Integration

e) Reassociation

f) QoS traffic scheduling (QoS facility only)

DSSs are specified for use by MAC sublayer entities.

Figure 5-7 combines the components from previous figures with both types of services to show the complete

IEEE 802.11 architecture.

See, e.g., 802.11-2007 § 5.3.2

5.4.4.1 TPC

Radio regulations may require radio local area networks (RLANs) operating in the 5 GHz band to use

transmitter power control, involving specification of a regulatory maximum transmit power and a mitigation

requirement for each allowed channel, to reduce interference with satellite services. The TPC service is used

to satisfy this regulatory requirement.

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 563 of 946 PageID #:

4667
563

Claim 14 of the ’802 Patent Prior Art Reference – 802.11-2007

The TPC service provides for the following:

— Association of STAs with an AP in a BSS based on the STAs’ power capability.

— Specification of regulatory and local maximum transmit power levels for the current channel.

— Selection of a transmit power for each transmission in a channel within constraints imposed by

regulatory requirements.

— Adaptation of transmit power based on a range of information, including path loss and link margin

estimates.

See, e.g., 802.11-2007 § 5.4.4.1

7.3.2.20 Channel Switch Announcement element

The Channel Switch Announcement element is used by an AP in a BSS or a STA in an IBSS to advertise

when it is changing to a new channel and the channel number of the new channel. The format of the Channel

Switch Announcement element is shown in Figure 7-57.

See, e.g., 802.11-2007 § 7.3.2.20

10.3.11 Spectrum management protocol layer model

The layer management extensions for measurement and channel switching assume a certain partition

of spectrum management functionality between the MLME and SME. This partitioning assumes that

policy decisions (e.g., regarding measurement and channel switching) reside in the SME, while the protocol

for measurement, switch timing, and the associated frame exchanges resides within the MLME (see

Figure 10-2).

...

The informative diagrams within this subclause further illustrate the spectrum management protocol model

adopted. Figure 10-3 and Figure 10-4 depict the measurement process for a peer STA to accept and reject a

measurement request, respectively. Figure 10-5 illustrates the TPC adaptation process. Lastly, Figure 10-6

depicts the management process for a channel switch using a Channel Switch Announcement frame.

See, e.g., 802.11-2007 § 10.3.11

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 564 of 946 PageID #:

4668
564

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 565 of 946 PageID #:

4669
565

Claim 14 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 § 10.4.3.2

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 566 of 946 PageID #:

4670
566

Claim 14 of the ’802 Patent Prior Art Reference – 802.11-2007

17.1 Introduction

This clause specifies the PHY entity for an orthogonal frequency division multiplexing (OFDM) system.

The OFDM system provides a WLAN with data payload communication capabilities of 6, 9, 12, 18, 24, 36,

48, and 54 Mb/s. The support of transmitting and receiving at data rates of 6, 12, and 24 Mb/s is mandatory.

The system uses 52 subcarriers that are modulated using binary or quadrature phase shift keying (BPSK or

QPSK) or using 16- or 64-quadrature amplitude modulation (16-QAM or 64-QAM). Forward error

correction coding (convolutional coding) is used with a coding rate of 1/2, 2/3, or 3/4.

The OFDM system also provides a “half-clocked” operation using 10 MHz channel spacings with data

communications capabilities of 3, 4.5, 6, 9, 12, 18, 24, and 27 Mb/s. The support of transmitting and

receiving at data rates of 3, 6, and 12 Mb/s is mandatory when using 10 MHz channel spacing. The halfclocked

operation doubles symbol times and clear channel assessment (CCA) times when using 10 MHz

channel spacing. The regulatory requirements and information regarding use of this OFDM system in

4.9 GHz and 5 GHz bands is in Annex I and Annex J.

The OFDM system also provides a “quarter-clocked” operation using 5 MHz channel spacing with data

communication capabilities of 1.5, 2.25, 3, 4.5, 6, 9, 12, and 13.5 Mb/s. The support of transmitting and

receiving at data rates of 1.5, 3, and 6 Mb/s is mandatory when using 5 MHz channel spacing. The quarterclocked

operation quadruples symbol times and CCA times when using 5 MHz channel spacing. The

regulatory requirements and information regarding use of this OFDM system in the 4.9 GHz band is in

Annex I and Annex J.

See, e.g., 802.11-2007 § 17.1

17.3.2.1 Overview of the PPDU encoding process

The encoding process is composed of many detailed steps, which are described fully in later subclauses, as

noted below. The following overview intends to facilitate understanding the details of the convergence

procedure:

a) Produce the PLCP Preamble field, composed of 10 repetitions of a “short training sequence” (used

for AGC convergence, diversity selection, timing acquisition, and coarse frequency acquisition in

the receiver) and two repetitions of a “long training sequence” (used for channel estimation and fine

frequency acquisition in the receiver), preceded by a guard interval (GI). Refer to 17.3.3 for details.

b) Produce the PLCP header field from the RATE, LENGTH, and SERVICE fields of the

TXVECTOR by filling the appropriate bit fields. The RATE and LENGTH fields of the PLCP

header are encoded by a convolutional code at a rate of R = 1/2, and are subsequently mapped onto a

single BPSK encoded OFDM symbol, denoted as the SIGNAL symbol. In order to facilitate a

reliable and timely detection of the RATE and LENGTH fields, 6 zero tail bits are inserted into the

PLCP header. The encoding of the SIGNAL field into an OFDM symbol follows the same steps for

convolutional encoding, interleaving, BPSK modulation, pilot insertion, Fourier transform, and

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 567 of 946 PageID #:

4671
567

Claim 14 of the ’802 Patent Prior Art Reference – 802.11-2007

prepending a GI as described subsequently for data transmission with BPSK-OFDM modulated at

coding rate 1/2. The contents of the SIGNAL field are not scrambled. Refer to 17.3.4 for details.

c) Calculate from RATE field of the TXVECTOR the number of data bits per OFDM symbol (NDBPS),

the coding rate (R), the number of bits in each OFDM subcarrier (NBPSC), and the number of coded

bits per OFDM symbol (NCBPS). Refer to 17.3.2.2 for details.

d) Append the PSDU to the SERVICE field of the TXVECTOR. Extend the resulting bit string with

zero bits (at least 6 bits) so that the resulting length will be a multiple of NDBPS. The resulting bit

string constitutes the DATA part of the packet. Refer to 17.3.5.3 for details.

e) Initiate the scrambler with a pseudo-random nonzero seed, generate a scrambling sequence, and

XOR it with the extended string of data bits. Refer to 17.3.5.4 for details.

f) Replace the six scrambled zero bits following the data with six nonscrambled zero bits. (Those bits

return the convolutional encoder to the zero state and are denoted as tail bits.) Refer to 17.3.5.2 for

details.

g) Encode the extended, scrambled data string with a convolutional encoder (R = 1/2). Omit (puncture)

some of the encoder output string (chosen according to “puncturing pattern”) to reach the desired

“coding rate.” Refer to 17.3.5.5 for details.

h) Divide the encoded bit string into groups of NCBPS bits. Within each group, perform an

“interleaving” (reordering) of the bits according to a rule corresponding to the desired RATE. Refer

to 17.3.5.6 for details.

i) Divide the resulting coded and interleaved data string into groups of NCBPS bits. For each of the bit

groups, convert the bit group into a complex number according to the modulation encoding tables.

Refer to 17.3.5.7 for details.

j) Divide the complex number string into groups of 48 complex numbers. Each such group will be

associated with one OFDM symbol. In each group, the complex numbers will be numbered 0 to 47

and mapped hereafter into OFDM subcarriers numbered –26 to –22, –20 to –8, –6 to –1, 1 to 6,

8 to 20, and 22 to 26. The subcarriers –21, –7, 7, and 21 are skipped and, subsequently, used for

inserting pilot subcarriers. The 0 subcarrier, associated with center frequency, is omitted and filled

with zero value. Refer to 17.3.5.9 for details.

k) Four subcarriers are inserted as pilots into positions –21, –7, 7, and 21. The total number of the

subcarriers is 52 (48 + 4). Refer to 17.3.5.8 for details.

l) For each group of subcarriers –26 to 26, convert the subcarriers to time domain using inverse

Fourier transform. Prepend to the Fourier-transformed waveform a circular extension of itself thus

forming a GI, and truncate the resulting periodic waveform to a single OFDM symbol length by

applying time domain windowing. Refer to 17.3.5.9 for details.

m) Append the OFDM symbols one after another, starting after the SIGNAL symbol describing the

RATE and LENGTH fields. Refer to 17.3.5.9 for details.

n) Up-convert the resulting “complex baseband” waveform to an RF according to the center frequency

of the desired channel and transmit. Refer to 17.3.2.4 and 17.3.8.1 for details.

An illustration of the transmitted frame and its parts appears in Figure 17-4 (in 17.3.3).

See, e.g., 802.11-2007 § 17.3.2.1

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 568 of 946 PageID #:

4672
568

Claim 14 of the ’802 Patent Prior Art Reference – 802.11-2007

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 569 of 946 PageID #:

4673
569

Claim 14 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 § 17.3.2.3

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 570 of 946 PageID #:

4674
570

Claim 14 of the ’802 Patent Prior Art Reference – 802.11-2007

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 571 of 946 PageID #:

4675
571

Claim 14 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 § 17.3.2.4 Eq. (17-1)

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 572 of 946 PageID #:

4676
572

Claim 14 of the ’802 Patent Prior Art Reference – 802.11-2007

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 573 of 946 PageID #:

4677
573

Claim 14 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 § 17.3.2.5

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 574 of 946 PageID #:

4678
574

Claim 14 of the ’802 Patent Prior Art Reference – 802.11-2007

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 575 of 946 PageID #:

4679
575

See, e.g., 802.11-2007 § 17.3.3

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 576 of 946 PageID #:

4680
576

Claim 14 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 § 17.3.5.7

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 577 of 946 PageID #:

4681
577

Claim 14 of the ’802 Patent Prior Art Reference – 802.11-2007

17.3.5.8 Pilot subcarriers

In each OFDM symbol, four of the subcarriers are dedicated to pilot signals in order to make the coherent

detection robust against frequency offsets and phase noise. These pilot signals shall be put in subcarriers

–21, –7, 7, and 21. The pilots shall be BPSK modulated by a pseudo-binary sequence to prevent the

generation of spectral lines. The contribution of the pilot subcarriers to each OFDM symbol is described in

17.3.5.9.

See, e.g., 802.11-2007 § 17.3.5.8

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 578 of 946 PageID #:

4682
578

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 579 of 946 PageID #:

4683
579

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 580 of 946 PageID #:

4684
580

Claim 14 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 § 17.3.5.9

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 581 of 946 PageID #:

4685
581

Claim 14 of the ’802 Patent Prior Art Reference – 802.11-2007

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 582 of 946 PageID #:

4686
582

Claim 14 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 § 17.3.8.1

17.3.8.3.1 Operating frequency range

The OFDM PHY shall operate in the 5 GHz band, as allocated by a regulatory body in its operational region.

Spectrum allocation in the 5 GHz band is subject to authorities responsible for geograp hic-specific

regulatory domains (e.g., global, regional, and national). The particular channelization to be used for this

standard is dependent on such allocation, as well as the associated regulations for use of the allocations.

These regulations are subject to revision, or may be superseded.

In some regulatory domains, several frequency bands may be available for OFDM PHY-based WLANs.

These bands may be contiguous or not, and different regulatory limits may be applicable. A compliant

OFDM PHY shall support at least one frequency band in at least one regulatory domain. The support of

specific regulatory domains, and bands within the domains, shall be indicated by PLME attributes

dot11RegDomainsSupported and dot11FrequencyBandsSupported.

See, e.g., 802.11-2007 § 17.3.8.3.1

17.3.9.1 Transmit power levels

The maximum allowable transmit power by regulatory domain is defined in Annex I.

See, e.g., 802.11-2007 § 17.3.9.1

17.3.9.6.2 Transmitter spectral flatness

The average energy of the constellations in each of the spectral lines –16.. –1 and +1.. +16 will deviate no

more than ± 2 dB from their average energy. The average energy of the constellations in each of the spectral

lines –26.. –17 and +17.. +26 will deviate no more than +2/–4 dB from the average energy of spectral lines

–16.. –1 and +1.. +16. The data for this test shall be derived from the channel estimation step.

See, e.g., 802.11-2007 § 17.3.9.6.2

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 583 of 946 PageID #:

4687
583

Claim 14 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 § I.2.2

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 584 of 946 PageID #:

4688
584

Claim 14 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 § I.2.3

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 585 of 946 PageID #:

4689
585

Claim 14 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 Figure 5-7

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 586 of 946 PageID #:

4690
586

Claim 14 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 Figure 10-6

Furthermore, this claim element is obvious in light of 802.11-2007 itself, when combined with any of 

the other references as charted for this claim element in Exs. A-1–A-31, First Supplemental Ex. ACase 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 587 of 946 PageID #:

4691
587

Claim 14 of the ’802 Patent Prior Art Reference – 802.11-2007

Obviousness 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.

[14.6] 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.

802.11-2007 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.” See, e.g.: 

1.1 Scope

The scope of this standard is to define one medium access control (MAC) and several physical layer (PHY)

specifications for wireless connectivity for fixed, portable, and moving stations (STAs) within a local area.

See, e.g., 802.11-2007 § 1.1

5.1.1 How WLAN systems are different

Wireless networks have fundamental characteristics that make them significantly different from traditional

wired LANs. Some countries impose specific requirements for radio equipment in addition to those

specified in this standard. This standard does not provide information to meet these country -specific radio

regulations.

5.1.1.1 Destination address does not equal destination location

In wired LANs, an address is equivalent to a physical location. This is implicitly assumed in the design of

wired LANs. In IEEE Std 802.11, the addressable unit is a station (STA). The STA is a message destination,

but not (in general) a fixed location.

5.1.1.2 Media impact on design and performance

The PHYs used in IEEE Std 802.11 are fundamentally different from wired media. Thus IEEE 802.11 PHYs

a) Use a medium that has neither absolute nor readily observable boundaries outside of which STAs

with conformant PHY transceivers are known to be unable to receive network frames

b) Are unprotected from other signals that may be sharing the medium

c) Communicate over a medium significantly less reliable than wired PHYs

d) Have dynamic topologies

e) Lack full connectivity, and therefore the assumption normally made that every STA can hear every

other STA is invalid (i.e., STAs may be “hidden” from each other)

f) Have time-varying and asymmetric propagation properties

g) May experience interference from logically disjoint IEEE 802.11 networks operating in overlapping

areas

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 588 of 946 PageID #:

4692
588

Claim 14 of the ’802 Patent Prior Art Reference – 802.11-2007

Because of limitations on wireless PHY ranges, WLANs intended to cover reasonable geographic distances

may be built from basic coverage building blocks. When providing QoS services it should be understood

that the MAC endeavors to provide QoS “service guarantees” within the limitations of the medium

properties identified above. In other words, particularly in unlicensed spectrum, true guarantees are often not

possible. However, gradations of service are always possible; and in sufficiently controlled en vironments,

QoS guarantees can truly be made.

5.1.1.3 The impact of handling mobile STAs

One of the requirements of IEEE Std 802.11 is to handle mobile as well as portable STAs. A portable STA

is one that is moved from location to location, but that is only used while at a fixed location. Mobile STAs

actually access the LAN while in motion.

For technical reasons, it is not sufficient to handle only portable STAs. Propagation effects blur the

distinction between portable and mobile STAs; stationary STAs often appear to be mobile due to

propagation effects.

Another aspect of mobile STAs is that they may often be battery powered. Hence power management is

an important consideration. For example, it cannot be presumed that a STA’s receiver will always be

powered on.

See, e.g., 802.11-2007 § 5.1.1 - § 5.1.1.3

5.2 Components of the IEEE 802.11 architecture

The IEEE 802.11 architecture consists of several components that interact to provide a WLAN that supports

STA mobility transparently to upper layers.

The basic service set (BSS) is the basic building block of an IEEE 802.11 LAN. Figure 5 -1 shows two BSSs,

each of which has two STAs that are members of the BSS.

It is useful to think of the ovals used to depict a BSS as the coverage area within which the membe r STAs of

the BSS may remain in communication. (The concept of area, while not precise, is often good enough.) This

area is called the Basic Service Area (BSA). If a STA moves out of its BSA, it can no longer directly

communicate with other STAs present in the BSA.

See, e.g., 802.11-2007 § 5.2

5.2.3 Distribution system (DS) concepts

PHY limitations determine the direct station-to-station distance that may be supported. For some networks

this distance is sufficient; for other networks, increased coverage is required.

Instead of existing independently, a BSS may also form a component of an extended form of network that is

built with multiple BSSs. The architectural component used to interconnect BSSs is the DS.

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 589 of 946 PageID #:

4693
589

Claim 14 of the ’802 Patent Prior Art Reference – 802.11-2007

IEEE Std 802.11 logically separates the WM from the distribution system medium (DSM). Each logical

medium is used for different purposes, by a different component of the architecture. The IEEE 802.11

definitions neither preclude, nor demand, that the multiple media be either the same or different.

Recognizing that the multiple media are logically different is key to understanding the flexibility of the

architecture. The IEEE 802.11 LAN architecture is specified independently of the physical characteristics of

any specific implementation.

The DS enables mobile device support by providing the logical services necessary to handle address to

destination mapping and seamless integration of multiple BSSs.

An access point (AP) is any entity that has STA functionality and enables access to the DS, via the WM for

associated STAs.

See, e.g., 802.11-2007 § 5.2.3

5.3.2 DSS

The service provided by the DS is known as the DSS.

This service is represented in the IEEE 802.11 architecture by arrows within the APs, indicating that the

service is used to cross media and possibly address space logical boundaries. An AP is a logical entity, and

the functions described may be shared by one or more physical entities.

The services that comprise the DSS are as follows:

a) Association

b) Disassociation

c) Distribution

d) Integration

e) Reassociation

f) QoS traffic scheduling (QoS facility only)

DSSs are specified for use by MAC sublayer entities.

Figure 5-7 combines the components from previous figures with both types of services to show the complete

IEEE 802.11 architecture.

See, e.g., 802.11-2007 § 5.3.2

5.4.4.1 TPC

Radio regulations may require radio local area networks (RLANs) operating in the 5 GHz band to use

transmitter power control, involving specification of a regulatory maximum transmit power and a mitigation

requirement for each allowed channel, to reduce interference with satellite services. The TPC service is used

to satisfy this regulatory requirement.

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 590 of 946 PageID #:

4694
590

Claim 14 of the ’802 Patent Prior Art Reference – 802.11-2007

The TPC service provides for the following:

— Association of STAs with an AP in a BSS based on the STAs’ power capability.

— Specification of regulatory and local maximum transmit power levels for the current channel.

— Selection of a transmit power for each transmission in a channel within constraints imposed by

regulatory requirements.

— Adaptation of transmit power based on a range of information, including path loss and link margin

estimates.

See, e.g., 802.11-2007 § 5.4.4.1

7.3.2.20 Channel Switch Announcement element

The Channel Switch Announcement element is used by an AP in a BSS or a STA in an IBSS to advertise

when it is changing to a new channel and the channel number of the new channel. The format of the Channel

Switch Announcement element is shown in Figure 7-57.

See, e.g., 802.11-2007 § 7.3.2.20

10.3.11 Spectrum management protocol layer model

The layer management extensions for measurement and channel switching assume a certain partition

of spectrum management functionality between the MLME and SME. This partitioning assumes that

policy decisions (e.g., regarding measurement and channel switching) reside in the SME, while the protocol

for measurement, switch timing, and the associated frame exchanges resides within the MLME (see

Figure 10-2).

...

The informative diagrams within this subclause further illustrate the spectrum management protocol model

adopted. Figure 10-3 and Figure 10-4 depict the measurement process for a peer STA to accept and reject a

measurement request, respectively. Figure 10-5 illustrates the TPC adaptation process. Lastly, Figure 10-6

depicts the management process for a channel switch using a Channel Switch Announcement frame.

See, e.g., 802.11-2007 § 10.3.11

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 591 of 946 PageID #:

4695
591

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 592 of 946 PageID #:

4696
592

Claim 14 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 § 10.4.3.2

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 593 of 946 PageID #:

4697
593

Claim 14 of the ’802 Patent Prior Art Reference – 802.11-2007

17.1 Introduction

This clause specifies the PHY entity for an orthogonal frequency division multiplexing (OFDM) system.

The OFDM system provides a WLAN with data payload communication capabilities of 6, 9, 12, 18, 24, 36,

48, and 54 Mb/s. The support of transmitting and receiving at data rates of 6, 12, and 24 Mb/s is mandatory.

The system uses 52 subcarriers that are modulated using binary or quadrature phase shift keying (BPSK or

QPSK) or using 16- or 64-quadrature amplitude modulation (16-QAM or 64-QAM). Forward error

correction coding (convolutional coding) is used with a coding rate of 1/2, 2 /3, or 3/4.

The OFDM system also provides a “half-clocked” operation using 10 MHz channel spacings with data

communications capabilities of 3, 4.5, 6, 9, 12, 18, 24, and 27 Mb/s. The support of transmitting and

receiving at data rates of 3, 6, and 12 Mb/s is mandatory when using 10 MHz channel spacing. The halfclocked

operation doubles symbol times and clear channel assessment (CCA) times when using 10 MHz

channel spacing. The regulatory requirements and information regarding use of this OFDM system in

4.9 GHz and 5 GHz bands is in Annex I and Annex J.

The OFDM system also provides a “quarter-clocked” operation using 5 MHz channel spacing with data

communication capabilities of 1.5, 2.25, 3, 4.5, 6, 9, 12, and 13.5 Mb/s. The support of transmitting and

receiving at data rates of 1.5, 3, and 6 Mb/s is mandatory when using 5 MHz channel spacing. The quarterclocked

operation quadruples symbol times and CCA times when using 5 MHz channel spacing. The

regulatory requirements and information regarding use of this OFDM system in the 4.9 GHz band is in

Annex I and Annex J.

See, e.g., 802.11-2007 § 17.1

17.3.2.1 Overview of the PPDU encoding process

The encoding process is composed of many detailed steps, which are described fully in later subclauses, as

noted below. The following overview intends to facilitate understanding the details of the convergence

procedure:

a) Produce the PLCP Preamble field, composed of 10 repetitions of a “short training sequence” (used

for AGC convergence, diversity selection, timing acquisition, and coarse frequency acquisition in

the receiver) and two repetitions of a “long training sequence” (used for channel estimation and fine

frequency acquisition in the receiver), preceded by a guard interval (GI). Refer to 17.3.3 for details.

b) Produce the PLCP header field from the RATE, LENGTH, and SERVICE fields of the

TXVECTOR by filling the appropriate bit fields. The RATE and LENGTH fields of the PLCP

header are encoded by a convolutional code at a rate of R = 1/2, and are subsequently mapped onto a

single BPSK encoded OFDM symbol, denoted as the SIGNAL symbol. In order to facilitate a

reliable and timely detection of the RATE and LENGTH fields, 6 zero tail bits are inserted into the

PLCP header. The encoding of the SIGNAL field into an OFDM symbol follows the same steps for

convolutional encoding, interleaving, BPSK modulation, pilot insertion, Fourier transform, and

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 594 of 946 PageID #:

4698
594

Claim 14 of the ’802 Patent Prior Art Reference – 802.11-2007

prepending a GI as described subsequently for data transmission with BPSK-OFDM modulated at

coding rate 1/2. The contents of the SIGNAL field are not scrambled. Refer to 17.3.4 for details.

c) Calculate from RATE field of the TXVECTOR the number of data bits per OFDM symbol (NDBPS),

the coding rate (R), the number of bits in each OFDM subcarrier (NBPSC), and the number of coded

bits per OFDM symbol (NCBPS). Refer to 17.3.2.2 for details.

d) Append the PSDU to the SERVICE field of the TXVECTOR. Extend the resulting bit string with

zero bits (at least 6 bits) so that the resulting length will be a multiple of NDBPS. The resulting bit

string constitutes the DATA part of the packet. Refer to 17.3.5.3 for details.

e) Initiate the scrambler with a pseudo-random nonzero seed, generate a scrambling sequence, and

XOR it with the extended string of data bits. Refer to 17.3.5.4 for details.

f) Replace the six scrambled zero bits following the data with six nonscrambled zero bits. (Those bits

return the convolutional encoder to the zero state and are denoted as tail bits.) Refer to 17.3.5.2 for

details.

g) Encode the extended, scrambled data string with a convolutional encoder (R = 1/2). Omit (puncture)

some of the encoder output string (chosen according to “puncturing pattern”) to reach the desired

“coding rate.” Refer to 17.3.5.5 for details.

h) Divide the encoded bit string into groups of NCBPS bits. Within each group, perform an

“interleaving” (reordering) of the bits according to a rule corresponding to the desired RATE. Refer

to 17.3.5.6 for details.

i) Divide the resulting coded and interleaved data string into groups of NCBPS bits. For each of the bit

groups, convert the bit group into a complex number according to the modulation encoding tables.

Refer to 17.3.5.7 for details.

j) Divide the complex number string into groups of 48 complex numbers. Each such group will be

associated with one OFDM symbol. In each group, the complex numbers will be numbered 0 to 47

and mapped hereafter into OFDM subcarriers numbered –26 to –22, –20 to –8, –6 to –1, 1 to 6,

8 to 20, and 22 to 26. The subcarriers –21, –7, 7, and 21 are skipped and, subsequently, used for

inserting pilot subcarriers. The 0 subcarrier, associated with center frequency, is omitted and filled

with zero value. Refer to 17.3.5.9 for details.

k) Four subcarriers are inserted as pilots into positions –21, –7, 7, and 21. The total number of the

subcarriers is 52 (48 + 4). Refer to 17.3.5.8 for details.

l) For each group of subcarriers –26 to 26, convert the subcarriers to time domain using inverse

Fourier transform. Prepend to the Fourier-transformed waveform a circular extension of itself thus

forming a GI, and truncate the resulting periodic waveform to a single OFDM symbol length by

applying time domain windowing. Refer to 17.3.5.9 for details.

m) Append the OFDM symbols one after another, starting after the SIGNAL symbo l describing the

RATE and LENGTH fields. Refer to 17.3.5.9 for details.

n) Up-convert the resulting “complex baseband” waveform to an RF according to the center frequency

of the desired channel and transmit. Refer to 17.3.2.4 and 17.3.8.1 for details.

An illustration of the transmitted frame and its parts appears in Figure 17-4 (in 17.3.3).

See, e.g., 802.11-2007 § 17.3.2.1

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 595 of 946 PageID #:

4699
595

Claim 14 of the ’802 Patent Prior Art Reference – 802.11-2007

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 596 of 946 PageID #:

4700
596

Claim 14 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 § 17.3.2.3

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 597 of 946 PageID #:

4701
597

Claim 14 of the ’802 Patent Prior Art Reference – 802.11-2007

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 598 of 946 PageID #:

4702
598

Claim 14 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 § 17.3.2.4 Eq. (17-1)

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 599 of 946 PageID #:

4703
599

Claim 14 of the ’802 Patent Prior Art Reference – 802.11-2007

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 600 of 946 PageID #:

4704
600

Claim 14 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 § 17.3.2.5

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 601 of 946 PageID #:

4705
601

Claim 14 of the ’802 Patent Prior Art Reference – 802.11-2007

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 602 of 946 PageID #:

4706
602

See, e.g., 802.11-2007 § 17.3.3

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 603 of 946 PageID #:

4707
603

Claim 14 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 § 17.3.5.7

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 604 of 946 PageID #:

4708
604

Claim 14 of the ’802 Patent Prior Art Reference – 802.11-2007

17.3.5.8 Pilot subcarriers

In each OFDM symbol, four of the subcarriers are dedicated to pilot signals in order to make the coherent

detection robust against frequency offsets and phase noise. These pilot signals shall be put in subcarriers

–21, –7, 7, and 21. The pilots shall be BPSK modulated by a pseudo-binary sequence to prevent the

generation of spectral lines. The contribution of the pilot subcarriers to each OFDM symbol is described in

17.3.5.9.

See, e.g., 802.11-2007 § 17.3.5.8

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 605 of 946 PageID #:

4709
605

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 606 of 946 PageID #:

4710
606

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 607 of 946 PageID #:

4711
607

Claim 14 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 § 17.3.5.9

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 608 of 946 PageID #:

4712
608

Claim 14 of the ’802 Patent Prior Art Reference – 802.11-2007

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 609 of 946 PageID #:

4713
609

Claim 14 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 § 17.3.8.1

17.3.8.3.1 Operating frequency range

The OFDM PHY shall operate in the 5 GHz band, as allocated by a regulatory body in its operational region.

Spectrum allocation in the 5 GHz band is subject to authorities responsible for geographic-specific

regulatory domains (e.g., global, regional, and national). The particular channelization to be used for this

standard is dependent on such allocation, as well as the associated regulations for use of the allocations.

These regulations are subject to revision, or may be superseded.

In some regulatory domains, several frequency bands may be available fo r OFDM PHY-based WLANs.

These bands may be contiguous or not, and different regulatory limits may be applicable. A compliant

OFDM PHY shall support at least one frequency band in at least one regulatory domain. The support of

specific regulatory domains, and bands within the domains, shall be indicated by PLME attributes

dot11RegDomainsSupported and dot11FrequencyBandsSupported.

See, e.g., 802.11-2007 § 17.3.8.3.1

17.3.9.1 Transmit power levels

The maximum allowable transmit power by regulatory domain is defined in Annex I.

See, e.g., 802.11-2007 § 17.3.9.1

17.3.9.6.2 Transmitter spectral flatness

The average energy of the constellations in each of the spectral lines –16.. –1 and +1.. +16 will deviate no

more than ± 2 dB from their average energy. The average energy of the constellations in each of the spectral

lines –26.. –17 and +17.. +26 will deviate no more than +2/–4 dB from the average energy of spectral lines

–16.. –1 and +1.. +16. The data for this test shall be derived from the channel estimation step.

See, e.g., 802.11-2007 § 17.3.9.6.2

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 610 of 946 PageID #:

4714
610

Claim 14 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 § I.2.2

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 611 of 946 PageID #:

4715
611

Claim 14 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 § I.2.3

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 612 of 946 PageID #:

4716
612

Claim 14 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 Figure 5-7

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 613 of 946 PageID #:

4717
613

Claim 14 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 Figure 10-6

Furthermore, this claim element is obvious in light of 802.11-2007 itself, when combined with any of 

the other references as charted for this claim element in Exs. A-1–A-31, First Supplemental Ex. ACase 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 614 of 946 PageID #:

4718
614

Claim 14 of the ’802 Patent Prior Art Reference – 802.11-2007

Obviousness 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.

Claim 17 of the ’802 Patent Prior Art Reference – 802.11-2007

[17.1] A wireless 

communication system 

comprising:

To the extent the preamble is limiting, 802.11-2007 discloses “A wireless communication system 

comprising.” See, e.g.: 

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 615 of 946 PageID #:

4719
615

Claim 17 of the ’802 Patent Prior Art Reference – 802.11-2007

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 616 of 946 PageID #:

4720
616

See, e.g., 802.11-2007 § 17.3.3

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 617 of 946 PageID #:

4721
617

Claim 17 of the ’802 Patent Prior Art Reference – 802.11-2007

Furthermore, this claim element is obvious in light of 802.11-2007 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;

802.11-2007 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 .” See, 

e.g.: 

1.1 Scope

The scope of this standard is to define one medium access control (MAC) and several physical layer (PHY)

specifications for wireless connectivity for fixed, portable, and moving stations (STAs) within a local area.

See, e.g., 802.11-2007 § 1.1

5.1.1 How WLAN systems are different

Wireless networks have fundamental characteristics that make them significantly different from traditional

wired LANs. Some countries impose specific requirements for radio equipment in addition to those

specified in this standard. This standard does not provide information to meet these country-specific radio

regulations.

5.1.1.1 Destination address does not equal destination location

In wired LANs, an address is equivalent to a physical location. This is implicitly assumed in the design of

wired LANs. In IEEE Std 802.11, the addressable unit is a station (STA). The STA is a message destination,

but not (in general) a fixed location.

5.1.1.2 Media impact on design and performance

The PHYs used in IEEE Std 802.11 are fundamentally different from wired media. Thus IEEE 802.11 PHYs

a) Use a medium that has neither absolute nor readily observable boundaries outside of which STAs

with conformant PHY transceivers are known to be unable to receive network frames

b) Are unprotected from other signals that may be sharing the medium

c) Communicate over a medium significantly less reliable than wired PHYs

d) Have dynamic topologies

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 618 of 946 PageID #:

4722
618

Claim 17 of the ’802 Patent Prior Art Reference – 802.11-2007

e) Lack full connectivity, and therefore the assumption normally made that every STA can hear every

other STA is invalid (i.e., STAs may be “hidden” from each other)

f) Have time-varying and asymmetric propagation properties

g) May experience interference from logically disjoint IEEE 802.11 networks operating in overlapping

areas

Because of limitations on wireless PHY ranges, WLANs intended to cover reasonable geographic distances

may be built from basic coverage building blocks. When providing QoS services it should be understood

that the MAC endeavors to provide QoS “service guarantees” within the limitations of the medium

properties identified above. In other words, particularly in unlicensed spectrum, true guarantees are often not

possible. However, gradations of service are always possible; and in sufficiently controlled environments,

QoS guarantees can truly be made.

5.1.1.3 The impact of handling mobile STAs

One of the requirements of IEEE Std 802.11 is to handle mobile as well as portable STAs. A portable STA

is one that is moved from location to location, but that is only used while at a fixed location. Mobile STAs

actually access the LAN while in motion.

For technical reasons, it is not sufficient to handle only portable STAs. Propagation effects blur the

distinction between portable and mobile STAs; stationary STAs often appear to be mobile due to

propagation effects.

Another aspect of mobile STAs is that they may often be battery powered. Hence power management is

an important consideration. For example, it cannot be presumed that a STA’s receiver will always be

powered on.

See, e.g., 802.11-2007 § 5.1.1 - § 5.1.1.3

5.2 Components of the IEEE 802.11 architecture

The IEEE 802.11 architecture consists of several components that interact to provide a WLAN that supports

STA mobility transparently to upper layers.

The basic service set (BSS) is the basic building block of an IEEE 802.11 LAN. Figure 5-1 shows two BSSs,

each of which has two STAs that are members of the BSS.

It is useful to think of the ovals used to depict a BSS as the coverage area within which the member STAs of

the BSS may remain in communication. (The concept of area, while not precise, is often good enough.) This

area is called the Basic Service Area (BSA). If a STA moves out of its BSA, it can no longer directly

communicate with other STAs present in the BSA.

See, e.g., 802.11-2007 § 5.2

5.2.3 Distribution system (DS) concepts

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 619 of 946 PageID #:

4723
619

Claim 17 of the ’802 Patent Prior Art Reference – 802.11-2007

PHY limitations determine the direct station-to-station distance that may be supported. For some networks

this distance is sufficient; for other networks, increased coverage is required.

Instead of existing independently, a BSS may also form a component of an extended form of network that is

built with multiple BSSs. The architectural component used to interconnect BSSs is the DS.

IEEE Std 802.11 logically separates the WM from the distribution system medium (DSM). Each logical

medium is used for different purposes, by a different component of the architecture. The IEEE 802.11

definitions neither preclude, nor demand, that the multiple media be either the same or different.

Recognizing that the multiple media are logically different is key to understanding the flexibility of the

architecture. The IEEE 802.11 LAN architecture is specified independently of the physical characteristics of

any specific implementation.

The DS enables mobile device support by providing the logical services necessary to handle address to

destination mapping and seamless integration of multiple BSSs.

An access point (AP) is any entity that has STA functionality and enables access to the DS, via the WM for

associated STAs.

See, e.g., 802.11-2007 § 5.2.3

5.3.2 DSS

The service provided by the DS is known as the DSS.

This service is represented in the IEEE 802.11 architecture by arrows within the APs, indicating that the

service is used to cross media and possibly address space logical boundaries. An AP is a logical entity, and

the functions described may be shared by one or more physical entities.

The services that comprise the DSS are as follows:

a) Association

b) Disassociation

c) Distribution

d) Integration

e) Reassociation

f) QoS traffic scheduling (QoS facility only)

DSSs are specified for use by MAC sublayer entities.

Figure 5-7 combines the components from previous figures with both types of services to show the complete

IEEE 802.11 architecture.

See, e.g., 802.11-2007 § 5.3.2

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 620 of 946 PageID #:

4724
620

Claim 17 of the ’802 Patent Prior Art Reference – 802.11-2007

5.4.4.1 TPC

Radio regulations may require radio local area networks (RLANs) operating in the 5 GHz band to use

transmitter power control, involving specification of a regulatory maximum transmit power and a mitigation

requirement for each allowed channel, to reduce interference with satellite services. The TPC service is used

to satisfy this regulatory requirement.

The TPC service provides for the following:

— Association of STAs with an AP in a BSS based on the STAs’ power capability.

— Specification of regulatory and local maximum transmit power levels for the current channel.

— Selection of a transmit power for each transmission in a channel within constraints imposed by

regulatory requirements.

— Adaptation of transmit power based on a range of information, including path loss and link margin

estimates.

See, e.g., 802.11-2007 § 5.4.4.1

7.3.2.20 Channel Switch Announcement element

The Channel Switch Announcement element is used by an AP in a BSS or a STA in an IBSS to advertise

when it is changing to a new channel and the channel number of the new channel. The format of the Channel

Switch Announcement element is shown in Figure 7-57.

See, e.g., 802.11-2007 § 7.3.2.20

10.3.11 Spectrum management protocol layer model

The layer management extensions for measurement and channel switching assume a certain partition

of spectrum management functionality between the MLME and SME. This partitioning assumes that

policy decisions (e.g., regarding measurement and channel switching) reside in the SME, while the protocol

for measurement, switch timing, and the associated frame exchanges resides within the MLME (see

Figure 10-2).

...

The informative diagrams within this subclause further illustrate the spectrum management protocol model

adopted. Figure 10-3 and Figure 10-4 depict the measurement process for a peer STA to accept and reject a

measurement request, respectively. Figure 10-5 illustrates the TPC adaptation process. Lastly, Figure 10-6

depicts the management process for a channel switch using a Channel Switch Announcement frame.

See, e.g., 802.11-2007 § 10.3.11

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 621 of 946 PageID #:

4725
621

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 622 of 946 PageID #:

4726
622

Claim 17 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 § 10.4.3.2

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 623 of 946 PageID #:

4727
623

Claim 17 of the ’802 Patent Prior Art Reference – 802.11-2007

17.1 Introduction

This clause specifies the PHY entity for an orthogonal frequency division multiplexing (OFDM) system.

The OFDM system provides a WLAN with data payload communication capabilities of 6, 9, 12, 18, 24, 36,

48, and 54 Mb/s. The support of transmitting and receiving at data rates of 6, 12, and 24 Mb/s is mandatory.

The system uses 52 subcarriers that are modulated using binary or quadrature phase shift keying (BPSK or

QPSK) or using 16- or 64-quadrature amplitude modulation (16-QAM or 64-QAM). Forward error

correction coding (convolutional coding) is used with a coding rate of 1/2, 2 /3, or 3/4.

The OFDM system also provides a “half-clocked” operation using 10 MHz channel spacings with data

communications capabilities of 3, 4.5, 6, 9, 12, 18, 24, and 27 Mb/s. The support of transmitting and

receiving at data rates of 3, 6, and 12 Mb/s is mandatory when using 10 MHz channel spacing. The halfclocked

operation doubles symbol times and clear channel assessment (CCA) times when using 10 MHz

channel spacing. The regulatory requirements and information regarding use of this OFDM system in

4.9 GHz and 5 GHz bands is in Annex I and Annex J.

The OFDM system also provides a “quarter-clocked” operation using 5 MHz channel spacing with data

communication capabilities of 1.5, 2.25, 3, 4.5, 6, 9, 12, and 13.5 Mb/s. The support of transmitting and

receiving at data rates of 1.5, 3, and 6 Mb/s is mandatory when using 5 MHz channel spacing. The quarterclocked

operation quadruples symbol times and CCA times when using 5 MHz channel spacing. The

regulatory requirements and information regarding use of this OFDM system in the 4.9 GHz band is in

Annex I and Annex J.

See, e.g., 802.11-2007 § 17.1

17.3.2.1 Overview of the PPDU encoding process

The encoding process is composed of many detailed steps, which are described fully in later subclauses, as

noted below. The following overview intends to facilitate understanding the details of the convergence

procedure:

a) Produce the PLCP Preamble field, composed of 10 repetitions of a “short training sequence” (used

for AGC convergence, diversity selection, timing acquisition, and coarse frequency acquisition in

the receiver) and two repetitions of a “long training sequence” (used for channel estimation and fine

frequency acquisition in the receiver), preceded by a guard interval (GI). Refer to 17.3.3 for details.

b) Produce the PLCP header field from the RATE, LENGTH, and SERVICE fields of the

TXVECTOR by filling the appropriate bit fields. The RATE and LENGTH fields of the PLCP

header are encoded by a convolutional code at a rate of R = 1/2, and are subsequently mapped onto a

single BPSK encoded OFDM symbol, denoted as the SIGNAL symbol. In order to facilitate a

reliable and timely detection of the RATE and LENGTH fields, 6 zero tail bits are inserted into the

PLCP header. The encoding of the SIGNAL field into an OFDM symbol follows the same steps for

convolutional encoding, interleaving, BPSK modulation, pilot insertion, Fourier transform, and

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 624 of 946 PageID #:

4728
624

Claim 17 of the ’802 Patent Prior Art Reference – 802.11-2007

prepending a GI as described subsequently for data transmission with BPSK-OFDM modulated at

coding rate 1/2. The contents of the SIGNAL field are not scrambled. Refer to 17.3.4 for details.

c) Calculate from RATE field of the TXVECTOR the number of data bits per OFDM symbol (NDBPS),

the coding rate (R), the number of bits in each OFDM subcarrier (NBPSC), and the number of coded

bits per OFDM symbol (NCBPS). Refer to 17.3.2.2 for details.

d) Append the PSDU to the SERVICE field of the TXVECTOR. Extend the resulting bit string with

zero bits (at least 6 bits) so that the resulting length will be a multiple of NDBPS. The resulting bit

string constitutes the DATA part of the packet. Refer to 17.3.5.3 for details.

e) Initiate the scrambler with a pseudo-random nonzero seed, generate a scrambling sequence, and

XOR it with the extended string of data bits. Refer to 17.3.5.4 for details.

f) Replace the six scrambled zero bits following the data with six nonscrambled zero bits. (Those bits

return the convolutional encoder to the zero state and are denoted as tail bits.) Refer to 17.3.5.2 for

details.

g) Encode the extended, scrambled data string with a convolutional encoder (R = 1/2). Omit (puncture)

some of the encoder output string (chosen according to “puncturing pattern”) to reach the desired

“coding rate.” Refer to 17.3.5.5 for details.

h) Divide the encoded bit string into groups of NCBPS bits. Within each group, perform an

“interleaving” (reordering) of the bits according to a rule corresponding to the desired RATE. Refer

to 17.3.5.6 for details.

i) Divide the resulting coded and interleaved data string into groups of NCBPS bits. For each of the bit

groups, convert the bit group into a complex number according to the modulation encoding tables.

Refer to 17.3.5.7 for details.

j) Divide the complex number string into groups of 48 complex numbers. Each such group will be

associated with one OFDM symbol. In each group, the complex numbers will be numbered 0 to 47

and mapped hereafter into OFDM subcarriers numbered –26 to –22, –20 to –8, –6 to –1, 1 to 6,

8 to 20, and 22 to 26. The subcarriers –21, –7, 7, and 21 are skipped and, subsequently, used for

inserting pilot subcarriers. The 0 subcarrier, associated with center frequency, is omitted and filled

with zero value. Refer to 17.3.5.9 for details.

k) Four subcarriers are inserted as pilots into positions –21, –7, 7, and 21. The total number of the

subcarriers is 52 (48 + 4). Refer to 17.3.5.8 for details.

l) For each group of subcarriers –26 to 26, convert the subcarriers to time domain using inverse

Fourier transform. Prepend to the Fourier-transformed waveform a circular extension of itself thus

forming a GI, and truncate the resulting periodic waveform to a single OFDM symbol length by

applying time domain windowing. Refer to 17.3.5.9 for details.

m) Append the OFDM symbols one after another, starting after the SIGNAL symbol describing the

RATE and LENGTH fields. Refer to 17.3.5.9 for details.

n) Up-convert the resulting “complex baseband” waveform to an RF according to the center frequency

of the desired channel and transmit. Refer to 17.3.2.4 and 17.3.8.1 for details.

An illustration of the transmitted frame and its parts appears in Figure 17-4 (in 17.3.3).

See, e.g., 802.11-2007 § 17.3.2.1

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 625 of 946 PageID #:

4729
625

Claim 17 of the ’802 Patent Prior Art Reference – 802.11-2007

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 626 of 946 PageID #:

4730
626

Claim 17 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 § 17.3.2.3

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 627 of 946 PageID #:

4731
627

Claim 17 of the ’802 Patent Prior Art Reference – 802.11-2007

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 628 of 946 PageID #:

4732
628

Claim 17 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 § 17.3.2.4 Eq. (17-1)

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 629 of 946 PageID #:

4733
629

Claim 17 of the ’802 Patent Prior Art Reference – 802.11-2007

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 630 of 946 PageID #:

4734
630

Claim 17 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 § 17.3.2.5

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 631 of 946 PageID #:

4735
631

Claim 17 of the ’802 Patent Prior Art Reference – 802.11-2007

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 632 of 946 PageID #:

4736
632

See, e.g., 802.11-2007 § 17.3.3

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 633 of 946 PageID #:

4737
633

Claim 17 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 § 17.3.5.7

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 634 of 946 PageID #:

4738
634

Claim 17 of the ’802 Patent Prior Art Reference – 802.11-2007

17.3.5.8 Pilot subcarriers

In each OFDM symbol, four of the subcarriers are dedicated to pilot signals in order to make the coherent

detection robust against frequency offsets and phase noise. These pilot signals shall be put in subcarriers

–21, –7, 7, and 21. The pilots shall be BPSK modulated by a pseudo-binary sequence to prevent the

generation of spectral lines. The contribution of the pilot subcarriers to each OFDM symbol is described in

17.3.5.9.

See, e.g., 802.11-2007 § 17.3.5.8

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 635 of 946 PageID #:

4739
635

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 636 of 946 PageID #:

4740
636

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 637 of 946 PageID #:

4741
637

Claim 17 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 § 17.3.5.9

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 638 of 946 PageID #:

4742
638

Claim 17 of the ’802 Patent Prior Art Reference – 802.11-2007

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 639 of 946 PageID #:

4743
639

Claim 17 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 § 17.3.8.1

17.3.8.3.1 Operating frequency range

The OFDM PHY shall operate in the 5 GHz band, as allocated by a regulatory body in its operational region.

Spectrum allocation in the 5 GHz band is subject to authorities responsible for geographic-specific

regulatory domains (e.g., global, regional, and national). The particular channelization to be used for this

standard is dependent on such allocation, as well as the associated regulations for use of the allocations.

These regulations are subject to revision, or may be superseded.

In some regulatory domains, several frequency bands may be available for OFDM PHY-based WLANs.

These bands may be contiguous or not, and different regulatory limits may be applicable. A compliant

OFDM PHY shall support at least one frequency band in at least one regulatory domain. The support of

specific regulatory domains, and bands within the domains, shall be indicated by PLME attributes

dot11RegDomainsSupported and dot11FrequencyBandsSupported.

See, e.g., 802.11-2007 § 17.3.8.3.1

17.3.9.1 Transmit power levels

The maximum allowable transmit power by regulatory domain is defined in Annex I.

See, e.g., 802.11-2007 § 17.3.9.1

17.3.9.6.2 Transmitter spectral flatness

The average energy of the constellations in each of the spectral lines –16.. –1 and +1.. +16 will deviate no

more than ± 2 dB from their average energy. The average energy of the constellations in each of the spectral

lines –26.. –17 and +17.. +26 will deviate no more than +2/–4 dB from the average energy of spectral lines

–16.. –1 and +1.. +16. The data for this test shall be derived from the channel estimation step.

See, e.g., 802.11-2007 § 17.3.9.6.2

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 640 of 946 PageID #:

4744
640

Claim 17 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 § I.2.2

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 641 of 946 PageID #:

4745
641

Claim 17 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 § I.2.3

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 642 of 946 PageID #:

4746
642

Claim 17 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 Figure 5-7

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 643 of 946 PageID #:

4747
643

Claim 17 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 Figure 10-6

Furthermore, this claim element is obvious in light of 802.11-2007 itself, when combined with any of 

the other references as charted for this claim element in Exs. A-1–A-31, First Supplemental Ex. ACase 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 644 of 946 PageID #:

4748
644

Claim 17 of the ’802 Patent Prior Art Reference – 802.11-2007

Obviousness 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;

802.11-2007 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.” See, e.g.: 

1.1 Scope

The scope of this standard is to define one medium access control (MAC) and several physical layer (PHY)

specifications for wireless connectivity for fixed, portable, and moving stations (STAs) within a local area.

See, e.g., 802.11-2007 § 1.1

5.1.1 How WLAN systems are different

Wireless networks have fundamental characteristics that make them significantly different from traditional

wired LANs. Some countries impose specific requirements for radio equipment in addition to those

specified in this standard. This standard does not provide information to meet these country -specific radio

regulations.

5.1.1.1 Destination address does not equal destination location

In wired LANs, an address is equivalent to a physical location. This is implicitly assumed in the design of

wired LANs. In IEEE Std 802.11, the addressable unit is a station (STA). The STA is a message destination,

but not (in general) a fixed location.

5.1.1.2 Media impact on design and performance

The PHYs used in IEEE Std 802.11 are fundamentally different from wired media. Thus IEEE 802.11 PHYs

a) Use a medium that has neither absolute nor readily observable boundaries outside of which STAs

with conformant PHY transceivers are known to be unable to receive network frames

b) Are unprotected from other signals that may be sharing the medium

c) Communicate over a medium significantly less reliable than wired PHYs

d) Have dynamic topologies

e) Lack full connectivity, and therefore the assumption normally made that every STA can hear every

other STA is invalid (i.e., STAs may be “hidden” from each other)

f) Have time-varying and asymmetric propagation properties

g) May experience interference from logically disjoint IEEE 802.11 networks operating in overlapping

areas

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 645 of 946 PageID #:

4749
645

Claim 17 of the ’802 Patent Prior Art Reference – 802.11-2007

Because of limitations on wireless PHY ranges, WLANs intended to cover reasonable geographic distances

may be built from basic coverage building blocks. When providing QoS services it should be understood

that the MAC endeavors to provide QoS “service guarantees” within the limitations of the medium

properties identified above. In other words, particularly in unlicensed spectrum, true guarantees are often not

possible. However, gradations of service are always possible; and in sufficiently controlled environments,

QoS guarantees can truly be made.

5.1.1.3 The impact of handling mobile STAs

One of the requirements of IEEE Std 802.11 is to handle mobile as well as portable STAs. A portable STA

is one that is moved from location to location, but that is only used while at a fixed location. Mobile STAs

actually access the LAN while in motion.

For technical reasons, it is not sufficient to handle only portable STAs. Propagation effects blur the

distinction between portable and mobile STAs; stationary STAs often appear to be mobile due to

propagation effects.

Another aspect of mobile STAs is that they may often be battery powered. Hence power management is

an important consideration. For example, it cannot be presumed that a STA’s receiver will always be

powered on.

See, e.g., 802.11-2007 § 5.1.1 - § 5.1.1.3

5.2 Components of the IEEE 802.11 architecture

The IEEE 802.11 architecture consists of several components that interact to provide a WLAN that supports

STA mobility transparently to upper layers.

The basic service set (BSS) is the basic building block of an IEEE 802.11 LAN. Figure 5 -1 shows two BSSs,

each of which has two STAs that are members of the BSS.

It is useful to think of the ovals used to depict a BSS as the coverage area within which the member STAs of

the BSS may remain in communication. (The concept of area, while not precise, is often good enough.) This

area is called the Basic Service Area (BSA). If a STA moves out of its BSA, it can no longer directly

communicate with other STAs present in the BSA.

See, e.g., 802.11-2007 § 5.2

5.2.3 Distribution system (DS) concepts

PHY limitations determine the direct station-to-station distance that may be supported. For some networks

this distance is sufficient; for other networks, increased coverage is required.

Instead of existing independently, a BSS may also form a component of an extended form of network that is

built with multiple BSSs. The architectural component used to interconnect BSSs is the DS.

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 646 of 946 PageID #:

4750
646

Claim 17 of the ’802 Patent Prior Art Reference – 802.11-2007

IEEE Std 802.11 logically separates the WM from the distribution system medium (DSM). Each logical

medium is used for different purposes, by a different component of the architecture. The IEEE 802.11

definitions neither preclude, nor demand, that the multiple media be either the same or different.

Recognizing that the multiple media are logically different is key to understanding the flexibility of the

architecture. The IEEE 802.11 LAN architecture is specified independently of the physical characteristics of

any specific implementation.

The DS enables mobile device support by providing the logical services necessary to handle address to

destination mapping and seamless integration of multiple BSSs.

An access point (AP) is any entity that has STA functionality and enables access to the DS, via the WM for

associated STAs.

See, e.g., 802.11-2007 § 5.2.3

5.3.2 DSS

The service provided by the DS is known as the DSS.

This service is represented in the IEEE 802.11 architecture by arrows within the APs, indicating that the

service is used to cross media and possibly address space logical boundaries. An AP is a logical entity, and

the functions described may be shared by one or more physical entities.

The services that comprise the DSS are as follows:

a) Association

b) Disassociation

c) Distribution

d) Integration

e) Reassociation

f) QoS traffic scheduling (QoS facility only)

DSSs are specified for use by MAC sublayer entities.

Figure 5-7 combines the components from previous figures with both types of services to show the complete

IEEE 802.11 architecture.

See, e.g., 802.11-2007 § 5.3.2

5.4.4.1 TPC

Radio regulations may require radio local area networks (RLANs) operating in the 5 GHz band to use

transmitter power control, involving specification of a regulatory maximum transmit power and a mitigation

requirement for each allowed channel, to reduce interference with satellite services. The TPC service is used

to satisfy this regulatory requirement.

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 647 of 946 PageID #:

4751
647

Claim 17 of the ’802 Patent Prior Art Reference – 802.11-2007

The TPC service provides for the following:

— Association of STAs with an AP in a BSS bas ed on the STAs’ power capability.

— Specification of regulatory and local maximum transmit power levels for the current channel.

— Selection of a transmit power for each transmission in a channel within constraints imposed by

regulatory requirements.

— Adaptation of transmit power based on a range of information, including path loss and link margin

estimates.

See, e.g., 802.11-2007 § 5.4.4.1

7.3.2.20 Channel Switch Announcement element

The Channel Switch Announcement element is used by an AP in a BSS or a STA in an IBSS to advertise

when it is changing to a new channel and the channel number of the new channel. The format of the Channel

Switch Announcement element is shown in Figure 7-57.

See, e.g., 802.11-2007 § 7.3.2.20

10.3.11 Spectrum management protocol layer model

The layer management extensions for measurement and channel switching assume a certain partition

of spectrum management functionality between the MLME and SME. This partitioning assumes that

policy decisions (e.g., regarding measurement and channel switching) reside in the SME, while the protocol

for measurement, switch timing, and the associated frame exchanges resides within the MLME (see

Figure 10-2).

...

The informative diagrams within this subclause further illustrate the spectrum man agement protocol model

adopted. Figure 10-3 and Figure 10-4 depict the measurement process for a peer STA to accept and reject a

measurement request, respectively. Figure 10-5 illustrates the TPC adaptation process. Lastly, Figure 10-6

depicts the management process for a channel switch using a Channel Switch Announcement frame.

See, e.g., 802.11-2007 § 10.3.11

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 648 of 946 PageID #:

4752
648

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 649 of 946 PageID #:

4753
649

Claim 17 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 § 10.4.3.2

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 650 of 946 PageID #:

4754
650

Claim 17 of the ’802 Patent Prior Art Reference – 802.11-2007

17.1 Introduction

This clause specifies the PHY entity for an orthogonal frequency division multiplexing (OFDM) system.

The OFDM system provides a WLAN with data payload communication capabilities of 6, 9, 12, 18, 24, 36,

48, and 54 Mb/s. The support of transmitting and receiving at data rates of 6, 12, and 24 Mb/s is mandatory.

The system uses 52 subcarriers that are modulated using binary or quadrature phase shift keying (BPSK or

QPSK) or using 16- or 64-quadrature amplitude modulation (16-QAM or 64-QAM). Forward error

correction coding (convolutional coding) is used with a coding rate of 1/2, 2 /3, or 3/4.

The OFDM system also provides a “half-clocked” operation using 10 MHz channel spacings with data

communications capabilities of 3, 4.5, 6, 9, 12, 18, 24, and 27 Mb/s. The support of transmitting and

receiving at data rates of 3, 6, and 12 Mb/s is mandatory when using 10 MHz channel spacing. The halfclocked

operation doubles symbol times and clear channel assessment (CCA) times when using 10 MHz

channel spacing. The regulatory requirements and information regarding use of this OFDM system in

4.9 GHz and 5 GHz bands is in Annex I and Annex J.

The OFDM system also provides a “quarter-clocked” operation using 5 MHz channel spacing with data

communication capabilities of 1.5, 2.25, 3, 4.5, 6, 9, 12, and 13.5 Mb/s. The support of transmitting and

receiving at data rates of 1.5, 3, and 6 Mb/s is mandatory when using 5 MHz channel spacing. The quarterclocked

operation quadruples symbol times and CCA times when using 5 MHz channel spacing. The

regulatory requirements and information regarding use of this OFDM system in the 4.9 GHz band is in

Annex I and Annex J.

See, e.g., 802.11-2007 § 17.1

17.3.2.1 Overview of the PPDU encoding process

The encoding process is composed of many detailed steps, which are described fully in later subclauses, as

noted below. The following overview intends to facilitate understanding the details of the convergence

procedure:

a) Produce the PLCP Preamble field, composed of 10 repetitions of a “short training sequence” (used

for AGC convergence, diversity selection, timing acquisition, and coarse frequency acquisition in

the receiver) and two repetitions of a “long training sequence” (used for channel estimation and fine

frequency acquisition in the receiver), preceded by a guard interval (GI). Refer to 17.3.3 for details.

b) Produce the PLCP header field from the RATE, LENGTH, and SERVICE fields of the

TXVECTOR by filling the appropriate bit fields. The RATE and LENGTH fields of the PLCP

header are encoded by a convolutional code at a rate of R = 1/2, and are subsequently mapped onto a

single BPSK encoded OFDM symbol, denoted as the SIGNAL symbol. In order to facilitate a

reliable and timely detection of the RATE and LENGTH fields, 6 zero tail bits are inserted into the

PLCP header. The encoding of the SIGNAL field into an OFDM symbol follows the same steps for

convolutional encoding, interleaving, BPSK modulation, pilot insertion, Fourier transform, and

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 651 of 946 PageID #:

4755
651

Claim 17 of the ’802 Patent Prior Art Reference – 802.11-2007

prepending a GI as described subsequently for data transmission with BPSK-OFDM modulated at

coding rate 1/2. The contents of the SIGNAL field are not scrambled. Refer to 17.3.4 for details.

c) Calculate from RATE field of the TXVECTOR the number of data bits per OFDM symbol (NDBPS),

the coding rate (R), the number of bits in each OFDM subcarrier (NBPSC), and the number of coded

bits per OFDM symbol (NCBPS). Refer to 17.3.2.2 for details.

d) Append the PSDU to the SERVICE field of the TXVECTOR. Extend the resulting bit string with

zero bits (at least 6 bits) so that the resulting length will be a multiple of NDBPS. The resulting bit

string constitutes the DATA part of the packet. Refer to 17.3.5.3 for details.

e) Initiate the scrambler with a pseudo-random nonzero seed, generate a scrambling sequence, and

XOR it with the extended string of data bits. Refer to 17.3.5.4 for details.

f) Replace the six scrambled zero bits following the data with six nonscrambled zero bits. (Those bits

return the convolutional encoder to the zero state and are denoted as tail bits.) Refer to 17.3.5.2 for

details.

g) Encode the extended, scrambled data string with a convolutional encoder (R = 1/2). Omit (puncture)

some of the encoder output string (chosen according to “puncturing pattern”) to reach the desired

“coding rate.” Refer to 17.3.5.5 for details.

h) Divide the encoded bit string into groups of NCBPS bits. Within each group, perform an

“interleaving” (reordering) of the bits according to a rule corresponding to the desired RATE. Refer

to 17.3.5.6 for details.

i) Divide the resulting coded and interleaved data string into groups of NCBPS bits. For each of the bit

groups, convert the bit group into a complex number according to the modulation encoding tables.

Refer to 17.3.5.7 for details.

j) Divide the complex number string into groups of 48 complex numbers. Each such group will be

associated with one OFDM symbol. In each group, the complex numbers will be numbered 0 to 47

and mapped hereafter into OFDM subcarriers numbered –26 to –22, –20 to –8, –6 to –1, 1 to 6,

8 to 20, and 22 to 26. The subcarriers –21, –7, 7, and 21 are skipped and, subsequently, used for

inserting pilot subcarriers. The 0 subcarrier, associated with center frequency, is omitted and filled

with zero value. Refer to 17.3.5.9 for details.

k) Four subcarriers are inserted as pilots into positions –21, –7, 7, and 21. The total number of the

subcarriers is 52 (48 + 4). Refer to 17.3.5.8 for details.

l) For each group of subcarriers –26 to 26, convert the subcarriers to time domain using inverse

Fourier transform. Prepend to the Fourier-transformed waveform a circular extension of itself thus

forming a GI, and truncate the resulting periodic waveform to a single OFDM symbol length by

applying time domain windowing. Refer to 17.3.5.9 for details.

m) Append the OFDM symbols one after another, starting after the SIGNAL symbol describing the

RATE and LENGTH fields. Refer to 17.3.5.9 for details.

n) Up-convert the resulting “complex baseband” waveform to an RF according to the center frequency

of the desired channel and transmit. Refer to 17.3.2.4 and 17.3.8.1 for details.

An illustration of the transmitted frame and its parts appears in Figure 17-4 (in 17.3.3).

See, e.g., 802.11-2007 § 17.3.2.1

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 652 of 946 PageID #:

4756
652

Claim 17 of the ’802 Patent Prior Art Reference – 802.11-2007

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 653 of 946 PageID #:

4757
653

Claim 17 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 § 17.3.2.3

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 654 of 946 PageID #:

4758
654

Claim 17 of the ’802 Patent Prior Art Reference – 802.11-2007

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 655 of 946 PageID #:

4759
655

Claim 17 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 § 17.3.2.4 Eq. (17-1)

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 656 of 946 PageID #:

4760
656

Claim 17 of the ’802 Patent Prior Art Reference – 802.11-2007

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 657 of 946 PageID #:

4761
657

Claim 17 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 § 17.3.2.5

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 658 of 946 PageID #:

4762
658

Claim 17 of the ’802 Patent Prior Art Reference – 802.11-2007

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 659 of 946 PageID #:

4763
659

See, e.g., 802.11-2007 § 17.3.3

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 660 of 946 PageID #:

4764
660

Claim 17 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 § 17.3.5.7

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 661 of 946 PageID #:

4765
661

Claim 17 of the ’802 Patent Prior Art Reference – 802.11-2007

17.3.5.8 Pilot subcarriers

In each OFDM symbol, four of the subcarriers are dedicated to pilot signals in order to make the coherent

detection robust against frequency offsets and phase noise. These pilot signals shall be put in subcarriers

–21, –7, 7, and 21. The pilots shall be BPSK modulated by a pseudo-binary sequence to prevent the

generation of spectral lines. The contribution of the pilot subcarriers to each OFDM symbol is described in

17.3.5.9.

See, e.g., 802.11-2007 § 17.3.5.8

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 662 of 946 PageID #:

4766
662

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 663 of 946 PageID #:

4767
663

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 664 of 946 PageID #:

4768
664

Claim 17 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 § 17.3.5.9

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 665 of 946 PageID #:

4769
665

Claim 17 of the ’802 Patent Prior Art Reference – 802.11-2007

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 666 of 946 PageID #:

4770
666

Claim 17 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 § 17.3.8.1

17.3.8.3.1 Operating frequency range

The OFDM PHY shall operate in the 5 GHz band, as allocated by a regulatory body in its operational region.

Spectrum allocation in the 5 GHz band is subject to authorities responsible for geographic-specific

regulatory domains (e.g., global, regional, and national). The particular channelization to be used for this

standard is dependent on such allocation, as well as the associated regulations for use of the allocations.

These regulations are subject to revision, or may be superseded.

In some regulatory domains, several frequency bands may be available for OFDM PHY-based WLANs.

These bands may be contiguous or not, and different regulatory limits may be applicable. A compliant

OFDM PHY shall support at least one frequency band in at least one regulatory domain. The support of

specific regulatory domains, and bands within the domains, shall be indicated by PLME attributes

dot11RegDomainsSupported and dot11FrequencyBandsSupported.

See, e.g., 802.11-2007 § 17.3.8.3.1

17.3.9.1 Transmit power levels

The maximum allowable transmit power by regulatory domain is defined in Annex I.

See, e.g., 802.11-2007 § 17.3.9.1

17.3.9.6.2 Transmitter spectral flatness

The average energy of the constellations in each of the spectral lines –16.. –1 and +1.. +16 will deviate no

more than ± 2 dB from their average energy. The average energy of the constellations in each of the spectral

lines –26.. –17 and +17.. +26 will deviate no more than +2/–4 dB from the average energy of spectral lines

–16.. –1 and +1.. +16. The data for this test shall be derived from the channel estimation step.

See, e.g., 802.11-2007 § 17.3.9.6.2

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 667 of 946 PageID #:

4771
667

Claim 17 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 § I.2.2

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 668 of 946 PageID #:

4772
668

Claim 17 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 § I.2.3

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 669 of 946 PageID #:

4773
669

Claim 17 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 Figure 5-7

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 670 of 946 PageID #:

4774
670

Claim 17 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 Figure 10-6

Furthermore, this claim element is obvious in light of 802.11-2007 itself, when combined with any of 

the other references as charted for this claim element in Exs. A-1–A-31, First Supplemental Ex. ACase 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 671 of 946 PageID #:

4775
671

Claim 17 of the ’802 Patent Prior Art Reference – 802.11-2007

Obviousness 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.

[17.4] 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;

802.11-2007 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.” See, e.g.: 

1.1 Scope

The scope of this standard is to define one medium access control (MAC) and several physical layer (PHY)

specifications for wireless connectivity for fixed, portable, and moving stations (STAs) within a local area.

See, e.g., 802.11-2007 § 1.1

5.1.1 How WLAN systems are different

Wireless networks have fundamental characteristics that make them significantly different from traditional

wired LANs. Some countries impose specific requirements for radio equipment in addition to those

specified in this standard. This standard does not provide information to meet these country -specific radio

regulations.

5.1.1.1 Destination address does not equal destination location

In wired LANs, an address is equivalent to a physical location. This is implicitly assumed in the design of

wired LANs. In IEEE Std 802.11, the addressable unit is a station (STA). The STA is a message destination,

but not (in general) a fixed location.

5.1.1.2 Media impact on design and performance

The PHYs used in IEEE Std 802.11 are fundamentally different from wired media. Thus IEEE 802.11 PHYs

a) Use a medium that has neither absolute nor readily observable boundaries outside of which STAs

with conformant PHY transceivers are known to be unable to receive network frames

b) Are unprotected from other signals that may be sharing the medium

c) Communicate over a medium significantly less reliable than wired PHYs

d) Have dynamic topologies

e) Lack full connectivity, and therefore the assumption normally made that every STA can hear every

other STA is invalid (i.e., STAs may be “hidden” from each other)

f) Have time-varying and asymmetric propagation properties

g) May experience interference from logically disjoint IEEE 802.11 networks operating in overlapping

areas

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 672 of 946 PageID #:

4776
672

Claim 17 of the ’802 Patent Prior Art Reference – 802.11-2007

Because of limitations on wireless PHY ranges, WLANs intended to cover reasonable geographic distances

may be built from basic coverage building blocks. When providing QoS services it should be understood

that the MAC endeavors to provide QoS “service guarantees” within the limitations of the medium

properties identified above. In other words, particularly in unlicensed spectrum, true guarantees are often not

possible. However, gradations of service are always possible; and in sufficiently controlled environments,

QoS guarantees can truly be made.

5.1.1.3 The impact of handling mobile STAs

One of the requirements of IEEE Std 802.11 is to handle mobile as well as portable STAs. A portable STA

is one that is moved from location to location, but that is only used while at a fixed location. Mobile STAs

actually access the LAN while in motion.

For technical reasons, it is not sufficient to handle only portable STAs. Propagation effects blur the

distinction between portable and mobile STAs; stationary STAs often appear to be mobile due to

propagation effects.

Another aspect of mobile STAs is that they may often be battery powered. Hence power management is

an important consideration. For example, it cannot be presumed that a STA’s receiver will always be

powered on.

See, e.g., 802.11-2007 § 5.1.1 - § 5.1.1.3

5.2 Components of the IEEE 802.11 architecture

The IEEE 802.11 architecture consists of several components that interact to provide a WLAN that supports

STA mobility transparently to upper layers.

The basic service set (BSS) is the basic building block of an IEEE 802.11 LAN. Figure 5 -1 shows two BSSs,

each of which has two STAs that are members of the BSS.

It is useful to think of the ovals used to depict a BSS as the coverage area within which the member STAs of

the BSS may remain in communication. (The concept of area, while not precise, is often good enough.) This

area is called the Basic Service Area (BSA). If a STA moves out of its BSA, it can no longer directly

communicate with other STAs present in the BSA.

See, e.g., 802.11-2007 § 5.2

5.2.3 Distribution system (DS) concepts

PHY limitations determine the direct station-to-station distance that may be supported. For some networks

this distance is sufficient; for other networks, increased coverage is required.

Instead of existing independently, a BSS may also form a component of an extended form of network that is

built with multiple BSSs. The architectural component used to interconnect BSSs is the DS.

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 673 of 946 PageID #:

4777
673

Claim 17 of the ’802 Patent Prior Art Reference – 802.11-2007

IEEE Std 802.11 logically separates the WM from the distribution system medium (DSM). Each logical

medium is used for different purposes, by a different component of the architecture. The IEEE 802.11

definitions neither preclude, nor demand, that the multiple media be either the same or different.

Recognizing that the multiple media are logically different is key to understanding the flexibility of the

architecture. The IEEE 802.11 LAN architecture is specified independently of the physical characteristics of

any specific implementation.

The DS enables mobile device support by providing the logical services necessary to handle addre ss to

destination mapping and seamless integration of multiple BSSs.

An access point (AP) is any entity that has STA functionality and enables access to the DS, via the WM for

associated STAs.

See, e.g., 802.11-2007 § 5.2.3

5.3.2 DSS

The service provided by the DS is known as the DSS.

This service is represented in the IEEE 802.11 architecture by arrows within the APs, indicating that the

service is used to cross media and possibly address space logical boundaries. An AP is a logical entity, and

the functions described may be shared by one or more physical entities.

The services that comprise the DSS are as follows:

a) Association

b) Disassociation

c) Distribution

d) Integration

e) Reassociation

f) QoS traffic scheduling (QoS facility only)

DSSs are specified for use by MAC sublayer entities.

Figure 5-7 combines the components from previous figures with both types of services to show the complete

IEEE 802.11 architecture.

See, e.g., 802.11-2007 § 5.3.2

5.4.4.1 TPC

Radio regulations may require radio local area networks (RLANs) operating in the 5 GHz band to use

transmitter power control, involving specification of a regulatory maximum transmit power and a mitigation

requirement for each allowed channel, to reduce interference with satellite services. The TPC service is used

to satisfy this regulatory requirement.

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 674 of 946 PageID #:

4778
674

Claim 17 of the ’802 Patent Prior Art Reference – 802.11-2007

The TPC service provides for the following:

— Association of STAs with an AP in a BSS based on the STAs’ power capability.

— Specification of regulatory and local maximum transmit power levels for the current channel.

— Selection of a transmit power for each transmission in a channel within constraints imposed by

regulatory requirements.

— Adaptation of transmit power based on a range of information, including path loss and link margin

estimates.

See, e.g., 802.11-2007 § 5.4.4.1

7.3.2.20 Channel Switch Announcement element

The Channel Switch Announcement element is used by an AP in a BSS or a STA in an IBSS to advertise

when it is changing to a new channel and the channel number of the new channel. The format of the Channel

Switch Announcement element is shown in Figure 7-57.

See, e.g., 802.11-2007 § 7.3.2.20

10.3.11 Spectrum management protocol layer model

The layer management extensions for measurement and channel switching assume a certain partition

of spectrum management functionality between the MLME and SME. This partitioning assumes that

policy decisions (e.g., regarding measurement and channel switching) reside in the SME, while the protocol

for measurement, switch timing, and the associated frame exchanges resides within the MLME (see

Figure 10-2).

...

The informative diagrams within this subclause further illustrate the spectrum management protocol model

adopted. Figure 10-3 and Figure 10-4 depict the measurement process for a peer STA to accept and reject a

measurement request, respectively. Figure 10-5 illustrates the TPC adaptation process. Lastly, Figure 10-6

depicts the management process for a channel switch using a Channel Switch Announcement frame.

See, e.g., 802.11-2007 § 10.3.11

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 675 of 946 PageID #:

4779
675

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 676 of 946 PageID #:

4780
676

Claim 17 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 § 10.4.3.2

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 677 of 946 PageID #:

4781
677

Claim 17 of the ’802 Patent Prior Art Reference – 802.11-2007

17.1 Introduction

This clause specifies the PHY entity for an orthogonal frequency division multiplexing (OFDM) system.

The OFDM system provides a WLAN with data payload communication capabilities of 6, 9, 12, 18, 24, 36,

48, and 54 Mb/s. The support of transmitting and receiving at data rates of 6, 12, and 24 Mb/s is mandatory.

The system uses 52 subcarriers that are modulated using binary or quadrature phase shift keying (BPSK or

QPSK) or using 16- or 64-quadrature amplitude modulation (16-QAM or 64-QAM). Forward error

correction coding (convolutional coding) is used with a coding rate of 1/2, 2/3, or 3/4.

The OFDM system also provides a “half-clocked” operation using 10 MHz channel spacings with data

communications capabilities of 3, 4.5, 6, 9, 12, 18, 24, and 27 Mb/s. The support of transmitting and

receiving at data rates of 3, 6, and 12 Mb/s is mandatory when using 10 MHz channel spacing. The halfclocked

operation doubles symbol times and clear channel assessment (CCA) times when using 10 MHz

channel spacing. The regulatory requirements and information regarding use of this OFDM system in

4.9 GHz and 5 GHz bands is in Annex I and Annex J.

The OFDM system also provides a “quarter-clocked” operation using 5 MHz channel spacing with data

communication capabilities of 1.5, 2.25, 3, 4.5, 6, 9, 12, and 13.5 Mb/s. The support of transmitting and

receiving at data rates of 1.5, 3, and 6 Mb/s is mandatory when using 5 MHz channel spacing. The quarterclocked

operation quadruples symbol times and CCA times when using 5 MHz channel spacing. The

regulatory requirements and information regarding use of this OFDM system in the 4.9 GHz band is in

Annex I and Annex J.

See, e.g., 802.11-2007 § 17.1

17.3.2.1 Overview of the PPDU encoding process

The encoding process is composed of many detailed steps, which are described fully in later subclauses, as

noted below. The following overview intends to facilitate understanding the details of the convergence

procedure:

a) Produce the PLCP Preamble field, composed of 10 repetitions of a “short training sequence” (used

for AGC convergence, diversity selection, timing acquisition, and coarse frequency acquisition in

the receiver) and two repetitions of a “long training sequence” (used for channel estimation and fine

frequency acquisition in the receiver), preceded by a guard interval (GI). Refer to 17.3.3 for details.

b) Produce the PLCP header field from the RATE, LENGTH, and SERVICE field s of the

TXVECTOR by filling the appropriate bit fields. The RATE and LENGTH fields of the PLCP

header are encoded by a convolutional code at a rate of R = 1/2, and are subsequently mapped onto a

single BPSK encoded OFDM symbol, denoted as the SIGNAL symbol. In order to facilitate a

reliable and timely detection of the RATE and LENGTH fields, 6 zero tail bits are inserted into the

PLCP header. The encoding of the SIGNAL field into an OFDM symbol follows the same steps for

convolutional encoding, interleaving, BPSK modulation, pilot insertion, Fourier transform, and

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 678 of 946 PageID #:

4782
678

Claim 17 of the ’802 Patent Prior Art Reference – 802.11-2007

prepending a GI as described subsequently for data transmission with BPSK-OFDM modulated at

coding rate 1/2. The contents of the SIGNAL field are not scrambled. Refer to 17.3.4 for details.

c) Calculate from RATE field of the TXVECTOR the number of data bits per OFDM symbol (NDBPS),

the coding rate (R), the number of bits in each OFDM subcarrier (NBPSC), and the number of coded

bits per OFDM symbol (NCBPS). Refer to 17.3.2.2 for details.

d) Append the PSDU to the SERVICE field of the TXVECTOR. Extend the resulting bit string with

zero bits (at least 6 bits) so that the resulting length will be a multiple of NDBPS. The resulting bit

string constitutes the DATA part of the packet. Refer to 17.3.5.3 for details.

e) Initiate the scrambler with a pseudo-random nonzero seed, generate a scrambling sequence, and

XOR it with the extended string of data bits. Refer to 17.3.5.4 for details.

f) Replace the six scrambled zero bits following the data with six nonscrambled zero bits. (Those bits

return the convolutional encoder to the zero state and are denoted as tail bits.) Refer to 17.3.5.2 for

details.

g) Encode the extended, scrambled data string with a convolutional encoder (R = 1/2). Omit (punc ture)

some of the encoder output string (chosen according to “puncturing pattern”) to reach the desired

“coding rate.” Refer to 17.3.5.5 for details.

h) Divide the encoded bit string into groups of NCBPS bits. Within each group, perform an

“interleaving” (reordering) of the bits according to a rule corresponding to the desired RATE. Refer

to 17.3.5.6 for details.

i) Divide the resulting coded and interleaved data string into groups of NCBPS bits. For each of the bit

groups, convert the bit group into a complex number according to the modulation encoding tables.

Refer to 17.3.5.7 for details.

j) Divide the complex number string into groups of 48 complex numbers. Each such group will be

associated with one OFDM symbol. In each group, the complex numbers will b e numbered 0 to 47

and mapped hereafter into OFDM subcarriers numbered –26 to –22, –20 to –8, –6 to –1, 1 to 6,

8 to 20, and 22 to 26. The subcarriers –21, –7, 7, and 21 are skipped and, subsequently, used for

inserting pilot subcarriers. The 0 subcarrier, associated with center frequency, is omitted and filled

with zero value. Refer to 17.3.5.9 for details.

k) Four subcarriers are inserted as pilots into positions –21, –7, 7, and 21. The total number of the

subcarriers is 52 (48 + 4). Refer to 17.3.5.8 for details.

l) For each group of subcarriers –26 to 26, convert the subcarriers to time domain using inverse

Fourier transform. Prepend to the Fourier-transformed waveform a circular extension of itself thus

forming a GI, and truncate the resulting periodic waveform to a single OFDM symbol length by

applying time domain windowing. Refer to 17.3.5.9 for details.

m) Append the OFDM symbols one after another, starting after the SIGNAL symbol describing the

RATE and LENGTH fields. Refer to 17.3.5.9 for details.

n) Up-convert the resulting “complex baseband” waveform to an RF according to the center frequency

of the desired channel and transmit. Refer to 17.3.2.4 and 17.3.8.1 for details.

An illustration of the transmitted frame and its parts appears in Figure 17-4 (in 17.3.3).

See, e.g., 802.11-2007 § 17.3.2.1

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 679 of 946 PageID #:

4783
679

Claim 17 of the ’802 Patent Prior Art Reference – 802.11-2007

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 680 of 946 PageID #:

4784
680

Claim 17 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 § 17.3.2.3

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 681 of 946 PageID #:

4785
681

Claim 17 of the ’802 Patent Prior Art Reference – 802.11-2007

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 682 of 946 PageID #:

4786
682

Claim 17 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 § 17.3.2.4 Eq. (17-1)

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 683 of 946 PageID #:

4787
683

Claim 17 of the ’802 Patent Prior Art Reference – 802.11-2007

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 684 of 946 PageID #:

4788
684

Claim 17 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 § 17.3.2.5

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 685 of 946 PageID #:

4789
685

Claim 17 of the ’802 Patent Prior Art Reference – 802.11-2007

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 686 of 946 PageID #:

4790
686

See, e.g., 802.11-2007 § 17.3.3

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 687 of 946 PageID #:

4791
687

Claim 17 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 § 17.3.5.7

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 688 of 946 PageID #:

4792
688

Claim 17 of the ’802 Patent Prior Art Reference – 802.11-2007

17.3.5.8 Pilot subcarriers

In each OFDM symbol, four of the subcarriers are dedicated to pilot signals in order to make the coherent

detection robust against frequency offsets and phase noise. These pilot signals shall be put in su bcarriers

–21, –7, 7, and 21. The pilots shall be BPSK modulated by a pseudo-binary sequence to prevent the

generation of spectral lines. The contribution of the pilot subcarriers to each OFDM symbol is described in

17.3.5.9.

See, e.g., 802.11-2007 § 17.3.5.8

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 689 of 946 PageID #:

4793
689

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 690 of 946 PageID #:

4794
690

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 691 of 946 PageID #:

4795
691

Claim 17 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 § 17.3.5.9

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 692 of 946 PageID #:

4796
692

Claim 17 of the ’802 Patent Prior Art Reference – 802.11-2007

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 693 of 946 PageID #:

4797
693

Claim 17 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 § 17.3.8.1

17.3.8.3.1 Operating frequency range

The OFDM PHY shall operate in the 5 GHz band, as allocated by a regulatory body in its operational region.

Spectrum allocation in the 5 GHz band is subject to authorities responsible for geographic-specific

regulatory domains (e.g., global, regional, and national). The particular channelization to be used for this

standard is dependent on such allocation, as well as the associated regulations for use of the allocations.

These regulations are subject to revision, or may be superseded.

In some regulatory domains, several frequency bands may be available for OFDM PHY-based WLANs.

These bands may be contiguous or not, and different regulatory limits may be applicable. A compliant

OFDM PHY shall support at least one frequency band in at least one regulatory domain. The support of

specific regulatory domains, and bands within the domains, shall be indicated by PLME attributes

dot11RegDomainsSupported and dot11FrequencyBandsSupported.

See, e.g., 802.11-2007 § 17.3.8.3.1

17.3.9.1 Transmit power levels

The maximum allowable transmit power by regulatory domain is defined in Annex I.

See, e.g., 802.11-2007 § 17.3.9.1

17.3.9.6.2 Transmitter spectral flatness

The average energy of the constellations in each of the spectral lines –16.. –1 and +1.. +16 will deviate no

more than ± 2 dB from their average energy. The average energy of the constellations in each of the spectral

lines –26.. –17 and +17.. +26 will deviate no more than +2/–4 dB from the average energy of spectral lines

–16.. –1 and +1.. +16. The data for this test shall be derived from the channel estimation step.

See, e.g., 802.11-2007 § 17.3.9.6.2

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 694 of 946 PageID #:

4798
694

Claim 17 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 § I.2.2

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 695 of 946 PageID #:

4799
695

Claim 17 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 § I.2.3

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 696 of 946 PageID #:

4800
696

Claim 17 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 Figure 5-7

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 697 of 946 PageID #:

4801
697

Claim 17 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 Figure 10-6

Furthermore, this claim element is obvious in light of 802.11-2007 itself, when combined with any of 

the other references as charted for this claim element in Exs. A-1–A-31, First Supplemental Ex. ACase 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 698 of 946 PageID #:

4802
698

Claim 17 of the ’802 Patent Prior Art Reference – 802.11-2007

Obviousness 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.

[17.5] 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;

802.11-2007 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 

up-converted 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.” See, e.g.: 

1.1 Scope

The scope of this standard is to define one medium access control (MAC) and several physical layer (PHY)

specifications for wireless connectivity for fixed, portable, and moving stations (STAs) within a local area.

See, e.g., 802.11-2007 § 1.1

5.1.1 How WLAN systems are different

Wireless networks have fundamental characteristics that make them significantly different from traditional

wired LANs. Some countries impose specific requirements for radio equipment in addition to those

specified in this standard. This standard does not provide information to meet these country-specific radio

regulations.

5.1.1.1 Destination address does not equal destination location

In wired LANs, an address is equivalent to a physical location. This is implicitly assumed in the design of

wired LANs. In IEEE Std 802.11, the addressable unit is a station (STA). The STA is a message destination,

but not (in general) a fixed location.

5.1.1.2 Media impact on design and performance

The PHYs used in IEEE Std 802.11 are fundamentally different from wired media. Thus IEEE 802.11 PHYs

a) Use a medium that has neither absolute nor readily observable boundaries outside of which STAs

with conformant PHY transceivers are known to be unable to receive network frames

b) Are unprotected from other signals that may be sharing the medium

c) Communicate over a medium significantly less reliable than wired PHYs

d) Have dynamic topologies

e) Lack full connectivity, and therefore the assumption normally made that every STA can hear every

other STA is invalid (i.e., STAs may be “hidden” from each other)

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 699 of 946 PageID #:

4803
699

Claim 17 of the ’802 Patent Prior Art Reference – 802.11-2007

f) Have time-varying and asymmetric propagation properties

g) May experience interference from logically disjoint IEEE 802.11 networks operating in overlapping

areas

Because of limitations on wireless PHY ranges, WLANs intended to cover reasonable geographic distances

may be built from basic coverage building blocks. When providing QoS services it should be understood

that the MAC endeavors to provide QoS “service guarantees” within the limitations of the medium

properties identified above. In other words, particularly in unlicensed spectrum, true guarantees are often not

possible. However, gradations of service are always possible; and in sufficiently controlled environments,

QoS guarantees can truly be made.

5.1.1.3 The impact of handling mobile STAs

One of the requirements of IEEE Std 802.11 is to handle mobile as well as portable STAs. A portable STA

is one that is moved from location to location, but that is only used while at a fixed location. Mobile STAs

actually access the LAN while in motion.

For technical reasons, it is not sufficient to handle only portable STAs. Propagation effects blur the

distinction between portable and mobile STAs; stationary STAs often appear to be mobile due to

propagation effects.

Another aspect of mobile STAs is that they may often be battery powered. Hence power management is

an important consideration. For example, it cannot be presumed that a STA’s receiver will always be

powered on.

See, e.g., 802.11-2007 § 5.1.1 - § 5.1.1.3

5.2 Components of the IEEE 802.11 architecture

The IEEE 802.11 architecture consists of several components that interact to provide a WLAN that supports

STA mobility transparently to upper layers.

The basic service set (BSS) is the basic building block of an IEEE 802.11 LAN. Figure 5-1 shows two BSSs,

each of which has two STAs that are members of the BSS.

It is useful to think of the ovals used to depict a BSS as the coverage area within which the member STAs of

the BSS may remain in communication. (The concept of area, while not precise, is often good enough.) This

area is called the Basic Service Area (BSA). If a STA moves out of its BSA, it can no longer directly

communicate with other STAs present in the BSA.

See, e.g., 802.11-2007 § 5.2

5.2.3 Distribution system (DS) concepts

PHY limitations determine the direct station-to-station distance that may be supported. For some networks

this distance is sufficient; for other networks, increased coverage is required.

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 700 of 946 PageID #:

4804
700

Claim 17 of the ’802 Patent Prior Art Reference – 802.11-2007

Instead of existing independently, a BSS may also form a component of an extended form of network that is

built with multiple BSSs. The architectural component used to interconnect BSSs is the DS.

IEEE Std 802.11 logically separates the WM from the distribution system medium (DSM). Each logical

medium is used for different purposes, by a different component of the architecture. The IEEE 802.11

definitions neither preclude, nor demand, that the multiple media be either the same or different.

Recognizing that the multiple media are logically different is key to understanding the flexibility of the

architecture. The IEEE 802.11 LAN architecture is specified independently of the physical characteristics of

any specific implementation.

The DS enables mobile device support by providing the logical services necessary to handle address to

destination mapping and seamless integration of multiple BSSs.

An access point (AP) is any entity that has STA functionality and enables access to the DS, via the WM for

associated STAs.

See, e.g., 802.11-2007 § 5.2.3

5.3.2 DSS

The service provided by the DS is known as the DSS.

This service is represented in the IEEE 802.11 architecture by arrows within the APs, indicating that the

service is used to cross media and possibly address space logical boundaries. An AP is a logical entity, and

the functions described may be shared by one or more physical entities.

The services that comprise the DSS are as follows:

a) Association

b) Disassociation

c) Distribution

d) Integration

e) Reassociation

f) QoS traffic scheduling (QoS facility only)

DSSs are specified for use by MAC sublayer entities.

Figure 5-7 combines the components from previous figures with both types of services to show the complete

IEEE 802.11 architecture.

See, e.g., 802.11-2007 § 5.3.2

5.4.4.1 TPC

Radio regulations may require radio local area networks (RLANs) operating in the 5 GHz band to use

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 701 of 946 PageID #:

4805
701

Claim 17 of the ’802 Patent Prior Art Reference – 802.11-2007

transmitter power control, involving specification of a regulatory maximum transmit power and a mitigation

requirement for each allowed channel, to reduce interference with satellite services. The TPC service is used

to satisfy this regulatory requirement.

The TPC service provides for the following:

— Association of STAs with an AP in a BSS based on the STAs’ power capability.

— Specification of regulatory and local maximum transmit power levels for the current channel.

— Selection of a transmit power for each transmission in a channel within constraints imposed by

regulatory requirements.

— Adaptation of transmit power based on a range of information, including path loss and link margin

estimates.

See, e.g., 802.11-2007 § 5.4.4.1

7.3.2.20 Channel Switch Announcement element

The Channel Switch Announcement element is used by an AP in a BSS or a STA in an IBSS to advertise

when it is changing to a new channel and the channel number of the new channel. The format of the Channel

Switch Announcement element is shown in Figure 7-57.

See, e.g., 802.11-2007 § 7.3.2.20

10.3.11 Spectrum management protocol layer model

The layer management extensions for measurement and channel switching assume a certain partition

of spectrum management functionality between the MLME and SME. This partitioning assumes that

policy decisions (e.g., regarding measurement and channel switching) reside in the SME, while the protocol

for measurement, switch timing, and the associated frame exchanges resides within the MLME (see

Figure 10-2).

...

The informative diagrams within this subclause further illustrate the spectrum management protocol model

adopted. Figure 10-3 and Figure 10-4 depict the measurement process for a peer STA to accept and reject a

measurement request, respectively. Figure 10-5 illustrates the TPC adaptation process. Lastly, Figure 10-6

depicts the management process for a channel switch using a Channel Switch Announcement frame.

See, e.g., 802.11-2007 § 10.3.11

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 702 of 946 PageID #:

4806
702

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 703 of 946 PageID #:

4807
703

Claim 17 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 § 10.4.3.2

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 704 of 946 PageID #:

4808
704

Claim 17 of the ’802 Patent Prior Art Reference – 802.11-2007

17.1 Introduction

This clause specifies the PHY entity for an orthogonal frequency division multiplexing (OFDM) system.

The OFDM system provides a WLAN with data payload communication capabilities of 6, 9, 12, 18, 24, 36,

48, and 54 Mb/s. The support of transmitting and receiving at data rates of 6, 12, and 24 Mb/s is mandatory.

The system uses 52 subcarriers that are modulated using binary or quadrature phase shift keying (BPSK or

QPSK) or using 16- or 64-quadrature amplitude modulation (16-QAM or 64-QAM). Forward error

correction coding (convolutional coding) is used with a coding rate of 1/2, 2/3, or 3/4.

The OFDM system also provides a “half-clocked” operation using 10 MHz channel spacings with data

communications capabilities of 3, 4.5, 6, 9, 12, 18, 24, and 27 Mb/s. The support of transmitting and

receiving at data rates of 3, 6, and 12 Mb/s is mandatory when using 10 MHz channel spacing. The halfclocked

operation doubles symbol times and clear channel assessment (CCA) times when using 10 MHz

channel spacing. The regulatory requirements and information regarding use of this OFDM system in

4.9 GHz and 5 GHz bands is in Annex I and Annex J.

The OFDM system also provides a “quarter-clocked” operation using 5 MHz channel spacing with data

communication capabilities of 1.5, 2.25, 3, 4.5, 6, 9, 12, and 13.5 Mb/s. The support of transmitting and

receiving at data rates of 1.5, 3, and 6 Mb/s is mandatory when using 5 MHz channel spacing. The quarterclocked

operation quadruples symbol times and CCA times when using 5 MHz channel spacing. The

regulatory requirements and information regarding use of this OFDM system in the 4.9 GHz band is in

Annex I and Annex J.

See, e.g., 802.11-2007 § 17.1

17.3.2.1 Overview of the PPDU encoding process

The encoding process is composed of many detailed steps, which are described fully in later subclauses, as

noted below. The following overview intends to facilitate understanding the details of the convergence

procedure:

a) Produce the PLCP Preamble field, composed of 10 repetitions of a “short training sequence” (used

for AGC convergence, diversity selection, timing acquisition, and coarse frequency acquisition in

the receiver) and two repetitions of a “long training sequence” (used for channel estimation and fine

frequency acquisition in the receiver), preceded by a guard interval (GI). Refer to 17.3.3 for details.

b) Produce the PLCP header field from the RATE, LENGTH, and SERVICE fields of the

TXVECTOR by filling the appropriate bit fields. The RATE and LENGTH fields of the PLCP

header are encoded by a convolutional code at a rate of R = 1/2, and are subsequently mapped onto a

single BPSK encoded OFDM symbol, denoted as the SIGNAL symbol. In order to facilitate a

reliable and timely detection of the RATE and LENGTH fields, 6 zero tail bits are inserted into the

PLCP header. The encoding of the SIGNAL field into an OFDM symbol follows the same steps for

convolutional encoding, interleaving, BPSK modulation, pilot insertion, Fourier transform, and

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 705 of 946 PageID #:

4809
705

Claim 17 of the ’802 Patent Prior Art Reference – 802.11-2007

prepending a GI as described subsequently for data transmission with BPSK-OFDM modulated at

coding rate 1/2. The contents of the SIGNAL field are not scrambled. Refer to 17.3.4 for details.

c) Calculate from RATE field of the TXVECTOR the number of data bits per OFDM symbol (NDBPS),

the coding rate (R), the number of bits in each OFDM subcarrier (NBPSC), and the number of coded

bits per OFDM symbol (NCBPS). Refer to 17.3.2.2 for details.

d) Append the PSDU to the SERVICE field of the TXVECTOR. Extend the resulting bit string with

zero bits (at least 6 bits) so that the resulting length will be a multiple of NDBPS. The resulting bit

string constitutes the DATA part of the packet. Refer to 17.3.5.3 for details.

e) Initiate the scrambler with a pseudo-random nonzero seed, generate a scrambling sequence, and

XOR it with the extended string of data bits. Refer to 17.3.5.4 for details.

f) Replace the six scrambled zero bits following the data with six nonscrambled zero bits. (Those bits

return the convolutional encoder to the zero state and are denoted as tail bits.) Refer to 17.3.5.2 for

details.

g) Encode the extended, scrambled data string with a convolutional encoder (R = 1/2). Omit (puncture)

some of the encoder output string (chosen according to “puncturing pattern”) to reach the desired

“coding rate.” Refer to 17.3.5.5 for details.

h) Divide the encoded bit string into groups of NCBPS bits. Within each group, perform an

“interleaving” (reordering) of the bits according to a rule corresponding to the desired RATE. Refer

to 17.3.5.6 for details.

i) Divide the resulting coded and interleaved data string into groups of NCBPS bits. For each of the bit

groups, convert the bit group into a complex number according to the modulation encoding tables.

Refer to 17.3.5.7 for details.

j) Divide the complex number string into groups of 48 complex numbers. Each such group will be

associated with one OFDM symbol. In each group, the complex numbers will be numbered 0 to 47

and mapped hereafter into OFDM subcarriers numbered –26 to –22, –20 to –8, –6 to –1, 1 to 6,

8 to 20, and 22 to 26. The subcarriers –21, –7, 7, and 21 are skipped and, subsequently, used for

inserting pilot subcarriers. The 0 subcarrier, associated with center frequency, is omitted and filled

with zero value. Refer to 17.3.5.9 for details.

k) Four subcarriers are inserted as pilots into positions –21, –7, 7, and 21. The total number of the

subcarriers is 52 (48 + 4). Refer to 17.3.5.8 for details.

l) For each group of subcarriers –26 to 26, convert the subcarriers to time domain using inverse

Fourier transform. Prepend to the Fourier-transformed waveform a circular extension of itself thus

forming a GI, and truncate the resulting periodic waveform to a single OFDM symbol length by

applying time domain windowing. Refer to 17.3.5.9 for details.

m) Append the OFDM symbols one after another, starting after the SIGNAL symbol describing the

RATE and LENGTH fields. Refer to 17.3.5.9 for details.

n) Up-convert the resulting “complex baseband” waveform to an RF according to the center frequency

of the desired channel and transmit. Refer to 17.3.2.4 and 17.3.8.1 for details.

An illustration of the transmitted frame and its parts appears in Figure 17-4 (in 17.3.3).

See, e.g., 802.11-2007 § 17.3.2.1

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 706 of 946 PageID #:

4810
706

Claim 17 of the ’802 Patent Prior Art Reference – 802.11-2007

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 707 of 946 PageID #:

4811
707

Claim 17 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 § 17.3.2.3

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 708 of 946 PageID #:

4812
708

Claim 17 of the ’802 Patent Prior Art Reference – 802.11-2007

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 709 of 946 PageID #:

4813
709

Claim 17 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 § 17.3.2.4 Eq. (17-1)

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 710 of 946 PageID #:

4814
710

Claim 17 of the ’802 Patent Prior Art Reference – 802.11-2007

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 711 of 946 PageID #:

4815
711

Claim 17 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 § 17.3.2.5

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 712 of 946 PageID #:

4816
712

Claim 17 of the ’802 Patent Prior Art Reference – 802.11-2007

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 713 of 946 PageID #:

4817
713

See, e.g., 802.11-2007 § 17.3.3

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 714 of 946 PageID #:

4818
714

Claim 17 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 § 17.3.5.7

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 715 of 946 PageID #:

4819
715

Claim 17 of the ’802 Patent Prior Art Reference – 802.11-2007

17.3.5.8 Pilot subcarriers

In each OFDM symbol, four of the subcarriers are dedicated to pilot signals in order to make the coherent

detection robust against frequency offsets and phase noise. These pilot signals shall be put in subcarriers

–21, –7, 7, and 21. The pilots shall be BPSK modulated by a pseudo-binary sequence to prevent the

generation of spectral lines. The contribution of the pilot subcarriers to each OFDM symbol is described in

17.3.5.9.

See, e.g., 802.11-2007 § 17.3.5.8

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 716 of 946 PageID #:

4820
716

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 717 of 946 PageID #:

4821
717

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 718 of 946 PageID #:

4822
718

Claim 17 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 § 17.3.5.9

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 719 of 946 PageID #:

4823
719

Claim 17 of the ’802 Patent Prior Art Reference – 802.11-2007

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 720 of 946 PageID #:

4824
720

Claim 17 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 § 17.3.8.1

17.3.8.3.1 Operating frequency range

The OFDM PHY shall operate in the 5 GHz band, as allocated by a regulatory body in its operational region.

Spectrum allocation in the 5 GHz band is subject to authorities responsible for geographic-specific

regulatory domains (e.g., global, regional, and national). The particular channelization to be used for this

standard is dependent on such allocation, as well as the associated regulations for use of the allocations.

These regulations are subject to revision, or may be superseded.

In some regulatory domains, several frequency bands may be available for OFDM PHY-based WLANs.

These bands may be contiguous or not, and different regulatory limits may be applicable. A compliant

OFDM PHY shall support at least one frequency band in at least one regulatory domain. The support of

specific regulatory domains, and bands within the domains, shall be indicated by PLME attributes

dot11RegDomainsSupported and dot11FrequencyBandsSupported.

See, e.g., 802.11-2007 § 17.3.8.3.1

17.3.9.1 Transmit power levels

The maximum allowable transmit power by regulatory domain is defined in Annex I.

See, e.g., 802.11-2007 § 17.3.9.1

17.3.9.6.2 Transmitter spectral flatness

The average energy of the constellations in each of the spectral lines –16.. –1 and +1.. +16 will deviate no

more than ± 2 dB from their average energy. The average energy of the constellations in each of the spectral

lines –26.. –17 and +17.. +26 will deviate no more than +2/–4 dB from the average energy of spectral lines

–16.. –1 and +1.. +16. The data for this test shall be derived from the channel estimation step.

See, e.g., 802.11-2007 § 17.3.9.6.2

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 721 of 946 PageID #:

4825
721

Claim 17 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 § I.2.2

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 722 of 946 PageID #:

4826
722

Claim 17 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 § I.2.3

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 723 of 946 PageID #:

4827
723

Claim 17 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 Figure 5-7

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 724 of 946 PageID #:

4828
724

Claim 17 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 Figure 10-6

Furthermore, this claim element is obvious in light of 802.11-2007 itself, when combined with any of 

the other references as charted for this claim element in Exs. A-1–A-31, First Supplemental Ex. ACase 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 725 of 946 PageID #:

4829
725

Claim 17 of the ’802 Patent Prior Art Reference – 802.11-2007

Obviousness 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.

[17.6] 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 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

802.11-2007 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 

second 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 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.” See, 

e.g.: 

1.1 Scope

The scope of this standard is to define one medium access control (MAC) and several physical layer (PHY)

specifications for wireless connectivity for fixed, portable, and moving stations (STAs) within a local area.

See, e.g., 802.11-2007 § 1.1

5.1.1 How WLAN systems are different

Wireless networks have fundamental characteristics that make them significantly different from traditional

wired LANs. Some countries impose specific requirements for radio equipment in addition to those

specified in this standard. This standard does not provide information to meet these country-specific radio

regulations.

5.1.1.1 Destination address does not equal destination location

In wired LANs, an address is equivalent to a physical location. This is implicitly assumed in the design of

wired LANs. In IEEE Std 802.11, the addressable unit is a station (STA). The STA is a message destination,

but not (in general) a fixed location.

5.1.1.2 Media impact on design and performance

The PHYs used in IEEE Std 802.11 are fundamentally different from wired media. Thus IEEE 802.11 PHYs

a) Use a medium that has neither absolute nor readily observable boundaries outside of which STAs

with conformant PHY transceivers are known to be unable to receive network frames

b) Are unprotected from other signals that may be sharing the medium

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 726 of 946 PageID #:

4830
726

Claim 17 of the ’802 Patent Prior Art Reference – 802.11-2007

c) Communicate over a medium significantly less reliable than wired PHYs

d) Have dynamic topologies

e) Lack full connectivity, and therefore the assumption normally made that every STA can hear every

other STA is invalid (i.e., STAs may be “hidden” from each other)

f) Have time-varying and asymmetric propagation properties

g) May experience interference from logically disjoint IEEE 802.11 networks operating in overlapping

areas

Because of limitations on wireless PHY ranges, WLANs intended to cover reasonable geographic distances

may be built from basic coverage building blocks. When providing QoS services it should be understood

that the MAC endeavors to provide QoS “service guarantees” within the limitations of the medium

properties identified above. In other words, particularly in unlicensed spectrum, true guarantees are often not

possible. However, gradations of service are always possible; and in sufficiently controlled environments,

QoS guarantees can truly be made.

5.1.1.3 The impact of handling mobile STAs

One of the requirements of IEEE Std 802.11 is to handle mobile as well as portable STAs. A portable STA

is one that is moved from location to location, but that is only used while at a fixed location. Mobile STAs

actually access the LAN while in motion.

For technical reasons, it is not sufficient to handle only portable STAs. Propagation effects blur the

distinction between portable and mobile STAs; stationary STAs often appear to be mobile due to

propagation effects.

Another aspect of mobile STAs is that they may often be battery powered. Hence power management is

an important consideration. For example, it cannot be presumed that a STA’s receiver will always be

powered on.

See, e.g., 802.11-2007 § 5.1.1 - § 5.1.1.3

5.2 Components of the IEEE 802.11 architecture

The IEEE 802.11 architecture consists of several components that interact to provide a WLAN that supports

STA mobility transparently to upper layers.

The basic service set (BSS) is the basic building block of an IEEE 802.11 LAN. Figure 5-1 shows two BSSs,

each of which has two STAs that are members of the BSS.

It is useful to think of the ovals used to depict a BSS as the coverage area within which the member STAs of

the BSS may remain in communication. (The concept of area, while not precise, is often good enough.) This

area is called the Basic Service Area (BSA). If a STA moves out of its BSA, it can no longer directly

communicate with other STAs present in the BSA.

See, e.g., 802.11-2007 § 5.2

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 727 of 946 PageID #:

4831
727

Claim 17 of the ’802 Patent Prior Art Reference – 802.11-2007

5.2.3 Distribution system (DS) concepts

PHY limitations determine the direct station-to-station distance that may be supported. For some networks

this distance is sufficient; for other networks, increased coverage is required.

Instead of existing independently, a BSS may also form a component of an extended form of network that is

built with multiple BSSs. The architectural component used to interconnect BSSs is the DS.

IEEE Std 802.11 logically separates the WM from the distribution system medium (DSM). Each logical

medium is used for different purposes, by a different component of the architecture. The IEEE 802.11

definitions neither preclude, nor demand, that the multiple media be either the same or different.

Recognizing that the multiple media are logically different is key to understanding the flexibility of the

architecture. The IEEE 802.11 LAN architecture is specified independently of the physical characteristics of

any specific implementation.

The DS enables mobile device support by providing the logical services necessary to handle address to

destination mapping and seamless integration of multiple BSSs.

An access point (AP) is any entity that has STA functionality and enables access to the DS, via the WM for

associated STAs.

See, e.g., 802.11-2007 § 5.2.3

5.3.2 DSS

The service provided by the DS is known as the DSS.

This service is represented in the IEEE 802.11 architecture by arrows within the APs, indicating that the

service is used to cross media and possibly address space logical boundaries. An AP is a logical entity, and

the functions described may be shared by one or more physical entities.

The services that comprise the DSS are as follows:

a) Association

b) Disassociation

c) Distribution

d) Integration

e) Reassociation

f) QoS traffic scheduling (QoS facility only)

DSSs are specified for use by MAC sublayer entities.

Figure 5-7 combines the components from previous figures with both types of services to show the complete

IEEE 802.11 architecture.

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 728 of 946 PageID #:

4832
728

Claim 17 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 § 5.3.2

5.4.4.1 TPC

Radio regulations may require radio local area networks (RLANs) operating in the 5 GHz band to use

transmitter power control, involving specification of a regulatory maximum transmit power and a mitigation

requirement for each allowed channel, to reduce interference with satellite services. The TPC service is used

to satisfy this regulatory requirement.

The TPC service provides for the following:

— Association of STAs with an AP in a BSS based on the STAs’ power capability.

— Specification of regulatory and local maximum transmit power levels for the current channel.

— Selection of a transmit power for each transmission in a channel within constraints imposed by

regulatory requirements.

— Adaptation of transmit power based on a range of information, including path loss and link margin

estimates.

See, e.g., 802.11-2007 § 5.4.4.1

7.3.2.20 Channel Switch Announcement element

The Channel Switch Announcement element is used by an AP in a BSS or a STA in an IBSS to advertise

when it is changing to a new channel and the channel number of the new channel. The format of the Channel

Switch Announcement element is shown in Figure 7-57.

See, e.g., 802.11-2007 § 7.3.2.20

10.3.11 Spectrum management protocol layer model

The layer management extensions for measurement and channel switching assume a certain partition

of spectrum management functionality between the MLME and SME. This partitioning assumes that

policy decisions (e.g., regarding measurement and channel switching) reside in the SME, while the protocol

for measurement, switch timing, and the associated frame exchanges resides within the MLME (see

Figure 10-2).

...

The informative diagrams within this subclause further illustrate the spectrum management protocol model

adopted. Figure 10-3 and Figure 10-4 depict the measurement process for a peer STA to accept and reject a

measurement request, respectively. Figure 10-5 illustrates the TPC adaptation process. Lastly, Figure 10-6

depicts the management process for a channel switch using a Channel Switch Announcement frame.

See, e.g., 802.11-2007 § 10.3.11

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 729 of 946 PageID #:

4833
729

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 730 of 946 PageID #:

4834
730

Claim 17 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 § 10.4.3.2

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 731 of 946 PageID #:

4835
731

Claim 17 of the ’802 Patent Prior Art Reference – 802.11-2007

17.1 Introduction

This clause specifies the PHY entity for an orthogonal frequency division multiplexing (OFDM) system.

The OFDM system provides a WLAN with data payload communication capabilities of 6, 9, 12, 18, 24, 36,

48, and 54 Mb/s. The support of transmitting and receiving at data rates of 6, 12, and 24 Mb/s is mandatory.

The system uses 52 subcarriers that are modulated using binary or quadrature phase shift keying (BPSK or

QPSK) or using 16- or 64-quadrature amplitude modulation (16-QAM or 64-QAM). Forward error

correction coding (convolutional coding) is used with a coding rate of 1/2, 2/3, or 3/4.

The OFDM system also provides a “half-clocked” operation using 10 MHz channel spacings with data

communications capabilities of 3, 4.5, 6, 9, 12, 18, 24, and 27 Mb/s. The support of transmitting and

receiving at data rates of 3, 6, and 12 Mb/s is mandatory when using 10 MHz channel spacing. The halfclocked

operation doubles symbol times and clear channel assessment (CCA) times when using 10 MHz

channel spacing. The regulatory requirements and information regarding use of this OFDM system in

4.9 GHz and 5 GHz bands is in Annex I and Annex J.

The OFDM system also provides a “quarter-clocked” operation using 5 MHz channel spacing with data

communication capabilities of 1.5, 2.25, 3, 4.5, 6, 9, 12, and 13.5 Mb/s. The support of transmitting and

receiving at data rates of 1.5, 3, and 6 Mb/s is mandatory when using 5 MHz channel spacing. The quarterclocked

operation quadruples symbol times and CCA times when using 5 MHz channel spacing. The

regulatory requirements and information regarding use of this OFDM system in the 4.9 GHz band is in

Annex I and Annex J.

See, e.g., 802.11-2007 § 17.1

17.3.2.1 Overview of the PPDU encoding process

The encoding process is composed of many detailed steps, which are described fully in later subclauses, as

noted below. The following overview intends to facilitate understanding the details of the convergence

procedure:

a) Produce the PLCP Preamble field, composed of 10 repetitions of a “short training sequence” (used

for AGC convergence, diversity selection, timing acquisition, and coarse frequ ency acquisition in

the receiver) and two repetitions of a “long training sequence” (used for channel estimation and fine

frequency acquisition in the receiver), preceded by a guard interval (GI). Refer to 17.3.3 for details.

b) Produce the PLCP header field from the RATE, LENGTH, and SERVICE fields of the

TXVECTOR by filling the appropriate bit fields. The RATE and LENGTH fields of the PLCP

header are encoded by a convolutional code at a rate of R = 1/2, and are subsequently mapped onto a

single BPSK encoded OFDM symbol, denoted as the SIGNAL symbol. In order to facilitate a

reliable and timely detection of the RATE and LENGTH fields, 6 zero tail bits are inserted into the

PLCP header. The encoding of the SIGNAL field into an OFDM symbol follows the same steps for

convolutional encoding, interleaving, BPSK modulation, pilot insertion, Fourier transform, and

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 732 of 946 PageID #:

4836
732

Claim 17 of the ’802 Patent Prior Art Reference – 802.11-2007

prepending a GI as described subsequently for data transmission with BPSK-OFDM modulated at

coding rate 1/2. The contents of the SIGNAL field are not scrambled. Refer to 17.3.4 for details.

c) Calculate from RATE field of the TXVECTOR the number of data bits per OFDM symbol (NDBPS),

the coding rate (R), the number of bits in each OFDM subcarrier (NBPSC), and the number of coded

bits per OFDM symbol (NCBPS). Refer to 17.3.2.2 for details.

d) Append the PSDU to the SERVICE field of the TXVECTOR. Extend the resulting bit string with

zero bits (at least 6 bits) so that the resulting length will be a multiple of NDBPS. The resulting bit

string constitutes the DATA part of the packet. Refer to 17.3.5.3 for details.

e) Initiate the scrambler with a pseudo-random nonzero seed, generate a scrambling sequence, and

XOR it with the extended string of data bits. Refer to 17.3.5.4 for details.

f) Replace the six scrambled zero bits following the data with six nonscrambled zero bits. (Those bits

return the convolutional encoder to the zero state and are denoted as tail bits.) Refer to 17.3.5.2 for

details.

g) Encode the extended, scrambled data string with a convolutional encoder (R = 1/2). Omit (puncture)

some of the encoder output string (chosen according to “puncturing pattern”) to reach the desired

“coding rate.” Refer to 17.3.5.5 for details.

h) Divide the encoded bit string into groups of NCBPS bits. Within each group, perform an

“interleaving” (reordering) of the bits according to a rule corresponding to the desired RATE. Refer

to 17.3.5.6 for details.

i) Divide the resulting coded and interleaved data string into groups of NCBPS bits. For each of the bit

groups, convert the bit group into a complex number according to the modulation encoding tables.

Refer to 17.3.5.7 for details.

j) Divide the complex number string into groups of 48 complex numbers. Each such group will be

associated with one OFDM symbol. In each group, the complex numbers will be numbered 0 to 47

and mapped hereafter into OFDM subcarriers numbered –26 to –22, –20 to –8, –6 to –1, 1 to 6,

8 to 20, and 22 to 26. The subcarriers –21, –7, 7, and 21 are skipped and, subsequently, used for

inserting pilot subcarriers. The 0 subcarrier, associated with center frequency, is omitted and filled

with zero value. Refer to 17.3.5.9 for details.

k) Four subcarriers are inserted as pilots into positions –21, –7, 7, and 21. The total number of the

subcarriers is 52 (48 + 4). Refer to 17.3.5.8 for details.

l) For each group of subcarriers –26 to 26, convert the subcarriers to time domain using inverse

Fourier transform. Prepend to the Fourier-transformed waveform a circular extension of itself thus

forming a GI, and truncate the resulting periodic waveform to a single OFDM symbol length by

applying time domain windowing. Refer to 17.3.5.9 for details.

m) Append the OFDM symbols one after another, starting after the SIGNAL symbol describing the

RATE and LENGTH fields. Refer to 17.3.5.9 for details.

n) Up-convert the resulting “complex baseband” waveform to an RF according to the center frequency

of the desired channel and transmit. Refer to 17.3.2.4 and 17.3.8.1 for details.

An illustration of the transmitted frame and its parts appears in Figure 17-4 (in 17.3.3).

See, e.g., 802.11-2007 § 17.3.2.1

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 733 of 946 PageID #:

4837
733

Claim 17 of the ’802 Patent Prior Art Reference – 802.11-2007

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 734 of 946 PageID #:

4838
734

Claim 17 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 § 17.3.2.3

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 735 of 946 PageID #:

4839
735

Claim 17 of the ’802 Patent Prior Art Reference – 802.11-2007

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 736 of 946 PageID #:

4840
736

Claim 17 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 § 17.3.2.4 Eq. (17-1)

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 737 of 946 PageID #:

4841
737

Claim 17 of the ’802 Patent Prior Art Reference – 802.11-2007

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 738 of 946 PageID #:

4842
738

Claim 17 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 § 17.3.2.5

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 739 of 946 PageID #:

4843
739

Claim 17 of the ’802 Patent Prior Art Reference – 802.11-2007

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 740 of 946 PageID #:

4844
740

See, e.g., 802.11-2007 § 17.3.3

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 741 of 946 PageID #:

4845
741

Claim 17 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 § 17.3.5.7

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 742 of 946 PageID #:

4846
742

Claim 17 of the ’802 Patent Prior Art Reference – 802.11-2007

17.3.5.8 Pilot subcarriers

In each OFDM symbol, four of the subcarriers are dedicated to pilot signals in order to make the coherent

detection robust against frequency offsets and phase noise. These pilot signals shall be put in subcarriers

–21, –7, 7, and 21. The pilots shall be BPSK modulated by a pseudo-binary sequence to prevent the

generation of spectral lines. The contribution of the pilot subcarriers to each OFDM symbol is described in

17.3.5.9.

See, e.g., 802.11-2007 § 17.3.5.8

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 743 of 946 PageID #:

4847
743

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 744 of 946 PageID #:

4848
744

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 745 of 946 PageID #:

4849
745

Claim 17 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 § 17.3.5.9

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 746 of 946 PageID #:

4850
746

Claim 17 of the ’802 Patent Prior Art Reference – 802.11-2007

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 747 of 946 PageID #:

4851
747

Claim 17 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 § 17.3.8.1

17.3.8.3.1 Operating frequency range

The OFDM PHY shall operate in the 5 GHz band, as allocated by a regulatory body in its operational region.

Spectrum allocation in the 5 GHz band is subject to authorities responsible for geographic-specific

regulatory domains (e.g., global, regional, and national). The particular channelization to be used for this

standard is dependent on such allocation, as well as the associated regulations for use of the allocations.

These regulations are subject to revision, or may be superseded.

In some regulatory domains, several frequency bands may be available for OFDM PHY-based WLANs.

These bands may be contiguous or not, and different regulatory limits may be applicable. A compliant

OFDM PHY shall support at least one frequency band in at least one regulatory domain. The support of

specific regulatory domains, and bands within the domains, shall be indicated by PLME attributes

dot11RegDomainsSupported and dot11FrequencyBandsSupported.

See, e.g., 802.11-2007 § 17.3.8.3.1

17.3.9.1 Transmit power levels

The maximum allowable transmit power by regulatory domain is defined in Annex I.

See, e.g., 802.11-2007 § 17.3.9.1

17.3.9.6.2 Transmitter spectral flatness

The average energy of the constellations in each of the spectral lines –16.. –1 and +1.. +16 will deviate no

more than ± 2 dB from their average energy. The average energy of the constellations in each of the spectral

lines –26.. –17 and +17.. +26 will deviate no more than +2/–4 dB from the average energy of spectral lines

–16.. –1 and +1.. +16. The data for this test shall be derived from the channel estimation step.

See, e.g., 802.11-2007 § 17.3.9.6.2

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 748 of 946 PageID #:

4852
748

Claim 17 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 § I.2.2

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 749 of 946 PageID #:

4853
749

Claim 17 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 § I.2.3

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 750 of 946 PageID #:

4854
750

Claim 17 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 Figure 5-7

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 751 of 946 PageID #:

4855
751

Claim 17 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 Figure 10-6

Furthermore, this claim element is obvious in light of 802.11-2007 itself, when combined with any of 

the other references as charted for this claim element in Exs. A-1–A-31, First Supplemental Ex. ACase 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 752 of 946 PageID #:

4856
752

Claim 17 of the ’802 Patent Prior Art Reference – 802.11-2007

Obviousness 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 

second up-converted 

frequency range.

802.11-2007 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.: 

1.1 Scope

The scope of this standard is to define one medium access control (MAC) and several physical layer (PHY)

specifications for wireless connectivity for fixed, portable, and moving stations (STAs) within a local area.

See, e.g., 802.11-2007 § 1.1

5.1.1 How WLAN systems are different

Wireless networks have fundamental characteristics that make them significantly different from traditional

wired LANs. Some countries impose specific requirements for radio equipment in addition to those

specified in this standard. This standard does not provide information to meet these country -specific radio

regulations.

5.1.1.1 Destination address does not equal destination location

In wired LANs, an address is equivalent to a physical location. This is implicitly assumed in the design of

wired LANs. In IEEE Std 802.11, the addressable unit is a station (STA). The STA is a message destination,

but not (in general) a fixed location.

5.1.1.2 Media impact on design and performance

The PHYs used in IEEE Std 802.11 are fundamentally different from wired media. Thus IEEE 802.11 PHYs

a) Use a medium that has neither absolute nor readily observable boundaries outside of which STAs

with conformant PHY transceivers are known to be unable to receive network frames

b) Are unprotected from other signals that may be sharing the medium

c) Communicate over a medium significantly less reliable than wired PHYs

d) Have dynamic topologies

e) Lack full connectivity, and therefore the assumption normally made that every STA can hear every

other STA is invalid (i.e., STAs may be “hidden” from each other)

f) Have time-varying and asymmetric propagation properties

g) May experience interference from logically disjoint IEEE 802.11 networks operating in overlapping

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 753 of 946 PageID #:

4857
753

Claim 17 of the ’802 Patent Prior Art Reference – 802.11-2007

areas

Because of limitations on wireless PHY ranges, WLANs intended to cover reasonable geographic distances

may be built from basic coverage building blocks. When providing QoS services it should be understood

that the MAC endeavors to provide QoS “service guarantees” within the limitations of the medium

properties identified above. In other words, particularly in unlicensed spectrum, true guarantees are often not

possible. However, gradations of service are always possible; and in sufficiently controlled environments,

QoS guarantees can truly be made.

5.1.1.3 The impact of handling mobile STAs

One of the requirements of IEEE Std 802.11 is to handle mobile as well as portable STAs. A portable STA

is one that is moved from location to location, but that is only used while at a fixed location. Mobile STAs

actually access the LAN while in motion.

For technical reasons, it is not sufficient to handle only portable STAs. Propagation effects blur the

distinction between portable and mobile STAs; stationary STAs often appear to be mobile due to

propagation effects.

Another aspect of mobile STAs is that they may often be battery powered. Hence power management is

an important consideration. For example, it cannot be presumed that a STA’s receiver will alway s be

powered on.

See, e.g., 802.11-2007 § 5.1.1 - § 5.1.1.3

5.2 Components of the IEEE 802.11 architecture

The IEEE 802.11 architecture consists of several components that interact to provide a WLAN that supports

STA mobility transparently to upper layers.

The basic service set (BSS) is the basic building block of an IEEE 802.11 LAN. Figure 5 -1 shows two BSSs,

each of which has two STAs that are members of the BSS.

It is useful to think of the ovals used to depict a BSS as the coverage area within which the member STAs of

the BSS may remain in communication. (The concept of area, while not precise, is often good enough.) This

area is called the Basic Service Area (BSA). If a STA moves out of its BSA, it can no longer directly

communicate with other STAs present in the BSA.

See, e.g., 802.11-2007 § 5.2

5.2.3 Distribution system (DS) concepts

PHY limitations determine the direct station-to-station distance that may be supported. For some networks

this distance is sufficient; for other networks, increased coverage is required.

Instead of existing independently, a BSS may also form a component of an extended form of network that is

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 754 of 946 PageID #:

4858
754

Claim 17 of the ’802 Patent Prior Art Reference – 802.11-2007

built with multiple BSSs. The architectural component used to interconnect BSSs is the DS.

IEEE Std 802.11 logically separates the WM from the distribution system medium (DSM). Each logical

medium is used for different purposes, by a different component of the architecture. The IEEE 802.11

definitions neither preclude, nor demand, that the multiple media be either the same or different.

Recognizing that the multiple media are logically different is key to understanding the flexibility of the

architecture. The IEEE 802.11 LAN architecture is specified independently of the physical characteristics of

any specific implementation.

The DS enables mobile device support by providing the logical services necessary to handle address to

destination mapping and seamless integration of multiple BSSs.

An access point (AP) is any entity that has STA functionality and enables access to the DS, via the WM for

associated STAs.

See, e.g., 802.11-2007 § 5.2.3

5.3.2 DSS

The service provided by the DS is known as the DSS.

This service is represented in the IEEE 802.11 architecture by arrows within the APs, indicating that the

service is used to cross media and possibly address space logical boundaries. An AP is a logical entity, and

the functions described may be shared by one or more physical entities.

The services that comprise the DSS are as follows:

a) Association

b) Disassociation

c) Distribution

d) Integration

e) Reassociation

f) QoS traffic scheduling (QoS facility only)

DSSs are specified for use by MAC sublayer entities.

Figure 5-7 combines the components from previous figures with both types of services to show the complete

IEEE 802.11 architecture.

See, e.g., 802.11-2007 § 5.3.2

5.4.4.1 TPC

Radio regulations may require radio local area networks (RLANs) operating in the 5 GHz band to use

transmitter power control, involving specification of a regulatory maximum transmit power and a mitigation

requirement for each allowed channel, to reduce interference with satellite services. The TPC service is used

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 755 of 946 PageID #:

4859
755

Claim 17 of the ’802 Patent Prior Art Reference – 802.11-2007

to satisfy this regulatory requirement.

The TPC service provides for the following:

— Association of STAs with an AP in a BSS based on the STAs’ power capability.

— Specification of regulatory and local maximum transmit power levels for the current channel.

— Selection of a transmit power for each transmission in a channel within constraints imposed by

regulatory requirements.

— Adaptation of transmit power based on a range of information, including path loss and link margin

estimates.

See, e.g., 802.11-2007 § 5.4.4.1

7.3.2.20 Channel Switch Announcement element

The Channel Switch Announcement element is used by an AP in a BSS or a STA in an IBSS to advertise

when it is changing to a new channel and the channel number of the new channel. The format of the Channel

Switch Announcement element is shown in Figure 7-57.

See, e.g., 802.11-2007 § 7.3.2.20

10.3.11 Spectrum management protocol layer model

The layer management extensions for measurement and channel switching assume a certain partition

of spectrum management functionality between the MLME and SME. This partitioning assumes that

policy decisions (e.g., regarding measurement and channel switching) reside in the SME, while the protocol

for measurement, switch timing, and the associated frame exchanges resides within the MLME (see

Figure 10-2).

...

The informative diagrams within this subclause further illustrate the spectrum management protocol model

adopted. Figure 10-3 and Figure 10-4 depict the measurement process for a peer STA to accept and reject a

measurement request, respectively. Figure 10-5 illustrates the TPC adaptation process. Lastly, Figure 10-6

depicts the management process for a channel switch using a Channel Switch Announcement frame.

See, e.g., 802.11-2007 § 10.3.11

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 756 of 946 PageID #:

4860
756

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 757 of 946 PageID #:

4861
757

Claim 17 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 § 10.4.3.2

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 758 of 946 PageID #:

4862
758

Claim 17 of the ’802 Patent Prior Art Reference – 802.11-2007

17.1 Introduction

This clause specifies the PHY entity for an orthogonal frequency division multiplexing (OFDM) system.

The OFDM system provides a WLAN with data payload communication capabilities of 6, 9, 12, 18, 24, 36,

48, and 54 Mb/s. The support of transmitting and receiving at data rates of 6, 12, and 24 Mb/s is mandatory.

The system uses 52 subcarriers that are modulated using binary or quadrature phase shift keying (BPSK or

QPSK) or using 16- or 64-quadrature amplitude modulation (16-QAM or 64-QAM). Forward error

correction coding (convolutional coding) is used with a coding rate of 1/2, 2 /3, or 3/4.

The OFDM system also provides a “half-clocked” operation using 10 MHz channel spacings with data

communications capabilities of 3, 4.5, 6, 9, 12, 18, 24, and 27 Mb/s. The support of transmitting and

receiving at data rates of 3, 6, and 12 Mb/s is mandatory when using 10 MHz channel spacing. The halfclocked

operation doubles symbol times and clear channel assessment (CCA) times when using 10 MHz

channel spacing. The regulatory requirements and information regarding use of this OFDM system in

4.9 GHz and 5 GHz bands is in Annex I and Annex J.

The OFDM system also provides a “quarter-clocked” operation using 5 MHz channel spacing with data

communication capabilities of 1.5, 2.25, 3, 4.5, 6, 9, 12, and 13.5 Mb/s. The support of transmitting and

receiving at data rates of 1.5, 3, and 6 Mb/s is mandatory when using 5 MHz channel spacing. The quarterclocked

operation quadruples symbol times and CCA times when using 5 MHz channel spacing. The

regulatory requirements and information regarding use of this OFDM system in the 4.9 GHz band is in

Annex I and Annex J.

See, e.g., 802.11-2007 § 17.1

17.3.2.1 Overview of the PPDU encoding process

The encoding process is composed of many detailed steps, which are described fully in later subclauses, as

noted below. The following overview intends to facilitate understanding the details of the convergence

procedure:

a) Produce the PLCP Preamble field, composed of 10 repetitions of a “short training sequence” (used

for AGC convergence, diversity selection, timing acquisition, and coarse frequency acquisition in

the receiver) and two repetitions of a “long training sequence” (used for channel estimation and fine

frequency acquisition in the receiver), preceded by a guard interval (GI). Refer to 17.3.3 for details.

b) Produce the PLCP header field from the RATE, LENGTH, and SERVICE fields of the

TXVECTOR by filling the appropriate bit fields. The RATE and LENGTH fields of the PLCP

header are encoded by a convolutional code at a rate of R = 1/2, and are subsequently mapped onto a

single BPSK encoded OFDM symbol, denoted as the SIGNAL symbol. In order to facilitate a

reliable and timely detection of the RATE and LENGTH fields, 6 zero tail bits are inserted into the

PLCP header. The encoding of the SIGNAL field into an OFDM symbol follows the same steps for

convolutional encoding, interleaving, BPSK modulation, pilot insertion, Fourier transform, and

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 759 of 946 PageID #:

4863
759

Claim 17 of the ’802 Patent Prior Art Reference – 802.11-2007

prepending a GI as described subsequently for data transmission with BPSK-OFDM modulated at

coding rate 1/2. The contents of the SIGNAL field are not scrambled. Refer to 17.3.4 for details.

c) Calculate from RATE field of the TXVECTOR the number of data bits per OFDM symbol (NDBPS),

the coding rate (R), the number of bits in each OFDM subcarrier (NBPSC), and the number of coded

bits per OFDM symbol (NCBPS). Refer to 17.3.2.2 for details.

d) Append the PSDU to the SERVICE field of the TXVECTOR. Extend the resulting bit string with

zero bits (at least 6 bits) so that the resulting length will be a multiple of NDBPS. The resulting bit

string constitutes the DATA part of the packet. Refer to 17.3.5.3 for details.

e) Initiate the scrambler with a pseudo-random nonzero seed, generate a scrambling sequence, and

XOR it with the extended string of data bits. Refer to 17.3.5.4 for details.

f) Replace the six scrambled zero bits following the data with six nonscrambled zero bits. (Those bits

return the convolutional encoder to the zero state and are denoted as tail bits.) Refer to 17.3.5.2 for

details.

g) Encode the extended, scrambled data string with a convolutional encoder (R = 1/2). Omit (puncture)

some of the encoder output string (chosen according to “puncturing pattern”) to reach the desired

“coding rate.” Refer to 17.3.5.5 for details.

h) Divide the encoded bit string into groups of NCBPS bits. Within each group, perform an

“interleaving” (reordering) of the bits according to a rule corresponding to the desired RATE. Refer

to 17.3.5.6 for details.

i) Divide the resulting coded and interleaved data string into groups of NCBPS bits. For each of the bit

groups, convert the bit group into a complex number according to the modulation encoding tables.

Refer to 17.3.5.7 for details.

j) Divide the complex number string into groups of 48 complex numbers. Each such group will be

associated with one OFDM symbol. In each group, the complex numbers will be numbered 0 to 47

and mapped hereafter into OFDM subcarriers numbered –26 to –22, –20 to –8, –6 to –1, 1 to 6,

8 to 20, and 22 to 26. The subcarriers –21, –7, 7, and 21 are skipped and, subsequently, used for

inserting pilot subcarriers. The 0 subcarrier, associated with center frequency, is omitted and filled

with zero value. Refer to 17.3.5.9 for details.

k) Four subcarriers are inserted as pilots into positions –21, –7, 7, and 21. The total number of the

subcarriers is 52 (48 + 4). Refer to 17.3.5.8 for details.

l) For each group of subcarriers –26 to 26, convert the subcarriers to time domain using inverse

Fourier transform. Prepend to the Fourier-transformed waveform a circular extension of itself thus

forming a GI, and truncate the resulting periodic waveform to a single OFDM symbol length by

applying time domain windowing. Refer to 17.3.5.9 for details.

m) Append the OFDM symbols one after another, starting after the SIGNAL symbol describing the

RATE and LENGTH fields. Refer to 17.3.5.9 for details.

n) Up-convert the resulting “complex baseband” waveform to an RF according to the center frequency

of the desired channel and transmit. Refer to 17.3.2.4 and 17.3.8.1 for details.

An illustration of the transmitted frame and its parts appears in Figure 17-4 (in 17.3.3).

See, e.g., 802.11-2007 § 17.3.2.1

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 760 of 946 PageID #:

4864
760

Claim 17 of the ’802 Patent Prior Art Reference – 802.11-2007

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 761 of 946 PageID #:

4865
761

Claim 17 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 § 17.3.2.3

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 762 of 946 PageID #:

4866
762

Claim 17 of the ’802 Patent Prior Art Reference – 802.11-2007

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 763 of 946 PageID #:

4867
763

Claim 17 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 § 17.3.2.4 Eq. (17-1)

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 764 of 946 PageID #:

4868
764

Claim 17 of the ’802 Patent Prior Art Reference – 802.11-2007

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 765 of 946 PageID #:

4869
765

Claim 17 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 § 17.3.2.5

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 766 of 946 PageID #:

4870
766

Claim 17 of the ’802 Patent Prior Art Reference – 802.11-2007

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 767 of 946 PageID #:

4871
767

See, e.g., 802.11-2007 § 17.3.3

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 768 of 946 PageID #:

4872
768

Claim 17 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 § 17.3.5.7

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 769 of 946 PageID #:

4873
769

Claim 17 of the ’802 Patent Prior Art Reference – 802.11-2007

17.3.5.8 Pilot subcarriers

In each OFDM symbol, four of the subcarriers are dedicated to pilot signals in order to make the coherent

detection robust against frequency offsets and phase noise. These pilot signals shall be put in subcarriers

–21, –7, 7, and 21. The pilots shall be BPSK modulated by a pseudo-binary sequence to prevent the

generation of spectral lines. The contribution of the pilot subcarriers to each OFDM symbol is described in

17.3.5.9.

See, e.g., 802.11-2007 § 17.3.5.8

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 770 of 946 PageID #:

4874
770

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 771 of 946 PageID #:

4875
771

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 772 of 946 PageID #:

4876
772

Claim 17 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 § 17.3.5.9

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 773 of 946 PageID #:

4877
773

Claim 17 of the ’802 Patent Prior Art Reference – 802.11-2007

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 774 of 946 PageID #:

4878
774

Claim 17 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 § 17.3.8.1

17.3.8.3.1 Operating frequency range

The OFDM PHY shall operate in the 5 GHz band, as allocated by a regulatory body in its operational region.

Spectrum allocation in the 5 GHz band is subject to authorities responsible for geographic-specific

regulatory domains (e.g., global, regional, and national). The particular channelization to be used for this

standard is dependent on such allocation, as well as the associated regulations for use of the allocations.

These regulations are subject to revision, or may be superseded.

In some regulatory domains, several frequency bands may be available fo r OFDM PHY-based WLANs.

These bands may be contiguous or not, and different regulatory limits may be applicable. A compliant

OFDM PHY shall support at least one frequency band in at least one regulatory domain. The support of

specific regulatory domains, and bands within the domains, shall be indicated by PLME attributes

dot11RegDomainsSupported and dot11FrequencyBandsSupported.

See, e.g., 802.11-2007 § 17.3.8.3.1

17.3.9.1 Transmit power levels

The maximum allowable transmit power by regulatory domain is defined in Annex I.

See, e.g., 802.11-2007 § 17.3.9.1

17.3.9.6.2 Transmitter spectral flatness

The average energy of the constellations in each of the spectral lines –16.. –1 and +1.. +16 will deviate no

more than ± 2 dB from their average energy. The average energy of the constellations in each of the spectral

lines –26.. –17 and +17.. +26 will deviate no more than +2/–4 dB from the average energy of spectral lines

–16.. –1 and +1.. +16. The data for this test shall be derived from the channel estimation step.

See, e.g., 802.11-2007 § 17.3.9.6.2

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 775 of 946 PageID #:

4879
775

Claim 17 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 § I.2.2

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 776 of 946 PageID #:

4880
776

Claim 17 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 § I.2.3

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 777 of 946 PageID #:

4881
777

Claim 17 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 Figure 5-7

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 778 of 946 PageID #:

4882
778

Claim 17 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 Figure 10-6

Furthermore, this claim element is obvious in light of 802.11-2007 itself, when combined with any of 

the other references as charted for this claim element in Exs. A-1–A-31, First Supplemental Ex. ACase 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 779 of 946 PageID #:

4883
779

Claim 17 of the ’802 Patent Prior Art Reference – 802.11-2007

Obviousness 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.

Claim 21 of the ’802 Patent Prior Art Reference – 802.11-2007

[21.1] The communication 

system of claim 17

802.11-2007 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.

802.11-2007 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.” See, e.g.: 

1.1 Scope

The scope of this standard is to define one medium access control (MAC) and several physical layer (PHY)

specifications for wireless connectivity for fixed, portable, and moving stations (STAs) within a local area.

See, e.g., 802.11-2007 § 1.1

5.1.1 How WLAN systems are different

Wireless networks have fundamental characteristics that make them significantly different from traditional

wired LANs. Some countries impose specific requirements for radio equipment in addition to those

specified in this standard. This standard does not provide information to meet these country -specific radio

regulations.

5.1.1.1 Destination address does not equal destination location

In wired LANs, an address is equivalent to a physical location. This is implicitly assumed in the design of

wired LANs. In IEEE Std 802.11, the addressable unit is a station (STA). The STA is a message destination,

but not (in general) a fixed location.

5.1.1.2 Media impact on design and performance

The PHYs used in IEEE Std 802.11 are fundamentally different from wired media. Thus IEEE 802.11 PHYs

a) Use a medium that has neither absolute nor readily observable boundaries outside of which STAs

with conformant PHY transceivers are known to be unable to receive network frames

b) Are unprotected from other signals that may be sharing the medium

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 780 of 946 PageID #:

4884
780

Claim 21 of the ’802 Patent Prior Art Reference – 802.11-2007

c) Communicate over a medium significantly less reliable than wired PHYs

d) Have dynamic topologies

e) Lack full connectivity, and therefore the assumption normally made that every STA can hear every

other STA is invalid (i.e., STAs may be “hidden” from each other)

f) Have time-varying and asymmetric propagation properties

g) May experience interference from logically disjoint IEEE 802.11 networks operating in overlapping

areas

Because of limitations on wireless PHY ranges, WLANs intended to cover reasonable geographic distances

may be built from basic coverage building blocks. When providing QoS services it should be understood

that the MAC endeavors to provide QoS “service guarantees” within the limitations of the medium

properties identified above. In other words, particularly in unlicensed spectrum, true guarantees are often not

possible. However, gradations of service are always possible; and in sufficiently controlled environments,

QoS guarantees can truly be made.

5.1.1.3 The impact of handling mobile STAs

One of the requirements of IEEE Std 802.11 is to handle mobile as well as portable STAs. A portable STA

is one that is moved from location to location, but that is only used while at a fixed location. Mobile STAs

actually access the LAN while in motion.

For technical reasons, it is not sufficient to handle only portable STAs. Propagation effects blur the

distinction between portable and mobile STAs; stationary STAs often appear to be mobile due to

propagation effects.

Another aspect of mobile STAs is that they may often be battery powered. Hence power management is

an important consideration. For example, it cannot be presumed that a STA’s receiver will always be

powered on.

See, e.g., 802.11-2007 § 5.1.1 - § 5.1.1.3

5.2 Components of the IEEE 802.11 architecture

The IEEE 802.11 architecture consists of several components that interact to provide a WLAN that supports

STA mobility transparently to upper layers.

The basic service set (BSS) is the basic building block of an IEEE 802.11 LAN. Figure 5-1 shows two BSSs,

each of which has two STAs that are members of the BSS.

It is useful to think of the ovals used to depict a BSS as the coverage area within which the member STAs of

the BSS may remain in communication. (The concept of area, while not precise, is often good enough.) This

area is called the Basic Service Area (BSA). If a STA moves out of its BSA, it can no longer directly

communicate with other STAs present in the BSA.

See, e.g., 802.11-2007 § 5.2

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 781 of 946 PageID #:

4885
781

Claim 21 of the ’802 Patent Prior Art Reference – 802.11-2007

5.2.3 Distribution system (DS) concepts

PHY limitations determine the direct station-to-station distance that may be supported. For some networks

this distance is sufficient; for other networks, increased coverage is required.

Instead of existing independently, a BSS may also form a component of an extended form of network that is

built with multiple BSSs. The architectural component used to interconnect BSSs is the DS.

IEEE Std 802.11 logically separates the WM from the distribution system medium (DSM). Each logical

medium is used for different purposes, by a different component of the architecture. The IEEE 802.11

definitions neither preclude, nor demand, that the multiple media be either the same or different.

Recognizing that the multiple media are logically different is key to understanding the flexibility of the

architecture. The IEEE 802.11 LAN architecture is specified independently of the physical characteristics of

any specific implementation.

The DS enables mobile device support by providing the logical services necessary to handle address to

destination mapping and seamless integration of multiple BSSs.

An access point (AP) is any entity that has STA functionality and enables access to the DS, via the WM for

associated STAs.

See, e.g., 802.11-2007 § 5.2.3

5.3.2 DSS

The service provided by the DS is known as the DSS.

This service is represented in the IEEE 802.11 architecture by arrows within the APs, indicating that the

service is used to cross media and possibly address space logical boundaries. An AP is a logical entity, and

the functions described may be shared by one or more physical entities.

The services that comprise the DSS are as follows:

a) Association

b) Disassociation

c) Distribution

d) Integration

e) Reassociation

f) QoS traffic scheduling (QoS facility only)

DSSs are specified for use by MAC sublayer entities.

Figure 5-7 combines the components from previous figures with both types of services to show the complete

IEEE 802.11 architecture.

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 782 of 946 PageID #:

4886
782

Claim 21 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 § 5.3.2

5.4.4.1 TPC

Radio regulations may require radio local area networks (RLANs) operating in the 5 GHz band to use

transmitter power control, involving specification of a regulatory maximum transmit power and a mitigation

requirement for each allowed channel, to reduce interference with satellite services. The TPC service is used

to satisfy this regulatory requirement.

The TPC service provides for the following:

— Association of STAs with an AP in a BSS based on the STAs’ power capability.

— Specification of regulatory and local maximum transmit power levels for the current channel.

— Selection of a transmit power for each transmission in a channel within constraints imposed by

regulatory requirements.

— Adaptation of transmit power based on a range of information, including path loss and link margin

estimates.

See, e.g., 802.11-2007 § 5.4.4.1

7.3.2.20 Channel Switch Announcement element

The Channel Switch Announcement element is used by an AP in a BSS or a STA in an IBSS to advertise

when it is changing to a new channel and the channel number of the new channel. The format of the Channel

Switch Announcement element is shown in Figure 7-57.

See, e.g., 802.11-2007 § 7.3.2.20

10.3.11 Spectrum management protocol layer model

The layer management extensions for measurement and channel switching assume a certain partition

of spectrum management functionality between the MLME and SME. This partitioning assumes that

policy decisions (e.g., regarding measurement and channel switching) reside in the SME, while the protocol

for measurement, switch timing, and the associated frame exchanges resides within the MLME (see

Figure 10-2).

...

The informative diagrams within this subclause further illustrate the spectrum management protocol model

adopted. Figure 10-3 and Figure 10-4 depict the measurement process for a peer STA to accept and reject a

measurement request, respectively. Figure 10-5 illustrates the TPC adaptation process. Lastly, Figure 10-6

depicts the management process for a channel switch using a Channel Switch Announcement frame.

See, e.g., 802.11-2007 § 10.3.11

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 783 of 946 PageID #:

4887
783

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 784 of 946 PageID #:

4888
784

Claim 21 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 § 10.4.3.2

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 785 of 946 PageID #:

4889
785

Claim 21 of the ’802 Patent Prior Art Reference – 802.11-2007

17.1 Introduction

This clause specifies the PHY entity for an orthogonal frequency division multiplex ing (OFDM) system.

The OFDM system provides a WLAN with data payload communication capabilities of 6, 9, 12, 18, 24, 36,

48, and 54 Mb/s. The support of transmitting and receiving at data rates of 6, 12, and 24 Mb/s is mandatory.

The system uses 52 subcarriers that are modulated using binary or quadrature phase shift keying (BPSK or

QPSK) or using 16- or 64-quadrature amplitude modulation (16-QAM or 64-QAM). Forward error

correction coding (convolutional coding) is used with a coding rate of 1/2, 2/3 , or 3/4.

The OFDM system also provides a “half-clocked” operation using 10 MHz channel spacings with data

communications capabilities of 3, 4.5, 6, 9, 12, 18, 24, and 27 Mb/s. The support of transmitting and

receiving at data rates of 3, 6, and 12 Mb/s is mandatory when using 10 MHz channel spacing. The halfclocked

operation doubles symbol times and clear channel assessment (CCA) times when using 10 MHz

channel spacing. The regulatory requirements and information regarding use of this OFDM system in

4.9 GHz and 5 GHz bands is in Annex I and Annex J.

The OFDM system also provides a “quarter-clocked” operation using 5 MHz channel spacing with data

communication capabilities of 1.5, 2.25, 3, 4.5, 6, 9, 12, and 13.5 Mb/s. The support of transmitting and

receiving at data rates of 1.5, 3, and 6 Mb/s is mandatory when using 5 MHz channel spacing. The quarterclocked

operation quadruples symbol times and CCA times when using 5 MHz channel spacing. The

regulatory requirements and information regarding use of this OFDM system in the 4.9 GHz band is in

Annex I and Annex J.

See, e.g., 802.11-2007 § 17.1

17.3.2.1 Overview of the PPDU encoding process

The encoding process is composed of many detailed steps, which are described fully in later subclauses, as

noted below. The following overview intends to facilitate understanding the details of the convergence

procedure:

a) Produce the PLCP Preamble field, composed of 10 repetitions of a “short training sequence” (used

for AGC convergence, diversity selection, timing acquisition, and coarse frequency acquisition in

the receiver) and two repetitions of a “long training sequence” (used for channel estimation and fine

frequency acquisition in the receiver), preceded by a guard interval (GI). Refer to 17.3.3 for details.

b) Produce the PLCP header field from the RATE, LENGTH, and SERVICE fields of the

TXVECTOR by filling the appropriate bit fields. The RATE and LENGTH fields of the PLCP

header are encoded by a convolutional code at a rate of R = 1/2, and are subsequently mapped onto a

single BPSK encoded OFDM symbol, denoted as the SIGNAL symbol. In order to facilitate a

reliable and timely detection of the RATE and LENGTH fields, 6 zero tail bits are inserted into the

PLCP header. The encoding of the SIGNAL field into an OFDM symbol follows the same steps for

convolutional encoding, interleaving, BPSK modulation, pilot insertion, Fourier transform, and

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 786 of 946 PageID #:

4890
786

Claim 21 of the ’802 Patent Prior Art Reference – 802.11-2007

prepending a GI as described subsequently for data transmission with BPSK-OFDM modulated at

coding rate 1/2. The contents of the SIGNAL field are not scrambled. Refer to 17.3.4 for details.

c) Calculate from RATE field of the TXVECTOR the number of data bits per OFDM symbol (NDBPS),

the coding rate (R), the number of bits in each OFDM subcarrier (NBPSC), and the number of coded

bits per OFDM symbol (NCBPS). Refer to 17.3.2.2 for details.

d) Append the PSDU to the SERVICE field of the TXVECTOR. Extend the resulting bit string with

zero bits (at least 6 bits) so that the resulting length will be a multiple of NDBPS. The resulting bit

string constitutes the DATA part of the packet. Refer to 17.3.5.3 for details.

e) Initiate the scrambler with a pseudo-random nonzero seed, generate a scrambling sequence, and

XOR it with the extended string of data bits. Refer to 17.3.5.4 for details.

f) Replace the six scrambled zero bits following the data with six nonscrambled zero bits. (Those bits

return the convolutional encoder to the zero state and are denoted as tail bits.) Refer to 17.3.5.2 for

details.

g) Encode the extended, scrambled data string with a convolutional encoder (R = 1/2). Omit (puncture)

some of the encoder output string (chosen according to “puncturing pattern”) to reach the desired

“coding rate.” Refer to 17.3.5.5 for details.

h) Divide the encoded bit string into groups of NCBPS bits. Within each group, perform an

“interleaving” (reordering) of the bits according to a rule corresponding to the desired RATE. Refer

to 17.3.5.6 for details.

i) Divide the resulting coded and interleaved data string into groups of NCBPS bits. For each of the bit

groups, convert the bit group into a complex number according to the modulation encoding tables.

Refer to 17.3.5.7 for details.

j) Divide the complex number string into groups of 48 complex numbers. Each such group will be

associated with one OFDM symbol. In each group, the complex numbers will be numbered 0 to 47

and mapped hereafter into OFDM subcarriers numbered –26 to –22, –20 to –8, –6 to –1, 1 to 6,

8 to 20, and 22 to 26. The subcarriers –21, –7, 7, and 21 are skipped and, subsequently, used for

inserting pilot subcarriers. The 0 subcarrier, associated with center frequency, is omitted and filled

with zero value. Refer to 17.3.5.9 for details.

k) Four subcarriers are inserted as pilots into positions –21, –7, 7, and 21. The total number of the

subcarriers is 52 (48 + 4). Refer to 17.3.5.8 for details.

l) For each group of subcarriers –26 to 26, convert the subcarriers to time domain using inverse

Fourier transform. Prepend to the Fourier-transformed waveform a circular extension of itself thus

forming a GI, and truncate the resulting periodic waveform to a single OFDM symbol length by

applying time domain windowing. Refer to 17.3.5.9 for details.

m) Append the OFDM symbols one after another, starting after the SIGNAL symbol describing the

RATE and LENGTH fields. Refer to 17.3.5.9 for details.

n) Up-convert the resulting “complex baseband” waveform to an RF according to the center frequency

of the desired channel and transmit. Refer to 17.3.2.4 and 17.3.8.1 for details.

An illustration of the transmitted frame and its parts appears in Figure 17-4 (in 17.3.3).

See, e.g., 802.11-2007 § 17.3.2.1

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 787 of 946 PageID #:

4891
787

Claim 21 of the ’802 Patent Prior Art Reference – 802.11-2007

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 788 of 946 PageID #:

4892
788

Claim 21 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 § 17.3.2.3

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 789 of 946 PageID #:

4893
789

Claim 21 of the ’802 Patent Prior Art Reference – 802.11-2007

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 790 of 946 PageID #:

4894
790

Claim 21 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 § 17.3.2.4 Eq. (17-1)

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 791 of 946 PageID #:

4895
791

Claim 21 of the ’802 Patent Prior Art Reference – 802.11-2007

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 792 of 946 PageID #:

4896
792

Claim 21 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 § 17.3.2.5

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 793 of 946 PageID #:

4897
793

Claim 21 of the ’802 Patent Prior Art Reference – 802.11-2007

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 794 of 946 PageID #:

4898
794

See, e.g., 802.11-2007 § 17.3.3

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 795 of 946 PageID #:

4899
795

Claim 21 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 § 17.3.5.7

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 796 of 946 PageID #:

4900
796

Claim 21 of the ’802 Patent Prior Art Reference – 802.11-2007

17.3.5.8 Pilot subcarriers

In each OFDM symbol, four of the subcarriers are dedicated to pilot signals in order to make the coherent

detection robust against frequency offsets and phase noise. These pilot signals shall be put in subcarriers

–21, –7, 7, and 21. The pilots shall be BPSK modulated by a pseudo-binary sequence to prevent the

generation of spectral lines. The contribution of the pilot subcarriers to each OFDM symbol is described in

17.3.5.9.

See, e.g., 802.11-2007 § 17.3.5.8

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 797 of 946 PageID #:

4901
797

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 798 of 946 PageID #:

4902
798

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 799 of 946 PageID #:

4903
799

Claim 21 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 § 17.3.5.9

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 800 of 946 PageID #:

4904
800

Claim 21 of the ’802 Patent Prior Art Reference – 802.11-2007

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 801 of 946 PageID #:

4905
801

Claim 21 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 § 17.3.8.1

17.3.8.3.1 Operating frequency range

The OFDM PHY shall operate in the 5 GHz band, as allocated by a regulatory body in its operational region.

Spectrum allocation in the 5 GHz band is subject to authorities responsible for geographic-specific

regulatory domains (e.g., global, regional, and national). The particular channelization to be used for this

standard is dependent on such allocation, as well as the associated regulations for use of the allocations.

These regulations are subject to revision, or may be superseded.

In some regulatory domains, several frequency bands may be available for OFDM PHY-based WLANs.

These bands may be contiguous or not, and different regulatory limits may be applicable. A compliant

OFDM PHY shall support at least one frequency band in at least one regulatory domain. The s upport of

specific regulatory domains, and bands within the domains, shall be indicated by PLME attributes

dot11RegDomainsSupported and dot11FrequencyBandsSupported.

See, e.g., 802.11-2007 § 17.3.8.3.1

17.3.9.1 Transmit power levels

The maximum allowable transmit power by regulatory domain is defined in Annex I.

See, e.g., 802.11-2007 § 17.3.9.1

17.3.9.6.2 Transmitter spectral flatness

The average energy of the constellations in each of the spectral lines –16.. –1 and +1.. +16 will deviate no

more than ± 2 dB from their average energy. The average energy of the constellations in each of the spectral

lines –26.. –17 and +17.. +26 will deviate no more than +2/–4 dB from the average energy of spectral lines

–16.. –1 and +1.. +16. The data for this test shall be derived from the channel estimation step.

See, e.g., 802.11-2007 § 17.3.9.6.2

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 802 of 946 PageID #:

4906
802

Claim 21 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 § I.2.2

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 803 of 946 PageID #:

4907
803

Claim 21 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 § I.2.3

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 804 of 946 PageID #:

4908
804

Claim 21 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 Figure 5-7

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 805 of 946 PageID #:

4909
805

Claim 21 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 Figure 10-6

Furthermore, this claim element is obvious in light of 802.11-2007 itself, when combined with any of 

the other references as charted for this claim element in Exs. A-1–A-31, First Supplemental Ex. ACase 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 806 of 946 PageID #:

4910
806

Claim 21 of the ’802 Patent Prior Art Reference – 802.11-2007

Obviousness 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 – 802.11-2007

[22.1] The communication 

system of claim 17

802.11-2007 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 

amplifier outputs a third upconverted signal comprising 

the up-converted first analog 

signal and the up-converted 

second analog signal.

802.11-2007 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.” See, e.g.: 

1.1 Scope

The scope of this standard is to define one medium access control (MAC) and several physical layer (PHY)

specifications for wireless connectivity for fixed, portable, and moving stations (STAs) within a local area.

See, e.g., 802.11-2007 § 1.1

5.1.1 How WLAN systems are different

Wireless networks have fundamental characteristics that make them significantly different from traditional

wired LANs. Some countries impose specific requirements for radio equipment in addition to those

specified in this standard. This standard does not provide information to meet these country -specific radio

regulations.

5.1.1.1 Destination address does not equal destination location

In wired LANs, an address is equivalent to a physical location. This is implicitly assumed in the design of

wired LANs. In IEEE Std 802.11, the addressable unit is a station (STA). The STA is a message destination,

but not (in general) a fixed location.

5.1.1.2 Media impact on design and performance

The PHYs used in IEEE Std 802.11 are fundamentally different from wired media. Thus IEEE 802.11 PHYs

a) Use a medium that has neither absolute nor readily observable boundaries outside of which STAs

with conformant PHY transceivers are known to be unable to receive network frames

b) Are unprotected from other signals that may be sharing the medium

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 807 of 946 PageID #:

4911
807

Claim 22 of the ’802 Patent Prior Art Reference – 802.11-2007

c) Communicate over a medium significantly less reliable than wired PHYs

d) Have dynamic topologies

e) Lack full connectivity, and therefore the assumption normally made that every STA can hear every

other STA is invalid (i.e., STAs may be “hidden” from each other)

f) Have time-varying and asymmetric propagation properties

g) May experience interference from logically disjoint IEEE 802.11 networks operating in overlapping

areas

Because of limitations on wireless PHY ranges, WLANs intended to cover reasonable geographic distances

may be built from basic coverage building blocks. When providing QoS services it should be understood

that the MAC endeavors to provide QoS “service guarantees” within the limitations of the medium

properties identified above. In other words, particularly in unlicensed spectrum, true guarantees are often not

possible. However, gradations of service are always possible; and in sufficiently controlled environments,

QoS guarantees can truly be made.

5.1.1.3 The impact of handling mobile STAs

One of the requirements of IEEE Std 802.11 is to handle mobile as well as portable STAs. A portable STA

is one that is moved from location to location, but that is only used while at a fixed location. Mobile STAs

actually access the LAN while in motion.

For technical reasons, it is not sufficient to handle only portable STAs. Propagation effects blur the

distinction between portable and mobile STAs; stationary STAs often appear to be mobile due to

propagation effects.

Another aspect of mobile STAs is that they may often be battery powered. Hence power management is

an important consideration. For example, it cannot be presumed that a STA’s receiver will always be

powered on.

See, e.g., 802.11-2007 § 5.1.1 - § 5.1.1.3

5.2 Components of the IEEE 802.11 architecture

The IEEE 802.11 architecture consists of several components that interact to provide a WLAN that supports

STA mobility transparently to upper layers.

The basic service set (BSS) is the basic building block of an IEEE 802.11 LAN. Figure 5 -1 shows two BSSs,

each of which has two STAs that are members of the BSS.

It is useful to think of the ovals used to depict a BSS as the coverage area within which the member STAs of

the BSS may remain in communication. (The concept of area, while not precise, is often good enough.) This

area is called the Basic Service Area (BSA). If a STA moves out of its BSA, it can no longer dir ectly

communicate with other STAs present in the BSA.

See, e.g., 802.11-2007 § 5.2

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 808 of 946 PageID #:

4912
808

Claim 22 of the ’802 Patent Prior Art Reference – 802.11-2007

5.2.3 Distribution system (DS) concepts

PHY limitations determine the direct station-to-station distance that may be supported. For some networks

this distance is sufficient; for other networks, increased coverage is required.

Instead of existing independently, a BSS may also form a component of an extended form of network that is

built with multiple BSSs. The architectural component used to interconnect BSSs is the DS.

IEEE Std 802.11 logically separates the WM from the distribution system medium (DSM). Each logical

medium is used for different purposes, by a different component of the architecture. The IEEE 802.11

definitions neither preclude, nor demand, that the multiple media be either the same or different.

Recognizing that the multiple media are logically different is key to understanding the flexibility of the

architecture. The IEEE 802.11 LAN architecture is specified independently o f the physical characteristics of

any specific implementation.

The DS enables mobile device support by providing the logical services necessary to handle address to

destination mapping and seamless integration of multiple BSSs.

An access point (AP) is any entity that has STA functionality and enables access to the DS, via the WM for

associated STAs.

See, e.g., 802.11-2007 § 5.2.3

5.3.2 DSS

The service provided by the DS is known as the DSS.

This service is represented in the IEEE 802.11 architecture by arrows within the APs, indicating that the

service is used to cross media and possibly address space logical boundaries. An AP is a logical entity, and

the functions described may be shared by one or more physical entities.

The services that comprise the DSS are as follows:

a) Association

b) Disassociation

c) Distribution

d) Integration

e) Reassociation

f) QoS traffic scheduling (QoS facility only)

DSSs are specified for use by MAC sublayer entities.

Figure 5-7 combines the components from previous figures with both types of services to show the complete

IEEE 802.11 architecture.

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 809 of 946 PageID #:

4913
809

Claim 22 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 § 5.3.2

5.4.4.1 TPC

Radio regulations may require radio local area networks (RLANs) operating in the 5 GHz band to use

transmitter power control, involving specification of a regulatory maximum transmit power and a mitigation

requirement for each allowed channel, to reduce interference with satellite services. The TPC service is used

to satisfy this regulatory requirement.

The TPC service provides for the following:

— Association of STAs with an AP in a BSS based on the STAs’ power capability.

— Specification of regulatory and local maximum transmit power levels for the current channel.

— Selection of a transmit power for each transmission in a channel within constraints imposed by

regulatory requirements.

— Adaptation of transmit power based on a range of information, including path loss and link margin

estimates.

See, e.g., 802.11-2007 § 5.4.4.1

7.3.2.20 Channel Switch Announcement element

The Channel Switch Announcement element is used by an AP in a BSS or a STA in an IBSS to advertise

when it is changing to a new channel and the channel number of the new channel. The format of the Channel

Switch Announcement element is shown in Figure 7-57.

See, e.g., 802.11-2007 § 7.3.2.20

10.3.11 Spectrum management protocol layer model

The layer management extensions for measurement and channel switching assume a certain partition

of spectrum management functionality between the MLME and SME. This partitioning assumes that

policy decisions (e.g., regarding measurement and channel switching) reside in the SME, while the protocol

for measurement, switch timing, and the associated frame exchanges resides within the MLME (see

Figure 10-2).

...

The informative diagrams within this subclause further illustrate the spectrum management protocol model

adopted. Figure 10-3 and Figure 10-4 depict the measurement process for a peer STA to accept and reject a

measurement request, respectively. Figure 10-5 illustrates the TPC adaptation process. Lastly, Figure 10-6

depicts the management process for a channel switch using a Channel Switch Announcement frame.

See, e.g., 802.11-2007 § 10.3.11

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 810 of 946 PageID #:

4914
810

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 811 of 946 PageID #:

4915
811

Claim 22 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 § 10.4.3.2

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 812 of 946 PageID #:

4916
812

Claim 22 of the ’802 Patent Prior Art Reference – 802.11-2007

17.1 Introduction

This clause specifies the PHY entity for an orthogonal frequency division multiplexing (OFDM) system.

The OFDM system provides a WLAN with data payload communication capabilities of 6, 9, 12, 18, 24, 36,

48, and 54 Mb/s. The support of transmitting and receiving at data rates of 6, 12, and 24 Mb/s is mandatory.

The system uses 52 subcarriers that are modulated using binary or quadrature phase shift keying (BPSK or

QPSK) or using 16- or 64-quadrature amplitude modulation (16-QAM or 64-QAM). Forward error

correction coding (convolutional coding) is used with a coding rate of 1/2, 2/3, or 3/4.

The OFDM system also provides a “half-clocked” operation using 10 MHz channel spacings with data

communications capabilities of 3, 4.5, 6, 9, 12, 18, 24, and 27 Mb/s. The support of transmitting and

receiving at data rates of 3, 6, and 12 Mb/s is mandatory when using 10 MHz channel spacing. The halfclocked

operation doubles symbol times and clear channel assessment (CCA) times when using 10 MHz

channel spacing. The regulatory requirements and information regarding use of this OFDM system in

4.9 GHz and 5 GHz bands is in Annex I and Annex J.

The OFDM system also provides a “quarter-clocked” operation using 5 MHz channel spacing with data

communication capabilities of 1.5, 2.25, 3, 4.5, 6, 9, 12, and 13.5 Mb/s. The support of transmitting and

receiving at data rates of 1.5, 3, and 6 Mb/s is mandatory when using 5 MHz channel spacing. The quarterclocked

operation quadruples symbol times and CCA times when using 5 MHz channel spacing. The

regulatory requirements and information regarding use of this OFDM system in the 4.9 GHz band is in

Annex I and Annex J.

See, e.g., 802.11-2007 § 17.1

17.3.2.1 Overview of the PPDU encoding process

The encoding process is composed of many detailed steps, which are described fully in later subclauses, as

noted below. The following overview intends to facilitate understanding the details of the convergence

procedure:

a) Produce the PLCP Preamble field, composed of 10 repetitions of a “short training sequence” (used

for AGC convergence, diversity selection, timing acquisition, and coarse frequency acquisition in

the receiver) and two repetitions of a “long training sequence” (used for channel estimation and fine

frequency acquisition in the receiver), preceded by a guard interval (GI). Refer to 17.3.3 for details.

b) Produce the PLCP header field from the RATE, LENGTH, and SERVICE fields of the

TXVECTOR by filling the appropriate bit fields. The RATE and LENGTH field s of the PLCP

header are encoded by a convolutional code at a rate of R = 1/2, and are subsequently mapped onto a

single BPSK encoded OFDM symbol, denoted as the SIGNAL symbol. In order to facilitate a

reliable and timely detection of the RATE and LENGTH fields, 6 zero tail bits are inserted into the

PLCP header. The encoding of the SIGNAL field into an OFDM symbol follows the same steps for

convolutional encoding, interleaving, BPSK modulation, pilot insertion, Fourier transform, and

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 813 of 946 PageID #:

4917
813

Claim 22 of the ’802 Patent Prior Art Reference – 802.11-2007

prepending a GI as described subsequently for data transmission with BPSK-OFDM modulated at

coding rate 1/2. The contents of the SIGNAL field are not scrambled. Refer to 17.3.4 for details.

c) Calculate from RATE field of the TXVECTOR the number of data bits per OFDM symbol (NDBPS),

the coding rate (R), the number of bits in each OFDM subcarrier (NBPSC), and the number of coded

bits per OFDM symbol (NCBPS). Refer to 17.3.2.2 for details.

d) Append the PSDU to the SERVICE field of the TXVECTOR. Extend the resulting bit string with

zero bits (at least 6 bits) so that the resulting length will be a multiple of NDBPS. The resulting bit

string constitutes the DATA part of the packet. Refer to 17.3.5.3 for details.

e) Initiate the scrambler with a pseudo-random nonzero seed, generate a scrambling sequence, and

XOR it with the extended string of data bits. Refer to 17.3.5.4 for details.

f) Replace the six scrambled zero bits following the data with six nonscrambled zero bits. (Those bits

return the convolutional encoder to the zero state and are denoted as tail bits.) Refer to 17.3.5.2 for

details.

g) Encode the extended, scrambled data string with a convolutional encoder (R = 1/2). Omit (puncture)

some of the encoder output string (chosen according to “puncturing pattern”) to reach the desired

“coding rate.” Refer to 17.3.5.5 for details.

h) Divide the encoded bit string into groups of NCBPS bits. Within each group, perform an

“interleaving” (reordering) of the bits according to a rule corresponding to the desired RATE. Refer

to 17.3.5.6 for details.

i) Divide the resulting coded and interleaved data string into groups of NCBPS bits. For each of the bit

groups, convert the bit group into a complex number according to the modulation encoding tables.

Refer to 17.3.5.7 for details.

j) Divide the complex number string into groups of 48 complex numbers. Each such group will be

associated with one OFDM symbol. In each group, the complex numbers will be numbered 0 to 47

and mapped hereafter into OFDM subcarriers numbered –26 to –22, –20 to –8, –6 to –1, 1 to 6,

8 to 20, and 22 to 26. The subcarriers –21, –7, 7, and 21 are skipped and, subsequently, used for

inserting pilot subcarriers. The 0 subcarrier, associated with center frequency, is omitted and filled

with zero value. Refer to 17.3.5.9 for details.

k) Four subcarriers are inserted as pilots into positions –21, –7, 7, and 21. The total number of the

subcarriers is 52 (48 + 4). Refer to 17.3.5.8 for details.

l) For each group of subcarriers –26 to 26, convert the subcarriers to time domain using inverse

Fourier transform. Prepend to the Fourier-transformed waveform a circular extension of itself thus

forming a GI, and truncate the resulting periodic waveform to a single OFDM symbol length by

applying time domain windowing. Refer to 17.3.5.9 for details.

m) Append the OFDM symbols one after another, starting after the SIGNAL symbol describing the

RATE and LENGTH fields. Refer to 17.3.5.9 for details.

n) Up-convert the resulting “complex baseband” waveform to an RF according to the center freq uency

of the desired channel and transmit. Refer to 17.3.2.4 and 17.3.8.1 for details.

An illustration of the transmitted frame and its parts appears in Figure 17-4 (in 17.3.3).

See, e.g., 802.11-2007 § 17.3.2.1

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 814 of 946 PageID #:

4918
814

Claim 22 of the ’802 Patent Prior Art Reference – 802.11-2007

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 815 of 946 PageID #:

4919
815

Claim 22 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 § 17.3.2.3

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 816 of 946 PageID #:

4920
816

Claim 22 of the ’802 Patent Prior Art Reference – 802.11-2007

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 817 of 946 PageID #:

4921
817

Claim 22 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 § 17.3.2.4 Eq. (17-1)

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 818 of 946 PageID #:

4922
818

Claim 22 of the ’802 Patent Prior Art Reference – 802.11-2007

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 819 of 946 PageID #:

4923
819

Claim 22 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 § 17.3.2.5

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 820 of 946 PageID #:

4924
820

Claim 22 of the ’802 Patent Prior Art Reference – 802.11-2007

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 821 of 946 PageID #:

4925
821

See, e.g., 802.11-2007 § 17.3.3

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 822 of 946 PageID #:

4926
822

Claim 22 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 § 17.3.5.7

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 823 of 946 PageID #:

4927
823

Claim 22 of the ’802 Patent Prior Art Reference – 802.11-2007

17.3.5.8 Pilot subcarriers

In each OFDM symbol, four of the subcarriers are dedicated to pilot signals in order to make the coherent

detection robust against frequency offsets and phase noise. These pilot signals shall be put in subcarriers

–21, –7, 7, and 21. The pilots shall be BPSK modulated by a pseudo-binary sequence to prevent the

generation of spectral lines. The contribution of the pilot subcarriers to each OFDM symbol is described in

17.3.5.9.

See, e.g., 802.11-2007 § 17.3.5.8

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 824 of 946 PageID #:

4928
824

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 825 of 946 PageID #:

4929
825

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 826 of 946 PageID #:

4930
826

Claim 22 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 § 17.3.5.9

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 827 of 946 PageID #:

4931
827

Claim 22 of the ’802 Patent Prior Art Reference – 802.11-2007

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 828 of 946 PageID #:

4932
828

Claim 22 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 § 17.3.8.1

17.3.8.3.1 Operating frequency range

The OFDM PHY shall operate in the 5 GHz band, as allocated by a regulatory body in its operational region.

Spectrum allocation in the 5 GHz band is subject to authorities responsible for geographic-specific

regulatory domains (e.g., global, regional, and national). The particular channelization to be used for this

standard is dependent on such allocation, as well as the associated regulations for use of the allocations.

These regulations are subject to revision, or may be superseded.

In some regulatory domains, several frequency bands may be available for OFDM PHY-based WLANs.

These bands may be contiguous or not, and different regulatory limits may be applicable. A compliant

OFDM PHY shall support at least one frequency band in at least one regulatory domain. The support of

specific regulatory domains, and bands within the domains, shall be indicated by PLME attributes

dot11RegDomainsSupported and dot11FrequencyBandsSupported.

See, e.g., 802.11-2007 § 17.3.8.3.1

17.3.9.1 Transmit power levels

The maximum allowable transmit power by regulatory domain is defined in Annex I.

See, e.g., 802.11-2007 § 17.3.9.1

17.3.9.6.2 Transmitter spectral flatness

The average energy of the constellations in each of the spectral lines –16.. –1 and +1.. +16 will deviate no

more than ± 2 dB from their average energy. The average energy of the constellations in each of the spectral

lines –26.. –17 and +17.. +26 will deviate no more than +2/–4 dB from the average energy of spectral lines

–16.. –1 and +1.. +16. The data for this test shall be derived from the channel estimation step.

See, e.g., 802.11-2007 § 17.3.9.6.2

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 829 of 946 PageID #:

4933
829

Claim 22 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 § I.2.2

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 830 of 946 PageID #:

4934
830

Claim 22 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 § I.2.3

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 831 of 946 PageID #:

4935
831

Claim 22 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 Figure 5-7

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 832 of 946 PageID #:

4936
832

Claim 22 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 Figure 10-6

Furthermore, this claim element is obvious in light of 802.11-2007 itself, when combined with any of 

the other references as charted for this claim element in Exs. A-1–A-31, First Supplemental Ex. ACase 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 833 of 946 PageID #:

4937
833

Claim 22 of the ’802 Patent Prior Art Reference – 802.11-2007

Obviousness 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 refe rences. 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 – 802.11-2007

[23.1] The communication 

system of claim 17

802.11-2007 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 

time slot across a second upconverted frequency range.

802.11-2007 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 up -

converted 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.” See, e.g.: 

1.1 Scope

The scope of this standard is to define one medium access control (MAC) and several physical layer (PHY)

specifications for wireless connectivity for fixed, portable, and moving stations (STAs) within a local area.

See, e.g., 802.11-2007 § 1.1

5.1.1 How WLAN systems are different

Wireless networks have fundamental characteristics that make them significantly different from traditional

wired LANs. Some countries impose specific requirements for radio equipment in addition to those

specified in this standard. This standard does not provide information to meet these co untry-specific radio

regulations.

5.1.1.1 Destination address does not equal destination location

In wired LANs, an address is equivalent to a physical location. This is implicitly assumed in the design of

wired LANs. In IEEE Std 802.11, the addressable unit is a station (STA). The STA is a message destination,

but not (in general) a fixed location.

5.1.1.2 Media impact on design and performance

The PHYs used in IEEE Std 802.11 are fundamentally different from wired media. Thus IEEE 802.11 PHYs

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 834 of 946 PageID #:

4938
834

Claim 23 of the ’802 Patent Prior Art Reference – 802.11-2007

a) Use a medium that has neither absolute nor readily observable boundaries outside of which STAs

with conformant PHY transceivers are known to be unable to receive network frames

b) Are unprotected from other signals that may be sharing the medium

c) Communicate over a medium significantly less reliable than wired PHYs

d) Have dynamic topologies

e) Lack full connectivity, and therefore the assumption normally made that every STA can hear every

other STA is invalid (i.e., STAs may be “hidden” from each other)

f) Have time-varying and asymmetric propagation properties

g) May experience interference from logically disjoint IEEE 802.11 networks operating in overlapping

areas

Because of limitations on wireless PHY ranges, WLANs intended to cover reasonable geographic distances

may be built from basic coverage building blocks. When providing QoS services it should be understood

that the MAC endeavors to provide QoS “service guarantees” within the limitations of the medium

properties identified above. In other words, particularly in unlicensed spectrum, true guarantees are often not

possible. However, gradations of service are always possible; and in sufficiently controlled environments,

QoS guarantees can truly be made.

5.1.1.3 The impact of handling mobile STAs

One of the requirements of IEEE Std 802.11 is to handle mobile as well as portable STAs. A portable STA

is one that is moved from location to location, but that is only used while at a fixed location. Mobile STAs

actually access the LAN while in motion.

For technical reasons, it is not sufficient to handle only portable STAs. Propagation effects blur the

distinction between portable and mobile STAs; stationary STAs often appear to be mobile due to

propagation effects.

Another aspect of mobile STAs is that they may often be battery powered. Hence power management is

an important consideration. For example, it cannot be presumed that a STA’s receiver will always be

powered on.

See, e.g., 802.11-2007 § 5.1.1 - § 5.1.1.3

5.2 Components of the IEEE 802.11 architecture

The IEEE 802.11 architecture consists of several components that interact to provide a WLAN that supports

STA mobility transparently to upper layers.

The basic service set (BSS) is the basic building block of an IEEE 802.11 LAN. Figure 5 -1 shows two BSSs,

each of which has two STAs that are members of the BSS.

It is useful to think of the ovals used to depict a BSS as the coverage area within which the member STAs of

the BSS may remain in communication. (The concept of area, while not precise, is often good enough.) This

area is called the Basic Service Area (BSA). If a STA moves out of its BSA, it can no longer directly

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 835 of 946 PageID #:

4939
835

Claim 23 of the ’802 Patent Prior Art Reference – 802.11-2007

communicate with other STAs present in the BSA.

See, e.g., 802.11-2007 § 5.2

5.2.3 Distribution system (DS) concepts

PHY limitations determine the direct station-to-station distance that may be supported. For some networks

this distance is sufficient; for other networks, increased coverage is required.

Instead of existing independently, a BSS may also form a component of an extended form of network that is

built with multiple BSSs. The architectural component used to interconnect BSSs is the DS.

IEEE Std 802.11 logically separates the WM from the distribution system medium (DSM). Each logical

medium is used for different purposes, by a different component of the architecture. The IEEE 802.11

definitions neither preclude, nor demand, that the multiple media be either the same or different.

Recognizing that the multiple media are logically different is key to understanding the flexibility of the

architecture. The IEEE 802.11 LAN architecture is specified independently of the physical characteristics of

any specific implementation.

The DS enables mobile device support by providing the logical services necessary to handle address to

destination mapping and seamless integration of multiple BSSs.

An access point (AP) is any entity that has STA functionality and enables access to the DS, via the WM for

associated STAs.

See, e.g., 802.11-2007 § 5.2.3

5.3.2 DSS

The service provided by the DS is known as the DSS.

This service is represented in the IEEE 802.11 architecture by arrows within the APs, indicating that the

service is used to cross media and possibly address space logical boundaries. An AP is a logical entity, and

the functions described may be shared by one or more physical entities.

The services that comprise the DSS are as follows:

a) Association

b) Disassociation

c) Distribution

d) Integration

e) Reassociation

f) QoS traffic scheduling (QoS facility only)

DSSs are specified for use by MAC sublayer entities.

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 836 of 946 PageID #:

4940
836

Claim 23 of the ’802 Patent Prior Art Reference – 802.11-2007

Figure 5-7 combines the components from previous figures with both types of services to show the complete

IEEE 802.11 architecture.

See, e.g., 802.11-2007 § 5.3.2

5.4.4.1 TPC

Radio regulations may require radio local area networks (RLANs) operating in the 5 GHz band to use

transmitter power control, involving specification of a regulatory maximum transmit power and a mitigation

requirement for each allowed channel, to reduce interference with satellite services. The TPC service is used

to satisfy this regulatory requirement.

The TPC service provides for the following:

— Association of STAs with an AP in a BSS based on the STAs’ power capability.

— Specification of regulatory and local maximum transmit power levels for the current channel.

— Selection of a transmit power for each transmission in a channel within constraints imposed by

regulatory requirements.

— Adaptation of transmit power based on a range of information, including path loss and link margin

estimates.

See, e.g., 802.11-2007 § 5.4.4.1

7.3.2.20 Channel Switch Announcement element

The Channel Switch Announcement element is used by an AP in a BSS or a STA in an IBSS to advertise

when it is changing to a new channel and the channel number of the new channel. The format of the Channel

Switch Announcement element is shown in Figure 7-57.

See, e.g., 802.11-2007 § 7.3.2.20

10.3.11 Spectrum management protocol layer model

The layer management extensions for measurement and channel switching assume a certain partition

of spectrum management functionality between the MLME and SME. This partitioning assumes that

policy decisions (e.g., regarding measurement and channel switching) reside in the SME, while the protocol

for measurement, switch timing, and the associated frame exchanges resides within the MLME (see

Figure 10-2).

...

The informative diagrams within this subclause further illustrate the spectrum management protocol model

adopted. Figure 10-3 and Figure 10-4 depict the measurement process for a peer STA to accept and reject a

measurement request, respectively. Figure 10-5 illustrates the TPC adaptation process. Lastly, Figure 10-6

depicts the management process for a channel switch using a Channel Switch Announcement frame.

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 837 of 946 PageID #:

4941
837

Claim 23 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 § 10.3.11

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 838 of 946 PageID #:

4942
838

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 839 of 946 PageID #:

4943
839

Claim 23 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 § 10.4.3.2

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 840 of 946 PageID #:

4944
840

Claim 23 of the ’802 Patent Prior Art Reference – 802.11-2007

17.1 Introduction

This clause specifies the PHY entity for an orthogonal frequency division multiplexing (OFDM) system.

The OFDM system provides a WLAN with data payload communication capabilities of 6, 9, 12, 18, 24, 36,

48, and 54 Mb/s. The support of transmitting and receiving at data rates of 6, 12, and 24 Mb/s is mandatory.

The system uses 52 subcarriers that are modulated using binary or quadrature phase shift keying (BPSK or

QPSK) or using 16- or 64-quadrature amplitude modulation (16-QAM or 64-QAM). Forward error

correction coding (convolutional coding) is used with a coding rate of 1/2, 2/3, or 3/4.

The OFDM system also provides a “half-clocked” operation using 10 MHz channel spacings with data

communications capabilities of 3, 4.5, 6, 9, 12, 18, 24, and 27 Mb/s. The support of transmitting and

receiving at data rates of 3, 6, and 12 Mb/s is mandatory when using 10 MHz channel spacing. The halfclocked

operation doubles symbol times and clear channel assessment (CCA) times when using 10 MHz

channel spacing. The regulatory requirements and information regarding use of this OFDM system in

4.9 GHz and 5 GHz bands is in Annex I and Annex J.

The OFDM system also provides a “quarter-clocked” operation using 5 MHz channel spacing with data

communication capabilities of 1.5, 2.25, 3, 4.5, 6, 9, 12, and 13.5 Mb/s. The support of transmitting and

receiving at data rates of 1.5, 3, and 6 Mb/s is mandatory when using 5 MHz channel spacing. The quarterclocked

operation quadruples symbol times and CCA times when using 5 MHz channel spacing. The

regulatory requirements and information regarding use of this OFDM system in the 4.9 GHz band is in

Annex I and Annex J.

See, e.g., 802.11-2007 § 17.1

17.3.2.1 Overview of the PPDU encoding process

The encoding process is composed of many detailed steps, which are described fully in later subclauses, as

noted below. The following overview intends to facilitate understanding the details of the convergence

procedure:

a) Produce the PLCP Preamble field, composed of 10 repetitions of a “short training sequence” (used

for AGC convergence, diversity selection, timing acquisition, and coarse frequency acquisition in

the receiver) and two repetitions of a “long training sequence” (used for channel estimation and fine

frequency acquisition in the receiver), preceded by a guard interval (GI). Refer to 17.3.3 for details.

b) Produce the PLCP header field from the RATE, LENGTH, and SERVICE field s of the

TXVECTOR by filling the appropriate bit fields. The RATE and LENGTH fields of the PLCP

header are encoded by a convolutional code at a rate of R = 1/2, and are subsequently mapped onto a

single BPSK encoded OFDM symbol, denoted as the SIGNAL symbol. In order to facilitate a

reliable and timely detection of the RATE and LENGTH fields, 6 zero tail bits are inserted into the

PLCP header. The encoding of the SIGNAL field into an OFDM symbol follows the same steps for

convolutional encoding, interleaving, BPSK modulation, pilot insertion, Fourier transform, and

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 841 of 946 PageID #:

4945
841

Claim 23 of the ’802 Patent Prior Art Reference – 802.11-2007

prepending a GI as described subsequently for data transmission with BPSK-OFDM modulated at

coding rate 1/2. The contents of the SIGNAL field are not scrambled. Refer to 17.3.4 for deta ils.

c) Calculate from RATE field of the TXVECTOR the number of data bits per OFDM symbol (NDBPS),

the coding rate (R), the number of bits in each OFDM subcarrier (NBPSC), and the number of coded

bits per OFDM symbol (NCBPS). Refer to 17.3.2.2 for details.

d) Append the PSDU to the SERVICE field of the TXVECTOR. Extend the resulting bit string with

zero bits (at least 6 bits) so that the resulting length will be a multiple of NDBPS. The resulting bit

string constitutes the DATA part of the packet. Refer to 17.3.5.3 for details.

e) Initiate the scrambler with a pseudo-random nonzero seed, generate a scrambling sequence, and

XOR it with the extended string of data bits. Refer to 17.3.5.4 for details.

f) Replace the six scrambled zero bits following the data with six nonscrambled zero bits. (Those bits

return the convolutional encoder to the zero state and are denoted as tail bits.) Refer to 17.3.5.2 for

details.

g) Encode the extended, scrambled data string with a convolutional encoder (R = 1/2). Omit (puncture )

some of the encoder output string (chosen according to “puncturing pattern”) to reach the desired

“coding rate.” Refer to 17.3.5.5 for details.

h) Divide the encoded bit string into groups of NCBPS bits. Within each group, perform an

“interleaving” (reordering) of the bits according to a rule corresponding to the desired RATE. Refer

to 17.3.5.6 for details.

i) Divide the resulting coded and interleaved data string into groups of NCBPS bits. For each of the bit

groups, convert the bit group into a complex number according to the modulation encoding tables.

Refer to 17.3.5.7 for details.

j) Divide the complex number string into groups of 48 complex numbers. Each such group will be

associated with one OFDM symbol. In each group, the complex numbers will be numbered 0 to 47

and mapped hereafter into OFDM subcarriers numbered –26 to –22, –20 to –8, –6 to –1, 1 to 6,

8 to 20, and 22 to 26. The subcarriers –21, –7, 7, and 21 are skipped and, subsequently, used for

inserting pilot subcarriers. The 0 subcarrier, associated with center frequency, is omitted and filled

with zero value. Refer to 17.3.5.9 for details.

k) Four subcarriers are inserted as pilots into positions –21, –7, 7, and 21. The total number of the

subcarriers is 52 (48 + 4). Refer to 17.3.5.8 for details.

l) For each group of subcarriers –26 to 26, convert the subcarriers to time domain using inverse

Fourier transform. Prepend to the Fourier-transformed waveform a circular extension of itself thus

forming a GI, and truncate the resulting periodic waveform to a single OFDM symbol length by

applying time domain windowing. Refer to 17.3.5.9 for details.

m) Append the OFDM symbols one after another, starting after the SIGNAL symbol describing the

RATE and LENGTH fields. Refer to 17.3.5.9 for details.

n) Up-convert the resulting “complex baseband” waveform to an RF according to the center frequency

of the desired channel and transmit. Refer to 17.3.2.4 and 17.3.8.1 for details.

An illustration of the transmitted frame and its parts appears in Figure 17-4 (in 17.3.3).

See, e.g., 802.11-2007 § 17.3.2.1

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 842 of 946 PageID #:

4946
842

Claim 23 of the ’802 Patent Prior Art Reference – 802.11-2007

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 843 of 946 PageID #:

4947
843

Claim 23 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 § 17.3.2.3

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 844 of 946 PageID #:

4948
844

Claim 23 of the ’802 Patent Prior Art Reference – 802.11-2007

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 845 of 946 PageID #:

4949
845

Claim 23 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 § 17.3.2.4 Eq. (17-1)

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 846 of 946 PageID #:

4950
846

Claim 23 of the ’802 Patent Prior Art Reference – 802.11-2007

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 847 of 946 PageID #:

4951
847

Claim 23 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 § 17.3.2.5

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 848 of 946 PageID #:

4952
848

Claim 23 of the ’802 Patent Prior Art Reference – 802.11-2007

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 849 of 946 PageID #:

4953
849

See, e.g., 802.11-2007 § 17.3.3

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 850 of 946 PageID #:

4954
850

Claim 23 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 § 17.3.5.7

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 851 of 946 PageID #:

4955
851

Claim 23 of the ’802 Patent Prior Art Reference – 802.11-2007

17.3.5.8 Pilot subcarriers

In each OFDM symbol, four of the subcarriers are dedicated to pilot signals in order to make the coherent

detection robust against frequency offsets and phase noise. These pilot signals shall be put in su bcarriers

–21, –7, 7, and 21. The pilots shall be BPSK modulated by a pseudo-binary sequence to prevent the

generation of spectral lines. The contribution of the pilot subcarriers to each OFDM symbol is described in

17.3.5.9.

See, e.g., 802.11-2007 § 17.3.5.8

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 852 of 946 PageID #:

4956
852

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 853 of 946 PageID #:

4957
853

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 854 of 946 PageID #:

4958
854

Claim 23 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 § 17.3.5.9

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 855 of 946 PageID #:

4959
855

Claim 23 of the ’802 Patent Prior Art Reference – 802.11-2007

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 856 of 946 PageID #:

4960
856

Claim 23 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 § 17.3.8.1

17.3.8.3.1 Operating frequency range

The OFDM PHY shall operate in the 5 GHz band, as allocated by a regulatory body in its operational region.

Spectrum allocation in the 5 GHz band is subject to authorities responsible for geographic-specific

regulatory domains (e.g., global, regional, and national). The particular channelization to be used for this

standard is dependent on such allocation, as well as the associated regulations for use of the allocations.

These regulations are subject to revision, or may be superseded.

In some regulatory domains, several frequency bands may be available for OFDM PHY-based WLANs.

These bands may be contiguous or not, and different regulatory limits may be applicable. A compliant

OFDM PHY shall support at least one frequency band in at least one regulatory domain. The support of

specific regulatory domains, and bands within the domains, shall be indicated by PLME attributes

dot11RegDomainsSupported and dot11FrequencyBandsSupported.

See, e.g., 802.11-2007 § 17.3.8.3.1

17.3.9.1 Transmit power levels

The maximum allowable transmit power by regulatory domain is defined in Annex I.

See, e.g., 802.11-2007 § 17.3.9.1

17.3.9.6.2 Transmitter spectral flatness

The average energy of the constellations in each of the spectral lines –16.. –1 and +1.. +16 will deviate no

more than ± 2 dB from their average energy. The average energy of the constellations in each of the spectral

lines –26.. –17 and +17.. +26 will deviate no more than +2/–4 dB from the average energy of spectral lines

–16.. –1 and +1.. +16. The data for this test shall be derived from the channel estimation step.

See, e.g., 802.11-2007 § 17.3.9.6.2

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 857 of 946 PageID #:

4961
857

Claim 23 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 § I.2.2

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 858 of 946 PageID #:

4962
858

Claim 23 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 § I.2.3

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 859 of 946 PageID #:

4963
859

Claim 23 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 Figure 5-7

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 860 of 946 PageID #:

4964
860

Claim 23 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 Figure 10-6

Furthermore, this claim element is obvious in light of 802.11-2007 itself, when combined with any of 

the other references as charted for this claim element in Exs. A-1–A-31, First Supplemental Ex. ACase 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 861 of 946 PageID #:

4965
861

Claim 23 of the ’802 Patent Prior Art Reference – 802.11-2007

Obviousness 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 24 of the ’802 Patent Prior Art Reference – 802.11-2007

[24.1] An electronic circuit 

comprising:

To the extent the preamble is limiting, 802.11-2007 discloses “An electronic circuit comprising.” 

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 862 of 946 PageID #:

4966
862

Claim 24 of the ’802 Patent Prior Art Reference – 802.11-2007

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 863 of 946 PageID #:

4967
863

Claim 24 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 § 17.3.8.1

Furthermore, this claim element is obvious in light of 802.11-2007 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.

[24.2] 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;

802.11-2007 discloses “a first down-converter circuit having a first input coupled to receive a first 

up-converted 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.” See, e.g.: 

1.1 Scope

The scope of this standard is to define one medium access control (MAC) and several physical layer (PHY)

specifications for wireless connectivity for fixed, portable, and moving stations (STAs) within a local area.

See, e.g., 802.11-2007 § 1.1

5.1.1 How WLAN systems are different

Wireless networks have fundamental characteristics that make them significantly different from traditional

wired LANs. Some countries impose specific requirements for radio equipment in addition to those

specified in this standard. This standard does not provide information to meet these country -specific radio

regulations.

5.1.1.1 Destination address does not equal destination location

In wired LANs, an address is equivalent to a physical location. This is implicitly assumed in the design of

wired LANs. In IEEE Std 802.11, the addressable unit is a station (STA). The STA is a message destination,

but not (in general) a fixed location.

5.1.1.2 Media impact on design and performance

The PHYs used in IEEE Std 802.11 are fundamentally different from wired media. Thus IEEE 802.11 PHYs

a) Use a medium that has neither absolute nor readily observable boundaries outside of which STAs

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 864 of 946 PageID #:

4968
864

Claim 24 of the ’802 Patent Prior Art Reference – 802.11-2007

with conformant PHY transceivers are known to be unable to receive network frames

b) Are unprotected from other signals that may be sharing the medium

c) Communicate over a medium significantly less reliable than wired PHYs

d) Have dynamic topologies

e) Lack full connectivity, and therefore the assumption normally made that every STA can hear every

other STA is invalid (i.e., STAs may be “hidden” from each other)

f) Have time-varying and asymmetric propagation properties

g) May experience interference from logically disjoint IEEE 802.11 networks operating in overlapping

areas

Because of limitations on wireless PHY ranges, WLANs intended to cover reasonable geographic distances

may be built from basic coverage building blocks. When providing QoS services it should be understood

that the MAC endeavors to provide QoS “service guarantees” within the limitations of the medium

properties identified above. In other words, particularly in unlicensed spectrum, true guarantees are often not

possible. However, gradations of service are always possible; and in sufficiently controlled environments,

QoS guarantees can truly be made.

5.1.1.3 The impact of handling mobile STAs

One of the requirements of IEEE Std 802.11 is to handle mobile as well as portable STAs. A portable STA

is one that is moved from location to location, but that is only used while at a fixed location. Mobile STAs

actually access the LAN while in motion.

For technical reasons, it is not sufficient to handle only portable STAs. Propagation effects blur the

distinction between portable and mobile STAs; stationary STAs often appear to be mobile due to

propagation effects.

Another aspect of mobile STAs is that they may often be battery powered. Hence power management is

an important consideration. For example, it cannot be presumed that a STA’s receiver will always be

powered on.

See, e.g., 802.11-2007 § 5.1.1 - § 5.1.1.3

5.2 Components of the IEEE 802.11 architecture

The IEEE 802.11 architecture consists of several components that interact to provide a WLAN that supports

STA mobility transparently to upper layers.

The basic service set (BSS) is the basic building block of an IEEE 802.11 LAN. Figure 5 -1 shows two BSSs,

each of which has two STAs that are members of the BSS.

It is useful to think of the ovals used to depict a BSS as the coverage area within which the member STAs of

the BSS may remain in communication. (The concept of area, while not precise, is often good enough.) This

area is called the Basic Service Area (BSA). If a STA moves out of its BSA, it can no longer directly

communicate with other STAs present in the BSA.

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 865 of 946 PageID #:

4969
865

Claim 24 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 § 5.2

5.2.3 Distribution system (DS) concepts

PHY limitations determine the direct station-to-station distance that may be supported. For some networks

this distance is sufficient; for other networks, increased coverage is required.

Instead of existing independently, a BSS may also form a component of an extended form of network that is

built with multiple BSSs. The architectural component used to interconnect BSSs is the DS.

IEEE Std 802.11 logically separates the WM from the distribution system medium (DSM). Each logical

medium is used for different purposes, by a different component of the architecture. The IEEE 802.11

definitions neither preclude, nor demand, that the multiple media be either the same or different.

Recognizing that the multiple media are logically different is key to understanding the flexibility of the

architecture. The IEEE 802.11 LAN architecture is specified independently of the physical characteristics of

any specific implementation.

The DS enables mobile device support by providing the logical services necessary to handle address to

destination mapping and seamless integration of multiple BSSs.

An access point (AP) is any entity that has STA functionality and enables access to the DS, via the WM for

associated STAs.

See, e.g., 802.11-2007 § 5.2.3

5.3.2 DSS

The service provided by the DS is known as the DSS.

This service is represented in the IEEE 802.11 architecture by arrows within the APs, indicating that the

service is used to cross media and possibly address space logical boundaries. An AP is a logical entity, and

the functions described may be shared by one or more physical entities.

The services that comprise the DSS are as follows:

a) Association

b) Disassociation

c) Distribution

d) Integration

e) Reassociation

f) QoS traffic scheduling (QoS facility only)

DSSs are specified for use by MAC sublayer entities.

Figure 5-7 combines the components from previous figures with both types of services to show the complete

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 866 of 946 PageID #:

4970
866

Claim 24 of the ’802 Patent Prior Art Reference – 802.11-2007

IEEE 802.11 architecture.

See, e.g., 802.11-2007 § 5.3.2

5.4.4.1 TPC

Radio regulations may require radio local area networks (RLANs) operating in the 5 GHz band to use

transmitter power control, involving specification of a regulatory maximum transmit power and a mitigation

requirement for each allowed channel, to reduce interference with satellite services. The TPC service is used

to satisfy this regulatory requirement.

The TPC service provides for the following:

— Association of STAs with an AP in a BSS based on the STAs’ power capability.

— Specification of regulatory and local maximum transmit power levels for the current channel.

— Selection of a transmit power for each transmission in a channel within constraints imposed by

regulatory requirements.

— Adaptation of transmit power based on a range of information, including path loss and link margin

estimates.

See, e.g., 802.11-2007 § 5.4.4.1

7.3.2.20 Channel Switch Announcement element

The Channel Switch Announcement element is used by an AP in a BSS or a STA in an IBSS to advertise

when it is changing to a new channel and the channel number of the new channel. The format of the Channel

Switch Announcement element is shown in Figure 7-57.

See, e.g., 802.11-2007 § 7.3.2.20

10.3.11 Spectrum management protocol layer model

The layer management extensions for measurement and channel switching assume a certain partition

of spectrum management functionality between the MLME and SME. This partitioning assumes th at

policy decisions (e.g., regarding measurement and channel switching) reside in the SME, while the protocol

for measurement, switch timing, and the associated frame exchanges resides within the MLME (see

Figure 10-2).

...

The informative diagrams within this subclause further illustrate the spectrum management protocol model

adopted. Figure 10-3 and Figure 10-4 depict the measurement process for a peer STA to accept and reject a

measurement request, respectively. Figure 10-5 illustrates the TPC adaptation process. Lastly, Figure 10-6

depicts the management process for a channel switch using a Channel Switch Announcement frame.

See, e.g., 802.11-2007 § 10.3.11

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 867 of 946 PageID #:

4971
867

Claim 24 of the ’802 Patent Prior Art Reference – 802.11-2007

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 868 of 946 PageID #:

4972
868

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 869 of 946 PageID #:

4973
869

Claim 24 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 § 10.4.3.2

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 870 of 946 PageID #:

4974
870

Claim 24 of the ’802 Patent Prior Art Reference – 802.11-2007

17.1 Introduction

This clause specifies the PHY entity for an orthogonal frequency division multiplexing (OFDM) system.

The OFDM system provides a WLAN with data payload communication capabilities of 6, 9, 12, 18, 24, 36,

48, and 54 Mb/s. The support of transmitting and receiving at data rates of 6, 12, and 24 Mb/s is mandatory.

The system uses 52 subcarriers that are modulated using binary or quadrature phase shift keying (BPSK or

QPSK) or using 16- or 64-quadrature amplitude modulation (16-QAM or 64-QAM). Forward error

correction coding (convolutional coding) is used with a coding rate of 1/2, 2/3, or 3/4.

The OFDM system also provides a “half-clocked” operation using 10 MHz channel spacings with data

communications capabilities of 3, 4.5, 6, 9, 12, 18, 24, and 27 Mb/s. The support of transmitting and

receiving at data rates of 3, 6, and 12 Mb/s is mandatory when using 10 MHz channel spacing. The halfclocked

operation doubles symbol times and clear channel assessment (CCA) times when using 10 MHz

channel spacing. The regulatory requirements and information regarding use of this OFDM system in

4.9 GHz and 5 GHz bands is in Annex I and Annex J.

The OFDM system also provides a “quarter-clocked” operation using 5 MHz channel spacing with data

communication capabilities of 1.5, 2.25, 3, 4.5, 6, 9, 12, and 13.5 Mb/s. The support of transmitting and

receiving at data rates of 1.5, 3, and 6 Mb/s is mandatory when using 5 MHz channel spacing. The quarterclocked

operation quadruples symbol times and CCA times when using 5 MHz channel spacing. The

regulatory requirements and information regarding use of this OFDM system in the 4.9 GHz band is in

Annex I and Annex J.

See, e.g., 802.11-2007 § 17.1

17.3.2.1 Overview of the PPDU encoding process

The encoding process is composed of many detailed steps, which are described fully in later subclauses, as

noted below. The following overview intends to facilitate understanding the details of the convergence

procedure:

a) Produce the PLCP Preamble field, composed of 10 repetitions of a “short training sequence” (used

for AGC convergence, diversity selection, timing acquisition, and coarse frequency acquisition in

the receiver) and two repetitions of a “long training sequence” (used for channel estimation and fine

frequency acquisition in the receiver), preceded by a guard interval (GI). Refer to 17.3.3 for details.

b) Produce the PLCP header field from the RATE, LENGTH, and SERVICE fields of the

TXVECTOR by filling the appropriate bit fields. The RATE and LENGTH fields of the PLCP

header are encoded by a convolutional code at a rate of R = 1/2, and are subsequently mapped onto a

single BPSK encoded OFDM symbol, denoted as the SIGNAL symbol. In order to facilitate a

reliable and timely detection of the RATE and LENGTH fields, 6 zero tail bits are inserted into the

PLCP header. The encoding of the SIGNAL field into an OFDM symbol follows the same steps for

convolutional encoding, interleaving, BPSK modulation, pilot insertion, Fourier transform, and

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 871 of 946 PageID #:

4975
871

Claim 24 of the ’802 Patent Prior Art Reference – 802.11-2007

prepending a GI as described subsequently for data transmission with BPSK-OFDM modulated at

coding rate 1/2. The contents of the SIGNAL field are not scrambled. Refer to 17.3.4 for details.

c) Calculate from RATE field of the TXVECTOR the number of data bits per OFDM symbol (NDBPS),

the coding rate (R), the number of bits in each OFDM subcarrier (NBPSC), and the number of coded

bits per OFDM symbol (NCBPS). Refer to 17.3.2.2 for details.

d) Append the PSDU to the SERVICE field of the TXVECTOR. Extend the resulting bit string with

zero bits (at least 6 bits) so that the resulting length will be a multiple of NDBPS. The resulting bit

string constitutes the DATA part of the packet. Refer to 17.3.5.3 for details.

e) Initiate the scrambler with a pseudo-random nonzero seed, generate a scrambling sequence, and

XOR it with the extended string of data bits. Refer to 17.3.5.4 for details.

f) Replace the six scrambled zero bits following the data with six nonscrambled zero bits. (Those bits

return the convolutional encoder to the zero state and are denoted as tail bits.) Refer to 17.3.5.2 for

details.

g) Encode the extended, scrambled data string with a convolutional encoder (R = 1/2). Omit (puncture)

some of the encoder output string (chosen according to “puncturing pattern”) to reach the desired

“coding rate.” Refer to 17.3.5.5 for details.

h) Divide the encoded bit string into groups of NCBPS bits. Within each group, perform an

“interleaving” (reordering) of the bits according to a rule corresponding to the desired RATE. Refer

to 17.3.5.6 for details.

i) Divide the resulting coded and interleaved data string into groups of NCBPS bits. For each of the bit

groups, convert the bit group into a complex number according to the modulation encoding tables.

Refer to 17.3.5.7 for details.

j) Divide the complex number string into groups of 48 complex numbers. Each such group will be

associated with one OFDM symbol. In each group, the complex numbers will be numbered 0 to 47

and mapped hereafter into OFDM subcarriers numbered –26 to –22, –20 to –8, –6 to –1, 1 to 6,

8 to 20, and 22 to 26. The subcarriers –21, –7, 7, and 21 are skipped and, subsequently, used for

inserting pilot subcarriers. The 0 subcarrier, associated with center frequency, is omitted and filled

with zero value. Refer to 17.3.5.9 for details.

k) Four subcarriers are inserted as pilots into positions –21, –7, 7, and 21. The total number of the

subcarriers is 52 (48 + 4). Refer to 17.3.5.8 for details.

l) For each group of subcarriers –26 to 26, convert the subcarriers to time domain using inverse

Fourier transform. Prepend to the Fourier-transformed waveform a circular extension of itself thus

forming a GI, and truncate the resulting periodic waveform to a single OFDM symbol length by

applying time domain windowing. Refer to 17.3.5.9 for details.

m) Append the OFDM symbols one after another, starting after the SIGNAL symbol describing the

RATE and LENGTH fields. Refer to 17.3.5.9 for details.

n) Up-convert the resulting “complex baseband” waveform to an RF according to the center frequency

of the desired channel and transmit. Refer to 17.3.2.4 and 17.3.8.1 for details.

An illustration of the transmitted frame and its parts appears in Figure 17-4 (in 17.3.3).

See, e.g., 802.11-2007 § 17.3.2.1

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 872 of 946 PageID #:

4976
872

Claim 24 of the ’802 Patent Prior Art Reference – 802.11-2007

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 873 of 946 PageID #:

4977
873

Claim 24 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 § 17.3.2.3

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 874 of 946 PageID #:

4978
874

Claim 24 of the ’802 Patent Prior Art Reference – 802.11-2007

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 875 of 946 PageID #:

4979
875

Claim 24 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 § 17.3.2.4 Eq. (17-1)

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 876 of 946 PageID #:

4980
876

Claim 24 of the ’802 Patent Prior Art Reference – 802.11-2007

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 877 of 946 PageID #:

4981
877

Claim 24 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 § 17.3.2.5

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 878 of 946 PageID #:

4982
878

Claim 24 of the ’802 Patent Prior Art Reference – 802.11-2007

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 879 of 946 PageID #:

4983
879

See, e.g., 802.11-2007 § 17.3.3

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 880 of 946 PageID #:

4984
880

Claim 24 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 § 17.3.5.7

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 881 of 946 PageID #:

4985
881

Claim 24 of the ’802 Patent Prior Art Reference – 802.11-2007

17.3.5.8 Pilot subcarriers

In each OFDM symbol, four of the subcarriers are dedicated to pilot signals in order to make the coherent

detection robust against frequency offsets and phase noise. These pilot signals shall be put in subcarriers

–21, –7, 7, and 21. The pilots shall be BPSK modulated by a pseudo-binary sequence to prevent the

generation of spectral lines. The contribution of the pilot subcarriers to each OFDM symbol is described in

17.3.5.9.

See, e.g., 802.11-2007 § 17.3.5.8

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 882 of 946 PageID #:

4986
882

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 883 of 946 PageID #:

4987
883

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 884 of 946 PageID #:

4988
884

Claim 24 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 § 17.3.5.9

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 885 of 946 PageID #:

4989
885

Claim 24 of the ’802 Patent Prior Art Reference – 802.11-2007

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 886 of 946 PageID #:

4990
886

Claim 24 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 § 17.3.8.1

17.3.8.3.1 Operating frequency range

The OFDM PHY shall operate in the 5 GHz band, as allocated by a regulatory body in its operational region.

Spectrum allocation in the 5 GHz band is subject to authorities responsible for geographic-specific

regulatory domains (e.g., global, regional, and national). The particular channelization to be used for this

standard is dependent on such allocation, as well as the associated regulations for use of the allocations.

These regulations are subject to revision, or may be superseded.

In some regulatory domains, several frequency bands may be available for OFDM PHY-based WLANs.

These bands may be contiguous or not, and different regulatory limits may be applicable. A compliant

OFDM PHY shall support at least one frequency band in at least one regulatory domain. The support of

specific regulatory domains, and bands within the domains, shall be indicated by PLME attributes

dot11RegDomainsSupported and dot11FrequencyBandsSupported.

See, e.g., 802.11-2007 § 17.3.8.3.1

17.3.9.1 Transmit power levels

The maximum allowable transmit power by regulatory domain is defined in Annex I.

See, e.g., 802.11-2007 § 17.3.9.1

17.3.9.6.2 Transmitter spectral flatness

The average energy of the constellations in each of the spectral lines –16.. –1 and +1.. +16 will deviate no

more than ± 2 dB from their average energy. The average energy of the constellations in each of the spectral

lines –26.. –17 and +17.. +26 will deviate no more than +2/–4 dB from the average energy of spectral lines

–16.. –1 and +1.. +16. The data for this test shall be derived from the channel estimation step.

See, e.g., 802.11-2007 § 17.3.9.6.2

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 887 of 946 PageID #:

4991
887

Claim 24 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 § I.2.2

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 888 of 946 PageID #:

4992
888

Claim 24 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 § I.2.3

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 889 of 946 PageID #:

4993
889

Claim 24 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 Figure 5-7

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 890 of 946 PageID #:

4994
890

Claim 24 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 Figure 10-6

Furthermore, this claim element is obvious in light of 802.11-2007 itself, when combined with any of 

the other references as charted for this claim element in Exs. A-1–A-31, First Supplemental Ex. ACase 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 891 of 946 PageID #:

4995
891

Claim 24 of the ’802 Patent Prior Art Reference – 802.11-2007

Obviousness 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 

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

802.11-2007 discloses “a second down-converter circuit having a first input coupled to receive the 

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 downconverter outputs a second down-converted signal on the second down-converter output, wherein the 

first up-converted signal comprises a first signal modulated at the first RF frequency and a second 

signal modulated at the second RF frequency.” See, e.g.: 

1.1 Scope

The scope of this standard is to define one medium access control (MAC) and several physical layer (PHY)

specifications for wireless connectivity for fixed, portable, and moving stations (STAs) within a local area.

See, e.g., 802.11-2007 § 1.1

5.1.1 How WLAN systems are different

Wireless networks have fundamental characteristics that make them significantly different from traditional

wired LANs. Some countries impose specific requirements for radio equipment in addition to those

specified in this standard. This standard does not provide information to meet these country -specific radio

regulations.

5.1.1.1 Destination address does not equal destination location

In wired LANs, an address is equivalent to a physical location. This is implicitly assumed in the design of

wired LANs. In IEEE Std 802.11, the addressable unit is a station (STA). The STA is a message destination,

but not (in general) a fixed location.

5.1.1.2 Media impact on design and performance

The PHYs used in IEEE Std 802.11 are fundamentally different from wired media. Thus IEEE 802.11 PHYs

a) Use a medium that has neither absolute nor readily observable boundaries outside of which STAs

with conformant PHY transceivers are known to be unable to receive network frames

b) Are unprotected from other signals that may be sharing the medium

c) Communicate over a medium significantly less reliable than wired PHYs

d) Have dynamic topologies

e) Lack full connectivity, and therefore the assumption normally made that every STA can hear every

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 892 of 946 PageID #:

4996
892

Claim 24 of the ’802 Patent Prior Art Reference – 802.11-2007

other STA is invalid (i.e., STAs may be “hidden” from each other)

f) Have time-varying and asymmetric propagation properties

g) May experience interference from logically disjoint IEEE 802.11 networks operating in overlapping

areas

Because of limitations on wireless PHY ranges, WLANs intended to cover reasonable geographic distances

may be built from basic coverage building blocks. When providing QoS services it should be understood

that the MAC endeavors to provide QoS “service guarantees” within the limitations of the medium

properties identified above. In other words, particularly in unlicensed spectrum, true guarantees are often not

possible. However, gradations of service are always possible; and in sufficiently controlled environments,

QoS guarantees can truly be made.

5.1.1.3 The impact of handling mobile STAs

One of the requirements of IEEE Std 802.11 is to handle mobile as well as portable STAs. A portable STA

is one that is moved from location to location, but that is only used while at a fixed location. Mobile STAs

actually access the LAN while in motion.

For technical reasons, it is not sufficient to handle only portable STAs. Propagation effects blur the

distinction between portable and mobile STAs; stationary STAs often appear to be mobile due to

propagation effects.

Another aspect of mobile STAs is that they may often be battery powered. Hence power management is

an important consideration. For example, it cannot be presumed that a STA’s receiver will always be

powered on.

See, e.g., 802.11-2007 § 5.1.1 - § 5.1.1.3

5.2 Components of the IEEE 802.11 architecture

The IEEE 802.11 architecture consists of several components that interact to provide a WLAN that supports

STA mobility transparently to upper layers.

The basic service set (BSS) is the basic building block of an IEEE 802.11 LAN. Figure 5 -1 shows two BSSs,

each of which has two STAs that are members of the BSS.

It is useful to think of the ovals used to depict a BSS as the coverage area within which the member STAs of

the BSS may remain in communication. (The concept of area, while not precise, is often good enough.) This

area is called the Basic Service Area (BSA). If a STA moves out of its BSA, it can no longer directly

communicate with other STAs present in the BSA.

See, e.g., 802.11-2007 § 5.2

5.2.3 Distribution system (DS) concepts

PHY limitations determine the direct station-to-station distance that may be supported. For some networks

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 893 of 946 PageID #:

4997
893

Claim 24 of the ’802 Patent Prior Art Reference – 802.11-2007

this distance is sufficient; for other networks, increased coverage is required.

Instead of existing independently, a BSS may also form a component of an extended form of network that is

built with multiple BSSs. The architectural component used to interconnect BSSs is the DS.

IEEE Std 802.11 logically separates the WM from the distribution system medium (DSM). Each logical

medium is used for different purposes, by a different component of the architecture. The IEEE 802.11

definitions neither preclude, nor demand, that the multiple media be either the same or different.

Recognizing that the multiple media are logically different is key to understanding the flexibility of the

architecture. The IEEE 802.11 LAN architecture is specified independently of the physical characteristics of

any specific implementation.

The DS enables mobile device support by providing the logical services necessary to handle address to

destination mapping and seamless integration of multiple BSSs.

An access point (AP) is any entity that has STA functionality and enables access to the DS, via the WM for

associated STAs.

See, e.g., 802.11-2007 § 5.2.3

5.3.2 DSS

The service provided by the DS is known as the DSS.

This service is represented in the IEEE 802.11 architecture by arrows within the APs, indicating that the

service is used to cross media and possibly address space logical boundaries. An AP is a logical entity, and

the functions described may be shared by one or more physical entities.

The services that comprise the DSS are as follows:

a) Association

b) Disassociation

c) Distribution

d) Integration

e) Reassociation

f) QoS traffic scheduling (QoS facility only)

DSSs are specified for use by MAC sublayer entities.

Figure 5-7 combines the components from previous figures with both types of services to show the complete

IEEE 802.11 architecture.

See, e.g., 802.11-2007 § 5.3.2

5.4.4.1 TPC

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 894 of 946 PageID #:

4998
894

Claim 24 of the ’802 Patent Prior Art Reference – 802.11-2007

Radio regulations may require radio local area networks (RLANs) operating in the 5 GHz band to use

transmitter power control, involving specification of a regulatory maximum transmit power and a mitigation

requirement for each allowed channel, to reduce interference with satellite services. The TPC service is used

to satisfy this regulatory requirement.

The TPC service provides for the following:

— Association of STAs with an AP in a BSS based on the STAs’ power capability.

— Specification of regulatory and local maximum transmit power levels for the current channel.

— Selection of a transmit power for each transmission in a channel within constraints imposed by

regulatory requirements.

— Adaptation of transmit power based on a range of information, including path loss and link margin

estimates.

See, e.g., 802.11-2007 § 5.4.4.1

7.3.2.20 Channel Switch Announcement element

The Channel Switch Announcement element is used by an AP in a BSS or a STA in an IBSS to advertise

when it is changing to a new channel and the channel number of the new channel. The format of the Channel

Switch Announcement element is shown in Figure 7-57.

See, e.g., 802.11-2007 § 7.3.2.20

10.3.11 Spectrum management protocol layer model

The layer management extensions for measurement and channel switching assume a certain partition

of spectrum management functionality between the MLME and SME. This partitioning assumes that

policy decisions (e.g., regarding measurement and channel switching) reside in the SME, while the protocol

for measurement, switch timing, and the associated frame exchanges resides within the MLME (see

Figure 10-2).

...

The informative diagrams within this subclause further illustrate the spectrum management protocol model

adopted. Figure 10-3 and Figure 10-4 depict the measurement process for a peer STA to accept and reject a

measurement request, respectively. Figure 10-5 illustrates the TPC adaptation process. Lastly, Figure 10-6

depicts the management process for a channel switch using a Channel Switch Announcement frame.

See, e.g., 802.11-2007 § 10.3.11

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 895 of 946 PageID #:

4999
895

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 896 of 946 PageID #:

5000
896

Claim 24 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 § 10.4.3.2

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 897 of 946 PageID #:

5001
897

Claim 24 of the ’802 Patent Prior Art Reference – 802.11-2007

17.1 Introduction

This clause specifies the PHY entity for an orthogonal frequency division multiplexing (OFDM) system.

The OFDM system provides a WLAN with data payload communication capabilities of 6, 9, 12, 18, 24, 36,

48, and 54 Mb/s. The support of transmitting and receiving at data rates of 6, 12, and 24 Mb/s is mandatory.

The system uses 52 subcarriers that are modulated using binary or quadrature phase shift keying (BPSK or

QPSK) or using 16- or 64-quadrature amplitude modulation (16-QAM or 64-QAM). Forward error

correction coding (convolutional coding) is used with a coding rate of 1/2, 2/3, or 3/4.

The OFDM system also provides a “half-clocked” operation using 10 MHz channel spacings with data

communications capabilities of 3, 4.5, 6, 9, 12, 18, 24, and 27 Mb/s. The support of transmitting and

receiving at data rates of 3, 6, and 12 Mb/s is mandatory when using 10 MHz channel spacing. The halfclocked

operation doubles symbol times and clear channel assessment (CCA) times when using 10 MHz

channel spacing. The regulatory requirements and information regarding use of this OFDM system in

4.9 GHz and 5 GHz bands is in Annex I and Annex J.

The OFDM system also provides a “quarter-clocked” operation using 5 MHz channel spacing with data

communication capabilities of 1.5, 2.25, 3, 4.5, 6, 9, 12, and 13.5 Mb/s. The support of transmitting and

receiving at data rates of 1.5, 3, and 6 Mb/s is mandatory when using 5 MHz channel spacing. The quarterclocked

operation quadruples symbol times and CCA times when using 5 MHz channel spacing. The

regulatory requirements and information regarding use of this OFDM system in the 4.9 GHz band is in

Annex I and Annex J.

See, e.g., 802.11-2007 § 17.1

17.3.2.1 Overview of the PPDU encoding process

The encoding process is composed of many detailed steps, which are described fully in later subclauses, as

noted below. The following overview intends to facilitate understanding the details of the convergence

procedure:

a) Produce the PLCP Preamble field, composed of 10 repetitions of a “short training sequence” (used

for AGC convergence, diversity selection, timing acquisition, and coarse frequency acquisition in

the receiver) and two repetitions of a “long training sequence” (used for channel estimation and fine

frequency acquisition in the receiver), preceded by a guard interval (GI). Refer to 17.3.3 for details.

b) Produce the PLCP header field from the RATE, LENGTH, and SERVICE fields of the

TXVECTOR by filling the appropriate bit fields. The RATE and LENGTH fields of the PLCP

header are encoded by a convolutional code at a rate of R = 1/2, and are subsequently mapped onto a

single BPSK encoded OFDM symbol, denoted as the SIGNAL symbol. In order to facilitate a

reliable and timely detection of the RATE and LENGTH fields, 6 zero tail bits are inserted into the

PLCP header. The encoding of the SIGNAL field into an OFDM symbol follows the same steps for

convolutional encoding, interleaving, BPSK modulation, pilot insertion, Fourier tr ansform, and

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 898 of 946 PageID #:

5002
898

Claim 24 of the ’802 Patent Prior Art Reference – 802.11-2007

prepending a GI as described subsequently for data transmission with BPSK-OFDM modulated at

coding rate 1/2. The contents of the SIGNAL field are not scrambled. Refer to 17.3.4 for details.

c) Calculate from RATE field of the TXVECTOR the number of data bits per OFDM symbol (NDBPS),

the coding rate (R), the number of bits in each OFDM subcarrier (NBPSC), and the number of coded

bits per OFDM symbol (NCBPS). Refer to 17.3.2.2 for details.

d) Append the PSDU to the SERVICE field of the TXVECTOR. Extend the resulting bit string with

zero bits (at least 6 bits) so that the resulting length will be a multiple of NDBPS. The resulting bit

string constitutes the DATA part of the packet. Refer to 17.3.5.3 for details.

e) Initiate the scrambler with a pseudo-random nonzero seed, generate a scrambling sequence, and

XOR it with the extended string of data bits. Refer to 17.3.5.4 for details.

f) Replace the six scrambled zero bits following the data with six nonscrambled zero bits. (Those bits

return the convolutional encoder to the zero state and are denoted as tail bits.) Refer to 17.3.5.2 for

details.

g) Encode the extended, scrambled data string with a convolutional encoder (R = 1/2). Omit (puncture)

some of the encoder output string (chosen according to “puncturing pattern”) to reach the desired

“coding rate.” Refer to 17.3.5.5 for details.

h) Divide the encoded bit string into groups of NCBPS bits. Within each group, perform an

“interleaving” (reordering) of the bits according to a rule corresponding to the desired RATE. Refer

to 17.3.5.6 for details.

i) Divide the resulting coded and interleaved data string into groups of NCBPS bits. For each of the bit

groups, convert the bit group into a complex number according to the modulation encoding tables.

Refer to 17.3.5.7 for details.

j) Divide the complex number string into groups of 48 complex numbers. Each such group will be

associated with one OFDM symbol. In each group, the complex numbers will be numbered 0 to 47

and mapped hereafter into OFDM subcarriers numbered –26 to –22, –20 to –8, –6 to –1, 1 to 6,

8 to 20, and 22 to 26. The subcarriers –21, –7, 7, and 21 are skipped and, subsequently, used for

inserting pilot subcarriers. The 0 subcarrier, associated with center frequency, is omitted and filled

with zero value. Refer to 17.3.5.9 for details.

k) Four subcarriers are inserted as pilots into positions –21, –7, 7, and 21. The total number of the

subcarriers is 52 (48 + 4). Refer to 17.3.5.8 for details.

l) For each group of subcarriers –26 to 26, convert the subcarriers to time domain using inverse

Fourier transform. Prepend to the Fourier-transformed waveform a circular extension of itself thus

forming a GI, and truncate the resulting periodic waveform to a single OFDM symbol length by

applying time domain windowing. Refer to 17.3.5.9 for details.

m) Append the OFDM symbols one after another, starting after the SIGNAL symbol describing the

RATE and LENGTH fields. Refer to 17.3.5.9 for details.

n) Up-convert the resulting “complex baseband” waveform to an RF according to the center frequency

of the desired channel and transmit. Refer to 17.3.2.4 and 17.3.8.1 for details.

An illustration of the transmitted frame and its parts appears in Figure 17-4 (in 17.3.3).

See, e.g., 802.11-2007 § 17.3.2.1

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 899 of 946 PageID #:

5003
899

Claim 24 of the ’802 Patent Prior Art Reference – 802.11-2007

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 900 of 946 PageID #:

5004
900

Claim 24 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 § 17.3.2.3

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 901 of 946 PageID #:

5005
901

Claim 24 of the ’802 Patent Prior Art Reference – 802.11-2007

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 902 of 946 PageID #:

5006
902

Claim 24 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 § 17.3.2.4 Eq. (17-1)

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 903 of 946 PageID #:

5007
903

Claim 24 of the ’802 Patent Prior Art Reference – 802.11-2007

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 904 of 946 PageID #:

5008
904

Claim 24 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 § 17.3.2.5

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 905 of 946 PageID #:

5009
905

Claim 24 of the ’802 Patent Prior Art Reference – 802.11-2007

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 906 of 946 PageID #:

5010
906

See, e.g., 802.11-2007 § 17.3.3

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 907 of 946 PageID #:

5011
907

Claim 24 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 § 17.3.5.7

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 908 of 946 PageID #:

5012
908

Claim 24 of the ’802 Patent Prior Art Reference – 802.11-2007

17.3.5.8 Pilot subcarriers

In each OFDM symbol, four of the subcarriers are dedicated to pilot signals in order to make the coherent

detection robust against frequency offsets and phase noise. These pilot signals shall be put in subcarriers

–21, –7, 7, and 21. The pilots shall be BPSK modulated by a pseudo-binary sequence to prevent the

generation of spectral lines. The contribution of the pilot subcarriers to each OFDM symbol is described in

17.3.5.9.

See, e.g., 802.11-2007 § 17.3.5.8

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 909 of 946 PageID #:

5013
909

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 910 of 946 PageID #:

5014
910

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 911 of 946 PageID #:

5015
911

Claim 24 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 § 17.3.5.9

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 912 of 946 PageID #:

5016
912

Claim 24 of the ’802 Patent Prior Art Reference – 802.11-2007

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 913 of 946 PageID #:

5017
913

Claim 24 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 § 17.3.8.1

17.3.8.3.1 Operating frequency range

The OFDM PHY shall operate in the 5 GHz band, as allocated by a regulatory body in its operational region.

Spectrum allocation in the 5 GHz band is subject to authorities responsible for geograp hic-specific

regulatory domains (e.g., global, regional, and national). The particular channelization to be used for this

standard is dependent on such allocation, as well as the associated regulations for use of the allocations.

These regulations are subject to revision, or may be superseded.

In some regulatory domains, several frequency bands may be available for OFDM PHY-based WLANs.

These bands may be contiguous or not, and different regulatory limits may be applicable. A compliant

OFDM PHY shall support at least one frequency band in at least one regulatory domain. The support of

specific regulatory domains, and bands within the domains, shall be indicated by PLME attributes

dot11RegDomainsSupported and dot11FrequencyBandsSupported.

See, e.g., 802.11-2007 § 17.3.8.3.1

17.3.9.1 Transmit power levels

The maximum allowable transmit power by regulatory domain is defined in Annex I.

See, e.g., 802.11-2007 § 17.3.9.1

17.3.9.6.2 Transmitter spectral flatness

The average energy of the constellations in each of the spectral lines –16.. –1 and +1.. +16 will deviate no

more than ± 2 dB from their average energy. The average energy of the constellations in each of the spectral

lines –26.. –17 and +17.. +26 will deviate no more than +2/–4 dB from the average energy of spectral lines

–16.. –1 and +1.. +16. The data for this test shall be derived from the channel estimation step.

See, e.g., 802.11-2007 § 17.3.9.6.2

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 914 of 946 PageID #:

5018
914

Claim 24 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 § I.2.2

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 915 of 946 PageID #:

5019
915

Claim 24 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 § I.2.3

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 916 of 946 PageID #:

5020
916

Claim 24 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 Figure 5-7

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 917 of 946 PageID #:

5021
917

Claim 24 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 Figure 10-6

Furthermore, this claim element is obvious in light of 802.11-2007 itself, when combined with any of 

the other references as charted for this claim element in Exs. A-1–A-31, First Supplemental Ex. ACase 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 918 of 946 PageID #:

5022
918

Claim 24 of the ’802 Patent Prior Art Reference – 802.11-2007

Obviousness 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.

802.11-2007 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.” See, e.g.: 

1.1 Scope

The scope of this standard is to define one medium access control (MAC) and several physical layer (PHY)

specifications for wireless connectivity for fixed, portable, and moving stations (STAs) within a local area.

See, e.g., 802.11-2007 § 1.1

5.1.1 How WLAN systems are different

Wireless networks have fundamental characteristics that make them significantly different from traditional

wired LANs. Some countries impose specific requirements for radio equipment in addition to those

specified in this standard. This standard does not provide information to meet these country-specific radio

regulations.

5.1.1.1 Destination address does not equal destination location

In wired LANs, an address is equivalent to a physical location. This is implicitly assumed in the de sign of

wired LANs. In IEEE Std 802.11, the addressable unit is a station (STA). The STA is a message destination,

but not (in general) a fixed location.

5.1.1.2 Media impact on design and performance

The PHYs used in IEEE Std 802.11 are fundamentally different from wired media. Thus IEEE 802.11 PHYs

a) Use a medium that has neither absolute nor readily observable boundaries outside of which STAs

with conformant PHY transceivers are known to be unable to receive network frames

b) Are unprotected from other signals that may be sharing the medium

c) Communicate over a medium significantly less reliable than wired PHYs

d) Have dynamic topologies

e) Lack full connectivity, and therefore the assumption normally made that every STA can hear every

other STA is invalid (i.e., STAs may be “hidden” from each other)

f) Have time-varying and asymmetric propagation properties

g) May experience interference from logically disjoint IEEE 802.11 networks operating in overlapping

areas

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 919 of 946 PageID #:

5023
919

Claim 24 of the ’802 Patent Prior Art Reference – 802.11-2007

Because of limitations on wireless PHY ranges, WLANs intended to cover reasonable geographic distances

may be built from basic coverage building blocks. When providing QoS services it should be understood

that the MAC endeavors to provide QoS “service guarantees” within the limitations of the medium

properties identified above. In other words, particularly in unlicensed spectrum, true guarantees are often not

possible. However, gradations of service are always possible; and in sufficiently controlled environments,

QoS guarantees can truly be made.

5.1.1.3 The impact of handling mobile STAs

One of the requirements of IEEE Std 802.11 is to handle mobile as well as portable STAs. A portable STA

is one that is moved from location to location, but that is only used while at a fixed location. Mobile STAs

actually access the LAN while in motion.

For technical reasons, it is not sufficient to handle only portable STAs. Propagation effects blur the

distinction between portable and mobile STAs; stationary STAs often appear to be mobile due to

propagation effects.

Another aspect of mobile STAs is that they may often be battery powered. Hence power management is

an important consideration. For example, it cannot be presumed that a STA’s receiver will always be

powered on.

See, e.g., 802.11-2007 § 5.1.1 - § 5.1.1.3

5.2 Components of the IEEE 802.11 architecture

The IEEE 802.11 architecture consists of several components that interact to provide a WLAN that supports

STA mobility transparently to upper layers.

The basic service set (BSS) is the basic building block of an IEEE 802.11 LAN. Figure 5-1 shows two BSSs,

each of which has two STAs that are members of the BSS.

It is useful to think of the ovals used to depict a BSS as the coverage area within which the member STAs of

the BSS may remain in communication. (The concept of area, while not precise, is often good enough.) This

area is called the Basic Service Area (BSA). If a STA moves out of its BSA, it can no longer directly

communicate with other STAs present in the BSA.

See, e.g., 802.11-2007 § 5.2

5.2.3 Distribution system (DS) concepts

PHY limitations determine the direct station-to-station distance that may be supported. For some networks

this distance is sufficient; for other networks, increased coverage is required.

Instead of existing independently, a BSS may also form a component of an extended form of network that is

built with multiple BSSs. The architectural component used to interconnect BSSs is the DS.

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 920 of 946 PageID #:

5024
920

Claim 24 of the ’802 Patent Prior Art Reference – 802.11-2007

IEEE Std 802.11 logically separates the WM from the distribution system medium (DSM). Each logical

medium is used for different purposes, by a different component of the architecture. The IEEE 802.11

definitions neither preclude, nor demand, that the multiple media be either the same or different.

Recognizing that the multiple media are logically different is key to understanding the flexibility of the

architecture. The IEEE 802.11 LAN architecture is specified independently of the physical characteristics of

any specific implementation.

The DS enables mobile device support by providing the logical services necessary to handle address to

destination mapping and seamless integration of multiple BSSs.

An access point (AP) is any entity that has STA functionality and enables access to the DS, via the WM for

associated STAs.

See, e.g., 802.11-2007 § 5.2.3

5.3.2 DSS

The service provided by the DS is known as the DSS.

This service is represented in the IEEE 802.11 architecture by arrows within the APs, indicating that the

service is used to cross media and possibly address space logical boundaries. An AP is a logical entity, and

the functions described may be shared by one or more physical entities.

The services that comprise the DSS are as follows:

a) Association

b) Disassociation

c) Distribution

d) Integration

e) Reassociation

f) QoS traffic scheduling (QoS facility only)

DSSs are specified for use by MAC sublayer entities.

Figure 5-7 combines the components from previous figures with both types of services to show the complete

IEEE 802.11 architecture.

See, e.g., 802.11-2007 § 5.3.2

5.4.4.1 TPC

Radio regulations may require radio local area networks (RLANs) operating in the 5 GHz band to use

transmitter power control, involving specification of a regulatory maximum transmit power and a mitigation

requirement for each allowed channel, to reduce interference with satellite services. The TPC service is used

to satisfy this regulatory requirement.

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 921 of 946 PageID #:

5025
921

Claim 24 of the ’802 Patent Prior Art Reference – 802.11-2007

The TPC service provides for the following:

— Association of STAs with an AP in a BSS based on the STAs’ power capability.

— Specification of regulatory and local maximum transmit power levels for the current channel.

— Selection of a transmit power for each transmission in a channel within constraints imposed by

regulatory requirements.

— Adaptation of transmit power based on a range of information, including path loss and link margin

estimates.

See, e.g., 802.11-2007 § 5.4.4.1

7.3.2.20 Channel Switch Announcement element

The Channel Switch Announcement element is used by an AP in a BSS or a STA in an IBSS to advertise

when it is changing to a new channel and the channel number of the new channel. The format of the Channel

Switch Announcement element is shown in Figure 7-57.

See, e.g., 802.11-2007 § 7.3.2.20

10.3.11 Spectrum management protocol layer model

The layer management extensions for measurement and channel switching assume a certain partition

of spectrum management functionality between the MLME and SME. This partitioning assumes that

policy decisions (e.g., regarding measurement and channel switching) reside in the SME, while the protocol

for measurement, switch timing, and the associated frame exchanges resides within the MLME (see

Figure 10-2).

...

The informative diagrams within this subclause further illustrate the spectrum management protocol model

adopted. Figure 10-3 and Figure 10-4 depict the measurement process for a peer STA to accept and reject a

measurement request, respectively. Figure 10-5 illustrates the TPC adaptation process. Lastly, Figure 10-6

depicts the management process for a channel switch using a Channel Switch Announcement frame.

See, e.g., 802.11-2007 § 10.3.11

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 922 of 946 PageID #:

5026
922

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 923 of 946 PageID #:

5027
923

Claim 24 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 § 10.4.3.2

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 924 of 946 PageID #:

5028
924

Claim 24 of the ’802 Patent Prior Art Reference – 802.11-2007

17.1 Introduction

This clause specifies the PHY entity for an orthogonal frequency division multiplex ing (OFDM) system.

The OFDM system provides a WLAN with data payload communication capabilities of 6, 9, 12, 18, 24, 36,

48, and 54 Mb/s. The support of transmitting and receiving at data rates of 6, 12, and 24 Mb/s is mandatory.

The system uses 52 subcarriers that are modulated using binary or quadrature phase shift keying (BPSK or

QPSK) or using 16- or 64-quadrature amplitude modulation (16-QAM or 64-QAM). Forward error

correction coding (convolutional coding) is used with a coding rate of 1/2, 2/3, or 3/4.

The OFDM system also provides a “half-clocked” operation using 10 MHz channel spacings with data

communications capabilities of 3, 4.5, 6, 9, 12, 18, 24, and 27 Mb/s. The support of transmitting and

receiving at data rates of 3, 6, and 12 Mb/s is mandatory when using 10 MHz channel spacing. The halfclocked

operation doubles symbol times and clear channel assessment (CCA) times when using 10 MHz

channel spacing. The regulatory requirements and information regarding use of this OFDM system in

4.9 GHz and 5 GHz bands is in Annex I and Annex J.

The OFDM system also provides a “quarter-clocked” operation using 5 MHz channel spacing with data

communication capabilities of 1.5, 2.25, 3, 4.5, 6, 9, 12, and 13.5 Mb/s. The support of transmitting and

receiving at data rates of 1.5, 3, and 6 Mb/s is mandatory when using 5 MHz channel spacing. The quarterclocked

operation quadruples symbol times and CCA times when using 5 MHz channel spacing. The

regulatory requirements and information regarding use of this OFDM system in the 4.9 GHz band is in

Annex I and Annex J.

See, e.g., 802.11-2007 § 17.1

17.3.2.1 Overview of the PPDU encoding process

The encoding process is composed of many detailed steps, which are described fully in later subclauses, as

noted below. The following overview intends to facilitate understanding the details of the convergence

procedure:

a) Produce the PLCP Preamble field, composed of 10 repetitions of a “short training sequence” (used

for AGC convergence, diversity selection, timing acquisition, and coarse frequency acquisition in

the receiver) and two repetitions of a “long training sequence” (used for channel estimation and fine

frequency acquisition in the receiver), preceded by a guard interval (GI). Refer to 17.3.3 for details.

b) Produce the PLCP header field from the RATE, LENGTH, and SERVICE fields of the

TXVECTOR by filling the appropriate bit fields. The RATE and LENGTH fields of the PLCP

header are encoded by a convolutional code at a rate of R = 1/2, and are subsequently mapped on to a

single BPSK encoded OFDM symbol, denoted as the SIGNAL symbol. In order to facilitate a

reliable and timely detection of the RATE and LENGTH fields, 6 zero tail bits are inserted into the

PLCP header. The encoding of the SIGNAL field into an OFDM symbol follows the same steps for

convolutional encoding, interleaving, BPSK modulation, pilot insertion, Fourier transform, and

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 925 of 946 PageID #:

5029
925

Claim 24 of the ’802 Patent Prior Art Reference – 802.11-2007

prepending a GI as described subsequently for data transmission with BPSK-OFDM modulated at

coding rate 1/2. The contents of the SIGNAL field are not scrambled. Refer to 17.3.4 for details.

c) Calculate from RATE field of the TXVECTOR the number of data bits per OFDM symbol (NDBPS),

the coding rate (R), the number of bits in each OFDM subcarrier (NBPSC), and the number of coded

bits per OFDM symbol (NCBPS). Refer to 17.3.2.2 for details.

d) Append the PSDU to the SERVICE field of the TXVECTOR. Extend the resulting bit string with

zero bits (at least 6 bits) so that the resulting length will be a multiple of NDBPS. The resulting bit

string constitutes the DATA part of the packet. Refer to 17.3.5.3 for details.

e) Initiate the scrambler with a pseudo-random nonzero seed, generate a scrambling sequence, and

XOR it with the extended string of data bits. Refer to 17.3.5.4 for details.

f) Replace the six scrambled zero bits following the data with six nonscrambled zero bits. (Those bits

return the convolutional encoder to the zero state and are denoted as tail bits.) Refer to 17.3.5.2 for

details.

g) Encode the extended, scrambled data string with a convolutional encoder (R = 1/2). Omit (puncture)

some of the encoder output string (chosen according to “puncturing pattern”) to reach the desired

“coding rate.” Refer to 17.3.5.5 for details.

h) Divide the encoded bit string into groups of NCBPS bits. Within each group, perform an

“interleaving” (reordering) of the bits according to a rule corresponding to the desired RATE. Refer

to 17.3.5.6 for details.

i) Divide the resulting coded and interleaved data string into groups of NCBPS bits. For each of the bit

groups, convert the bit group into a complex number according to the modulation encoding tables.

Refer to 17.3.5.7 for details.

j) Divide the complex number string into groups of 48 complex numbers. Each such group will be

associated with one OFDM symbol. In each group, the complex numbers will be numbered 0 to 47

and mapped hereafter into OFDM subcarriers numbered –26 to –22, –20 to –8, –6 to –1, 1 to 6,

8 to 20, and 22 to 26. The subcarriers –21, –7, 7, and 21 are skipped and, subsequently, used for

inserting pilot subcarriers. The 0 subcarrier, associated with center frequency, is omitted and filled

with zero value. Refer to 17.3.5.9 for details.

k) Four subcarriers are inserted as pilots into positions –21, –7, 7, and 21. The total number of the

subcarriers is 52 (48 + 4). Refer to 17.3.5.8 for details.

l) For each group of subcarriers –26 to 26, convert the subcarriers to time domain using inverse

Fourier transform. Prepend to the Fourier-transformed waveform a circular extension of itself thus

forming a GI, and truncate the resulting periodic waveform to a single OFDM symbol length by

applying time domain windowing. Refer to 17.3.5.9 for details.

m) Append the OFDM symbols one after another, starting after the SIGNAL symbol describing the

RATE and LENGTH fields. Refer to 17.3.5.9 for details.

n) Up-convert the resulting “complex baseband” waveform to an RF according to the center frequency

of the desired channel and transmit. Refer to 17.3.2.4 and 17.3.8.1 for details.

An illustration of the transmitted frame and its parts appears in Figure 17-4 (in 17.3.3).

See, e.g., 802.11-2007 § 17.3.2.1

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 926 of 946 PageID #:

5030
926

Claim 24 of the ’802 Patent Prior Art Reference – 802.11-2007

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 927 of 946 PageID #:

5031
927

Claim 24 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 § 17.3.2.3

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 928 of 946 PageID #:

5032
928

Claim 24 of the ’802 Patent Prior Art Reference – 802.11-2007

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 929 of 946 PageID #:

5033
929

Claim 24 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 § 17.3.2.4 Eq. (17-1)

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 930 of 946 PageID #:

5034
930

Claim 24 of the ’802 Patent Prior Art Reference – 802.11-2007

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 931 of 946 PageID #:

5035
931

Claim 24 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 § 17.3.2.5

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 932 of 946 PageID #:

5036
932

Claim 24 of the ’802 Patent Prior Art Reference – 802.11-2007

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 933 of 946 PageID #:

5037
933

See, e.g., 802.11-2007 § 17.3.3

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 934 of 946 PageID #:

5038
934

Claim 24 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 § 17.3.5.7

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 935 of 946 PageID #:

5039
935

Claim 24 of the ’802 Patent Prior Art Reference – 802.11-2007

17.3.5.8 Pilot subcarriers

In each OFDM symbol, four of the subcarriers are dedicated to pilot signals in order to make the coherent

detection robust against frequency offsets and phase noise. These pilot signals shall be put in subcarriers

–21, –7, 7, and 21. The pilots shall be BPSK modulated by a pseudo-binary sequence to prevent the

generation of spectral lines. The contribution of the pilot subcarriers to each OFDM symbol is de scribed in

17.3.5.9.

See, e.g., 802.11-2007 § 17.3.5.8

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 936 of 946 PageID #:

5040
936

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 937 of 946 PageID #:

5041
937

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 938 of 946 PageID #:

5042
938

Claim 24 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 § 17.3.5.9

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 939 of 946 PageID #:

5043
939

Claim 24 of the ’802 Patent Prior Art Reference – 802.11-2007

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 940 of 946 PageID #:

5044
940

Claim 24 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 § 17.3.8.1

17.3.8.3.1 Operating frequency range

The OFDM PHY shall operate in the 5 GHz band, as allocated by a regulatory body in its operational region.

Spectrum allocation in the 5 GHz band is subject to authorities responsible for geographic-specific

regulatory domains (e.g., global, regional, and national). The particular channelization to be used for this

standard is dependent on such allocation, as well as the associated regulations for use of the allocations.

These regulations are subject to revision, or may be superseded.

In some regulatory domains, several frequency bands may be available for OFDM PHY-based WLANs.

These bands may be contiguous or not, and different regulatory limits may be applicable. A compliant

OFDM PHY shall support at least one frequency band in at least one regulatory domain. The support of

specific regulatory domains, and bands within the domains, shall be indicated by PLME attributes

dot11RegDomainsSupported and dot11FrequencyBandsSupported.

See, e.g., 802.11-2007 § 17.3.8.3.1

17.3.9.1 Transmit power levels

The maximum allowable transmit power by regulatory domain is defined in Ann ex I.

See, e.g., 802.11-2007 § 17.3.9.1

17.3.9.6.2 Transmitter spectral flatness

The average energy of the constellations in each of the spectral lines –16.. –1 and +1.. +16 will deviate no

more than ± 2 dB from their average energy. The average energy of the constellations in each of the spectral

lines –26.. –17 and +17.. +26 will deviate no more than +2/–4 dB from the average energy of spectral lines

–16.. –1 and +1.. +16. The data for this test shall be derived from the channel estimation step.

See, e.g., 802.11-2007 § 17.3.9.6.2

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 941 of 946 PageID #:

5045
941

Claim 24 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 § I.2.2

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 942 of 946 PageID #:

5046
942

Claim 24 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 § I.2.3

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 943 of 946 PageID #:

5047
943

Claim 24 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 Figure 5-7

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 944 of 946 PageID #:

5048
944

Claim 24 of the ’802 Patent Prior Art Reference – 802.11-2007

See, e.g., 802.11-2007 Figure 10-6

Furthermore, this claim element is obvious in light of 802.11-2007 itself, when combined with any of 

the other references as charted for this claim element in Exs. A-1–A-31, First Supplemental Ex. ACase 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 945 of 946 PageID #:

5049
945

Claim 24 of the ’802 Patent Prior Art Reference – 802.11-2007

Obviousness 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.

Case 2:23-cv-00285-JRG-RSP Document 59-13 Filed 07/11/24 Page 946 of 946 PageID #:

5050