EXHIBIT K

Case 2:23-cv-00285-JRG-RSP Document 59-11 Filed 07/11/24 Page 1 of 158 PageID #:

3087
1

Exhibit A-29

Invalidity Claim Chart for U.S. Patent No. 7,924,802 vs. U.S. Patent No. 6,359,868

U.S. Patent No. 6,359,868 (“Chen-868”) was filed on October 10, 2000 and issued on March 19, 2002. Chen-868 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. Chen-868 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 Chen-868 does not disclose any particular limitation of the asserted claims in the ’802 Patent, either 

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

modify Chen-868 and/or to combine the teachings of Chen-868 with other prior art references, including but not limited to the present 

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

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

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

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

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

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

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

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

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

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

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

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

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

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

1

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

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

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

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

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

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

Case 2:23-cv-00285-JRG-RSP Document 59-11 Filed 07/11/24 Page 2 of 158 PageID #:

3088
2

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 obta ined during discovery as the case progresses. 

Claim 1 of the ’802 Patent Prior Art Reference – Chen-868

[1.1] A method of 

transmitting information in a 

wireless communication 

channel comprising:

To the extent the preamble is limiting, Chen-868 discloses “A method of transmitting information in 

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

In the present invention, high speed data is provided by transmitting data on multiple carrier 

frequencies, multiple code channels and/or from multiple base stations. In a first embodiment of the 

present invention, multiplexed code symbols are transmitted on a plurality of carrier frequencies from 

the same base station. In second embodiment, code symbols are transmitted on multiple carrier 

frequencies with at least one corner frequency providing the code symbols is a multiple code 

channels. In a third embodiment, a subset of the multiplexed code symbols are redundantly provided 

on a different carrier from at least one additional base station. In a fourth embodiment, multiplexed 

symbols as transmitted on different carriers from the same base station and are redundantly 

transmitted on another set of carriers from a different base station. In a fifth embodiment, code 

symbols are multiplexed onto carriers from a plurality of base stations for increased throughput. In a 

sixth embodiment, code symbols are transmitted on carriers from a first base station and redundantly 

provided on at least one additional base station on the same carriers as used by the first base station.

See, e.g., Chen-868 at Abstract.

Furthermore, this claim element is obvious in light of Chen-868 itself, when combined with any of 

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

Case 2:23-cv-00285-JRG-RSP Document 59-11 Filed 07/11/24 Page 3 of 158 PageID #:

3089
3

Claim 1 of the ’802 Patent Prior Art Reference – Chen-868

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

Chen-868 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.: 

In the present invention, high speed data is provided by transmitting data on multiple carrier 

frequencies, multiple code channels and/or from multiple base stations. In a first embodiment of the 

present invention, multiplexed code symbols are transmitted on a plurality of carrier frequencies from 

the same base station. In second embodiment, code symbols are transmitted on multiple carrier 

frequencies with at least one corner frequency providing the code symbols is a multiple code 

channels. In a third embodiment, a subset of the multiplexed code symbols are redundantly provided 

on a different carrier from at least one additional base station. In a fourth embodiment, multiplexed 

symbols as transmitted on different carriers from the same base station and are redundantly 

transmitted on another set of carriers from a different base station. In a fifth embodiment, code 

symbols are multiplexed onto carriers from a plurality of base stations for increased throughput. In a 

sixth embodiment, code symbols are transmitted on carriers from a first base station and redundantly 

provided on at least one additional base station on the same carriers as used by the first base station.

See, e.g., Chen-868 at Abstract.

Case 2:23-cv-00285-JRG-RSP Document 59-11 Filed 07/11/24 Page 4 of 158 PageID #:

3090
4

Claim 1 of the ’802 Patent Prior Art Reference – Chen-868

See, e.g., Chen-868 at Figure 5.

See, e.g., Chen-868 at Figure 6.

Case 2:23-cv-00285-JRG-RSP Document 59-11 Filed 07/11/24 Page 5 of 158 PageID #:

3091
5

Claim 1 of the ’802 Patent Prior Art Reference – Chen-868

FIG. 6 is a block diagram of a receiver structure which provides for reduced hardware requirement in 

the reception of signals transmitted in accordance with the present invention.

See, e.g., Chen-868 at 3:7-10.

Referring to FIG. 3B, the data is again provided in three bands, although the present invention is 

easily extendible to an arbitrary number of bands. The first signal 160 is transmitted on a frequency 

of 850 MHz, the second signal 162 is transmitted on a frequency of 920 MHz, and the third signal is 

transmitted on a frequency of 928 MHz. In order to demodulate data transmitted on these three bands, 

the signals might first be down converted by 800 MHz and then provided to downconverters 110 a -

110 j, which would complete the downconversion to a baseband. A first downconverter 104 performs 

a downconversion of 48 MHz to provide a first low frequency signal at 2 MHz. A second 

downconverter 110 performs a downconversion of 68 MHz to provide a second low frequency signal 

at 2 MHz. A third downconverter 110 performs a downconversion of 76 MHz to provide a third low 

frequency signal at 2 MHz.

See, e.g., Chen-868 at 4:56-5:4.

FIG. 5 illustrates a frequency band allotment of two separate 5 MHz (or 3.75 MHz) bands. The first 

group of adjacent carriers is illustrated by frequency bands 250 a, 250 b and 250 c. The second group 

of adjacent carriers is illustrated by carriers 252 a, 252 b and 252 c. The receiver structure illustrated 

in FIG. 6 is capable of receiving information on the three carriers 250 a, 250 b and 250 c and 

simultaneously searching or receiving data on one of carriers 252 a, 252 b and 252 c.

To illustrate the operation and advantages of the receiver in FIG. 6, it will be assumed that the mobile 

station in which receiver 350 is located is currently receiving data on carriers 250 a, 250 b and 250 c 

and that the mobile station will search band 252 a to determine whether it is capable of receiving 

service from the system providing the signal comprising carriers 252 a, 252 b and 252 c. It will be 

understood by one skilled in the art that data for the mobile station could be provided on carriers 252 

a, 252 b or 252 c by simply changing the searching operation to a demodulation operation.

Case 2:23-cv-00285-JRG-RSP Document 59-11 Filed 07/11/24 Page 6 of 158 PageID #:

3092
6

Claim 1 of the ’802 Patent Prior Art Reference – Chen-868

Signals 250 a, 250 b, 250 c and 252 a are received at antenna 300 and provided through duplexer 302 

to low noise amplifier (LNA) 304. The amplified signal is provided to mixer 306. Mixer 306 down 

converts the signal in accordance with a signal provided by local oscillator 308 which brings the 5 

MHz band consisting of carriers 250 a, 250 b and 250 c down to a MHz wide baseband signal. The 

down converted signal is low pass filtered by filter (BPF1) 314 which is a low pass filter with a 5 

MHz pass band. The received signal is also provided to downconverter 310 which brings the signal 

carried on carrier 252 a down to base band. The down converted signal is low pass filtered by filter 

(BPF2) 316 which is a low pass filter with a 1.23 MHz pass band.

The filtered signal from filter 314 is summed with the filtered signal from filter 316 in summer 318. 

The summed signal is amplified by automatic gain control (AGC) 320. The amplified signal is 

provided to analog to digital (A/D) converter 322. The digital signals are provided to downconverters 

324 a, 324 b and filter (BPF) 328 c. Downconverters 324 a and 324 b bring the signals carried on 

carriers 250 b and 250 c down to base band. The signal carried on carriers 250 a and 252 a are 

already at baseband and is provided directly to filter 328 c. The signals 250 a and 252 a act as 

interference to one another in the demodulation process but given sufficient coding and spre ading 

gain, both the signals can be demodulated. In the present context of searching, it more often than not 

be the case that no signal is found and in that case the signal degradation will be minimum.

Downconverter 324 a and downconverter 324 b are driven by local oscillators 326 a and 326 b 

respectively. The down converted signals are provided to filters 328 a and 328 b, which are low pass 

filters with a 1.228 MHz pass band. Similarly, filter 328 c is a low pass filter with a 1.228 MHz pass 

band. The base band signals are then provided to demodulator and searcher 330 which operate as 

described with respect to demodulator and searcher 116 of FIG. 2. The signal provided through filter 

328 c can be demodulated by two demodulators, one to demodulate the signal transmitted from the 

first system (on carrier 250 a) and one to demodulate the signal transmitted by the second system (on 

carrier 252 a). In the alternative, a single demodulator can be time shared demodulating the signal 

from the first system and at certain intervals demodulating the signal transmitted from the second 

system.

Case 2:23-cv-00285-JRG-RSP Document 59-11 Filed 07/11/24 Page 7 of 158 PageID #:

3093
7

Claim 1 of the ’802 Patent Prior Art Reference – Chen-868

See, e.g., Chen-868 at 13:41-14:36.

Furthermore, this claim element is obvious in light of Chen-868 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.

[1.3] 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.

Chen-868 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.: 

In the present invention, high speed data is provided by transmitting data on multiple carrier 

frequencies, multiple code channels and/or from multiple base stations. In a first embodiment of the 

present invention, multiplexed code symbols are transmitted on a plurality of carrier frequencies from 

the same base station. In second embodiment, code symbols are transmitted on multiple carrier 

frequencies with at least one corner frequency providing the code symbols is a multiple code 

channels. In a third embodiment, a subset of the multiplexed code symbols are redundantly provided 

on a different carrier from at least one additional base station. In a fourth embodiment, multiplexed 

symbols as transmitted on different carriers from the same base station and are redundantly 

transmitted on another set of carriers from a different base station. In a fifth embodiment, code 

symbols are multiplexed onto carriers from a plurality of base stations for increased throughput. In a 

sixth embodiment, code symbols are transmitted on carriers from a first base station and redundantly 

provided on at least one additional base station on the same carriers as used by the first base station.

See, e.g., Chen-868 at Abstract.

Case 2:23-cv-00285-JRG-RSP Document 59-11 Filed 07/11/24 Page 8 of 158 PageID #:

3094
8

Claim 1 of the ’802 Patent Prior Art Reference – Chen-868

See, e.g., Chen-868 at Figure 5.

See, e.g., Chen-868 at Figure 6.

Case 2:23-cv-00285-JRG-RSP Document 59-11 Filed 07/11/24 Page 9 of 158 PageID #:

3095
9

Claim 1 of the ’802 Patent Prior Art Reference – Chen-868

FIG. 6 is a block diagram of a receiver structure which provides for reduced hardware requirement in 

the reception of signals transmitted in accordance with the present invention.

See, e.g., Chen-868 at 3:7-10.

Referring to FIG. 3B, the data is again provided in three bands, although the present invention is 

easily extendible to an arbitrary number of bands. The first signal 160 is transmitted on a frequency 

of 850 MHz, the second signal 162 is transmitted on a frequency of 920 MHz, and the third signal is 

transmitted on a frequency of 928 MHz. In order to demodulate data transmitted on these three bands, 

the signals might first be down converted by 800 MHz and then provided to downconverters 110 a110 j, which would complete the downconversion to a baseband. A first downconverter 104 performs 

a downconversion of 48 MHz to provide a first low frequency signal at 2 MHz. A second 

downconverter 110 performs a downconversion of 68 MHz to provide a second low frequency signal 

at 2 MHz. A third downconverter 110 performs a downconversion of 76 MHz to provide a third low 

frequency signal at 2 MHz.

See, e.g., Chen-868 at 4:56-5:4.

FIG. 5 illustrates a frequency band allotment of two separate 5 MHz (or 3.75 MHz) bands. The first 

group of adjacent carriers is illustrated by frequency bands 250 a, 250 b and 250 c. The second group 

of adjacent carriers is illustrated by carriers 252 a, 252 b and 252 c. The receiver structure illustrated 

in FIG. 6 is capable of receiving information on the three carriers 250 a, 250 b and 250 c and 

simultaneously searching or receiving data on one of carriers 252 a, 252 b and 252 c.

To illustrate the operation and advantages of the receiver in FIG. 6, it will be assumed that the mobile 

station in which receiver 350 is located is currently receiving data on carriers 250 a, 250 b and 250 c 

and that the mobile station will search band 252 a to determine whether it is capable of receiving 

service from the system providing the signal comprising carriers 252 a, 252 b and 252 c. It will be 

understood by one skilled in the art that data for the mobile station could be provided on carriers 252 

a, 252 b or 252 c by simply changing the searching operation to a demodulation operation.

Case 2:23-cv-00285-JRG-RSP Document 59-11 Filed 07/11/24 Page 10 of 158 PageID #:

3096
10

Claim 1 of the ’802 Patent Prior Art Reference – Chen-868

Signals 250 a, 250 b, 250 c and 252 a are received at antenna 300 and provided through duplexer 302 

to low noise amplifier (LNA) 304. The amplified signal is provided to mixer 306. Mixer 306 down 

converts the signal in accordance with a signal provided by local oscillator 308 which brings the 5 

MHz band consisting of carriers 250 a, 250 b and 250 c down to a MHz wide baseband signal. The 

down converted signal is low pass filtered by filter (BPF1) 314 which is a low pass filter with a 5 

MHz pass band. The received signal is also provided to downconverter 310 which brings the signal 

carried on carrier 252 a down to base band. The down converted signal is low pass filtered by filter 

(BPF2) 316 which is a low pass filter with a 1.23 MHz pass band.

The filtered signal from filter 314 is summed with the filtered signal from filter 316 in summer 318. 

The summed signal is amplified by automatic gain control (AGC) 320. The amplified signal is 

provided to analog to digital (A/D) converter 322. The digital signals are provided to downconverters 

324 a, 324 b and filter (BPF) 328 c. Downconverters 324 a and 324 b bring the signals carried on 

carriers 250 b and 250 c down to base band. The signal carried on carriers 250 a and 252 a are 

already at baseband and is provided directly to filter 328 c. The signals 250 a and 252 a act as 

interference to one another in the demodulation process but given sufficient coding and spreading 

gain, both the signals can be demodulated. In the present context of searching, it more often than n ot 

be the case that no signal is found and in that case the signal degradation will be minimum.

Downconverter 324 a and downconverter 324 b are driven by local oscillators 326 a and 326 b 

respectively. The down converted signals are provided to filters 328 a and 328 b, which are low pass 

filters with a 1.228 MHz pass band. Similarly, filter 328 c is a low pass filter with a 1.228 MHz pass 

band. The base band signals are then provided to demodulator and searcher 330 which operate as 

described with respect to demodulator and searcher 116 of FIG. 2. The signal provided through filter 

328 c can be demodulated by two demodulators, one to demodulate the signal transmitted from the 

first system (on carrier 250 a) and one to demodulate the signal transmitted by the second system (on 

carrier 252 a). In the alternative, a single demodulator can be time shared demodulating the signal 

from the first system and at certain intervals demodulating the signal transmitted from the second 

system.

Case 2:23-cv-00285-JRG-RSP Document 59-11 Filed 07/11/24 Page 11 of 158 PageID #:

3097
11

Claim 1 of the ’802 Patent Prior Art Reference – Chen-868

See, e.g., Chen-868 at 13:41-14:36.

Furthermore, this claim element is obvious in light of Chen-868 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 2 of the ’802 Patent Prior Art Reference – Chen-868

[2.1] The method of claim 1 Chen-868 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.

Chen-868 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.:

In the present invention, high speed data is provided by transmitting data on multiple carrier 

frequencies, multiple code channels and/or from multiple base stations. In a first embodiment of the 

present invention, multiplexed code symbols are transmitted on a plurality of carrier frequencies from 

the same base station. In second embodiment, code symbols are transmitted on multiple carrier 

frequencies with at least one corner frequency providing the code symbols is a multiple code 

channels. In a third embodiment, a subset of the multiplexed code symbols are redundantly provided 

on a different carrier from at least one additional base station. In a fourth embodiment, multiplexed 

symbols as transmitted on different carriers from the same base station and are redundantly 

transmitted on another set of carriers from a different base station. In a fifth embodiment, code 

symbols are multiplexed onto carriers from a plurality of base stations for increased throughput. In a 

sixth embodiment, code symbols are transmitted on carriers from a first base station and redundantly 

provided on at least one additional base station on the same carriers as used by the first base station.

Case 2:23-cv-00285-JRG-RSP Document 59-11 Filed 07/11/24 Page 12 of 158 PageID #:

3098
12

Claim 2 of the ’802 Patent Prior Art Reference – Chen-868

See, e.g., Chen-868 at Abstract.

See, e.g., Chen-868 at Figure 5.

Case 2:23-cv-00285-JRG-RSP Document 59-11 Filed 07/11/24 Page 13 of 158 PageID #:

3099
13

Claim 2 of the ’802 Patent Prior Art Reference – Chen-868

See, e.g., Chen-868 at Figure 6.

FIG. 6 is a block diagram of a receiver structure which provides for reduced hardware requirement in 

the reception of signals transmitted in accordance with the present invention.

See, e.g., Chen-868 at 3:7-10.

Referring to FIG. 3B, the data is again provided in three bands, although the present invention is 

easily extendible to an arbitrary number of bands. The first signal 160 is transmitted on a frequency 

of 850 MHz, the second signal 162 is transmitted on a frequency of 920 MHz, and the third signal is 

transmitted on a frequency of 928 MHz. In order to demodulate data transmitted on these three bands, 

the signals might first be down converted by 800 MHz and then provided to downconverters 110 a -

110 j, which would complete the downconversion to a baseband. A first downconverter 104 performs 

a downconversion of 48 MHz to provide a first low frequency signal at 2 MHz. A second 

downconverter 110 performs a downconversion of 68 MHz to provide a second low frequency signal 

at 2 MHz. A third downconverter 110 performs a downconversion of 76 MHz to provide a third low 

frequency signal at 2 MHz.

See, e.g., Chen-868 at 4:56-5:4.

FIG. 5 illustrates a frequency band allotment of two separate 5 MHz (or 3.75 MHz) bands. The first 

group of adjacent carriers is illustrated by frequency bands 250 a, 250 b and 250 c. The second group 

of adjacent carriers is illustrated by carriers 252 a, 252 b and 252 c. The receiver structure illustrated 

in FIG. 6 is capable of receiving information on the three carriers 250 a, 250 b and 250 c and 

simultaneously searching or receiving data on one of carriers 252 a, 252 b and 252 c.

To illustrate the operation and advantages of the receiver in FIG. 6, it will be assumed that the mobile 

station in which receiver 350 is located is currently receiving data on carriers 250 a, 250 b and 250 c 

and that the mobile station will search band 252 a to determine whether it is capable of receiving 

service from the system providing the signal comprising carriers 252 a, 252 b and 252 c. It will be 

Case 2:23-cv-00285-JRG-RSP Document 59-11 Filed 07/11/24 Page 14 of 158 PageID #:

3100
14

Claim 2 of the ’802 Patent Prior Art Reference – Chen-868

understood by one skilled in the art that data for the mobile station could be provided on carriers 252 

a, 252 b or 252 c by simply changing the searching operation to a demodulation operation.

Signals 250 a, 250 b, 250 c and 252 a are received at antenna 300 and provided through duplexer 302 

to low noise amplifier (LNA) 304. The amplified signal is provided to mixer 306. Mixer 306 down 

converts the signal in accordance with a signal provided by local oscillator 308 which brings the 5 

MHz band consisting of carriers 250 a, 250 b and 250 c down to a MHz wide baseband signal. The 

down converted signal is low pass filtered by filter (BPF1) 314 which is a low pass filter with a 5 

MHz pass band. The received signal is also provided to downconverter 310 which brings the signal 

carried on carrier 252 a down to base band. The down converted signal is low pass filtered by filter 

(BPF2) 316 which is a low pass filter with a 1.23 MHz pass band.

The filtered signal from filter 314 is summed with the filtered signal from filter 316 in summer 318. 

The summed signal is amplified by automatic gain control (AGC) 320. The amplified signal is 

provided to analog to digital (A/D) converter 322. The digital signals are provided to downconverters 

324 a, 324 b and filter (BPF) 328 c. Downconverters 324 a and 324 b bring the signals carried on 

carriers 250 b and 250 c down to base band. The signal carried on carriers 250 a and 252 a are 

already at baseband and is provided directly to filter 328 c. The signals 250 a and 252 a act as 

interference to one another in the demodulation process but given sufficient coding and spreading 

gain, both the signals can be demodulated. In the present context of searching, it more often than not 

be the case that no signal is found and in that case the signal degradation will be minimum.

Downconverter 324 a and downconverter 324 b are driven by local oscillators 326 a and 326 b 

respectively. The down converted signals are provided to filters 328 a and 328 b, which are low p ass 

filters with a 1.228 MHz pass band. Similarly, filter 328 c is a low pass filter with a 1.228 MHz pass 

band. The base band signals are then provided to demodulator and searcher 330 which operate as 

described with respect to demodulator and searcher 116 of FIG. 2. The signal provided through filter 

328 c can be demodulated by two demodulators, one to demodulate the signal transmitted from the 

first system (on carrier 250 a) and one to demodulate the signal transmitted by the second system (on 

carrier 252 a). In the alternative, a single demodulator can be time shared demodulating the signal 

Case 2:23-cv-00285-JRG-RSP Document 59-11 Filed 07/11/24 Page 15 of 158 PageID #:

3101
15

Claim 2 of the ’802 Patent Prior Art Reference – Chen-868

from the first system and at certain intervals demodulating the signal transmitted from the second 

system.

See, e.g., Chen-868 at 13:41-14:36.

Furthermore, this claim element is obvious in light of Chen-868 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 3 of the ’802 Patent Prior Art Reference – Chen-868

[3.1] The method of claim 1 Chen-868 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.

Chen-868 discloses “wherein the first and second information are transmitted using the same power 

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

In the present invention, high speed data is provided by transmitting data on multiple carrier 

frequencies, multiple code channels and/or from multiple base stations. In a first embodiment of the 

present invention, multiplexed code symbols are transmitted on a plurality of carrier frequencies from 

the same base station. In second embodiment, code symbols are transmitted on multiple carrier 

frequencies with at least one corner frequency providing the code symbols is a multiple code 

channels. In a third embodiment, a subset of the multiplexed code symbols are redundantly provided 

on a different carrier from at least one additional base station. In a fourth embodiment, multiplexed 

symbols as transmitted on different carriers from the same base station and are redundantly 

transmitted on another set of carriers from a different base station. In a fifth embodiment, code 

symbols are multiplexed onto carriers from a plurality of base stations for increased throughput. In a 

Case 2:23-cv-00285-JRG-RSP Document 59-11 Filed 07/11/24 Page 16 of 158 PageID #:

3102
16

Claim 3 of the ’802 Patent Prior Art Reference – Chen-868

sixth embodiment, code symbols are transmitted on carriers from a first base station and redundantly 

provided on at least one additional base station on the same carriers as used by the first base station.

See, e.g., Chen-868 at Abstract.

See, e.g., Chen-868 at Figure 5.

Case 2:23-cv-00285-JRG-RSP Document 59-11 Filed 07/11/24 Page 17 of 158 PageID #:

3103
17

Claim 3 of the ’802 Patent Prior Art Reference – Chen-868

See, e.g., Chen-868 at Figure 6.

FIG. 6 is a block diagram of a receiver structure which provides for reduced hardware requirement in 

the reception of signals transmitted in accordance with the present invention.

See, e.g., Chen-868 at 3:7-10.

Referring to FIG. 3B, the data is again provided in three bands, although the present invention is 

easily extendible to an arbitrary number of bands. The first signal 160 is transmitted on a frequency 

of 850 MHz, the second signal 162 is transmitted on a frequency of 920 MHz, and the third signal is 

transmitted on a frequency of 928 MHz. In order to demodulate data transmitted on these three bands, 

the signals might first be down converted by 800 MHz and then provided to downconverters 110 a -

110 j, which would complete the downconversion to a baseband. A first downconverter 104 performs 

Case 2:23-cv-00285-JRG-RSP Document 59-11 Filed 07/11/24 Page 18 of 158 PageID #:

3104
18

Claim 3 of the ’802 Patent Prior Art Reference – Chen-868

a downconversion of 48 MHz to provide a first low frequency signal at 2 MHz. A second 

downconverter 110 performs a downconversion of 68 MHz to provide a second low frequency signal 

at 2 MHz. A third downconverter 110 performs a downconversion of 76 MHz to provide a third low 

frequency signal at 2 MHz.

See, e.g., Chen-868 at 4:56-5:4.

FIG. 5 illustrates a frequency band allotment of two separate 5 MHz (or 3.75 MHz) bands. The first 

group of adjacent carriers is illustrated by frequency bands 250 a, 250 b and 250 c. The second group 

of adjacent carriers is illustrated by carriers 252 a, 252 b and 252 c. The receiver structure illustrated 

in FIG. 6 is capable of receiving information on the three carriers 250 a, 250 b and 250 c and 

simultaneously searching or receiving data on one of carriers 252 a, 252 b and 252 c.

To illustrate the operation and advantages of the receiver in FIG. 6, it will be assumed that the mobile 

station in which receiver 350 is located is currently receiving data on carriers 250 a, 250 b and 250 c 

and that the mobile station will search band 252 a to determine whether it is capable of receiving 

service from the system providing the signal comprising carriers 252 a, 252 b and 252 c. It will be 

understood by one skilled in the art that data for the mobile station could be provided on carriers 252 

a, 252 b or 252 c by simply changing the searching operation to a demodulation operation.

Signals 250 a, 250 b, 250 c and 252 a are received at antenna 300 and provided through duplexer 302 

to low noise amplifier (LNA) 304. The amplified signal is provided to mixer 306. Mixer 306 down 

converts the signal in accordance with a signal provided by local oscillator 308 which brings the 5 

MHz band consisting of carriers 250 a, 250 b and 250 c down to a MHz wide baseband signal. The 

down converted signal is low pass filtered by filter (BPF1) 314 which is a low pass filter with a 5 

MHz pass band. The received signal is also provided to downconverter 310 which brings the signal 

carried on carrier 252 a down to base band. The down converted signal is low pass filtered by filter 

(BPF2) 316 which is a low pass filter with a 1.23 MHz pass band.

The filtered signal from filter 314 is summed with the filtered signal from filter 316 in summer 318. 

The summed signal is amplified by automatic gain control (AGC) 320. The amplified signal is 

Case 2:23-cv-00285-JRG-RSP Document 59-11 Filed 07/11/24 Page 19 of 158 PageID #:

3105
19

Claim 3 of the ’802 Patent Prior Art Reference – Chen-868

provided to analog to digital (A/D) converter 322. The digital signals are provided to downconverters 

324 a, 324 b and filter (BPF) 328 c. Downconverters 324 a and 324 b bring the signals carried on 

carriers 250 b and 250 c down to base band. The signal carried on carriers 250 a and 252 a are 

already at baseband and is provided directly to filter 328 c. The signals 250 a and 252 a act as 

interference to one another in the demodulation process but given sufficient coding and spreading 

gain, both the signals can be demodulated. In the present context of searching, it more often than not 

be the case that no signal is found and in that case the signal degradation will be minimum.

Downconverter 324 a and downconverter 324 b are driven by local oscillators 326 a and 326 b 

respectively. The down converted signals are provided to filters 328 a and 328 b, which are low pass 

filters with a 1.228 MHz pass band. Similarly, filter 328 c is a low pass filter with a 1.228 MHz pass 

band. The base band signals are then provided to demodulator and searcher 330 which operate as 

described with respect to demodulator and searcher 116 of FIG. 2. The signal provided through filter 

328 c can be demodulated by two demodulators, one to demodulate the signal transmitted from the 

first system (on carrier 250 a) and one to demodulate the signal transmitted by the second system (on 

carrier 252 a). In the alternative, a single demodulator can be time shared demodulating the signal 

from the first system and at certain intervals demodulating the signal transmitted from the second 

system.

See, e.g., Chen-868 at 13:41-14:36.

Furthermore, this claim element is obvious in light of Chen-868 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.

Case 2:23-cv-00285-JRG-RSP Document 59-11 Filed 07/11/24 Page 20 of 158 PageID #:

3106
20

Claim 4 of the ’802 Patent Prior Art Reference – Chen-868

[4.1] The method of claim 3 Chen-868 discloses all the elements of claim 3 for all the reasons provided above.

[4.2] wherein the bandwidth 

of said power amplifier is 

greater than the difference 

between the first lowest 

frequency and the second 

highest frequency.

Chen-868 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.: 

In the present invention, high speed data is provided by transmitting data on multiple carrier 

frequencies, multiple code channels and/or from multiple base stations. In a first embodiment of the 

present invention, multiplexed code symbols are transmitted on a plurality of carrier frequencies from 

the same base station. In second embodiment, code symbols are transmitted on multiple carrier 

frequencies with at least one corner frequency providing the code symbols is a multiple code 

channels. In a third embodiment, a subset of the multiplexed code symbols are redundantly provided 

on a different carrier from at least one additional base station. In a fourth embodiment, multiplexed 

symbols as transmitted on different carriers from the same base station and are redundantly 

transmitted on another set of carriers from a different base station. In a fifth embodiment, code 

symbols are multiplexed onto carriers from a plurality of base stations for increased throughput. In a 

sixth embodiment, code symbols are transmitted on carriers from a first base station and redundantly 

provided on at least one additional base station on the same carriers as used by the first base station.

See, e.g., Chen-868 at Abstract.

See, e.g., Chen-868 at Figure 5.

Case 2:23-cv-00285-JRG-RSP Document 59-11 Filed 07/11/24 Page 21 of 158 PageID #:

3107
21

Claim 4 of the ’802 Patent Prior Art Reference – Chen-868

See, e.g., Chen-868 at Figure 6.

FIG. 6 is a block diagram of a receiver structure which provides for reduced hardware requirement in 

the reception of signals transmitted in accordance with the present invention.

See, e.g., Chen-868 at 3:7-10.

Referring to FIG. 3B, the data is again provided in three bands, although the present invention is 

easily extendible to an arbitrary number of bands. The first signal 160 is transmitted on a frequency 

of 850 MHz, the second signal 162 is transmitted on a frequency of 920 MHz, and the third signal is 

transmitted on a frequency of 928 MHz. In order to demodulate data transmitted on these three bands, 

the signals might first be down converted by 800 MHz and then provided to downconverters 110 a -

Case 2:23-cv-00285-JRG-RSP Document 59-11 Filed 07/11/24 Page 22 of 158 PageID #:

3108
22

Claim 4 of the ’802 Patent Prior Art Reference – Chen-868

110 j, which would complete the downconversion to a baseband. A first downconverter 104 performs 

a downconversion of 48 MHz to provide a first low frequency signal at 2 MHz. A second 

downconverter 110 performs a downconversion of 68 MHz to provide a second low frequency signal 

at 2 MHz. A third downconverter 110 performs a downconversion of 76 MHz to provide a third low 

frequency signal at 2 MHz.

See, e.g., Chen-868 at 4:56-5:4.

FIG. 5 illustrates a frequency band allotment of two separate 5 MHz (or 3.75 MHz) bands. The first 

group of adjacent carriers is illustrated by frequency bands 250 a, 250 b and 250 c. The second group 

of adjacent carriers is illustrated by carriers 252 a, 252 b and 252 c. The receiver structure illustrated 

in FIG. 6 is capable of receiving information on the three carriers 250 a, 250 b and 250 c and 

simultaneously searching or receiving data on one of carriers 252 a, 252 b and 252 c.

To illustrate the operation and advantages of the receiver in FIG. 6, it will be assumed that the mobile 

station in which receiver 350 is located is currently receiving data on carriers 250 a, 250 b and 250 c 

and that the mobile station will search band 252 a to determine whether it is capable of receiving 

service from the system providing the signal comprising carriers 252 a, 252 b and 252 c. It will be 

understood by one skilled in the art that data for the mobile station could be provided on carriers 252 

a, 252 b or 252 c by simply changing the searching operation to a demodulation operation.

Signals 250 a, 250 b, 250 c and 252 a are received at antenna 300 and provided through duplexer 302 

to low noise amplifier (LNA) 304. The amplified signal is provided to mixer 306. Mixer 306 down 

converts the signal in accordance with a signal provided by local oscillator 308 which brings the 5 

MHz band consisting of carriers 250 a, 250 b and 250 c down to a MHz wide baseband signal. The 

down converted signal is low pass filtered by filter (BPF1) 314 which is a low pass filter with a 5 

MHz pass band. The received signal is also provided to downconverter 310 which brings the signal 

carried on carrier 252 a down to base band. The down converted signal is low pass filtered by filter 

(BPF2) 316 which is a low pass filter with a 1.23 MHz pass band.

Case 2:23-cv-00285-JRG-RSP Document 59-11 Filed 07/11/24 Page 23 of 158 PageID #:

3109
23

Claim 4 of the ’802 Patent Prior Art Reference – Chen-868

The filtered signal from filter 314 is summed with the filtered signal from filter 316 in summer 318. 

The summed signal is amplified by automatic gain control (AGC) 320. The amplified signal is 

provided to analog to digital (A/D) converter 322. The digital signals are provided to downconverters 

324 a, 324 b and filter (BPF) 328 c. Downconverters 324 a and 324 b bring the signals carried on 

carriers 250 b and 250 c down to base band. The signal carried on carriers 250 a and 252 a are 

already at baseband and is provided directly to filter 328 c. The signals 250 a and 252 a act as 

interference to one another in the demodulation process but given sufficient coding and spreading 

gain, both the signals can be demodulated. In the present context of searching, it more often than not 

be the case that no signal is found and in that case the signal degradation will be minimum.

Downconverter 324 a and downconverter 324 b are driven by local oscillators 326 a and 326 b 

respectively. The down converted signals are provided to filters 328 a and 328 b, which are low pass 

filters with a 1.228 MHz pass band. Similarly, filter 328 c is a low pass filter with a 1.228 MHz pass 

band. The base band signals are then provided to demodulator and searcher 330 which operate as 

described with respect to demodulator and searcher 116 of FIG. 2. The signal provided through filter 

328 c can be demodulated by two demodulators, one to demodulate the signal transmitted from the 

first system (on carrier 250 a) and one to demodulate the signal transmitted by the second system (on 

carrier 252 a). In the alternative, a single demodulator can be time shared demodulating the signal 

from the first system and at certain intervals demodulating the signal transmitted from the second 

system.

See, e.g., Chen-868 at 13:41-14:36.

Furthermore, this claim element is obvious in light of Chen-868 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 59-11 Filed 07/11/24 Page 24 of 158 PageID #:

3110
24

Claim 6 of the ’802 Patent Prior Art Reference – Chen-868

[6.1] The method of claim 1 Chen-868 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.

Chen-868 discloses “wherein the first information corresponds to a first wireless protocol and the 

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

In the present invention, high speed data is provided by transmitting data on multiple carrier 

frequencies, multiple code channels and/or from multiple base stations. In a first embodiment of the 

present invention, multiplexed code symbols are transmitted on a plurality of carrier frequencies from 

the same base station. In second embodiment, code symbols are transmitted on multiple carrier 

frequencies with at least one corner frequency providing the code symbols is a multiple code 

channels. In a third embodiment, a subset of the multiplexed code symbols are redundantly provided 

on a different carrier from at least one additional base station. In a fourth embodiment, multiplexed 

symbols as transmitted on different carriers from the same base station and are redundantly 

transmitted on another set of carriers from a different base station. In a fifth embodiment, code 

symbols are multiplexed onto carriers from a plurality of base stations for increased throughput. In a 

sixth embodiment, code symbols are transmitted on carriers from a first base station and redundantly 

provided on at least one additional base station on the same carriers as used by the first base station.

See, e.g., Chen-868 at Abstract.

See, e.g., Chen-868 at Figure 5.

Case 2:23-cv-00285-JRG-RSP Document 59-11 Filed 07/11/24 Page 25 of 158 PageID #:

3111
25

Claim 6 of the ’802 Patent Prior Art Reference – Chen-868

See, e.g., Chen-868 at Figure 6.

FIG. 6 is a block diagram of a receiver structure which provides for reduced hardware requirement in 

the reception of signals transmitted in accordance with the present invention.

See, e.g., Chen-868 at 3:7-10.

Referring to FIG. 3B, the data is again provided in three bands, although the present invention is 

easily extendible to an arbitrary number of bands. The first signal 160 is transmitted on a frequency 

of 850 MHz, the second signal 162 is transmitted on a frequency of 920 MHz, and the third signal is 

transmitted on a frequency of 928 MHz. In order to demodulate data transmitted on these three bands, 

the signals might first be down converted by 800 MHz and then provided to downconverters 110 a -

Case 2:23-cv-00285-JRG-RSP Document 59-11 Filed 07/11/24 Page 26 of 158 PageID #:

3112
26

Claim 6 of the ’802 Patent Prior Art Reference – Chen-868

110 j, which would complete the downconversion to a baseband. A first downconverter 104 performs 

a downconversion of 48 MHz to provide a first low frequency signal at 2 MHz. A second 

downconverter 110 performs a downconversion of 68 MHz to provide a second low frequency signal 

at 2 MHz. A third downconverter 110 performs a downconversion of 76 MHz to provide a third low 

frequency signal at 2 MHz.

See, e.g., Chen-868 at 4:56-5:4.

FIG. 5 illustrates a frequency band allotment of two separate 5 MHz (or 3.75 MHz) bands. The first 

group of adjacent carriers is illustrated by frequency bands 250 a, 250 b and 250 c. The second group 

of adjacent carriers is illustrated by carriers 252 a, 252 b and 252 c. The receiver structure illustrated 

in FIG. 6 is capable of receiving information on the three carriers 250 a, 250 b and 250 c and 

simultaneously searching or receiving data on one of carriers 252 a, 252 b and 252 c.

To illustrate the operation and advantages of the receiver in FIG. 6, it will be assumed that the mobile 

station in which receiver 350 is located is currently receiving data on carriers 250 a, 250 b and 250 c 

and that the mobile station will search band 252 a to determine whether it is capable of receiving 

service from the system providing the signal comprising carriers 252 a, 252 b and 252 c. It will be 

understood by one skilled in the art that data for the mobile station could be provided on carriers 252 

a, 252 b or 252 c by simply changing the searching operation to a demodulation operation.

Signals 250 a, 250 b, 250 c and 252 a are received at antenna 300 and provided through duplexer 302 

to low noise amplifier (LNA) 304. The amplified signal is provided to mixer 306. Mixer 306 down 

converts the signal in accordance with a signal provided by local oscillator 308 which brings the 5 

MHz band consisting of carriers 250 a, 250 b and 250 c down to a MHz wide baseband signal. The 

down converted signal is low pass filtered by filter (BPF1) 314 which is a low pass filter with a 5 

MHz pass band. The received signal is also provided to downconverter 310 which brings the signal 

carried on carrier 252 a down to base band. The down converted signal is low pass filtered by filter 

(BPF2) 316 which is a low pass filter with a 1.23 MHz pass band.

Case 2:23-cv-00285-JRG-RSP Document 59-11 Filed 07/11/24 Page 27 of 158 PageID #:

3113
27

Claim 6 of the ’802 Patent Prior Art Reference – Chen-868

The filtered signal from filter 314 is summed with the filtered signal from filter 316 in summer 318. 

The summed signal is amplified by automatic gain control (AGC) 320. The amplified signal is 

provided to analog to digital (A/D) converter 322. The digital signals are provided to downconverters 

324 a, 324 b and filter (BPF) 328 c. Downconverters 324 a and 324 b bring the signals carried on 

carriers 250 b and 250 c down to base band. The signal carried on carriers 250 a and 252 a are 

already at baseband and is provided directly to filter 328 c. The signals 250 a and 252 a act as 

interference to one another in the demodulation process but given sufficient coding and spreading 

gain, both the signals can be demodulated. In the present context of searching, it more often than not 

be the case that no signal is found and in that case the signal degradation will be minimum.

Downconverter 324 a and downconverter 324 b are driven by local oscillators 326 a and 326 b 

respectively. The down converted signals are provided to filters 328 a and 328 b, which are low p ass 

filters with a 1.228 MHz pass band. Similarly, filter 328 c is a low pass filter with a 1.228 MHz pass 

band. The base band signals are then provided to demodulator and searcher 330 which operate as 

described with respect to demodulator and searcher 116 of FIG. 2. The signal provided through filter 

328 c can be demodulated by two demodulators, one to demodulate the signal transmitted from the 

first system (on carrier 250 a) and one to demodulate the signal transmitted by the second system (on 

carrier 252 a). In the alternative, a single demodulator can be time shared demodulating the signal 

from the first system and at certain intervals demodulating the signal transmitted from the second 

system.

See, e.g., Chen-868 at 13:41-14:36.

Furthermore, this claim element is obvious in light of Chen-868 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.

Case 2:23-cv-00285-JRG-RSP Document 59-11 Filed 07/11/24 Page 28 of 158 PageID #:

3114
28

Claim 7 of the ’802 Patent Prior Art Reference – Chen-868

[7.1] The method of claim 1 Chen-868 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.

Chen-868 discloses “wherein the first information and the second information are the same data 

transmitted across two different frequencies.” See, e.g.: 

In the present invention, high speed data is provided by transmitting data on multiple carrier 

frequencies, multiple code channels and/or from multiple base stations. In a first embodiment of the 

present invention, multiplexed code symbols are transmitted on a plurality of carrier frequencies from 

the same base station. In second embodiment, code symbols are transmitted on multiple carrier 

frequencies with at least one corner frequency providing the code symbols is a multiple code 

channels. In a third embodiment, a subset of the multiplexed code symbols are redundantly provided 

on a different carrier from at least one additional base station. In a fourth embodiment, multiplexed 

symbols as transmitted on different carriers from the same base station and are redundantly 

transmitted on another set of carriers from a different base station. In a fifth embodiment, code 

symbols are multiplexed onto carriers from a plurality of base stations for increased throughput. In a 

sixth embodiment, code symbols are transmitted on carriers from a first base station and redundantly 

provided on at least one additional base station on the same carriers as used by the first base station.

See, e.g., Chen-868 at Abstract.

See, e.g., Chen-868 at Figure 5.

Case 2:23-cv-00285-JRG-RSP Document 59-11 Filed 07/11/24 Page 29 of 158 PageID #:

3115
29

Claim 7 of the ’802 Patent Prior Art Reference – Chen-868

See, e.g., Chen-868 at Figure 6.

FIG. 6 is a block diagram of a receiver structure which provides for reduced hardware requirement in 

the reception of signals transmitted in accordance with the present invention.

See, e.g., Chen-868 at 3:7-10.

Referring to FIG. 3B, the data is again provided in three bands, although the present invention is 

easily extendible to an arbitrary number of bands. The first signal 160 is transmitted on a frequency 

of 850 MHz, the second signal 162 is transmitted on a frequency of 920 MHz, and the third signal is 

transmitted on a frequency of 928 MHz. In order to demodulate data transmitted on these three bands, 

the signals might first be down converted by 800 MHz and then provided to downconverters 110 aCase 2:23-cv-00285-JRG-RSP Document 59-11 Filed 07/11/24 Page 30 of 158 PageID #:

3116
30

Claim 7 of the ’802 Patent Prior Art Reference – Chen-868

110 j, which would complete the downconversion to a baseband. A first downconverter 104 performs 

a downconversion of 48 MHz to provide a first low frequency signal at 2 MHz. A second 

downconverter 110 performs a downconversion of 68 MHz to provide a second low frequency signal 

at 2 MHz. A third downconverter 110 performs a downconversion of 76 MHz to provide a third low 

frequency signal at 2 MHz.

See, e.g., Chen-868 at 4:56-5:4.

FIG. 5 illustrates a frequency band allotment of two separate 5 MHz (or 3.75 MHz) bands. The first 

group of adjacent carriers is illustrated by frequency bands 250 a, 250 b and 250 c. The second group 

of adjacent carriers is illustrated by carriers 252 a, 252 b and 252 c. The receiver structure illustrated 

in FIG. 6 is capable of receiving information on the three carriers 250 a, 250 b and 250 c and 

simultaneously searching or receiving data on one of carriers 252 a, 252 b and 252 c.

To illustrate the operation and advantages of the receiver in FIG. 6, it will be assumed that the mobile 

station in which receiver 350 is located is currently receiving data on carriers 250 a, 250 b and 250 c 

and that the mobile station will search band 252 a to determine whether it is capable of receiving 

service from the system providing the signal comprising carriers 252 a, 252 b and 252 c. It will be 

understood by one skilled in the art that data for the mobile station could be provided on carriers 252 

a, 252 b or 252 c by simply changing the searching operation to a demodulation operation.

Signals 250 a, 250 b, 250 c and 252 a are received at antenna 300 and provided through duplexer 302 

to low noise amplifier (LNA) 304. The amplified signal is provided to mixer 306. Mixer 306 d own 

converts the signal in accordance with a signal provided by local oscillator 308 which brings the 5 

MHz band consisting of carriers 250 a, 250 b and 250 c down to a MHz wide baseband signal. The 

down converted signal is low pass filtered by filter (BPF1) 314 which is a low pass filter with a 5 

MHz pass band. The received signal is also provided to downconverter 310 which brings the signal 

carried on carrier 252 a down to base band. The down converted signal is low pass filtered by filter 

(BPF2) 316 which is a low pass filter with a 1.23 MHz pass band.

Case 2:23-cv-00285-JRG-RSP Document 59-11 Filed 07/11/24 Page 31 of 158 PageID #:

3117
31

Claim 7 of the ’802 Patent Prior Art Reference – Chen-868

The filtered signal from filter 314 is summed with the filtered signal from filter 316 in summer 318. 

The summed signal is amplified by automatic gain control (AGC) 320. The amplified signal is 

provided to analog to digital (A/D) converter 322. The digital signals are provided to downconverters 

324 a, 324 b and filter (BPF) 328 c. Downconverters 324 a and 324 b bring the signals carried on 

carriers 250 b and 250 c down to base band. The signal carried on carriers 250 a and 252 a are 

already at baseband and is provided directly to filter 328 c. The signals 250 a and 252 a act as 

interference to one another in the demodulation process but given sufficient coding and spreading 

gain, both the signals can be demodulated. In the present context of searching, it more often than not 

be the case that no signal is found and in that case the signal degradation will be minimum.

Downconverter 324 a and downconverter 324 b are driven by local oscillators 326 a and 326 b 

respectively. The down converted signals are provided to filters 328 a and 328 b, which are low pass 

filters with a 1.228 MHz pass band. Similarly, filter 328 c is a low pass filter with a 1.228 MHz pass 

band. The base band signals are then provided to demodulator and searcher 330 which operate as 

described with respect to demodulator and searcher 116 of FIG. 2. The signal provided through filter 

328 c can be demodulated by two demodulators, one to demodulate the signal transmitted from the 

first system (on carrier 250 a) and one to demodulate the signal transmitted by the second system (on 

carrier 252 a). In the alternative, a single demodulator can be time shared demodulating the signal 

from the first system and at certain intervals demodulating the signal transmitted from the second 

system.

See, e.g., Chen-868 at 13:41-14:36.

Furthermore, this claim element is obvious in light of Chen-868 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 59-11 Filed 07/11/24 Page 32 of 158 PageID #:

3118
32

Claim 8 of the ’802 Patent Prior Art Reference – Chen-868

[8.1] The method of claim 1 Chen-868 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.

Chen-868 discloses “wherein the first information and the second information are from the same data 

stream.” See, e.g.: 

In the present invention, high speed data is provided by transmitting data on multiple carrier 

frequencies, multiple code channels and/or from multiple base stations. In a first embodiment of the 

present invention, multiplexed code symbols are transmitted on a plurality of carrier frequencies from 

the same base station. In second embodiment, code symbols are transmitted on multiple carrier 

frequencies with at least one corner frequency providing the code symbols is a multiple code 

channels. In a third embodiment, a subset of the multiplexed code symbols are redundantly provided 

on a different carrier from at least one additional base station. In a fourth embodiment, multiplexed 

symbols as transmitted on different carriers from the same base station and are redundantly 

transmitted on another set of carriers from a different base station. In a fifth embodiment, co de 

symbols are multiplexed onto carriers from a plurality of base stations for increased throughput. In a 

sixth embodiment, code symbols are transmitted on carriers from a first base station and redundantly 

provided on at least one additional base station on the same carriers as used by the first base station.

See, e.g., Chen-868 at Abstract.

See, e.g., Chen-868 at Figure 5.

Case 2:23-cv-00285-JRG-RSP Document 59-11 Filed 07/11/24 Page 33 of 158 PageID #:

3119
33

Claim 8 of the ’802 Patent Prior Art Reference – Chen-868

See, e.g., Chen-868 at Figure 6.

FIG. 6 is a block diagram of a receiver structure which provides for reduced hardware requirement in 

the reception of signals transmitted in accordance with the present invention.

See, e.g., Chen-868 at 3:7-10.

Referring to FIG. 3B, the data is again provided in three bands, although the present invention is 

easily extendible to an arbitrary number of bands. The first signal 160 is transmitted on a frequency 

of 850 MHz, the second signal 162 is transmitted on a frequency of 920 MHz, and the third signal is 

transmitted on a frequency of 928 MHz. In order to demodulate data transmitted on these three bands, 

the signals might first be down converted by 800 MHz and then provided to downconverters 110 a -

Case 2:23-cv-00285-JRG-RSP Document 59-11 Filed 07/11/24 Page 34 of 158 PageID #:

3120
34

Claim 8 of the ’802 Patent Prior Art Reference – Chen-868

110 j, which would complete the downconversion to a baseband. A first downconverter 104 performs 

a downconversion of 48 MHz to provide a first low frequency signal at 2 MHz. A second 

downconverter 110 performs a downconversion of 68 MHz to provide a second low frequency signal 

at 2 MHz. A third downconverter 110 performs a downconversion of 76 MHz to provide a third low 

frequency signal at 2 MHz.

See, e.g., Chen-868 at 4:56-5:4.

FIG. 5 illustrates a frequency band allotment of two separate 5 MHz (or 3.75 MHz) bands. The first 

group of adjacent carriers is illustrated by frequency bands 250 a, 250 b and 250 c. The second group 

of adjacent carriers is illustrated by carriers 252 a, 252 b and 252 c. The receiver structure illustrated 

in FIG. 6 is capable of receiving information on the three carriers 250 a, 250 b and 250 c and 

simultaneously searching or receiving data on one of carriers 252 a, 252 b and 252 c.

To illustrate the operation and advantages of the receiver in FIG. 6, it will be assumed that the mobile 

station in which receiver 350 is located is currently receiving data on carriers 250 a, 250 b and 250 c 

and that the mobile station will search band 252 a to determine whether it is capable of receiving 

service from the system providing the signal comprising carriers 252 a, 252 b and 252 c. It will be 

understood by one skilled in the art that data for the mobile station could be provided on carriers 252 

a, 252 b or 252 c by simply changing the searching operation to a demodulation operation.

Signals 250 a, 250 b, 250 c and 252 a are received at antenna 300 and provided through duplexer 302 

to low noise amplifier (LNA) 304. The amplified signal is provided to mixer 306. Mixer 306 down 

converts the signal in accordance with a signal provided by local oscillator 308 which brings the 5 

MHz band consisting of carriers 250 a, 250 b and 250 c down to a MHz wide baseband signal. The 

down converted signal is low pass filtered by filter (BPF1) 314 which is a low pass filter with a 5 

MHz pass band. The received signal is also provided to downconverter 310 which brings the signal 

carried on carrier 252 a down to base band. The down converted signal is low pass filtered by filter 

(BPF2) 316 which is a low pass filter with a 1.23 MHz pass band.

Case 2:23-cv-00285-JRG-RSP Document 59-11 Filed 07/11/24 Page 35 of 158 PageID #:

3121
35

Claim 8 of the ’802 Patent Prior Art Reference – Chen-868

The filtered signal from filter 314 is summed with the filtered signal from filter 316 in summer 318. 

The summed signal is amplified by automatic gain control (AGC) 320. The amplified signal is 

provided to analog to digital (A/D) converter 322. The digital signals are provided to downconverters 

324 a, 324 b and filter (BPF) 328 c. Downconverters 324 a and 324 b bring the signals carried on 

carriers 250 b and 250 c down to base band. The signal carried on carriers 250 a and 252 a are 

already at baseband and is provided directly to filter 328 c. The signals 250 a and 252 a act as 

interference to one another in the demodulation process but given sufficient coding and spreading 

gain, both the signals can be demodulated. In the present context of searching, it more often than not 

be the case that no signal is found and in that case the signal degradation will be minimum.

Downconverter 324 a and downconverter 324 b are driven by local oscillators 326 a and 326 b 

respectively. The down converted signals are provided to filters 328 a and 328 b, which are low pass 

filters with a 1.228 MHz pass band. Similarly, filter 328 c is a low pass filter with a 1.228 MHz pass 

band. The base band signals are then provided to demodulator and searcher 330 which operate as 

described with respect to demodulator and searcher 116 of FIG. 2. The signal provided through filter 

328 c can be demodulated by two demodulators, one to demodulate the signal transmitted from the 

first system (on carrier 250 a) and one to demodulate the signal transmitted by the second system (on 

carrier 252 a). In the alternative, a single demodulator can be time shared demodulating the signal 

from the first system and at certain intervals demodulating the signal transmitted from the second 

system.

See, e.g., Chen-868 at 13:41-14:36.

Furthermore, this claim element is obvious in light of Chen-868 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 59-11 Filed 07/11/24 Page 36 of 158 PageID #:

3122
36

Claim 9 of the ’802 Patent Prior Art Reference – Chen-868

[9.1] The method of claim 1 Chen-868 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.

Chen-868 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.: 

In the present invention, high speed data is provided by transmitting data on multiple carrier 

frequencies, multiple code channels and/or from multiple base stations. In a first embodiment of the 

present invention, multiplexed code symbols are transmitted on a plurality of carrier frequencies from 

the same base station. In second embodiment, code symbols are transmitted on multiple carrier 

frequencies with at least one corner frequency providing the code symbols is a multiple code 

channels. In a third embodiment, a subset of the multiplexed code symbols are redundantly provided 

on a different carrier from at least one additional base station. In a fourth embodiment, multiplexed 

symbols as transmitted on different carriers from the same base station and are redundantly 

transmitted on another set of carriers from a different base station. In a fifth embodiment, code 

symbols are multiplexed onto carriers from a plurality of base stations for increased throughput. In a 

sixth embodiment, code symbols are transmitted on carriers from a first base station and redundantly 

provided on at least one additional base station on the same carriers as used by the first base station.

See, e.g., Chen-868 at Abstract.

Case 2:23-cv-00285-JRG-RSP Document 59-11 Filed 07/11/24 Page 37 of 158 PageID #:

3123
37

Claim 9 of the ’802 Patent Prior Art Reference – Chen-868

See, e.g., Chen-868 at Figure 5.

See, e.g., Chen-868 at Figure 6.

Case 2:23-cv-00285-JRG-RSP Document 59-11 Filed 07/11/24 Page 38 of 158 PageID #:

3124
38

Claim 9 of the ’802 Patent Prior Art Reference – Chen-868

FIG. 6 is a block diagram of a receiver structure which provides for reduced hardware requirement in 

the reception of signals transmitted in accordance with the present invention.

See, e.g., Chen-868 at 3:7-10.

Referring to FIG. 3B, the data is again provided in three bands, although the present invention is 

easily extendible to an arbitrary number of bands. The first signal 160 is transmitted on a frequency 

of 850 MHz, the second signal 162 is transmitted on a frequency of 920 MHz, and the third signal is 

transmitted on a frequency of 928 MHz. In order to demodulate data transmitted on these three bands, 

the signals might first be down converted by 800 MHz and then provided to downconverters 110 a -

110 j, which would complete the downconversion to a baseband. A first downconverter 104 performs 

a downconversion of 48 MHz to provide a first low frequency signal at 2 MHz. A second 

downconverter 110 performs a downconversion of 68 MHz to provide a second low frequency signal 

at 2 MHz. A third downconverter 110 performs a downconversion of 76 MHz to provide a third low 

frequency signal at 2 MHz.

See, e.g., Chen-868 at 4:56-5:4.

FIG. 5 illustrates a frequency band allotment of two separate 5 MHz (or 3.75 MHz) bands. The first 

group of adjacent carriers is illustrated by frequency bands 250 a, 250 b and 250 c. The second group 

of adjacent carriers is illustrated by carriers 252 a, 252 b and 252 c. The receiver structure illustrated 

in FIG. 6 is capable of receiving information on the three carriers 250 a, 250 b and 250 c and 

simultaneously searching or receiving data on one of carriers 252 a, 252 b and 252 c.

To illustrate the operation and advantages of the receiver in FIG. 6, it will be assumed that the mobile 

station in which receiver 350 is located is currently receiving data on carriers 250 a, 250 b and 250 c 

and that the mobile station will search band 252 a to determine whether it is capable of receiving 

service from the system providing the signal comprising carriers 252 a, 252 b and 252 c. It will be 

understood by one skilled in the art that data for the mobile station could be provided on carriers 252 

a, 252 b or 252 c by simply changing the searching operation to a demodulation operation.

Case 2:23-cv-00285-JRG-RSP Document 59-11 Filed 07/11/24 Page 39 of 158 PageID #:

3125
39

Claim 9 of the ’802 Patent Prior Art Reference – Chen-868

Signals 250 a, 250 b, 250 c and 252 a are received at antenna 300 and provided through duplexer 302 

to low noise amplifier (LNA) 304. The amplified signal is provided to mixer 306. Mixer 306 down 

converts the signal in accordance with a signal provided by local oscillator 308 which brings the 5 

MHz band consisting of carriers 250 a, 250 b and 250 c down to a MHz wide baseband signal. The 

down converted signal is low pass filtered by filter (BPF1) 314 which is a low pass filter with a 5 

MHz pass band. The received signal is also provided to downconverter 310 which brings the signal 

carried on carrier 252 a down to base band. The down converted signal is low pass filtered by filter 

(BPF2) 316 which is a low pass filter with a 1.23 MHz pass band.

The filtered signal from filter 314 is summed with the filtered signal from filter 316 in summer 318. 

The summed signal is amplified by automatic gain control (AGC) 320. The amplified signal is 

provided to analog to digital (A/D) converter 322. The digital signals are provided to downconverters 

324 a, 324 b and filter (BPF) 328 c. Downconverters 324 a and 324 b bring the signals carried on 

carriers 250 b and 250 c down to base band. The signal carried on carriers 250 a and 252 a are 

already at baseband and is provided directly to filter 328 c. The signals 250 a and 252 a act as 

interference to one another in the demodulation process but given sufficient coding and spreading 

gain, both the signals can be demodulated. In the present context of searching, it more often than not 

be the case that no signal is found and in that case the signal degradation will be minimum.

Downconverter 324 a and downconverter 324 b are driven by local oscillators 326 a and 326 b 

respectively. The down converted signals are provided to filters 328 a and 328 b, which are low pass 

filters with a 1.228 MHz pass band. Similarly, filter 328 c is a low pass filter with a 1.228 MHz p ass 

band. The base band signals are then provided to demodulator and searcher 330 which operate as 

described with respect to demodulator and searcher 116 of FIG. 2. The signal provided through filter 

328 c can be demodulated by two demodulators, one to demodulate the signal transmitted from the 

first system (on carrier 250 a) and one to demodulate the signal transmitted by the second system (on 

carrier 252 a). In the alternative, a single demodulator can be time shared demodulating the signal 

from the first system and at certain intervals demodulating the signal transmitted from the second 

system.

Case 2:23-cv-00285-JRG-RSP Document 59-11 Filed 07/11/24 Page 40 of 158 PageID #:

3126
40

Claim 9 of the ’802 Patent Prior Art Reference – Chen-868

See, e.g., Chen-868 at 13:41-14:36.

Furthermore, this claim element is obvious in light of Chen-868 itself, when combined with any of 

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

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

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

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

First Supplemental Ex. A-Obviousness Chart.

Claim 10 of the ’802 Patent Prior Art Reference – Chen-868

[10.1] A method of 

transmitting information in a 

wireless communication 

channel comprising:

To the extent the preamble is limiting, Chen-868 discloses “A method of transmitting information in 

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

In the present invention, high speed data is provided by transmitting data on multiple carrier 

frequencies, multiple code channels and/or from multiple base stations. In a first embodiment of the 

present invention, multiplexed code symbols are transmitted on a plurality of carrier frequencies from 

the same base station. In second embodiment, code symbols are transmitted on multiple carrier 

frequencies with at least one corner frequency providing the code symbols is a multiple code 

channels. In a third embodiment, a subset of the multiplexed code symbols are redundantly provided 

on a different carrier from at least one additional base station. In a fourth embodiment, multiplexed 

symbols as transmitted on different carriers from the same base station and are redundantly 

transmitted on another set of carriers from a different base station. In a fifth embodiment, code 

symbols are multiplexed onto carriers from a plurality of base stations for increased throughput. In a 

sixth embodiment, code symbols are transmitted on carriers from a first base station and redundantly 

provided on at least one additional base station on the same carriers as used by the first base station.

See, e.g., Chen-868 at Abstract.

Case 2:23-cv-00285-JRG-RSP Document 59-11 Filed 07/11/24 Page 41 of 158 PageID #:

3127
41

Claim 10 of the ’802 Patent Prior Art Reference – Chen-868

Furthermore, this claim element is obvious in light of Chen-868 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;

Chen-868 discloses “receiving a first digital signal comprising first data to be transmitted.” See, e.g.: 

In the present invention, high speed data is provided by transmitting data on multiple carrier 

frequencies, multiple code channels and/or from multiple base stations. In a first embodiment of the 

present invention, multiplexed code symbols are transmitted on a plurality of carrier frequencies from 

the same base station. In second embodiment, code symbols are transmitted on multiple carrier 

frequencies with at least one corner frequency providing the code symbols is a mu ltiple code 

channels. In a third embodiment, a subset of the multiplexed code symbols are redundantly provided 

on a different carrier from at least one additional base station. In a fourth embodiment, multiplexed 

symbols as transmitted on different carriers from the same base station and are redundantly 

transmitted on another set of carriers from a different base station. In a fifth embodiment, code 

symbols are multiplexed onto carriers from a plurality of base stations for increased throughput. In a 

sixth embodiment, code symbols are transmitted on carriers from a first base station and redundantly 

provided on at least one additional base station on the same carriers as used by the first base station.

See, e.g., Chen-868 at Abstract.

Case 2:23-cv-00285-JRG-RSP Document 59-11 Filed 07/11/24 Page 42 of 158 PageID #:

3128
42

Claim 10 of the ’802 Patent Prior Art Reference – Chen-868

See, e.g., Chen-868 at Figure 5.

See, e.g., Chen-868 at Figure 6.

Case 2:23-cv-00285-JRG-RSP Document 59-11 Filed 07/11/24 Page 43 of 158 PageID #:

3129
43

Claim 10 of the ’802 Patent Prior Art Reference – Chen-868

FIG. 6 is a block diagram of a receiver structure which provides for reduced hardware requirement in 

the reception of signals transmitted in accordance with the present invention.

See, e.g., Chen-868 at 3:7-10.

Referring to FIG. 3B, the data is again provided in three bands, although the present invention is 

easily extendible to an arbitrary number of bands. The first signal 160 is transmitted on a frequency 

of 850 MHz, the second signal 162 is transmitted on a frequency of 920 MHz, and the third signal is 

transmitted on a frequency of 928 MHz. In order to demodulate data transmitted on these three bands, 

the signals might first be down converted by 800 MHz and then provided to downconverters 110 a110 j, which would complete the downconversion to a baseband. A first downconverter 104 performs 

a downconversion of 48 MHz to provide a first low frequency signal at 2 MHz. A second 

downconverter 110 performs a downconversion of 68 MHz to provide a second low frequency signal 

at 2 MHz. A third downconverter 110 performs a downconversion of 76 MHz to provide a third low 

frequency signal at 2 MHz.

See, e.g., Chen-868 at 4:56-5:4.

FIG. 5 illustrates a frequency band allotment of two separate 5 MHz (or 3.75 MHz) bands. The first 

group of adjacent carriers is illustrated by frequency bands 250 a, 250 b and 250 c. The second group 

of adjacent carriers is illustrated by carriers 252 a, 252 b and 252 c. The receiver structure illustrated 

in FIG. 6 is capable of receiving information on the three carriers 250 a, 250 b and 250 c and 

simultaneously searching or receiving data on one of carriers 252 a, 252 b and 252 c.

To illustrate the operation and advantages of the receiver in FIG. 6, it will be assumed that the mobile 

station in which receiver 350 is located is currently receiving data on carriers 250 a, 250 b and 250 c 

and that the mobile station will search band 252 a to determine whether it is capable of receiving 

service from the system providing the signal comprising carriers 252 a, 252 b and 252 c. It will be 

understood by one skilled in the art that data for the mobile station could be provided on carriers 252 

a, 252 b or 252 c by simply changing the searching operation to a demodulation operation.

Case 2:23-cv-00285-JRG-RSP Document 59-11 Filed 07/11/24 Page 44 of 158 PageID #:

3130
44

Claim 10 of the ’802 Patent Prior Art Reference – Chen-868

Signals 250 a, 250 b, 250 c and 252 a are received at antenna 300 and provided through duplexer 302 

to low noise amplifier (LNA) 304. The amplified signal is provided to mixer 306. Mixer 306 down 

converts the signal in accordance with a signal provided by local oscillator 308 which brings the 5 

MHz band consisting of carriers 250 a, 250 b and 250 c down to a MHz wide baseband signal. The 

down converted signal is low pass filtered by filter (BPF1) 314 which is a low pass filter with a 5 

MHz pass band. The received signal is also provided to downconverter 310 which brings the signal 

carried on carrier 252 a down to base band. The down converted signal is low pass filtered by filter 

(BPF2) 316 which is a low pass filter with a 1.23 MHz pass band.

The filtered signal from filter 314 is summed with the filtered signal from filter 316 in summer 318. 

The summed signal is amplified by automatic gain control (AGC) 320. The amplified signal is 

provided to analog to digital (A/D) converter 322. The digital signals are provided to downconverters 

324 a, 324 b and filter (BPF) 328 c. Downconverters 324 a and 324 b bring the signals carried on 

carriers 250 b and 250 c down to base band. The signal carried on carriers 250 a and 252 a are 

already at baseband and is provided directly to filter 328 c. The signals 250 a and 252 a act as 

interference to one another in the demodulation process but given sufficient coding and spreading 

gain, both the signals can be demodulated. In the present context of searching, it more often than not 

be the case that no signal is found and in that case the signal degradation will be minimum.

Downconverter 324 a and downconverter 324 b are driven by local oscillators 326 a and 326 b 

respectively. The down converted signals are provided to filters 328 a and 328 b, which are low pass 

filters with a 1.228 MHz pass band. Similarly, filter 328 c is a low pass filter with a 1.228 MHz pass 

band. The base band signals are then provided to demodulator and searcher 330 which operate as 

described with respect to demodulator and searcher 116 of FIG. 2. The signal provided through filter 

328 c can be demodulated by two demodulators, one to demodulate the signal transmitted from the 

first system (on carrier 250 a) and one to demodulate the signal transmitted by the second system (on 

carrier 252 a). In the alternative, a single demodulator can be time shared demodulating the signal 

from the first system and at certain intervals demodulating the signal transmitted from the second 

system.

Case 2:23-cv-00285-JRG-RSP Document 59-11 Filed 07/11/24 Page 45 of 158 PageID #:

3131
45

Claim 10 of the ’802 Patent Prior Art Reference – Chen-868

See, e.g., Chen-868 at 13:41-14:36.

Furthermore, this claim element is obvious in light of Chen-868 itself, when combined with any of 

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

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

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

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

First Supplemental Ex. A-Obviousness Chart.

[10.3] receiving a second 

digital signal comprising 

second data to be transmitted;

Chen-868 discloses “receiving a second digital signal comprising second data to be transmitted.” 

See, e.g.: 

In the present invention, high speed data is provided by transmitting data on multiple carrier 

frequencies, multiple code channels and/or from multiple base stations. In a first embodiment of the 

present invention, multiplexed code symbols are transmitted on a plurality of carrier frequencies from 

the same base station. In second embodiment, code symbols are transmitted on multiple carrier 

frequencies with at least one corner frequency providing the code symbols is a multiple code 

channels. In a third embodiment, a subset of the multiplexed code symbols are redundantly provided 

on a different carrier from at least one additional base station. In a fourth embodiment, multiplexed 

symbols as transmitted on different carriers from the same base station and are redundantly 

transmitted on another set of carriers from a different base station. In a fifth embodiment, code 

symbols are multiplexed onto carriers from a plurality of base stations for increased throughput. In a 

sixth embodiment, code symbols are transmitted on carriers from a first base station and redundantly 

provided on at least one additional base station on the same carriers as used by the first base station.

See, e.g., Chen-868 at Abstract.

Case 2:23-cv-00285-JRG-RSP Document 59-11 Filed 07/11/24 Page 46 of 158 PageID #:

3132
46

Claim 10 of the ’802 Patent Prior Art Reference – Chen-868

See, e.g., Chen-868 at Figure 5.

See, e.g., Chen-868 at Figure 6.

Case 2:23-cv-00285-JRG-RSP Document 59-11 Filed 07/11/24 Page 47 of 158 PageID #:

3133
47

Claim 10 of the ’802 Patent Prior Art Reference – Chen-868

FIG. 6 is a block diagram of a receiver structure which provides for reduced hardware requirement in 

the reception of signals transmitted in accordance with the present invention.

See, e.g., Chen-868 at 3:7-10.

Referring to FIG. 3B, the data is again provided in three bands, although the present invention is 

easily extendible to an arbitrary number of bands. The first signal 160 is transmitted on a frequency 

of 850 MHz, the second signal 162 is transmitted on a frequency of 920 MHz, and the third signal is 

transmitted on a frequency of 928 MHz. In order to demodulate data transmitted on these three bands, 

the signals might first be down converted by 800 MHz and then provided to downconverters 110 a -

110 j, which would complete the downconversion to a baseband. A first downconverter 104 performs 

a downconversion of 48 MHz to provide a first low frequency signal at 2 MHz. A second 

downconverter 110 performs a downconversion of 68 MHz to provide a second low frequency signal 

at 2 MHz. A third downconverter 110 performs a downconversion of 76 MHz to provide a third low 

frequency signal at 2 MHz.

See, e.g., Chen-868 at 4:56-5:4.

FIG. 5 illustrates a frequency band allotment of two separate 5 MHz (or 3.75 MHz) bands. The first 

group of adjacent carriers is illustrated by frequency bands 250 a, 250 b and 250 c. The second group 

of adjacent carriers is illustrated by carriers 252 a, 252 b and 252 c. The receiver structure illustrated 

in FIG. 6 is capable of receiving information on the three carriers 250 a, 250 b and 250 c and 

simultaneously searching or receiving data on one of carriers 252 a, 252 b and 252 c.

To illustrate the operation and advantages of the receiver in FIG. 6, it will be assumed that the mobile 

station in which receiver 350 is located is currently receiving data on carriers 250 a, 250 b and 250 c 

and that the mobile station will search band 252 a to determine whether it is capable of receiving 

service from the system providing the signal comprising carriers 252 a, 252 b and 252 c. It will be 

understood by one skilled in the art that data for the mobile station could be provided on carriers 252 

a, 252 b or 252 c by simply changing the searching operation to a demodulation operation.

Case 2:23-cv-00285-JRG-RSP Document 59-11 Filed 07/11/24 Page 48 of 158 PageID #:

3134
48

Claim 10 of the ’802 Patent Prior Art Reference – Chen-868

Signals 250 a, 250 b, 250 c and 252 a are received at antenna 300 and provided through duplexer 302 

to low noise amplifier (LNA) 304. The amplified signal is provided to mixer 306. Mixer 306 down 

converts the signal in accordance with a signal provided by local oscillator 308 which brings the 5 

MHz band consisting of carriers 250 a, 250 b and 250 c down to a MHz wide baseband signal. The 

down converted signal is low pass filtered by filter (BPF1) 314 which is a low pass filter with a 5 

MHz pass band. The received signal is also provided to downconverter 310 which brings the signal 

carried on carrier 252 a down to base band. The down converted signal is low pass filtered by filter 

(BPF2) 316 which is a low pass filter with a 1.23 MHz pass band.

The filtered signal from filter 314 is summed with the filtered signal from filter 316 in summer 318. 

The summed signal is amplified by automatic gain control (AGC) 320. The amplified signal is 

provided to analog to digital (A/D) converter 322. The digital signals are provided to downconverters 

324 a, 324 b and filter (BPF) 328 c. Downconverters 324 a and 324 b bring the signals carried on 

carriers 250 b and 250 c down to base band. The signal carried on carriers 250 a and 252 a are 

already at baseband and is provided directly to filter 328 c. The signals 250 a and 252 a act as 

interference to one another in the demodulation process but given sufficient coding and spreading 

gain, both the signals can be demodulated. In the present context of searching, it more often than not 

be the case that no signal is found and in that case the signal degradation will be minimum.

Downconverter 324 a and downconverter 324 b are driven by local oscillators 326 a and 326 b 

respectively. The down converted signals are provided to filters 328 a and 328 b, which are low pass 

filters with a 1.228 MHz pass band. Similarly, filter 328 c is a low pass filter with a 1.228 MHz pass 

band. The base band signals are then provided to demodulator and searcher 330 which operate as 

described with respect to demodulator and searcher 116 of FIG. 2. The signal provided through filter 

328 c can be demodulated by two demodulators, one to demodulate the signal transmitted from the 

first system (on carrier 250 a) and one to demodulate the signal transmitted by the second system (on 

carrier 252 a). In the alternative, a single demodulator can be time shared demodulating the signal 

from the first system and at certain intervals demodulating the signal transmitted from the second 

system.

Case 2:23-cv-00285-JRG-RSP Document 59-11 Filed 07/11/24 Page 49 of 158 PageID #:

3135
49

Claim 10 of the ’802 Patent Prior Art Reference – Chen-868

See, e.g., Chen-868 at 13:41-14:36.

Furthermore, this claim element is obvious in light of Chen-868 itself, when combined with any of 

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

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

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

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

First Supplemental Ex. A-Obviousness Chart.

[10.4] converting the first 

digital signal into a first 

analog signal using a first 

digital-to-analog converter, 

the first analog signal carrying 

the first data across a first 

frequency range;.

Chen-868 discloses “converting the first digital signal into a first analog signal using a first digital-toanalog converter, the first analog signal carrying the first data across a first frequency range .” See, 

e.g.: 

In the present invention, high speed data is provided by transmitting data on multiple carrier 

frequencies, multiple code channels and/or from multiple base stations. In a first embodiment of the 

present invention, multiplexed code symbols are transmitted on a plurality of carrier frequencies from 

the same base station. In second embodiment, code symbols are transmitted on multiple carrier 

frequencies with at least one corner frequency providing the code symbols is a multiple code 

channels. In a third embodiment, a subset of the multiplexed code symbols are redundantly provided 

on a different carrier from at least one additional base station. In a fourth embodiment, multiplexed 

symbols as transmitted on different carriers from the same base station and are redundantly 

transmitted on another set of carriers from a different base station. In a fifth embodiment, code 

symbols are multiplexed onto carriers from a plurality of base stations for increased throughput. In a 

sixth embodiment, code symbols are transmitted on carriers from a first base station and redundantly 

provided on at least one additional base station on the same carriers as used by the first base station.

See, e.g., Chen-868 at Abstract.

Case 2:23-cv-00285-JRG-RSP Document 59-11 Filed 07/11/24 Page 50 of 158 PageID #:

3136
50

Claim 10 of the ’802 Patent Prior Art Reference – Chen-868

See, e.g., Chen-868 at Figure 5.

See, e.g., Chen-868 at Figure 6.

Case 2:23-cv-00285-JRG-RSP Document 59-11 Filed 07/11/24 Page 51 of 158 PageID #:

3137
51

Claim 10 of the ’802 Patent Prior Art Reference – Chen-868

FIG. 6 is a block diagram of a receiver structure which provides for reduced hardware requirement in 

the reception of signals transmitted in accordance with the present invention.

See, e.g., Chen-868 at 3:7-10.

Referring to FIG. 3B, the data is again provided in three bands, although the present invention is 

easily extendible to an arbitrary number of bands. The first signal 160 is transmitted on a frequency 

of 850 MHz, the second signal 162 is transmitted on a frequency of 920 MHz, and the third signal is 

transmitted on a frequency of 928 MHz. In order to demodulate data transmitted on these three bands, 

the signals might first be down converted by 800 MHz and then provided to downconverters 110 a -

110 j, which would complete the downconversion to a baseband. A first downconverter 104 performs 

a downconversion of 48 MHz to provide a first low frequency signal at 2 MHz. A second 

downconverter 110 performs a downconversion of 68 MHz to provide a second low frequency signal 

at 2 MHz. A third downconverter 110 performs a downconversion of 76 MHz to provide a third low 

frequency signal at 2 MHz.

See, e.g., Chen-868 at 4:56-5:4.

FIG. 5 illustrates a frequency band allotment of two separate 5 MHz (or 3.75 MHz) bands. The first 

group of adjacent carriers is illustrated by frequency bands 250 a, 250 b and 250 c. The second group 

of adjacent carriers is illustrated by carriers 252 a, 252 b and 252 c. The receiver structure illustrated 

in FIG. 6 is capable of receiving information on the three carriers 250 a, 250 b and 250 c and 

simultaneously searching or receiving data on one of carriers 252 a, 252 b and 252 c.

To illustrate the operation and advantages of the receiver in FIG. 6, it will be assumed that the mobile 

station in which receiver 350 is located is currently receiving data on carriers 250 a, 250 b and 250 c 

and that the mobile station will search band 252 a to determine whether it is capable of receiving 

service from the system providing the signal comprising carriers 252 a, 252 b and 252 c. It will be 

understood by one skilled in the art that data for the mobile station could be provided on carriers 252 

a, 252 b or 252 c by simply changing the searching operation to a demodulation operation.

Case 2:23-cv-00285-JRG-RSP Document 59-11 Filed 07/11/24 Page 52 of 158 PageID #:

3138
52

Claim 10 of the ’802 Patent Prior Art Reference – Chen-868

Signals 250 a, 250 b, 250 c and 252 a are received at antenna 300 and provided through duplexer 302 

to low noise amplifier (LNA) 304. The amplified signal is provided to mixer 306. Mixer 306 down 

converts the signal in accordance with a signal provided by local oscillator 308 which brings the 5 

MHz band consisting of carriers 250 a, 250 b and 250 c down to a MHz wide baseband signal. The 

down converted signal is low pass filtered by filter (BPF1) 314 which is a low pass filter with a 5 

MHz pass band. The received signal is also provided to downconverter 310 which brings the signal 

carried on carrier 252 a down to base band. The down converted signal is low pass filtered by filter 

(BPF2) 316 which is a low pass filter with a 1.23 MHz pass band.

The filtered signal from filter 314 is summed with the filtered signal from filter 316 in summer 318. 

The summed signal is amplified by automatic gain control (AGC) 320. The amplified signal is 

provided to analog to digital (A/D) converter 322. The digital signals are provided to downconverters 

324 a, 324 b and filter (BPF) 328 c. Downconverters 324 a and 324 b bring the signals carried on 

carriers 250 b and 250 c down to base band. The signal carried on carriers 250 a and 252 a are 

already at baseband and is provided directly to filter 328 c. The signals 250 a and 252 a act as 

interference to one another in the demodulation process but given sufficient coding and spreading 

gain, both the signals can be demodulated. In the present context of searching, it more often than not 

be the case that no signal is found and in that case the signal degradation will be minimum.

Downconverter 324 a and downconverter 324 b are driven by local oscillators 326 a and 326 b 

respectively. The down converted signals are provided to filters 328 a and 328 b, which are low pass 

filters with a 1.228 MHz pass band. Similarly, filter 328 c is a low pass filter with a 1.228 MHz pass 

band. The base band signals are then provided to demodulator and searcher 330 which operate as 

described with respect to demodulator and searcher 116 of FIG. 2. The signal provided through filter 

328 c can be demodulated by two demodulators, one to demodulate the signal transmitted from the 

first system (on carrier 250 a) and one to demodulate the signal transmitted by the second system (on 

carrier 252 a). In the alternative, a single demodulator can be time shared demodulating the signal 

from the first system and at certain intervals demodulating the signal transmitted from the second 

system.

Case 2:23-cv-00285-JRG-RSP Document 59-11 Filed 07/11/24 Page 53 of 158 PageID #:

3139
53

Claim 10 of the ’802 Patent Prior Art Reference – Chen-868

See, e.g., Chen-868 at 13:41-14:36.

Furthermore, this claim element is obvious in light of Chen-868 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.

[10.5] 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;

Chen-868 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.: 

In the present invention, high speed data is provided by transmitting data on multiple carrier 

frequencies, multiple code channels and/or from multiple base stations. In a first embodiment of the 

present invention, multiplexed code symbols are transmitted on a plurality of carrier frequencies from 

the same base station. In second embodiment, code symbols are transmitted on multiple carrier 

frequencies with at least one corner frequency providing the code symbols is a multiple code 

channels. In a third embodiment, a subset of the multiplexed code symbols are redundantly provided 

on a different carrier from at least one additional base station. In a fourth embodiment, multiplexed 

symbols as transmitted on different carriers from the same base station and are redundantly 

transmitted on another set of carriers from a different base station. In a fifth embodiment, code 

symbols are multiplexed onto carriers from a plurality of base stations for increased throughput. In a 

sixth embodiment, code symbols are transmitted on carriers from a first base station and redundantly 

provided on at least one additional base station on the same carriers as used by the first base station.

See, e.g., Chen-868 at Abstract.

Case 2:23-cv-00285-JRG-RSP Document 59-11 Filed 07/11/24 Page 54 of 158 PageID #:

3140
54

Claim 10 of the ’802 Patent Prior Art Reference – Chen-868

See, e.g., Chen-868 at Figure 5.

See, e.g., Chen-868 at Figure 6.

Case 2:23-cv-00285-JRG-RSP Document 59-11 Filed 07/11/24 Page 55 of 158 PageID #:

3141
55

Claim 10 of the ’802 Patent Prior Art Reference – Chen-868

FIG. 6 is a block diagram of a receiver structure which provides for reduced hardware requirement in 

the reception of signals transmitted in accordance with the present invention.

See, e.g., Chen-868 at 3:7-10.

Referring to FIG. 3B, the data is again provided in three bands, although the present invention is 

easily extendible to an arbitrary number of bands. The first signal 160 is transmitted on a frequency 

of 850 MHz, the second signal 162 is transmitted on a frequency of 920 MHz, and the third signal is 

transmitted on a frequency of 928 MHz. In order to demodulate data transmitted on these three bands, 

the signals might first be down converted by 800 MHz and then provided to downconverters 110 a -

110 j, which would complete the downconversion to a baseband. A first downconverter 104 performs 

a downconversion of 48 MHz to provide a first low frequency signal at 2 MHz. A second 

downconverter 110 performs a downconversion of 68 MHz to provide a second low frequency signal 

at 2 MHz. A third downconverter 110 performs a downconversion of 76 MHz to provide a third low 

frequency signal at 2 MHz.

See, e.g., Chen-868 at 4:56-5:4.

FIG. 5 illustrates a frequency band allotment of two separate 5 MHz (or 3.75 MHz) bands. The first 

group of adjacent carriers is illustrated by frequency bands 250 a, 250 b and 250 c. The second group 

of adjacent carriers is illustrated by carriers 252 a, 252 b and 252 c. The receiver structure illustrated 

in FIG. 6 is capable of receiving information on the three carriers 250 a, 250 b and 250 c and 

simultaneously searching or receiving data on one of carriers 252 a, 252 b and 252 c.

To illustrate the operation and advantages of the receiver in FIG. 6, it will be assumed that the mobile 

station in which receiver 350 is located is currently receiving data on carriers 250 a, 250 b and 250 c 

and that the mobile station will search band 252 a to determine whether it is capable of receiving 

service from the system providing the signal comprising carriers 252 a, 252 b and 252 c. It will be 

understood by one skilled in the art that data for the mobile station could be provided on carriers 252 

a, 252 b or 252 c by simply changing the searching operation to a demodulation operation.

Case 2:23-cv-00285-JRG-RSP Document 59-11 Filed 07/11/24 Page 56 of 158 PageID #:

3142
56

Claim 10 of the ’802 Patent Prior Art Reference – Chen-868

Signals 250 a, 250 b, 250 c and 252 a are received at antenna 300 and provided through duplexer 302 

to low noise amplifier (LNA) 304. The amplified signal is provided to mixer 306. Mixer 306 down 

converts the signal in accordance with a signal provided by local oscillator 308 which brings the 5 

MHz band consisting of carriers 250 a, 250 b and 250 c down to a MHz wide baseband signal. The 

down converted signal is low pass filtered by filter (BPF1) 314 which is a low pass filter with a 5 

MHz pass band. The received signal is also provided to downconverter 310 which brings the signal 

carried on carrier 252 a down to base band. The down converted signal is low pass filtered by filter 

(BPF2) 316 which is a low pass filter with a 1.23 MHz pass band.

The filtered signal from filter 314 is summed with the filtered signal from filter 316 in summer 318. 

The summed signal is amplified by automatic gain control (AGC) 320. The amplified signal is 

provided to analog to digital (A/D) converter 322. The digital signals are provided to downconverters 

324 a, 324 b and filter (BPF) 328 c. Downconverters 324 a and 324 b bring the signals carried on 

carriers 250 b and 250 c down to base band. The signal carried on carriers 250 a and 252 a are 

already at baseband and is provided directly to filter 328 c. The signals 250 a and 252 a act as 

interference to one another in the demodulation process but given sufficient coding and spreading 

gain, both the signals can be demodulated. In the present context of searching, it more often than not 

be the case that no signal is found and in that case the signal degradation will be minimum.

Downconverter 324 a and downconverter 324 b are driven by local oscillators 326 a and 326 b 

respectively. The down converted signals are provided to filters 328 a and 328 b, which are low pass 

filters with a 1.228 MHz pass band. Similarly, filter 328 c is a low pass filter with a 1.228 MHz pass 

band. The base band signals are then provided to demodulator and searcher 330 which operate as 

described with respect to demodulator and searcher 116 of FIG. 2. The signal provided through filter 

328 c can be demodulated by two demodulators, one to demodulate the signal transmitted from the 

first system (on carrier 250 a) and one to demodulate the signal transmitted by the second system (on 

carrier 252 a). In the alternative, a single demodulator can be time shared demodulating the signal 

from the first system and at certain intervals demodulating the signal transmitted from the second 

system.

Case 2:23-cv-00285-JRG-RSP Document 59-11 Filed 07/11/24 Page 57 of 158 PageID #:

3143
57

Claim 10 of the ’802 Patent Prior Art Reference – Chen-868

See, e.g., Chen-868 at 13:41-14:36.

Furthermore, this claim element is obvious in light of Chen-868 itself, when combined with any of 

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

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

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

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

First Supplemental Ex. A-Obviousness Chart.

[10.6] up-converting the first 

analog signal to a first RF 

center frequency to produce a 

first up-converted analog 

signal, wherein the first upconverted analog signal 

comprises a first up-converted 

frequency range from the first 

RF center frequency minus 

one-half the first frequency 

range to the first RF center 

frequency plus one-half the 

first frequency range;

Chen-868 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.: 

In the present invention, high speed data is provided by transmitting data on multiple carrier 

frequencies, multiple code channels and/or from multiple base stations. In a first embodiment of the 

present invention, multiplexed code symbols are transmitted on a plurality of carrier frequencies from 

the same base station. In second embodiment, code symbols are transmitted on multiple carrier 

frequencies with at least one corner frequency providing the code symbols is a multiple code 

channels. In a third embodiment, a subset of the multiplexed code symbols are redundantly provided 

on a different carrier from at least one additional base station. In a fourth embodiment, multiplexed 

symbols as transmitted on different carriers from the same base station and are redundantly 

transmitted on another set of carriers from a different base station. In a fifth embodiment, code 

symbols are multiplexed onto carriers from a plurality of base stations for increased throughput. In a 

sixth embodiment, code symbols are transmitted on carriers from a first base station and redundantly 

provided on at least one additional base station on the same carriers as used by the first base station.

See, e.g., Chen-868 at Abstract.

Case 2:23-cv-00285-JRG-RSP Document 59-11 Filed 07/11/24 Page 58 of 158 PageID #:

3144
58

Claim 10 of the ’802 Patent Prior Art Reference – Chen-868

See, e.g., Chen-868 at Figure 5.

See, e.g., Chen-868 at Figure 6.

Case 2:23-cv-00285-JRG-RSP Document 59-11 Filed 07/11/24 Page 59 of 158 PageID #:

3145
59

Claim 10 of the ’802 Patent Prior Art Reference – Chen-868

FIG. 6 is a block diagram of a receiver structure which provides for reduced hardware requirement in 

the reception of signals transmitted in accordance with the present invention.

See, e.g., Chen-868 at 3:7-10.

Referring to FIG. 3B, the data is again provided in three bands, although the present invention is 

easily extendible to an arbitrary number of bands. The first signal 160 is transmitted on a frequency 

of 850 MHz, the second signal 162 is transmitted on a frequency of 920 MHz, and the third signal is 

transmitted on a frequency of 928 MHz. In order to demodulate data transmitted on these three bands, 

the signals might first be down converted by 800 MHz and then provided to downconverters 110 a110 j, which would complete the downconversion to a baseband. A first downconverter 104 performs 

a downconversion of 48 MHz to provide a first low frequency signal at 2 MHz. A second 

downconverter 110 performs a downconversion of 68 MHz to provide a second low frequency signal 

at 2 MHz. A third downconverter 110 performs a downconversion of 76 MHz to provide a third low 

frequency signal at 2 MHz.

See, e.g., Chen-868 at 4:56-5:4.

FIG. 5 illustrates a frequency band allotment of two separate 5 MHz (or 3.75 MHz) bands. The first 

group of adjacent carriers is illustrated by frequency bands 250 a, 250 b and 250 c. The second group 

of adjacent carriers is illustrated by carriers 252 a, 252 b and 252 c. The receiver structure illustrated 

in FIG. 6 is capable of receiving information on the three carriers 250 a, 250 b and 250 c and 

simultaneously searching or receiving data on one of carriers 252 a, 252 b and 252 c.

To illustrate the operation and advantages of the receiver in FIG. 6, it will be assumed that the mobile 

station in which receiver 350 is located is currently receiving data on carriers 250 a, 250 b and 250 c 

and that the mobile station will search band 252 a to determine whether it is capable of receiving 

service from the system providing the signal comprising carriers 252 a, 252 b and 252 c. It will be 

understood by one skilled in the art that data for the mobile station could be provided on carriers 252 

a, 252 b or 252 c by simply changing the searching operation to a demodulation operation.

Case 2:23-cv-00285-JRG-RSP Document 59-11 Filed 07/11/24 Page 60 of 158 PageID #:

3146
60

Claim 10 of the ’802 Patent Prior Art Reference – Chen-868

Signals 250 a, 250 b, 250 c and 252 a are received at antenna 300 and provided through duplexer 302 

to low noise amplifier (LNA) 304. The amplified signal is provided to mixer 306. Mixer 306 down 

converts the signal in accordance with a signal provided by local oscillator 308 which brings the 5 

MHz band consisting of carriers 250 a, 250 b and 250 c down to a MHz wide baseband signal. The 

down converted signal is low pass filtered by filter (BPF1) 314 which is a low pass filter with a 5 

MHz pass band. The received signal is also provided to downconverter 310 which brings the signal 

carried on carrier 252 a down to base band. The down converted signal is low pass filtered by filter 

(BPF2) 316 which is a low pass filter with a 1.23 MHz pass band.

The filtered signal from filter 314 is summed with the filtered signal from filter 316 in summer 318. 

The summed signal is amplified by automatic gain control (AGC) 320. The amplified signal is 

provided to analog to digital (A/D) converter 322. The digital signals are provided to downconverters 

324 a, 324 b and filter (BPF) 328 c. Downconverters 324 a and 324 b bring the signals carried on 

carriers 250 b and 250 c down to base band. The signal carried on carriers 250 a and 252 a are 

already at baseband and is provided directly to filter 328 c. The signals 250 a and 252 a act as 

interference to one another in the demodulation process but given sufficient coding and spreading 

gain, both the signals can be demodulated. In the present context of searching, it more often than not 

be the case that no signal is found and in that case the signal degradation will be minimum.

Downconverter 324 a and downconverter 324 b are driven by local oscillators 326 a and 326 b 

respectively. The down converted signals are provided to filters 328 a and 328 b, which are low pass 

filters with a 1.228 MHz pass band. Similarly, filter 328 c is a low pass filter with a 1.228 MHz pass 

band. The base band signals are then provided to demodulator and searcher 330 which oper ate as 

described with respect to demodulator and searcher 116 of FIG. 2. The signal provided through filter 

328 c can be demodulated by two demodulators, one to demodulate the signal transmitted from the 

first system (on carrier 250 a) and one to demodulate the signal transmitted by the second system (on 

carrier 252 a). In the alternative, a single demodulator can be time shared demodulating the signal 

from the first system and at certain intervals demodulating the signal transmitted from the second 

system.

Case 2:23-cv-00285-JRG-RSP Document 59-11 Filed 07/11/24 Page 61 of 158 PageID #:

3147
61

Claim 10 of the ’802 Patent Prior Art Reference – Chen-868

See, e.g., Chen-868 at 13:41-14:36.

Furthermore, this claim element is obvious in light of Chen-868 itself, when combined with any of 

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

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

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

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

First Supplemental Ex. A-Obviousness Chart.

[10.7] 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 oneChen-868 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.: 

In the present invention, high speed data is provided by transmitting data on multiple carrier 

frequencies, multiple code channels and/or from multiple base stations. In a first embodiment of the 

present invention, multiplexed code symbols are transmitted on a plurality of carrier frequencies from 

the same base station. In second embodiment, code symbols are transmitted on multiple carrier 

frequencies with at least one corner frequency providing the code symbols is a multiple code 

channels. In a third embodiment, a subset of the multiplexed code symbols are redundantly provided 

on a different carrier from at least one additional base station. In a fourth embodiment, multiplexed 

symbols as transmitted on different carriers from the same base station and are redundantly 

transmitted on another set of carriers from a different base station. In a fifth embodiment, cod e 

symbols are multiplexed onto carriers from a plurality of base stations for increased throughput. In a 

sixth embodiment, code symbols are transmitted on carriers from a first base station and redundantly 

provided on at least one additional base station on the same carriers as used by the first base station.

See, e.g., Chen-868 at Abstract.

Case 2:23-cv-00285-JRG-RSP Document 59-11 Filed 07/11/24 Page 62 of 158 PageID #:

3148
62

Claim 10 of the ’802 Patent Prior Art Reference – Chen-868

half the second frequency 

range;

See, e.g., Chen-868 at Figure 5.

Case 2:23-cv-00285-JRG-RSP Document 59-11 Filed 07/11/24 Page 63 of 158 PageID #:

3149
63

Claim 10 of the ’802 Patent Prior Art Reference – Chen-868

See, e.g., Chen-868 at Figure 6.

FIG. 6 is a block diagram of a receiver structure which provides for reduced hardware requirement in 

the reception of signals transmitted in accordance with the present invention.

See, e.g., Chen-868 at 3:7-10.

Referring to FIG. 3B, the data is again provided in three bands, although the present invention is 

easily extendible to an arbitrary number of bands. The first signal 160 is transmitted on a frequency 

of 850 MHz, the second signal 162 is transmitted on a frequency of 920 MHz, and the third signal is 

transmitted on a frequency of 928 MHz. In order to demodulate data transmitted on these three bands, 

the signals might first be down converted by 800 MHz and then provided to downconverters 110 a -

110 j, which would complete the downconversion to a baseband. A first downconverter 104 performs 

a downconversion of 48 MHz to provide a first low frequency signal at 2 MHz. A second 

downconverter 110 performs a downconversion of 68 MHz to provide a second low frequency signal 

at 2 MHz. A third downconverter 110 performs a downconversion of 76 MHz to provide a third low 

frequency signal at 2 MHz.

See, e.g., Chen-868 at 4:56-5:4.

FIG. 5 illustrates a frequency band allotment of two separate 5 MHz (or 3.75 MHz) bands. The first 

group of adjacent carriers is illustrated by frequency bands 250 a, 250 b and 250 c. The second group 

of adjacent carriers is illustrated by carriers 252 a, 252 b and 252 c. The receiver structure illustrated 

in FIG. 6 is capable of receiving information on the three carriers 250 a, 250 b and 250 c and 

simultaneously searching or receiving data on one of carriers 252 a, 252 b and 252 c.

To illustrate the operation and advantages of the receiver in FIG. 6, it will be assumed that the mobile 

station in which receiver 350 is located is currently receiving data on carriers 250 a, 250 b and 250 c 

and that the mobile station will search band 252 a to determine whether it is capable of receiving 

service from the system providing the signal comprising carriers 252 a, 252 b and 252 c. It will be 

Case 2:23-cv-00285-JRG-RSP Document 59-11 Filed 07/11/24 Page 64 of 158 PageID #:

3150
64

Claim 10 of the ’802 Patent Prior Art Reference – Chen-868

understood by one skilled in the art that data for the mobile station could be provided on carriers 252 

a, 252 b or 252 c by simply changing the searching operation to a demodulation operation.

Signals 250 a, 250 b, 250 c and 252 a are received at antenna 300 and provided through duplexer 302 

to low noise amplifier (LNA) 304. The amplified signal is provided to mixer 306. Mixer 306 down 

converts the signal in accordance with a signal provided by local oscillator 308 which brings the 5 

MHz band consisting of carriers 250 a, 250 b and 250 c down to a MHz wide baseband signal. The 

down converted signal is low pass filtered by filter (BPF1) 314 which is a low pass filter with a 5 

MHz pass band. The received signal is also provided to downconverter 310 which brings the signal 

carried on carrier 252 a down to base band. The down converted signal is low pass filtered by filter 

(BPF2) 316 which is a low pass filter with a 1.23 MHz pass band.

The filtered signal from filter 314 is summed with the filtered signal from filter 316 in summer 318. 

The summed signal is amplified by automatic gain control (AGC) 320. The amplified signal is 

provided to analog to digital (A/D) converter 322. The digital signals are provided to downconverters 

324 a, 324 b and filter (BPF) 328 c. Downconverters 324 a and 324 b bring the signals carried on 

carriers 250 b and 250 c down to base band. The signal carried on carriers 250 a and 252 a are 

already at baseband and is provided directly to filter 328 c. The signals 250 a and 252 a act as 

interference to one another in the demodulation process but given sufficient coding and spreading 

gain, both the signals can be demodulated. In the present context of searching, it more often than not 

be the case that no signal is found and in that case the signal degradation will be minimum.

Downconverter 324 a and downconverter 324 b are driven by local oscillators 326 a and 326 b 

respectively. The down converted signals are provided to filters 328 a and 328 b, which are low pass 

filters with a 1.228 MHz pass band. Similarly, filter 328 c is a low pass filter with a 1.228 MHz pass 

band. The base band signals are then provided to demodulator and searcher 330 which operate as 

described with respect to demodulator and searcher 116 of FIG. 2. The signal provided through filter 

328 c can be demodulated by two demodulators, one to demodulate the signal transmitted from the 

first system (on carrier 250 a) and one to demodulate the signal transmitted by the second system (on 

carrier 252 a). In the alternative, a single demodulator can be time shared demodulating the signal 

Case 2:23-cv-00285-JRG-RSP Document 59-11 Filed 07/11/24 Page 65 of 158 PageID #:

3151
65

Claim 10 of the ’802 Patent Prior Art Reference – Chen-868

from the first system and at certain intervals demodulating the signal transmitted from the second 

system.

See, e.g., Chen-868 at 13:41-14:36.

Furthermore, this claim element is obvious in light of Chen-868 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.

[10.8] combining the first upconverted analog signal and 

the second up-converted 

analog signal to produce a 

combined up-converted 

signal;

Chen-868 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.: 

In the present invention, high speed data is provided by transmitting data on multiple carrier 

frequencies, multiple code channels and/or from multiple base stations. In a first embodiment of the 

present invention, multiplexed code symbols are transmitted on a plurality of carrier frequencies from 

the same base station. In second embodiment, code symbols are transmitted on multiple carrier 

frequencies with at least one corner frequency providing the code symbols is a multiple code 

channels. In a third embodiment, a subset of the multiplexed code symbols are redundantly provided 

on a different carrier from at least one additional base station. In a fourth embodiment, multiplexed 

symbols as transmitted on different carriers from the same base station and are redundantly 

transmitted on another set of carriers from a different base station. In a fifth embodiment, code 

symbols are multiplexed onto carriers from a plurality of base stations for increased throughput. In a 

sixth embodiment, code symbols are transmitted on carriers from a first base station and redundantly 

provided on at least one additional base station on the same carriers as used by the first base station.

See, e.g., Chen-868 at Abstract.

Case 2:23-cv-00285-JRG-RSP Document 59-11 Filed 07/11/24 Page 66 of 158 PageID #:

3152
66

Claim 10 of the ’802 Patent Prior Art Reference – Chen-868

See, e.g., Chen-868 at Figure 5.

See, e.g., Chen-868 at Figure 6.

Case 2:23-cv-00285-JRG-RSP Document 59-11 Filed 07/11/24 Page 67 of 158 PageID #:

3153
67

Claim 10 of the ’802 Patent Prior Art Reference – Chen-868

FIG. 6 is a block diagram of a receiver structure which provides for reduced hardware requirement in 

the reception of signals transmitted in accordance with the present invention.

See, e.g., Chen-868 at 3:7-10.

Referring to FIG. 3B, the data is again provided in three bands, although the present invention is 

easily extendible to an arbitrary number of bands. The first signal 160 is transmitted on a frequency 

of 850 MHz, the second signal 162 is transmitted on a frequency of 920 MHz, and the third signal is 

transmitted on a frequency of 928 MHz. In order to demodulate data transmitted on these three bands, 

the signals might first be down converted by 800 MHz and then provided to downconverters 110 a -

110 j, which would complete the downconversion to a baseband. A first downconverter 104 performs 

a downconversion of 48 MHz to provide a first low frequency signal at 2 MHz. A second 

downconverter 110 performs a downconversion of 68 MHz to provide a second low frequency signal 

at 2 MHz. A third downconverter 110 performs a downconversion of 76 MHz to provide a third low 

frequency signal at 2 MHz.

See, e.g., Chen-868 at 4:56-5:4.

FIG. 5 illustrates a frequency band allotment of two separate 5 MHz (or 3.75 MHz) bands. The first 

group of adjacent carriers is illustrated by frequency bands 250 a, 250 b and 250 c. The second group 

of adjacent carriers is illustrated by carriers 252 a, 252 b and 252 c. The receiver structure illustrated 

in FIG. 6 is capable of receiving information on the three carriers 250 a, 250 b and 250 c and 

simultaneously searching or receiving data on one of carriers 252 a, 252 b and 252 c.

To illustrate the operation and advantages of the receiver in FIG. 6, it will be assumed that the mobile

station in which receiver 350 is located is currently receiving data on carriers 250 a, 250 b and 250 c 

and that the mobile station will search band 252 a to determine whether it is capable of receiving 

service from the system providing the signal comprising carriers 252 a, 252 b and 252 c. It will be 

understood by one skilled in the art that data for the mobile station could be provided on carriers 252 

a, 252 b or 252 c by simply changing the searching operation to a demodulation operation.

Case 2:23-cv-00285-JRG-RSP Document 59-11 Filed 07/11/24 Page 68 of 158 PageID #:

3154
68

Claim 10 of the ’802 Patent Prior Art Reference – Chen-868

Signals 250 a, 250 b, 250 c and 252 a are received at antenna 300 and provided through duplexer 302 

to low noise amplifier (LNA) 304. The amplified signal is provided to mixer 306. Mixer 306 down 

converts the signal in accordance with a signal provided by local oscillator 308 which brings the 5 

MHz band consisting of carriers 250 a, 250 b and 250 c down to a MHz wide baseband signal. The 

down converted signal is low pass filtered by filter (BPF1) 314 which is a low pass filter with a 5 

MHz pass band. The received signal is also provided to downconverter 310 which brings the signal 

carried on carrier 252 a down to base band. The down converted signal is low pass filtered by filter 

(BPF2) 316 which is a low pass filter with a 1.23 MHz pass band.

The filtered signal from filter 314 is summed with the filtered signal from filter 316 in summer 318. 

The summed signal is amplified by automatic gain control (AGC) 320. The amplified signal is 

provided to analog to digital (A/D) converter 322. The digital signals are provided to downconverters 

324 a, 324 b and filter (BPF) 328 c. Downconverters 324 a and 324 b bring the signals carried on 

carriers 250 b and 250 c down to base band. The signal carried on carriers 250 a and 252 a are 

already at baseband and is provided directly to filter 328 c. The signals 250 a and 252 a act as 

interference to one another in the demodulation process but given sufficient coding and spreading 

gain, both the signals can be demodulated. In the present context of searching, it more often than not 

be the case that no signal is found and in that case the signal degradation will be minimum.

Downconverter 324 a and downconverter 324 b are driven by local oscillators 326 a and 326 b 

respectively. The down converted signals are provided to filters 328 a and 328 b, which are low pass 

filters with a 1.228 MHz pass band. Similarly, filter 328 c is a low pass filter with a 1.228 MHz pass 

band. The base band signals are then provided to demodulator and searcher 330 which operate as 

described with respect to demodulator and searcher 116 of FIG. 2. The signal provided through filter 

328 c can be demodulated by two demodulators, one to demodulate the signal transmitted from the 

first system (on carrier 250 a) and one to demodulate the signal transmitted by the second system (on 

carrier 252 a). In the alternative, a single demodulator can be time shared demodulating the signal 

from the first system and at certain intervals demodulating the signal transmitted from the second 

system.

Case 2:23-cv-00285-JRG-RSP Document 59-11 Filed 07/11/24 Page 69 of 158 PageID #:

3155
69

Claim 10 of the ’802 Patent Prior Art Reference – Chen-868

See, e.g., Chen-868 at 13:41-14:36.

Furthermore, this claim element is obvious in light of Chen-868 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.

[10.9] amplifying the 

combined up-converted signal 

in a power amplifier resulting 

in an amplified combined upconverted signal; and

Chen-868 discloses “amplifying the combined up-converted signal in a power amplifier resulting in 

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

In the present invention, high speed data is provided by transmitting data on multiple carrier 

frequencies, multiple code channels and/or from multiple base stations. In a first embodiment of the 

present invention, multiplexed code symbols are transmitted on a plurality of carrier frequencies from 

the same base station. In second embodiment, code symbols are transmitted on multiple carrier 

frequencies with at least one corner frequency providing the code symbols is a multiple code 

channels. In a third embodiment, a subset of the multiplexed code symbols are redundantly provided 

on a different carrier from at least one additional base station. In a fourth embodiment, multiplexed 

symbols as transmitted on different carriers from the same base station and are redundantly 

transmitted on another set of carriers from a different base station. In a fifth embodiment, code 

symbols are multiplexed onto carriers from a plurality of base stations for increased throughput. In a 

sixth embodiment, code symbols are transmitted on carriers from a first base station and redundantly 

provided on at least one additional base station on the same carriers as used by the first base station.

See, e.g., Chen-868 at Abstract.

Case 2:23-cv-00285-JRG-RSP Document 59-11 Filed 07/11/24 Page 70 of 158 PageID #:

3156
70

Claim 10 of the ’802 Patent Prior Art Reference – Chen-868

See, e.g., Chen-868 at Figure 5.

See, e.g., Chen-868 at Figure 6.

Case 2:23-cv-00285-JRG-RSP Document 59-11 Filed 07/11/24 Page 71 of 158 PageID #:

3157
71

Claim 10 of the ’802 Patent Prior Art Reference – Chen-868

FIG. 6 is a block diagram of a receiver structure which provides for reduced hardware requirement in 

the reception of signals transmitted in accordance with the present invention.

See, e.g., Chen-868 at 3:7-10.

Referring to FIG. 3B, the data is again provided in three bands, although the present invention is 

easily extendible to an arbitrary number of bands. The first signal 160 is transmitted on a frequency 

of 850 MHz, the second signal 162 is transmitted on a frequency of 920 MHz, and the third signal is 

transmitted on a frequency of 928 MHz. In order to demodulate data transmitted on these three bands, 

the signals might first be down converted by 800 MHz and then provided to downconverters 110 a -

110 j, which would complete the downconversion to a baseband. A first downconverter 104 performs 

a downconversion of 48 MHz to provide a first low frequency signal at 2 MHz. A second 

downconverter 110 performs a downconversion of 68 MHz to provide a second low frequency signal 

at 2 MHz. A third downconverter 110 performs a downconversion of 76 MHz to provide a third low 

frequency signal at 2 MHz.

See, e.g., Chen-868 at 4:56-5:4.

FIG. 5 illustrates a frequency band allotment of two separate 5 MHz (or 3.75 MHz) bands. The first 

group of adjacent carriers is illustrated by frequency bands 250 a, 250 b and 250 c. The second group 

of adjacent carriers is illustrated by carriers 252 a, 252 b and 252 c. The receiver structure illustrated 

in FIG. 6 is capable of receiving information on the three carriers 250 a, 250 b and 250 c and 

simultaneously searching or receiving data on one of carriers 252 a, 252 b and 252 c.

To illustrate the operation and advantages of the receiver in FIG. 6, it will be assumed that the mobile 

station in which receiver 350 is located is currently receiving data on carriers 250 a, 250 b and 250 c 

and that the mobile station will search band 252 a to determine whether it is capable of receiving 

service from the system providing the signal comprising carriers 252 a, 252 b and 252 c. It will be 

understood by one skilled in the art that data for the mobile station could be provided on carriers 252 

a, 252 b or 252 c by simply changing the searching operation to a demodulation operation.

Case 2:23-cv-00285-JRG-RSP Document 59-11 Filed 07/11/24 Page 72 of 158 PageID #:

3158
72

Claim 10 of the ’802 Patent Prior Art Reference – Chen-868

Signals 250 a, 250 b, 250 c and 252 a are received at antenna 300 and provided through duplexer 302 

to low noise amplifier (LNA) 304. The amplified signal is provided to mixer 306. Mix er 306 down 

converts the signal in accordance with a signal provided by local oscillator 308 which brings the 5 

MHz band consisting of carriers 250 a, 250 b and 250 c down to a MHz wide baseband signal. The 

down converted signal is low pass filtered by filter (BPF1) 314 which is a low pass filter with a 5 

MHz pass band. The received signal is also provided to downconverter 310 which brings the signal 

carried on carrier 252 a down to base band. The down converted signal is low pass filtered by filter 

(BPF2) 316 which is a low pass filter with a 1.23 MHz pass band.

The filtered signal from filter 314 is summed with the filtered signal from filter 316 in summer 318. 

The summed signal is amplified by automatic gain control (AGC) 320. The amplified signal is 

provided to analog to digital (A/D) converter 322. The digital signals are provided to downconverters 

324 a, 324 b and filter (BPF) 328 c. Downconverters 324 a and 324 b bring the signals carried on 

carriers 250 b and 250 c down to base band. The signal carried on carriers 250 a and 252 a are 

already at baseband and is provided directly to filter 328 c. The signals 250 a and 252 a act as 

interference to one another in the demodulation process but given sufficient coding and spreading 

gain, both the signals can be demodulated. In the present context of searching, it more often than not 

be the case that no signal is found and in that case the signal degradation will be minimum.

Downconverter 324 a and downconverter 324 b are driven by local oscillators 326 a and 326 b 

respectively. The down converted signals are provided to filters 328 a and 328 b, which are low pass 

filters with a 1.228 MHz pass band. Similarly, filter 328 c is a low pass filter with a 1.228 MHz pass 

band. The base band signals are then provided to demodulator and searcher 330 which operate as 

described with respect to demodulator and searcher 116 of FIG. 2. The signal provided through filter 

328 c can be demodulated by two demodulators, one to demodulate the signal transmitted from the 

first system (on carrier 250 a) and one to demodulate the signal transmitted by the second system (on 

carrier 252 a). In the alternative, a single demodulator can be time shared demodulating the signal 

from the first system and at certain intervals demodulating the signal transmitted from the second 

system.

Case 2:23-cv-00285-JRG-RSP Document 59-11 Filed 07/11/24 Page 73 of 158 PageID #:

3159
73

Claim 10 of the ’802 Patent Prior Art Reference – Chen-868

See, e.g., Chen-868 at 13:41-14:36.

Furthermore, this claim element is obvious in light of Chen-868 itself, when combined with any of 

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

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

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

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

First Supplemental Ex. A-Obviousness Chart.

[10.10] transmitting the 

amplified combined upconverted signal on a first 

antenna,

Chen-868 discloses “transmitting the amplified combined up-converted signal on a first antenna.” 

See, e.g.: 

In the present invention, high speed data is provided by transmitting data on multiple carrier 

frequencies, multiple code channels and/or from multiple base stations. In a first embodiment of the 

present invention, multiplexed code symbols are transmitted on a plurality of carrier frequencies from 

the same base station. In second embodiment, code symbols are transmitted on multiple carrier 

frequencies with at least one corner frequency providing the code symbols is a multiple code 

channels. In a third embodiment, a subset of the multiplexed code symbols are redundantly provided 

on a different carrier from at least one additional base station. In a fourth embodiment, multiplexed 

symbols as transmitted on different carriers from the same base station and are redundantly 

transmitted on another set of carriers from a different base station. In a fifth embodiment, code 

symbols are multiplexed onto carriers from a plurality of base stations for increased throughput. In a 

sixth embodiment, code symbols are transmitted on carriers from a first base station and redundantly 

provided on at least one additional base station on the same carriers as used by the first base station.

See, e.g., Chen-868 at Abstract.

Case 2:23-cv-00285-JRG-RSP Document 59-11 Filed 07/11/24 Page 74 of 158 PageID #:

3160
74

Claim 10 of the ’802 Patent Prior Art Reference – Chen-868

See, e.g., Chen-868 at Figure 5.

See, e.g., Chen-868 at Figure 6.

Case 2:23-cv-00285-JRG-RSP Document 59-11 Filed 07/11/24 Page 75 of 158 PageID #:

3161
75

Claim 10 of the ’802 Patent Prior Art Reference – Chen-868

FIG. 6 is a block diagram of a receiver structure which provides for reduced hardware requirement in 

the reception of signals transmitted in accordance with the present invention.

See, e.g., Chen-868 at 3:7-10.

Referring to FIG. 3B, the data is again provided in three bands, although the present invention is 

easily extendible to an arbitrary number of bands. The first signal 160 is transmitted on a frequency 

of 850 MHz, the second signal 162 is transmitted on a frequency of 920 MHz, and the third signal is 

transmitted on a frequency of 928 MHz. In order to demodulate data transmitted on these three bands, 

the signals might first be down converted by 800 MHz and then provided to downconverters 110 a -

110 j, which would complete the downconversion to a baseband. A first downconverter 104 performs 

a downconversion of 48 MHz to provide a first low frequency signal at 2 MHz. A second 

downconverter 110 performs a downconversion of 68 MHz to provide a second low frequency signal 

at 2 MHz. A third downconverter 110 performs a downconversion of 76 MHz to provide a third low 

frequency signal at 2 MHz.

See, e.g., Chen-868 at 4:56-5:4.

FIG. 5 illustrates a frequency band allotment of two separate 5 MHz (or 3.75 MHz) bands. The first 

group of adjacent carriers is illustrated by frequency bands 250 a, 250 b and 250 c. The second group 

of adjacent carriers is illustrated by carriers 252 a, 252 b and 252 c. The receiver structure illustrated 

in FIG. 6 is capable of receiving information on the three carriers 250 a, 250 b and 250 c and 

simultaneously searching or receiving data on one of carriers 252 a, 252 b and 252 c.

To illustrate the operation and advantages of the receiver in FIG. 6, it will be assumed that the mobile 

station in which receiver 350 is located is currently receiving data on carriers 250 a, 250 b and 250 c 

and that the mobile station will search band 252 a to determine whether it is capable of receiving 

service from the system providing the signal comprising carriers 252 a, 252 b and 252 c. It will be 

understood by one skilled in the art that data for the mobile station could be provided on carriers 252 

a, 252 b or 252 c by simply changing the searching operation to a demodulation operation.

Case 2:23-cv-00285-JRG-RSP Document 59-11 Filed 07/11/24 Page 76 of 158 PageID #:

3162
76

Claim 10 of the ’802 Patent Prior Art Reference – Chen-868

Signals 250 a, 250 b, 250 c and 252 a are received at antenna 300 and provided through duplexer 302 

to low noise amplifier (LNA) 304. The amplified signal is provided to mixer 306. Mixer 306 down 

converts the signal in accordance with a signal provided by local oscillator 308 which brings the 5 

MHz band consisting of carriers 250 a, 250 b and 250 c down to a MHz wide baseband signal. The 

down converted signal is low pass filtered by filter (BPF1) 314 which is a low pass filter with a 5 

MHz pass band. The received signal is also provided to downconverter 310 which brings the signal 

carried on carrier 252 a down to base band. The down converted signal is low pass filtered by filter 

(BPF2) 316 which is a low pass filter with a 1.23 MHz pass band.

The filtered signal from filter 314 is summed with the filtered signal from filter 316 in summer 318. 

The summed signal is amplified by automatic gain control (AGC) 320. The amplified signal is 

provided to analog to digital (A/D) converter 322. The digital signals are provided to downconverters 

324 a, 324 b and filter (BPF) 328 c. Downconverters 324 a and 324 b bring the signals carried on 

carriers 250 b and 250 c down to base band. The signal carried on carriers 250 a and 252 a are 

already at baseband and is provided directly to filter 328 c. The signals 250 a and 252 a act as 

interference to one another in the demodulation process but given sufficient coding and spreading 

gain, both the signals can be demodulated. In the present context of searching, it more often than not 

be the case that no signal is found and in that case the signal degradation will be minimum.

Downconverter 324 a and downconverter 324 b are driven by local oscillators 326 a and 326 b 

respectively. The down converted signals are provided to filters 328 a and 328 b, which are low pass 

filters with a 1.228 MHz pass band. Similarly, filter 328 c is a low pass filter with a 1.228 MHz pass 

band. The base band signals are then provided to demodulator and searcher 330 which operate as 

described with respect to demodulator and searcher 116 of FIG. 2. The signal provided through filter 

328 c can be demodulated by two demodulators, one to demodulate the signal transmitted from the 

first system (on carrier 250 a) and one to demodulate the signal transmitted by the second system (on 

carrier 252 a). In the alternative, a single demodulator can be time shared demodulating the signal 

from the first system and at certain intervals demodulating the signal transmitted from the second 

system.

Case 2:23-cv-00285-JRG-RSP Document 59-11 Filed 07/11/24 Page 77 of 158 PageID #:

3163
77

Claim 10 of the ’802 Patent Prior Art Reference – Chen-868

See, e.g., Chen-868 at 13:41-14:36.

Furthermore, this claim element is obvious in light of Chen-868 itself, when combined with any of 

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

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

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

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

First Supplemental Ex. A-Obviousness Chart.

[10.11] 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.

Chen-868 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.: 

In the present invention, high speed data is provided by transmitting data on multiple carrier 

frequencies, multiple code channels and/or from multiple base stations. In a first embodiment of the 

present invention, multiplexed code symbols are transmitted on a plurality of carrier frequencies from 

the same base station. In second embodiment, code symbols are transmitted on multiple carrier 

frequencies with at least one corner frequency providing the code symbols is a multiple code 

channels. In a third embodiment, a subset of the multiplexed code symbols are redundantly provided 

on a different carrier from at least one additional base station. In a fourth embodiment, multiplexed 

symbols as transmitted on different carriers from the same base station and are redundantly 

transmitted on another set of carriers from a different base station. In a fifth embodiment, code 

symbols are multiplexed onto carriers from a plurality of base stations for increased throughput. In a 

sixth embodiment, code symbols are transmitted on carriers from a first base station and redundantly 

provided on at least one additional base station on the same carriers as used by the first base station .

See, e.g., Chen-868 at Abstract.

Case 2:23-cv-00285-JRG-RSP Document 59-11 Filed 07/11/24 Page 78 of 158 PageID #:

3164
78

Claim 10 of the ’802 Patent Prior Art Reference – Chen-868

See, e.g., Chen-868 at Figure 5.

See, e.g., Chen-868 at Figure 6.

Case 2:23-cv-00285-JRG-RSP Document 59-11 Filed 07/11/24 Page 79 of 158 PageID #:

3165
79

Claim 10 of the ’802 Patent Prior Art Reference – Chen-868

FIG. 6 is a block diagram of a receiver structure which provides for reduced hardware requirement in 

the reception of signals transmitted in accordance with the present invention.

See, e.g., Chen-868 at 3:7-10.

Referring to FIG. 3B, the data is again provided in three bands, although the present invention is 

easily extendible to an arbitrary number of bands. The first signal 160 is transmitted on a frequency 

of 850 MHz, the second signal 162 is transmitted on a frequency of 920 MHz, and the third signal is 

transmitted on a frequency of 928 MHz. In order to demodulate data transmitted on these three bands, 

the signals might first be down converted by 800 MHz and then provided to downconverters 110 a110 j, which would complete the downconversion to a baseband. A first downconverter 104 performs 

a downconversion of 48 MHz to provide a first low frequency signal at 2 MHz. A second 

downconverter 110 performs a downconversion of 68 MHz to provide a second low frequency signal 

at 2 MHz. A third downconverter 110 performs a downconversion of 76 MHz to provide a third low 

frequency signal at 2 MHz.

See, e.g., Chen-868 at 4:56-5:4.

FIG. 5 illustrates a frequency band allotment of two separate 5 MHz (or 3.75 MHz) bands. The first 

group of adjacent carriers is illustrated by frequency bands 250 a, 250 b and 250 c. The second group 

of adjacent carriers is illustrated by carriers 252 a, 252 b and 252 c. The receiver structure illustrated 

in FIG. 6 is capable of receiving information on the three carriers 250 a, 250 b and 250 c and 

simultaneously searching or receiving data on one of carriers 252 a, 252 b and 252 c.

To illustrate the operation and advantages of the receiver in FIG. 6, it will be assumed that the mobile 

station in which receiver 350 is located is currently receiving data on carriers 250 a, 250 b and 250 c 

and that the mobile station will search band 252 a to determine whether it is capable of receiving 

service from the system providing the signal comprising carriers 252 a, 252 b and 252 c. It will be 

understood by one skilled in the art that data for the mobile station could be provided on carriers 252 

a, 252 b or 252 c by simply changing the searching operation to a demodulation operation.

Case 2:23-cv-00285-JRG-RSP Document 59-11 Filed 07/11/24 Page 80 of 158 PageID #:

3166
80

Claim 10 of the ’802 Patent Prior Art Reference – Chen-868

Signals 250 a, 250 b, 250 c and 252 a are received at antenna 300 and provided through duplexer 302 

to low noise amplifier (LNA) 304. The amplified signal is provided to mixer 306. Mixer 306 d own 

converts the signal in accordance with a signal provided by local oscillator 308 which brings the 5 

MHz band consisting of carriers 250 a, 250 b and 250 c down to a MHz wide baseband signal. The 

down converted signal is low pass filtered by filter (BPF1) 314 which is a low pass filter with a 5 

MHz pass band. The received signal is also provided to downconverter 310 which brings the signal 

carried on carrier 252 a down to base band. The down converted signal is low pass filtered by filter 

(BPF2) 316 which is a low pass filter with a 1.23 MHz pass band.

The filtered signal from filter 314 is summed with the filtered signal from filter 316 in summer 318. 

The summed signal is amplified by automatic gain control (AGC) 320. The amplified signal is 

provided to analog to digital (A/D) converter 322. The digital signals are provided to downconverters 

324 a, 324 b and filter (BPF) 328 c. Downconverters 324 a and 324 b bring the signals carried on 

carriers 250 b and 250 c down to base band. The signal carried on carriers 250 a and 252 a are 

already at baseband and is provided directly to filter 328 c. The signals 250 a and 252 a act as 

interference to one another in the demodulation process but given sufficient coding and spreading 

gain, both the signals can be demodulated. In the present context of searching, it more often than not 

be the case that no signal is found and in that case the signal degradation will be minimum.

Downconverter 324 a and downconverter 324 b are driven by local oscillators 326 a and 326 b 

respectively. The down converted signals are provided to filters 328 a and 328 b, which are low pass 

filters with a 1.228 MHz pass band. Similarly, filter 328 c is a low pass filter with a 1.228 MHz pass 

band. The base band signals are then provided to demodulator and searcher 330 which operate as 

described with respect to demodulator and searcher 116 of FIG. 2. The signal provided through filter 

328 c can be demodulated by two demodulators, one to demodulate the signal transmitted from the 

first system (on carrier 250 a) and one to demodulate the signal transmitted by the second system (on 

carrier 252 a). In the alternative, a single demodulator can be time shared demodulating the signal 

from the first system and at certain intervals demodulating the signal transmitted from the second 

system.

Case 2:23-cv-00285-JRG-RSP Document 59-11 Filed 07/11/24 Page 81 of 158 PageID #:

3167
81

Claim 10 of the ’802 Patent Prior Art Reference – Chen-868

See, e.g., Chen-868 at 13:41-14:36.

Furthermore, this claim element is obvious in light of Chen-868 itself, when combined with any of 

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

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

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

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

First Supplemental Ex. A-Obviousness Chart.

Claim 13 of the ’802 Patent Prior Art Reference – Chen-868

[13.1] The method of claim 10 Chen-868 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.

Chen-868 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.: 

In the present invention, high speed data is provided by transmitting data on multiple carrier 

frequencies, multiple code channels and/or from multiple base stations. In a first embodiment of the 

present invention, multiplexed code symbols are transmitted on a plurality of carrier frequencies from 

the same base station. In second embodiment, code symbols are transmitted on multiple carrier 

frequencies with at least one corner frequency providing the code symbols is a multiple code 

channels. In a third embodiment, a subset of the multiplexed code symbols are redundantly provided 

on a different carrier from at least one additional base station. In a fourth embodiment, multiplexed 

symbols as transmitted on different carriers from the same base station and are redundantly 

transmitted on another set of carriers from a different base station. In a fifth embodiment, code 

symbols are multiplexed onto carriers from a plurality of base stations for increased throughput. In a 

sixth embodiment, code symbols are transmitted on carriers from a first base station and redundantly 

provided on at least one additional base station on the same carriers as used by the first base station.

See, e.g., Chen-868 at Abstract.

Case 2:23-cv-00285-JRG-RSP Document 59-11 Filed 07/11/24 Page 82 of 158 PageID #:

3168
82

Claim 13 of the ’802 Patent Prior Art Reference – Chen-868

See, e.g., Chen-868 at Figure 5.

Case 2:23-cv-00285-JRG-RSP Document 59-11 Filed 07/11/24 Page 83 of 158 PageID #:

3169
83

Claim 13 of the ’802 Patent Prior Art Reference – Chen-868

See, e.g., Chen-868 at Figure 6.

FIG. 6 is a block diagram of a receiver structure which provides for reduced hardware requirement in 

the reception of signals transmitted in accordance with the present invention.

See, e.g., Chen-868 at 3:7-10.

Referring to FIG. 3B, the data is again provided in three bands, although the present invention is 

easily extendible to an arbitrary number of bands. The first signal 160 is transmitted on a frequency 

of 850 MHz, the second signal 162 is transmitted on a frequency of 920 MHz, and the third signal is 

transmitted on a frequency of 928 MHz. In order to demodulate data transmitted on these three bands, 

the signals might first be down converted by 800 MHz and then provided to downconverters 110 a -

110 j, which would complete the downconversion to a baseband. A first downconverter 104 performs 

a downconversion of 48 MHz to provide a first low frequency signal at 2 MHz. A second 

downconverter 110 performs a downconversion of 68 MHz to provide a second low frequency signal 

at 2 MHz. A third downconverter 110 performs a downconversion of 76 MHz to provide a third low 

frequency signal at 2 MHz.

See, e.g., Chen-868 at 4:56-5:4.

FIG. 5 illustrates a frequency band allotment of two separate 5 MHz (or 3.75 MHz) bands. The first 

group of adjacent carriers is illustrated by frequency bands 250 a, 250 b and 250 c. The second group 

of adjacent carriers is illustrated by carriers 252 a, 252 b and 252 c. The receiver structure illustrated 

in FIG. 6 is capable of receiving information on the three carriers 250 a, 250 b and 250 c and 

simultaneously searching or receiving data on one of carriers 252 a, 252 b and 252 c.

To illustrate the operation and advantages of the receiver in FIG. 6, it will be assumed that the mobile 

station in which receiver 350 is located is currently receiving data on carriers 250 a, 250 b and 250 c 

and that the mobile station will search band 252 a to determine whether it is capable of receiving 

service from the system providing the signal comprising carriers 252 a, 252 b and 252 c. It will be 

Case 2:23-cv-00285-JRG-RSP Document 59-11 Filed 07/11/24 Page 84 of 158 PageID #:

3170
84

Claim 13 of the ’802 Patent Prior Art Reference – Chen-868

understood by one skilled in the art that data for the mobile station could be provided on carriers 252 

a, 252 b or 252 c by simply changing the searching operation to a demodulation operation.

Signals 250 a, 250 b, 250 c and 252 a are received at antenna 300 and provided through duplexer 302 

to low noise amplifier (LNA) 304. The amplified signal is provided to mixer 306. Mixer 306 down 

converts the signal in accordance with a signal provided by local oscillator 308 which brings the 5 

MHz band consisting of carriers 250 a, 250 b and 250 c down to a MHz wide baseband signal. The 

down converted signal is low pass filtered by filter (BPF1) 314 which is a low pass filter with a 5 

MHz pass band. The received signal is also provided to downconverter 310 which brings the signal 

carried on carrier 252 a down to base band. The down converted signal is low pass filtered by filter 

(BPF2) 316 which is a low pass filter with a 1.23 MHz pass band.

The filtered signal from filter 314 is summed with the filtered signal from filter 316 in summer 318. 

The summed signal is amplified by automatic gain control (AGC) 320. The amplified signal is 

provided to analog to digital (A/D) converter 322. The digital signals are provided to downconverters 

324 a, 324 b and filter (BPF) 328 c. Downconverters 324 a and 324 b bring the signals carried on 

carriers 250 b and 250 c down to base band. The signal carried on carriers 250 a and 252 a are 

already at baseband and is provided directly to filter 328 c. The signals 250 a and 252 a act as 

interference to one another in the demodulation process but given sufficient coding and spreading 

gain, both the signals can be demodulated. In the present context of searching, it more often than not 

be the case that no signal is found and in that case the signal degradation will be minimum.

Downconverter 324 a and downconverter 324 b are driven by local oscillators 326 a and 326 b 

respectively. The down converted signals are provided to filters 328 a and 328 b, which are low pass 

filters with a 1.228 MHz pass band. Similarly, filter 328 c is a low pass filter with a 1.228 MHz p ass 

band. The base band signals are then provided to demodulator and searcher 330 which operate as 

described with respect to demodulator and searcher 116 of FIG. 2. The signal provided through filter 

328 c can be demodulated by two demodulators, one to demodulate the signal transmitted from the 

first system (on carrier 250 a) and one to demodulate the signal transmitted by the second system (on 

carrier 252 a). In the alternative, a single demodulator can be time shared demodulating the signal 

Case 2:23-cv-00285-JRG-RSP Document 59-11 Filed 07/11/24 Page 85 of 158 PageID #:

3171
85

Claim 13 of the ’802 Patent Prior Art Reference – Chen-868

from the first system and at certain intervals demodulating the signal transmitted from the second 

system.

See, e.g., Chen-868 at 13:41-14:36.

Furthermore, this claim element is obvious in light of Chen-868 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 14 of the ’802 Patent Prior Art Reference – Chen-868

[14.1] The method of claim 10 Chen-868 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:

Chen-868 discloses “wherein the second data is the same as the first data, the method further 

comprising.” See, e.g.: 

In the present invention, high speed data is provided by transmitting data on multiple carrier 

frequencies, multiple code channels and/or from multiple base stations. In a first embodiment of the 

present invention, multiplexed code symbols are transmitted on a plurality of carrier frequencies from 

the same base station. In second embodiment, code symbols are transmitted on multiple carrier 

frequencies with at least one corner frequency providing the code symbols is a multiple code 

channels. In a third embodiment, a subset of the multiplexed code symbols are redundantly provided 

on a different carrier from at least one additional base station. In a fourth embodiment, multiplexed 

symbols as transmitted on different carriers from the same base station and are redundantly 

transmitted on another set of carriers from a different base station. In a fifth embodiment, code 

symbols are multiplexed onto carriers from a plurality of base stations for increased throughput. In a 

Case 2:23-cv-00285-JRG-RSP Document 59-11 Filed 07/11/24 Page 86 of 158 PageID #:

3172
86

Claim 14 of the ’802 Patent Prior Art Reference – Chen-868

sixth embodiment, code symbols are transmitted on carriers from a first base station and redundantly 

provided on at least one additional base station on the same carriers as used by the first base station.

See, e.g., Chen-868 at Abstract.

See, e.g., Chen-868 at Figure 5.

Case 2:23-cv-00285-JRG-RSP Document 59-11 Filed 07/11/24 Page 87 of 158 PageID #:

3173
87

Claim 14 of the ’802 Patent Prior Art Reference – Chen-868

See, e.g., Chen-868 at Figure 6.

FIG. 6 is a block diagram of a receiver structure which provides for reduced hardware requirement in 

the reception of signals transmitted in accordance with the present invention.

See, e.g., Chen-868 at 3:7-10.

Referring to FIG. 3B, the data is again provided in three bands, although the present invention is 

easily extendible to an arbitrary number of bands. The first signal 160 is transmitted on a frequency 

of 850 MHz, the second signal 162 is transmitted on a frequency of 920 MHz, and the third signal is 

transmitted on a frequency of 928 MHz. In order to demodulate data transmitted on these three bands, 

the signals might first be down converted by 800 MHz and then provided to downconverters 110 a110 j, which would complete the downconversion to a baseband. A first downconverter 104 performs 

Case 2:23-cv-00285-JRG-RSP Document 59-11 Filed 07/11/24 Page 88 of 158 PageID #:

3174
88

Claim 14 of the ’802 Patent Prior Art Reference – Chen-868

a downconversion of 48 MHz to provide a first low frequency signal at 2 MHz. A second 

downconverter 110 performs a downconversion of 68 MHz to provide a second low frequency signal 

at 2 MHz. A third downconverter 110 performs a downconversion of 76 MHz to provide a third low 

frequency signal at 2 MHz.

See, e.g., Chen-868 at 4:56-5:4.

FIG. 5 illustrates a frequency band allotment of two separate 5 MHz (or 3.75 MHz) bands. The first 

group of adjacent carriers is illustrated by frequency bands 250 a, 250 b and 250 c. The second group 

of adjacent carriers is illustrated by carriers 252 a, 252 b and 252 c. The receiver structure illustrated 

in FIG. 6 is capable of receiving information on the three carriers 250 a, 250 b and 250 c and 

simultaneously searching or receiving data on one of carriers 252 a, 252 b and 252 c.

To illustrate the operation and advantages of the receiver in FIG. 6, it will be assumed that the mobile 

station in which receiver 350 is located is currently receiving data on carriers 250 a, 250 b and 250 c 

and that the mobile station will search band 252 a to determine whether it is capable of receiving 

service from the system providing the signal comprising carriers 252 a, 252 b and 252 c. It will be 

understood by one skilled in the art that data for the mobile station could be provided on carriers 252 

a, 252 b or 252 c by simply changing the searching operation to a demodulation operation.

Signals 250 a, 250 b, 250 c and 252 a are received at antenna 300 and provided through duplexer 302 

to low noise amplifier (LNA) 304. The amplified signal is provided to mixer 306. Mixer 306 down 

converts the signal in accordance with a signal provided by local oscillator 308 which brings the 5 

MHz band consisting of carriers 250 a, 250 b and 250 c down to a MHz wide baseband signal. The 

down converted signal is low pass filtered by filter (BPF1) 314 which is a low pass filter with a 5 

MHz pass band. The received signal is also provided to downconverter 310 which brings the signal 

carried on carrier 252 a down to base band. The down converted signal is low pass filtered by filter 

(BPF2) 316 which is a low pass filter with a 1.23 MHz pass band.

The filtered signal from filter 314 is summed with the filtered signal from filter 316 in summer 318. 

The summed signal is amplified by automatic gain control (AGC) 320. The amplified signal is 

Case 2:23-cv-00285-JRG-RSP Document 59-11 Filed 07/11/24 Page 89 of 158 PageID #:

3175
89

Claim 14 of the ’802 Patent Prior Art Reference – Chen-868

provided to analog to digital (A/D) converter 322. The digital signals are provided to downconverters 

324 a, 324 b and filter (BPF) 328 c. Downconverters 324 a and 324 b bring the signals carried on 

carriers 250 b and 250 c down to base band. The signal carried on carriers 250 a and 252 a are 

already at baseband and is provided directly to filter 328 c. The signals 250 a and 252 a act as 

interference to one another in the demodulation process but given sufficient coding and spreading 

gain, both the signals can be demodulated. In the present context of searching, it more often than not 

be the case that no signal is found and in that case the signal degradation will be minimum.

Downconverter 324 a and downconverter 324 b are driven by local oscillators 326 a and 326 b 

respectively. The down converted signals are provided to filters 328 a and 328 b, which are low pass 

filters with a 1.228 MHz pass band. Similarly, filter 328 c is a low pass filter with a 1.228 MHz pass 

band. The base band signals are then provided to demodulator and searcher 330 which operate as 

described with respect to demodulator and searcher 116 of FIG. 2. The signal provided through filter 

328 c can be demodulated by two demodulators, one to demodulate the signal transmitted from the 

first system (on carrier 250 a) and one to demodulate the signal transmitted by the second system (on 

carrier 252 a). In the alternative, a single demodulator can be time shared demodulating the signal 

from the first system and at certain intervals demodulating the signal transmitted from the second 

system.

See, e.g., Chen-868 at 13:41-14:36.

Furthermore, this claim element is obvious in light of Chen-868 itself, when combined with any of 

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

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

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

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

First Supplemental Ex. A-Obviousness Chart.

[14.3] receiving the 

transmitted signal on a second 

antenna;

Chen-868 discloses “receiving the transmitted signal on a second antenna.” See, e.g.: 

Case 2:23-cv-00285-JRG-RSP Document 59-11 Filed 07/11/24 Page 90 of 158 PageID #:

3176
90

Claim 14 of the ’802 Patent Prior Art Reference – Chen-868

In the present invention, high speed data is provided by transmitting data on multiple carrier 

frequencies, multiple code channels and/or from multiple base stations. In a first embodiment of the 

present invention, multiplexed code symbols are transmitted on a plurality of carrier frequencies from 

the same base station. In second embodiment, code symbols are transmitted on multiple carrier 

frequencies with at least one corner frequency providing the code symbols is a multiple code 

channels. In a third embodiment, a subset of the multiplexed code symbols are redundantly provided 

on a different carrier from at least one additional base station. In a fourth embodiment, multiplexed 

symbols as transmitted on different carriers from the same base station and are redundantly 

transmitted on another set of carriers from a different base station. In a fifth embodiment, code 

symbols are multiplexed onto carriers from a plurality of base stations for increased throughput. In a 

sixth embodiment, code symbols are transmitted on carriers from a first base station and redundantly 

provided on at least one additional base station on the same carriers as used by the first base station.

See, e.g., Chen-868 at Abstract.

See, e.g., Chen-868 at Figure 5.

Case 2:23-cv-00285-JRG-RSP Document 59-11 Filed 07/11/24 Page 91 of 158 PageID #:

3177
91

Claim 14 of the ’802 Patent Prior Art Reference – Chen-868

See, e.g., Chen-868 at Figure 6.

FIG. 6 is a block diagram of a receiver structure which provides for reduced hardware requirement in 

the reception of signals transmitted in accordance with the present invention.

See, e.g., Chen-868 at 3:7-10.

Referring to FIG. 3B, the data is again provided in three bands, although the present invention is 

easily extendible to an arbitrary number of bands. The first signal 160 is transmitted on a frequency 

of 850 MHz, the second signal 162 is transmitted on a frequency of 920 MHz, and the third signal is 

transmitted on a frequency of 928 MHz. In order to demodulate data transmitted on these three bands, 

the signals might first be down converted by 800 MHz and then provided to downconverters 110 a -

110 j, which would complete the downconversion to a baseband. A first downconverter 104 performs 

Case 2:23-cv-00285-JRG-RSP Document 59-11 Filed 07/11/24 Page 92 of 158 PageID #:

3178
92

Claim 14 of the ’802 Patent Prior Art Reference – Chen-868

a downconversion of 48 MHz to provide a first low frequency signal at 2 MHz. A second 

downconverter 110 performs a downconversion of 68 MHz to provide a second low frequency signal 

at 2 MHz. A third downconverter 110 performs a downconversion of 76 MHz to provide a third low 

frequency signal at 2 MHz.

See, e.g., Chen-868 at 4:56-5:4.

FIG. 5 illustrates a frequency band allotment of two separate 5 MHz (or 3.75 MHz) bands. The first 

group of adjacent carriers is illustrated by frequency bands 250 a, 250 b and 250 c. The second group 

of adjacent carriers is illustrated by carriers 252 a, 252 b and 252 c. The receiver structure illustrated 

in FIG. 6 is capable of receiving information on the three carriers 250 a, 250 b and 250 c and 

simultaneously searching or receiving data on one of carriers 252 a, 252 b and 252 c.

To illustrate the operation and advantages of the receiver in FIG. 6, it will be assumed that the mobile 

station in which receiver 350 is located is currently receiving data on carriers 250 a, 250 b and 250 c 

and that the mobile station will search band 252 a to determine whether it is capable of receiving 

service from the system providing the signal comprising carriers 252 a, 252 b and 252 c. It will be

understood by one skilled in the art that data for the mobile station could be provided on carriers 252 

a, 252 b or 252 c by simply changing the searching operation to a demodulation operation.

Signals 250 a, 250 b, 250 c and 252 a are received at antenna 300 and provided through duplexer 302 

to low noise amplifier (LNA) 304. The amplified signal is provided to mixer 306. Mixer 306 down 

converts the signal in accordance with a signal provided by local oscillator 308 which brings the 5 

MHz band consisting of carriers 250 a, 250 b and 250 c down to a MHz wide baseband signal. The 

down converted signal is low pass filtered by filter (BPF1) 314 which is a low pass filter with a 5 

MHz pass band. The received signal is also provided to downconverter 310 which brings the signal 

carried on carrier 252 a down to base band. The down converted signal is low pass filtered by filter 

(BPF2) 316 which is a low pass filter with a 1.23 MHz pass band.

The filtered signal from filter 314 is summed with the filtered signal from filter 316 in summer 318. 

The summed signal is amplified by automatic gain control (AGC) 320. The amplified signal is 

Case 2:23-cv-00285-JRG-RSP Document 59-11 Filed 07/11/24 Page 93 of 158 PageID #:

3179
93

Claim 14 of the ’802 Patent Prior Art Reference – Chen-868

provided to analog to digital (A/D) converter 322. The digital signals are provided to downconverters 

324 a, 324 b and filter (BPF) 328 c. Downconverters 324 a and 324 b bring the signals carried on 

carriers 250 b and 250 c down to base band. The signal carried on carriers 250 a and 252 a are 

already at baseband and is provided directly to filter 328 c. The signals 250 a and 252 a act as 

interference to one another in the demodulation process but given sufficient coding and spreading 

gain, both the signals can be demodulated. In the present context of searching, it more often than not 

be the case that no signal is found and in that case the signal degradation will be minimum.

Downconverter 324 a and downconverter 324 b are driven by local oscillators 326 a and 326 b 

respectively. The down converted signals are provided to filters 328 a and 328 b, which are low pass 

filters with a 1.228 MHz pass band. Similarly, filter 328 c is a low pass filter with a 1.228 MHz pass 

band. The base band signals are then provided to demodulator and searcher 330 which operate as 

described with respect to demodulator and searcher 116 of FIG. 2. The signal provided through filter 

328 c can be demodulated by two demodulators, one to demodulate the signal transmitted from the 

first system (on carrier 250 a) and one to demodulate the signal transmitted by the second system (on 

carrier 252 a). In the alternative, a single demodulator can be time shared demodulating the signal 

from the first system and at certain intervals demodulating the signal transmitted from the second 

system.

See, e.g., Chen-868 at 13:41-14:36.

Furthermore, this claim element is obvious in light of Chen-868 itself, when combined with any of 

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

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

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

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

First Supplemental Ex. A-Obviousness Chart.

[14.4] amplifying the received 

signal in a low noise amplifier 

resulting in an amplified 

Chen-868 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 

Case 2:23-cv-00285-JRG-RSP Document 59-11 Filed 07/11/24 Page 94 of 158 PageID #:

3180
94

Claim 14 of the ’802 Patent Prior Art Reference – Chen-868

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;

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.: 

In the present invention, high speed data is provided by transmitting data on multiple carrier 

frequencies, multiple code channels and/or from multiple base stations. In a first embodiment of the 

present invention, multiplexed code symbols are transmitted on a plurality of carrier frequencies from 

the same base station. In second embodiment, code symbols are transmitted on multiple carrier 

frequencies with at least one corner frequency providing the code symbols is a multiple code 

channels. In a third embodiment, a subset of the multiplexed code symbols are redundantly provided 

on a different carrier from at least one additional base station. In a fourth embodiment, multiplexed 

symbols as transmitted on different carriers from the same base station and are redundantly 

transmitted on another set of carriers from a different base station. In a fifth embodiment, code 

symbols are multiplexed onto carriers from a plurality of base stations for increased throughput. In a 

sixth embodiment, code symbols are transmitted on carriers from a first base station and redundantly 

provided on at least one additional base station on the same carriers as used by the first base station.

See, e.g., Chen-868 at Abstract.

See, e.g., Chen-868 at Figure 5.

Case 2:23-cv-00285-JRG-RSP Document 59-11 Filed 07/11/24 Page 95 of 158 PageID #:

3181
95

Claim 14 of the ’802 Patent Prior Art Reference – Chen-868

See, e.g., Chen-868 at Figure 6.

FIG. 6 is a block diagram of a receiver structure which provides for reduced hardware requirement in 

the reception of signals transmitted in accordance with the present invention.

See, e.g., Chen-868 at 3:7-10.

Referring to FIG. 3B, the data is again provided in three bands, although the present invention is 

easily extendible to an arbitrary number of bands. The first signal 160 is transmitted on a frequency 

of 850 MHz, the second signal 162 is transmitted on a frequency of 920 MHz, and the third signal is 

transmitted on a frequency of 928 MHz. In order to demodulate data transmitted on these three bands, 

the signals might first be down converted by 800 MHz and then provided to downconverters 110 a110 j, which would complete the downconversion to a baseband. A first downconverter 104 performs 

Case 2:23-cv-00285-JRG-RSP Document 59-11 Filed 07/11/24 Page 96 of 158 PageID #:

3182
96

Claim 14 of the ’802 Patent Prior Art Reference – Chen-868

a downconversion of 48 MHz to provide a first low frequency signal at 2 MHz. A second 

downconverter 110 performs a downconversion of 68 MHz to provide a second low frequency signal 

at 2 MHz. A third downconverter 110 performs a downconversion of 76 MHz to provide a third low 

frequency signal at 2 MHz.

See, e.g., Chen-868 at 4:56-5:4.

FIG. 5 illustrates a frequency band allotment of two separate 5 MHz (or 3.75 MHz) bands. The first 

group of adjacent carriers is illustrated by frequency bands 250 a, 250 b and 250 c. The second group 

of adjacent carriers is illustrated by carriers 252 a, 252 b and 252 c. The receiver structure illustrated 

in FIG. 6 is capable of receiving information on the three carriers 250 a, 250 b and 250 c and 

simultaneously searching or receiving data on one of carriers 252 a, 252 b and 252 c.

To illustrate the operation and advantages of the receiver in FIG. 6, it will be assumed that the mobile 

station in which receiver 350 is located is currently receiving data on carriers 250 a, 250 b and 250 c 

and that the mobile station will search band 252 a to determine whether it is capable of receiving 

service from the system providing the signal comprising carriers 252 a, 252 b and 252 c. It will be 

understood by one skilled in the art that data for the mobile station could be provided on carriers 252 

a, 252 b or 252 c by simply changing the searching operation to a demodulation operation.

Signals 250 a, 250 b, 250 c and 252 a are received at antenna 300 and provided through duplexer 302 

to low noise amplifier (LNA) 304. The amplified signal is provided to mixer 306. Mixer 306 down 

converts the signal in accordance with a signal provided by local oscillator 308 which brings the 5 

MHz band consisting of carriers 250 a, 250 b and 250 c down to a MHz wide baseband signal. The 

down converted signal is low pass filtered by filter (BPF1) 314 which is a low pass filter with a 5 

MHz pass band. The received signal is also provided to downconverter 310 which brings the signal 

carried on carrier 252 a down to base band. The down converted signal is low pass filtered by filter 

(BPF2) 316 which is a low pass filter with a 1.23 MHz pass band.

The filtered signal from filter 314 is summed with the filtered signal from filter 316 in summer 318. 

The summed signal is amplified by automatic gain control (AGC) 320. The amplified signal is 

Case 2:23-cv-00285-JRG-RSP Document 59-11 Filed 07/11/24 Page 97 of 158 PageID #:

3183
97

Claim 14 of the ’802 Patent Prior Art Reference – Chen-868

provided to analog to digital (A/D) converter 322. The digital signals are provided to downconverters 

324 a, 324 b and filter (BPF) 328 c. Downconverters 324 a and 324 b bring the signals carried on 

carriers 250 b and 250 c down to base band. The signal carried on carriers 250 a an d 252 a are 

already at baseband and is provided directly to filter 328 c. The signals 250 a and 252 a act as 

interference to one another in the demodulation process but given sufficient coding and spreading 

gain, both the signals can be demodulated. In the present context of searching, it more often than not 

be the case that no signal is found and in that case the signal degradation will be minimum.

Downconverter 324 a and downconverter 324 b are driven by local oscillators 326 a and 326 b 

respectively. The down converted signals are provided to filters 328 a and 328 b, which are low pass 

filters with a 1.228 MHz pass band. Similarly, filter 328 c is a low pass filter with a 1.228 MHz pass 

band. The base band signals are then provided to demodulator and searcher 330 which operate as 

described with respect to demodulator and searcher 116 of FIG. 2. The signal provided through filter 

328 c can be demodulated by two demodulators, one to demodulate the signal transmitted from the 

first system (on carrier 250 a) and one to demodulate the signal transmitted by the second system (on 

carrier 252 a). In the alternative, a single demodulator can be time shared demodulating the signal 

from the first system and at certain intervals demodulating the signal transmitted from the second 

system.

See, e.g., Chen-868 at 13:41-14:36.

Furthermore, this claim element is obvious in light of Chen-868 itself, when combined with any of 

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

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

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

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

First Supplemental Ex. A-Obviousness Chart.

[14.5] down-converting the 

amplified received upconverted signal using a first 

Chen-868 discloses “down-converting the amplified received up-converted signal using a first downconverter and a signal corresponding to the first RF center frequency to produce a fourth analog 

signal corresponding to the first analog signal.” See, e.g.:

Case 2:23-cv-00285-JRG-RSP Document 59-11 Filed 07/11/24 Page 98 of 158 PageID #:

3184
98

Claim 14 of the ’802 Patent Prior Art Reference – Chen-868

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

In the present invention, high speed data is provided by transmitting data on multiple carrier 

frequencies, multiple code channels and/or from multiple base stations. In a first embodiment of the 

present invention, multiplexed code symbols are transmitted on a plurality of carrier frequencies from 

the same base station. In second embodiment, code symbols are transmitted on multiple carrier 

frequencies with at least one corner frequency providing the code symbols is a multiple code 

channels. In a third embodiment, a subset of the multiplexed code symbols are redundantly provided 

on a different carrier from at least one additional base station. In a fourth embodiment, multiplexed 

symbols as transmitted on different carriers from the same base station and are redundantly 

transmitted on another set of carriers from a different base station. In a fifth embodiment, code 

symbols are multiplexed onto carriers from a plurality of base stations for increased throughput. In a 

sixth embodiment, code symbols are transmitted on carriers from a first base station and redundantly 

provided on at least one additional base station on the same carriers as used by the first base station.

See, e.g., Chen-868 at Abstract.

See, e.g., Chen-868 at Figure 5.

Case 2:23-cv-00285-JRG-RSP Document 59-11 Filed 07/11/24 Page 99 of 158 PageID #:

3185
99

Claim 14 of the ’802 Patent Prior Art Reference – Chen-868

See, e.g., Chen-868 at Figure 6.

FIG. 6 is a block diagram of a receiver structure which provides for reduced hardware requirement in 

the reception of signals transmitted in accordance with the present invention.

See, e.g., Chen-868 at 3:7-10.

Referring to FIG. 3B, the data is again provided in three bands, although the present invention is 

easily extendible to an arbitrary number of bands. The first signal 160 is transmitted on a frequency 

of 850 MHz, the second signal 162 is transmitted on a frequency of 920 MHz, and the third signal is 

transmitted on a frequency of 928 MHz. In order to demodulate data transmitted on these three bands, 

the signals might first be down converted by 800 MHz and then provided to downconverters 110 a -

110 j, which would complete the downconversion to a baseband. A first downconverter 104 performs 

Case 2:23-cv-00285-JRG-RSP Document 59-11 Filed 07/11/24 Page 100 of 158 PageID #:

3186
100

Claim 14 of the ’802 Patent Prior Art Reference – Chen-868

a downconversion of 48 MHz to provide a first low frequency signal at 2 MHz. A second 

downconverter 110 performs a downconversion of 68 MHz to provide a second low frequency signal 

at 2 MHz. A third downconverter 110 performs a downconversion of 76 MHz to provide a third low 

frequency signal at 2 MHz.

See, e.g., Chen-868 at 4:56-5:4.

FIG. 5 illustrates a frequency band allotment of two separate 5 MHz (or 3.75 MHz) bands. The first 

group of adjacent carriers is illustrated by frequency bands 250 a, 250 b and 250 c. The second group 

of adjacent carriers is illustrated by carriers 252 a, 252 b and 252 c. The receiver structure illustrated 

in FIG. 6 is capable of receiving information on the three carriers 250 a, 250 b and 250 c and 

simultaneously searching or receiving data on one of carriers 252 a, 252 b and 252 c.

To illustrate the operation and advantages of the receiver in FIG. 6, it will be assumed that the mobile 

station in which receiver 350 is located is currently receiving data on carriers 250 a, 250 b and 250 c 

and that the mobile station will search band 252 a to determine whether it is capable of receiving 

service from the system providing the signal comprising carriers 252 a, 252 b and 252 c. It will be 

understood by one skilled in the art that data for the mobile station could be provided on carriers 252 

a, 252 b or 252 c by simply changing the searching operation to a demodulation operation.

Signals 250 a, 250 b, 250 c and 252 a are received at antenna 300 and provided through duplexer 302 

to low noise amplifier (LNA) 304. The amplified signal is provided to mixer 306. Mixer 306 down 

converts the signal in accordance with a signal provided by local oscillator 308 wh ich brings the 5 

MHz band consisting of carriers 250 a, 250 b and 250 c down to a MHz wide baseband signal. The 

down converted signal is low pass filtered by filter (BPF1) 314 which is a low pass filter with a 5 

MHz pass band. The received signal is also provided to downconverter 310 which brings the signal 

carried on carrier 252 a down to base band. The down converted signal is low pass filtered by filter 

(BPF2) 316 which is a low pass filter with a 1.23 MHz pass band.

The filtered signal from filter 314 is summed with the filtered signal from filter 316 in summer 318. 

The summed signal is amplified by automatic gain control (AGC) 320. The amplified signal is 

Case 2:23-cv-00285-JRG-RSP Document 59-11 Filed 07/11/24 Page 101 of 158 PageID #:

3187
101

Claim 14 of the ’802 Patent Prior Art Reference – Chen-868

provided to analog to digital (A/D) converter 322. The digital signals are provided to downconverters 

324 a, 324 b and filter (BPF) 328 c. Downconverters 324 a and 324 b bring the signals carried on 

carriers 250 b and 250 c down to base band. The signal carried on carriers 250 a and 252 a are 

already at baseband and is provided directly to filter 328 c. The signals 250 a and 252 a act as 

interference to one another in the demodulation process but given sufficient coding and spreading 

gain, both the signals can be demodulated. In the present context of searching, it more often than not 

be the case that no signal is found and in that case the signal degradation will be minimum.

Downconverter 324 a and downconverter 324 b are driven by local oscillators 326 a and 326 b 

respectively. The down converted signals are provided to filters 328 a and 328 b, which are low pass 

filters with a 1.228 MHz pass band. Similarly, filter 328 c is a low pass filter with a 1.228 MHz pass 

band. The base band signals are then provided to demodulator and searcher 330 which operate as 

described with respect to demodulator and searcher 116 of FIG. 2. The signal provided through filter 

328 c can be demodulated by two demodulators, one to demodulate the signal transmitted from the 

first system (on carrier 250 a) and one to demodulate the signal transmitted by the second system (on 

carrier 252 a). In the alternative, a single demodulator can be time shared demodulating the signal 

from the first system and at certain intervals demodulating the signal transmitted from the second 

system.

See, e.g., Chen-868 at 13:41-14:36.

Furthermore, this claim element is obvious in light of Chen-868 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.

[14.6] down-converting the 

amplified received upconverted analog signal using 

Chen-868 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.: 

Case 2:23-cv-00285-JRG-RSP Document 59-11 Filed 07/11/24 Page 102 of 158 PageID #:

3188
102

Claim 14 of the ’802 Patent Prior Art Reference – Chen-868

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.

In the present invention, high speed data is provided by transmitting data on multiple carrier 

frequencies, multiple code channels and/or from multiple base stations. In a first embodiment of the 

present invention, multiplexed code symbols are transmitted on a plurality of carrier frequencies from 

the same base station. In second embodiment, code symbols are transmitted on multiple carrier 

frequencies with at least one corner frequency providing the code symbols is a multiple code 

channels. In a third embodiment, a subset of the multiplexed code symbols are redundantly provided 

on a different carrier from at least one additional base station. In a fourth embodiment, multiplexed 

symbols as transmitted on different carriers from the same base station and are redundantly 

transmitted on another set of carriers from a different base station. In a fifth embodiment, code 

symbols are multiplexed onto carriers from a plurality of base stations for increased throughput. In a 

sixth embodiment, code symbols are transmitted on carriers from a first base station and redundantly 

provided on at least one additional base station on the same carriers as used by the first base station.

See, e.g., Chen-868 at Abstract.

See, e.g., Chen-868 at Figure 5.

Case 2:23-cv-00285-JRG-RSP Document 59-11 Filed 07/11/24 Page 103 of 158 PageID #:

3189
103

Claim 14 of the ’802 Patent Prior Art Reference – Chen-868

See, e.g., Chen-868 at Figure 6.

FIG. 6 is a block diagram of a receiver structure which provides for reduced hardware requirement in 

the reception of signals transmitted in accordance with the present invention.

See, e.g., Chen-868 at 3:7-10.

Referring to FIG. 3B, the data is again provided in three bands, although the present invention is 

easily extendible to an arbitrary number of bands. The first signal 160 is transmitted on a frequency 

of 850 MHz, the second signal 162 is transmitted on a frequency of 920 MHz, and the third signal is 

transmitted on a frequency of 928 MHz. In order to demodulate data transmitted on these three bands, 

the signals might first be down converted by 800 MHz and then provided to downconverters 110 a -

110 j, which would complete the downconversion to a baseband. A first downconverter 104 performs 

Case 2:23-cv-00285-JRG-RSP Document 59-11 Filed 07/11/24 Page 104 of 158 PageID #:

3190
104

Claim 14 of the ’802 Patent Prior Art Reference – Chen-868

a downconversion of 48 MHz to provide a first low frequency signal at 2 MHz. A second 

downconverter 110 performs a downconversion of 68 MHz to provide a second low frequency signal 

at 2 MHz. A third downconverter 110 performs a downconversion of 76 MHz to provide a third low 

frequency signal at 2 MHz.

See, e.g., Chen-868 at 4:56-5:4.

FIG. 5 illustrates a frequency band allotment of two separate 5 MHz (or 3.75 MHz) bands. The first 

group of adjacent carriers is illustrated by frequency bands 250 a, 250 b and 250 c. The second group 

of adjacent carriers is illustrated by carriers 252 a, 252 b and 252 c. The receiver structure illustrated 

in FIG. 6 is capable of receiving information on the three carriers 250 a, 250 b and 250 c and 

simultaneously searching or receiving data on one of carriers 252 a, 252 b and 252 c.

To illustrate the operation and advantages of the receiver in FIG. 6, it will be assumed that the mobile 

station in which receiver 350 is located is currently receiving data on carriers 250 a, 250 b and 250 c 

and that the mobile station will search band 252 a to determine whether it is capable of receiving 

service from the system providing the signal comprising carriers 252 a, 252 b and 252 c. It will be 

understood by one skilled in the art that data for the mobile station could be provided on carriers 252 

a, 252 b or 252 c by simply changing the searching operation to a demodulation operation.

Signals 250 a, 250 b, 250 c and 252 a are received at antenna 300 and provided through duplexer 302 

to low noise amplifier (LNA) 304. The amplified signal is provided to mixer 306. Mixer 306 down 

converts the signal in accordance with a signal provided by local oscillator 308 wh ich brings the 5 

MHz band consisting of carriers 250 a, 250 b and 250 c down to a MHz wide baseband signal. The 

down converted signal is low pass filtered by filter (BPF1) 314 which is a low pass filter with a 5 

MHz pass band. The received signal is also provided to downconverter 310 which brings the signal 

carried on carrier 252 a down to base band. The down converted signal is low pass filtered by filter 

(BPF2) 316 which is a low pass filter with a 1.23 MHz pass band.

The filtered signal from filter 314 is summed with the filtered signal from filter 316 in summer 318. 

The summed signal is amplified by automatic gain control (AGC) 320. The amplified signal is 

Case 2:23-cv-00285-JRG-RSP Document 59-11 Filed 07/11/24 Page 105 of 158 PageID #:

3191
105

Claim 14 of the ’802 Patent Prior Art Reference – Chen-868

provided to analog to digital (A/D) converter 322. The digital signals are provided to downconverters 

324 a, 324 b and filter (BPF) 328 c. Downconverters 324 a and 324 b bring the signals carried on 

carriers 250 b and 250 c down to base band. The signal carried on carriers 250 a and 252 a are 

already at baseband and is provided directly to filter 328 c. The signals 250 a and 252 a act as 

interference to one another in the demodulation process but given sufficient coding and spreading 

gain, both the signals can be demodulated. In the present context of searching, it more often than not 

be the case that no signal is found and in that case the signal degradation will be minimum.

Downconverter 324 a and downconverter 324 b are driven by local oscillators 326 a and 326 b 

respectively. The down converted signals are provided to filters 328 a and 328 b, which are low pass 

filters with a 1.228 MHz pass band. Similarly, filter 328 c is a low pass filter with a 1.228 MHz pass 

band. The base band signals are then provided to demodulator and searcher 330 which operate as 

described with respect to demodulator and searcher 116 of FIG. 2. The signal provided through filter 

328 c can be demodulated by two demodulators, one to demodulate the signal transmitted from the 

first system (on carrier 250 a) and one to demodulate the signal transmitted by the second system (on 

carrier 252 a). In the alternative, a single demodulator can be time shared demodulating the signal 

from the first system and at certain intervals demodulating the signal transmitted from the second 

system.

See, e.g., Chen-868 at 13:41-14:36.

Furthermore, this claim element is obvious in light of Chen-868 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 59-11 Filed 07/11/24 Page 106 of 158 PageID #:

3192
106

Claim 17 of the ’802 Patent Prior Art Reference – Chen-868

[17.1] A wireless 

communication system 

comprising:

To the extent the preamble is limiting, Chen-868 discloses “A wireless communication system 

comprising.” See, e.g.: 

In the present invention, high speed data is provided by transmitting data on multiple carrier 

frequencies, multiple code channels and/or from multiple base stations. In a first embodiment of the 

present invention, multiplexed code symbols are transmitted on a plurality of carrier frequencies from 

the same base station. In second embodiment, code symbols are transmitted on multiple carrier 

frequencies with at least one corner frequency providing the code symbols is a multiple code 

channels. In a third embodiment, a subset of the multiplexed code symbols are redundantly provided 

on a different carrier from at least one additional base station. In a fourth embodiment, multiplexed 

symbols as transmitted on different carriers from the same base station and are redundantly 

transmitted on another set of carriers from a different base station. In a fifth embodiment, code 

symbols are multiplexed onto carriers from a plurality of base stations for increased throughput. In a 

sixth embodiment, code symbols are transmitted on carriers from a first base station and redundantly 

provided on at least one additional base station on the same carriers as used by the first base station.

See, e.g., Chen-868 at Abstract.

Furthermore, this claim element is obvious in light of Chen-868 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 

Chen-868 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.: 

Case 2:23-cv-00285-JRG-RSP Document 59-11 Filed 07/11/24 Page 107 of 158 PageID #:

3193
107

Claim 17 of the ’802 Patent Prior Art Reference – Chen-868

comprising a second data to 

be transmitted;

In the present invention, high speed data is provided by transmitting data on multiple carrier 

frequencies, multiple code channels and/or from multiple base stations. In a first embodiment of the 

present invention, multiplexed code symbols are transmitted on a plurality of carrier frequencies from

the same base station. In second embodiment, code symbols are transmitted on multiple carrier 

frequencies with at least one corner frequency providing the code symbols is a multiple code 

channels. In a third embodiment, a subset of the multiplexed code symbols are redundantly provided 

on a different carrier from at least one additional base station. In a fourth embodiment, multiplexed 

symbols as transmitted on different carriers from the same base station and are redundantly 

transmitted on another set of carriers from a different base station. In a fifth embodiment, code 

symbols are multiplexed onto carriers from a plurality of base stations for increased throughput. In a 

sixth embodiment, code symbols are transmitted on carriers from a first base station and redundantly 

provided on at least one additional base station on the same carriers as used by the first base station.

See, e.g., Chen-868 at Abstract.

See, e.g., Chen-868 at Figure 5.

Case 2:23-cv-00285-JRG-RSP Document 59-11 Filed 07/11/24 Page 108 of 158 PageID #:

3194
108

Claim 17 of the ’802 Patent Prior Art Reference – Chen-868

See, e.g., Chen-868 at Figure 6.

FIG. 6 is a block diagram of a receiver structure which provides for reduced hardware requirement in 

the reception of signals transmitted in accordance with the present invention.

See, e.g., Chen-868 at 3:7-10.

Referring to FIG. 3B, the data is again provided in three bands, although the present invention is 

easily extendible to an arbitrary number of bands. The first signal 160 is transmitted on a frequency 

of 850 MHz, the second signal 162 is transmitted on a frequency of 920 MHz, and the third signal is 

transmitted on a frequency of 928 MHz. In order to demodulate data transmitted on these three bands, 

the signals might first be down converted by 800 MHz and then provided to downconverters 110 a -

110 j, which would complete the downconversion to a baseband. A first downconverter 104 performs 

Case 2:23-cv-00285-JRG-RSP Document 59-11 Filed 07/11/24 Page 109 of 158 PageID #:

3195
109

Claim 17 of the ’802 Patent Prior Art Reference – Chen-868

a downconversion of 48 MHz to provide a first low frequency signal at 2 MHz. A second 

downconverter 110 performs a downconversion of 68 MHz to provide a second low frequency signal 

at 2 MHz. A third downconverter 110 performs a downconversion of 76 MHz to provide a third low 

frequency signal at 2 MHz.

See, e.g., Chen-868 at 4:56-5:4.

FIG. 5 illustrates a frequency band allotment of two separate 5 MHz (or 3.75 MHz) bands. The first 

group of adjacent carriers is illustrated by frequency bands 250 a, 250 b and 250 c. The second group 

of adjacent carriers is illustrated by carriers 252 a, 252 b and 252 c. The receiver structure illustrated 

in FIG. 6 is capable of receiving information on the three carriers 250 a, 250 b and 250 c and 

simultaneously searching or receiving data on one of carriers 252 a, 252 b and 252 c.

To illustrate the operation and advantages of the receiver in FIG. 6, it will be assumed that the mobile 

station in which receiver 350 is located is currently receiving data on carriers 250 a, 250 b and 250 c 

and that the mobile station will search band 252 a to determine whether it is capable of receiving 

service from the system providing the signal comprising carriers 252 a, 252 b and 252 c. It will be 

understood by one skilled in the art that data for the mobile station could be provided on carriers 252 

a, 252 b or 252 c by simply changing the searching operation to a demodulation operation.

Signals 250 a, 250 b, 250 c and 252 a are received at antenna 300 and provided through duplexer 302 

to low noise amplifier (LNA) 304. The amplified signal is provided to mixer 306. Mixer 306 down 

converts the signal in accordance with a signal provided by local oscillator 308 which brings the 5 

MHz band consisting of carriers 250 a, 250 b and 250 c down to a MHz wide baseband signal. The 

down converted signal is low pass filtered by filter (BPF1) 314 which is a low pass filter with a 5 

MHz pass band. The received signal is also provided to downconverter 310 which brings the signal 

carried on carrier 252 a down to base band. The down converted signal is low pass filtered by filter 

(BPF2) 316 which is a low pass filter with a 1.23 MHz pass band.

The filtered signal from filter 314 is summed with the filtered signal from filter 316 in summer 318. 

The summed signal is amplified by automatic gain control (AGC) 320. The amplified signal is 

Case 2:23-cv-00285-JRG-RSP Document 59-11 Filed 07/11/24 Page 110 of 158 PageID #:

3196
110

Claim 17 of the ’802 Patent Prior Art Reference – Chen-868

provided to analog to digital (A/D) converter 322. The digital signals are provided to downconverters 

324 a, 324 b and filter (BPF) 328 c. Downconverters 324 a and 324 b bring the signals carried on 

carriers 250 b and 250 c down to base band. The signal carried on carriers 250 a and 252 a are 

already at baseband and is provided directly to filter 328 c. The signals 250 a and 252 a act as 

interference to one another in the demodulation process but given sufficient coding and spreading 

gain, both the signals can be demodulated. In the present context of searching, it more often than not 

be the case that no signal is found and in that case the signal degradation will be minimum.

Downconverter 324 a and downconverter 324 b are driven by local oscillators 326 a and 326 b 

respectively. The down converted signals are provided to filters 328 a and 328 b, which are low pass 

filters with a 1.228 MHz pass band. Similarly, filter 328 c is a low pass filter with a 1.228 MHz pass 

band. The base band signals are then provided to demodulator and searcher 330 which operate as 

described with respect to demodulator and searcher 116 of FIG. 2. The signal provided through filter 

328 c can be demodulated by two demodulators, one to demodulate the signal transmitted from the 

first system (on carrier 250 a) and one to demodulate the signal transmitted by the second system (on 

carrier 252 a). In the alternative, a single demodulator can be time shared demodulating the signal 

from the first system and at certain intervals demodulating the signal transmitted from the second 

system.

See, e.g., Chen-868 at 13:41-14:36.

Furthermore, this claim element is obvious in light of Chen-868 itself, when combined with any of 

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

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

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

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

First Supplemental Ex. A-Obviousness Chart.

[17.3] a first digital-to-analog 

converter for receiving the 

first digital signal and 

Chen-868 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.: 

Case 2:23-cv-00285-JRG-RSP Document 59-11 Filed 07/11/24 Page 111 of 158 PageID #:

3197
111

Claim 17 of the ’802 Patent Prior Art Reference – Chen-868

converting the first digital 

signal into a first analog 

signal, the first analog signal 

carrying the first data across a 

first frequency range;

In the present invention, high speed data is provided by transmitting data on multiple carrier 

frequencies, multiple code channels and/or from multiple base stations. In a first embodiment of the 

present invention, multiplexed code symbols are transmitted on a plurality of carrier frequencies from 

the same base station. In second embodiment, code symbols are transmitted on multiple carrier 

frequencies with at least one corner frequency providing the code symbols is a multiple code 

channels. In a third embodiment, a subset of the multiplexed code symbols are redundantly provided 

on a different carrier from at least one additional base station. In a fourth embodiment, multiplexed 

symbols as transmitted on different carriers from the same base station and are redundantly 

transmitted on another set of carriers from a different base station. In a fifth embodiment, code 

symbols are multiplexed onto carriers from a plurality of base stations for increased throughput. In a 

sixth embodiment, code symbols are transmitted on carriers from a first base station and redundantly 

provided on at least one additional base station on the same carriers as used by the first base station.

See, e.g., Chen-868 at Abstract.

See, e.g., Chen-868 at Figure 5.

Case 2:23-cv-00285-JRG-RSP Document 59-11 Filed 07/11/24 Page 112 of 158 PageID #:

3198
112

Claim 17 of the ’802 Patent Prior Art Reference – Chen-868

See, e.g., Chen-868 at Figure 6.

FIG. 6 is a block diagram of a receiver structure which provides for reduced hardware requirement in 

the reception of signals transmitted in accordance with the present invention.

See, e.g., Chen-868 at 3:7-10.

Referring to FIG. 3B, the data is again provided in three bands, although the present invention is 

easily extendible to an arbitrary number of bands. The first signal 160 is transmitted on a frequency 

of 850 MHz, the second signal 162 is transmitted on a frequency of 920 MHz, and the third signal is 

transmitted on a frequency of 928 MHz. In order to demodulate data transmitted on these three bands, 

the signals might first be down converted by 800 MHz and then provided to downconverters 110 a110 j, which would complete the downconversion to a baseband. A first downconverter 104 performs 

Case 2:23-cv-00285-JRG-RSP Document 59-11 Filed 07/11/24 Page 113 of 158 PageID #:

3199
113

Claim 17 of the ’802 Patent Prior Art Reference – Chen-868

a downconversion of 48 MHz to provide a first low frequency signal at 2 MHz. A second 

downconverter 110 performs a downconversion of 68 MHz to provide a second low frequency signal 

at 2 MHz. A third downconverter 110 performs a downconversion of 76 MHz to provide a third low 

frequency signal at 2 MHz.

See, e.g., Chen-868 at 4:56-5:4.

FIG. 5 illustrates a frequency band allotment of two separate 5 MHz (or 3.75 MHz) bands. The first 

group of adjacent carriers is illustrated by frequency bands 250 a, 250 b and 250 c. The second group 

of adjacent carriers is illustrated by carriers 252 a, 252 b and 252 c. The receiver structure illustrated 

in FIG. 6 is capable of receiving information on the three carriers 250 a, 250 b and 250 c and 

simultaneously searching or receiving data on one of carriers 252 a, 252 b and 252 c.

To illustrate the operation and advantages of the receiver in FIG. 6, it will be assumed that the mobile 

station in which receiver 350 is located is currently receiving data on carriers 250 a, 250 b and 250 c 

and that the mobile station will search band 252 a to determine whether it is capable of receiving 

service from the system providing the signal comprising carriers 252 a, 252 b and 252 c. It will be 

understood by one skilled in the art that data for the mobile station could be provided on carriers 252 

a, 252 b or 252 c by simply changing the searching operation to a demodulation operation.

Signals 250 a, 250 b, 250 c and 252 a are received at antenna 300 and provided through duplexer 302 

to low noise amplifier (LNA) 304. The amplified signal is provided to mixer 306. Mixer 306 down 

converts the signal in accordance with a signal provided by local oscillator 308 which brings the 5 

MHz band consisting of carriers 250 a, 250 b and 250 c down to a MHz wide baseband signal. The 

down converted signal is low pass filtered by filter (BPF1) 314 which is a low pass filter with a 5 

MHz pass band. The received signal is also provided to downconverter 310 which brings the signal 

carried on carrier 252 a down to base band. The down converted signal is low pass filtered by filter 

(BPF2) 316 which is a low pass filter with a 1.23 MHz pass band.

The filtered signal from filter 314 is summed with the filtered signal from filter 316 in summer 318. 

The summed signal is amplified by automatic gain control (AGC) 320. The amplified signal is 

Case 2:23-cv-00285-JRG-RSP Document 59-11 Filed 07/11/24 Page 114 of 158 PageID #:

3200
114

Claim 17 of the ’802 Patent Prior Art Reference – Chen-868

provided to analog to digital (A/D) converter 322. The digital signals are provided to downconverters 

324 a, 324 b and filter (BPF) 328 c. Downconverters 324 a and 324 b bring the signals carried on 

carriers 250 b and 250 c down to base band. The signal carried on carriers 250 a and 252 a are 

already at baseband and is provided directly to filter 328 c. The signals 250 a and 252 a act as 

interference to one another in the demodulation process but given sufficient coding and spreading 

gain, both the signals can be demodulated. In the present context of searching, it more often than not 

be the case that no signal is found and in that case the signal degradation will be minimum.

Downconverter 324 a and downconverter 324 b are driven by local oscillators 326 a and 326 b 

respectively. The down converted signals are provided to filters 328 a and 328 b, which are low pass 

filters with a 1.228 MHz pass band. Similarly, filter 328 c is a low pass filter with a 1.228 MHz pass 

band. The base band signals are then provided to demodulator and searcher 330 which operate as 

described with respect to demodulator and searcher 116 of FIG. 2. The signal provided through filter 

328 c can be demodulated by two demodulators, one to demodulate the signal transmitted from the 

first system (on carrier 250 a) and one to demodulate the signal transmitted by the second system (on 

carrier 252 a). In the alternative, a single demodulator can be time shared demodulating the signal 

from the first system and at certain intervals demodulating the signal transmitted from the second 

system.

See, e.g., Chen-868 at 13:41-14:36.

Furthermore, this claim element is obvious in light of Chen-868 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.

[17.4] a second digital-toanalog converter for receiving 

the second digital signal and 

Chen-868 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.: 

Case 2:23-cv-00285-JRG-RSP Document 59-11 Filed 07/11/24 Page 115 of 158 PageID #:

3201
115

Claim 17 of the ’802 Patent Prior Art Reference – Chen-868

converting the second digital 

signal into a second analog 

signal, the second analog 

signal carrying the second 

data across a second 

frequency range;

In the present invention, high speed data is provided by transmitting data on multiple carrier 

frequencies, multiple code channels and/or from multiple base stations. In a first embodiment of the 

present invention, multiplexed code symbols are transmitted on a plurality of carrier frequencies from 

the same base station. In second embodiment, code symbols are transmitted on multiple carrier 

frequencies with at least one corner frequency providing the code symbols is a multiple code 

channels. In a third embodiment, a subset of the multiplexed code symbols are redundantly provided 

on a different carrier from at least one additional base station. In a fourth embodiment, multiplexed 

symbols as transmitted on different carriers from the same base station and are redundantly 

transmitted on another set of carriers from a different base station. In a fifth embodiment, code 

symbols are multiplexed onto carriers from a plurality of base stations for increased throughput. In a 

sixth embodiment, code symbols are transmitted on carriers from a first base station and redundantly 

provided on at least one additional base station on the same carriers as used by the first base station.

See, e.g., Chen-868 at Abstract.

See, e.g., Chen-868 at Figure 5.

Case 2:23-cv-00285-JRG-RSP Document 59-11 Filed 07/11/24 Page 116 of 158 PageID #:

3202
116

Claim 17 of the ’802 Patent Prior Art Reference – Chen-868

See, e.g., Chen-868 at Figure 6.

FIG. 6 is a block diagram of a receiver structure which provides for reduced hardware requirement in 

the reception of signals transmitted in accordance with the present invention.

See, e.g., Chen-868 at 3:7-10.

Referring to FIG. 3B, the data is again provided in three bands, although the present invention is 

easily extendible to an arbitrary number of bands. The first signal 160 is transmitted on a frequency 

of 850 MHz, the second signal 162 is transmitted on a frequency of 920 MHz, and the third signal is 

transmitted on a frequency of 928 MHz. In order to demodulate data transmitted on these three bands, 

the signals might first be down converted by 800 MHz and then provided to downconverters 110 a -

110 j, which would complete the downconversion to a baseband. A first downconverter 104 performs 

Case 2:23-cv-00285-JRG-RSP Document 59-11 Filed 07/11/24 Page 117 of 158 PageID #:

3203
117

Claim 17 of the ’802 Patent Prior Art Reference – Chen-868

a downconversion of 48 MHz to provide a first low frequency signal at 2 MHz. A second 

downconverter 110 performs a downconversion of 68 MHz to provide a second low frequency signal 

at 2 MHz. A third downconverter 110 performs a downconversion of 76 MHz to provide a third low 

frequency signal at 2 MHz.

See, e.g., Chen-868 at 4:56-5:4.

FIG. 5 illustrates a frequency band allotment of two separate 5 MHz (or 3.75 MHz) bands. The first 

group of adjacent carriers is illustrated by frequency bands 250 a, 250 b and 250 c. The second group 

of adjacent carriers is illustrated by carriers 252 a, 252 b and 252 c. The receiver structure illustrated 

in FIG. 6 is capable of receiving information on the three carriers 250 a, 250 b and 250 c and 

simultaneously searching or receiving data on one of carriers 252 a, 252 b and 252 c.

To illustrate the operation and advantages of the receiver in FIG. 6, it will be assumed that the mobile 

station in which receiver 350 is located is currently receiving data on carriers 250 a, 250 b and 250 c 

and that the mobile station will search band 252 a to determine whether it is capable of receiving 

service from the system providing the signal comprising carriers 252 a, 252 b and 252 c. It will be 

understood by one skilled in the art that data for the mobile station could be provided on carriers 252 

a, 252 b or 252 c by simply changing the searching operation to a demodulation operation.

Signals 250 a, 250 b, 250 c and 252 a are received at antenna 300 and provided through duplexer 302 

to low noise amplifier (LNA) 304. The amplified signal is provided to mixer 306. Mixer 306 down 

converts the signal in accordance with a signal provided by local oscillator 308 which brings the 5 

MHz band consisting of carriers 250 a, 250 b and 250 c down to a MHz wide baseband signal. The 

down converted signal is low pass filtered by filter (BPF1) 314 which is a low pass filter with a 5 

MHz pass band. The received signal is also provided to downconverter 310 which brings the signal 

carried on carrier 252 a down to base band. The down converted signal is low pass filtered by filter 

(BPF2) 316 which is a low pass filter with a 1.23 MHz pass band.

The filtered signal from filter 314 is summed with the filtered signal from filter 316 in summer 318. 

The summed signal is amplified by automatic gain control (AGC) 320. The amplified signal is 

Case 2:23-cv-00285-JRG-RSP Document 59-11 Filed 07/11/24 Page 118 of 158 PageID #:

3204
118

Claim 17 of the ’802 Patent Prior Art Reference – Chen-868

provided to analog to digital (A/D) converter 322. The digital signals are provided to downconverters 

324 a, 324 b and filter (BPF) 328 c. Downconverters 324 a and 324 b bring the signals carried on 

carriers 250 b and 250 c down to base band. The signal carried on carriers 250 a and 252 a are 

already at baseband and is provided directly to filter 328 c. The signals 250 a and 252 a act as 

interference to one another in the demodulation process but given sufficient coding and spreading 

gain, both the signals can be demodulated. In the present context of searching, it more often than not 

be the case that no signal is found and in that case the signal degradation will be minimum.

Downconverter 324 a and downconverter 324 b are driven by local oscillators 326 a and 326 b 

respectively. The down converted signals are provided to filters 328 a and 328 b, which are low pass 

filters with a 1.228 MHz pass band. Similarly, filter 328 c is a low pass filter with a 1.228 MHz pass 

band. The base band signals are then provided to demodulator and searcher 330 which operate as 

described with respect to demodulator and searcher 116 of FIG. 2. The signal provided through filter 

328 c can be demodulated by two demodulators, one to demodulate the signal transmitted from the 

first system (on carrier 250 a) and one to demodulate the signal transmitted by the second system (on 

carrier 252 a). In the alternative, a single demodulator can be time shared demodulating the signal 

from the first system and at certain intervals demodulating the signal transmitted from the second 

system.

See, e.g., Chen-868 at 13:41-14:36.

Furthermore, this claim element is obvious in light of Chen-868 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.

[17.5] a first up-converter 

circuit having a first input 

coupled to receive the first 

Chen-868 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 upCase 2:23-cv-00285-JRG-RSP Document 59-11 Filed 07/11/24 Page 119 of 158 PageID #:

3205
119

Claim 17 of the ’802 Patent Prior Art Reference – Chen-868

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;

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.: 

In the present invention, high speed data is provided by transmitting data on multiple carrier 

frequencies, multiple code channels and/or from multiple base stations. In a first embodiment of the 

present invention, multiplexed code symbols are transmitted on a plurality of carrier frequencies from 

the same base station. In second embodiment, code symbols are transmitted on multiple carrier 

frequencies with at least one corner frequency providing the code symbols is a multiple code 

channels. In a third embodiment, a subset of the multiplexed code symbols are redundantly provided 

on a different carrier from at least one additional base station. In a fourth embodiment, multiplexed 

symbols as transmitted on different carriers from the same base station and are redundantly 

transmitted on another set of carriers from a different base station. In a fifth embodiment, code 

symbols are multiplexed onto carriers from a plurality of base stations for increased throughput. In a 

sixth embodiment, code symbols are transmitted on carriers from a first base station and redundantly 

provided on at least one additional base station on the same carriers as used by the first base station.

See, e.g., Chen-868 at Abstract.

See, e.g., Chen-868 at Figure 5.

Case 2:23-cv-00285-JRG-RSP Document 59-11 Filed 07/11/24 Page 120 of 158 PageID #:

3206
120

Claim 17 of the ’802 Patent Prior Art Reference – Chen-868

See, e.g., Chen-868 at Figure 6.

FIG. 6 is a block diagram of a receiver structure which provides for reduced hardware requirement in 

the reception of signals transmitted in accordance with the present invention.

See, e.g., Chen-868 at 3:7-10.

Referring to FIG. 3B, the data is again provided in three bands, although the present invention is 

easily extendible to an arbitrary number of bands. The first signal 160 is transmitted on a frequency 

of 850 MHz, the second signal 162 is transmitted on a frequency of 920 MHz, and the third signal is 

transmitted on a frequency of 928 MHz. In order to demodulate data transmitted on these three bands, 

the signals might first be down converted by 800 MHz and then provided to downconverters 110 a -

110 j, which would complete the downconversion to a baseband. A first downconverter 104 performs 

Case 2:23-cv-00285-JRG-RSP Document 59-11 Filed 07/11/24 Page 121 of 158 PageID #:

3207
121

Claim 17 of the ’802 Patent Prior Art Reference – Chen-868

a downconversion of 48 MHz to provide a first low frequency signal at 2 MHz. A second 

downconverter 110 performs a downconversion of 68 MHz to provide a second low frequency signal 

at 2 MHz. A third downconverter 110 performs a downconversion of 76 MHz to provide a third low 

frequency signal at 2 MHz.

See, e.g., Chen-868 at 4:56-5:4.

FIG. 5 illustrates a frequency band allotment of two separate 5 MHz (or 3.75 MHz) bands. The first 

group of adjacent carriers is illustrated by frequency bands 250 a, 250 b and 250 c. The second group 

of adjacent carriers is illustrated by carriers 252 a, 252 b and 252 c. The receiver structure illustrated 

in FIG. 6 is capable of receiving information on the three carriers 250 a, 250 b and 250 c and 

simultaneously searching or receiving data on one of carriers 252 a, 252 b and 252 c.

To illustrate the operation and advantages of the receiver in FIG. 6, it will be assumed that the mobile 

station in which receiver 350 is located is currently receiving data on carriers 250 a, 250 b and 250 c 

and that the mobile station will search band 252 a to determine whether it is capable of receiving 

service from the system providing the signal comprising carriers 252 a, 252 b and 252 c. It will be 

understood by one skilled in the art that data for the mobile station could be provided on carriers 252 

a, 252 b or 252 c by simply changing the searching operation to a demodulation operation.

Signals 250 a, 250 b, 250 c and 252 a are received at antenna 300 and provided through duplexer 302 

to low noise amplifier (LNA) 304. The amplified signal is provided to mixer 306. Mixer 306 down 

converts the signal in accordance with a signal provided by local oscillator 308 wh ich brings the 5 

MHz band consisting of carriers 250 a, 250 b and 250 c down to a MHz wide baseband signal. The 

down converted signal is low pass filtered by filter (BPF1) 314 which is a low pass filter with a 5 

MHz pass band. The received signal is also provided to downconverter 310 which brings the signal 

carried on carrier 252 a down to base band. The down converted signal is low pass filtered by filter 

(BPF2) 316 which is a low pass filter with a 1.23 MHz pass band.

The filtered signal from filter 314 is summed with the filtered signal from filter 316 in summer 318. 

The summed signal is amplified by automatic gain control (AGC) 320. The amplified signal is 

Case 2:23-cv-00285-JRG-RSP Document 59-11 Filed 07/11/24 Page 122 of 158 PageID #:

3208
122

Claim 17 of the ’802 Patent Prior Art Reference – Chen-868

provided to analog to digital (A/D) converter 322. The digital signals are provided to downconverters 

324 a, 324 b and filter (BPF) 328 c. Downconverters 324 a and 324 b bring the signals carried on 

carriers 250 b and 250 c down to base band. The signal carried on carriers 250 a and 252 a are 

already at baseband and is provided directly to filter 328 c. The signals 250 a and 252 a act as 

interference to one another in the demodulation process but given sufficient coding and spreading 

gain, both the signals can be demodulated. In the present context of searching, it more often than not 

be the case that no signal is found and in that case the signal degradation will be minimum.

Downconverter 324 a and downconverter 324 b are driven by local oscillators 326 a and 326 b 

respectively. The down converted signals are provided to filters 328 a and 328 b, which are low pass 

filters with a 1.228 MHz pass band. Similarly, filter 328 c is a low pass filter with a 1.228 MHz pass 

band. The base band signals are then provided to demodulator and searcher 330 which operate as 

described with respect to demodulator and searcher 116 of FIG. 2. The signal provided through filter 

328 c can be demodulated by two demodulators, one to demodulate the signal transmitted from the 

first system (on carrier 250 a) and one to demodulate the signal transmitted by the second system (on 

carrier 252 a). In the alternative, a single demodulator can be time shared demodulating the signal 

from the first system and at certain intervals demodulating the signal transmitted from the second 

system.

See, e.g., Chen-868 at 13:41-14:36.

Furthermore, this claim element is obvious in light of Chen-868 itself, when combined with any of 

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

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

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

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

First Supplemental Ex. A-Obviousness Chart.

[17.6] a second up-converter 

circuit having a first input 

coupled to receive the second 

Chen-868 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 

Case 2:23-cv-00285-JRG-RSP Document 59-11 Filed 07/11/24 Page 123 of 158 PageID #:

3209
123

Claim 17 of the ’802 Patent Prior Art Reference – Chen-868

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

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.: 

In the present invention, high speed data is provided by transmitting data on multiple carrier 

frequencies, multiple code channels and/or from multiple base stations. In a first embodiment of the 

present invention, multiplexed code symbols are transmitted on a plurality of carrier frequencies from 

the same base station. In second embodiment, code symbols are transmitted on multiple carrier 

frequencies with at least one corner frequency providing the code symbols is a multiple code 

channels. In a third embodiment, a subset of the multiplexed code symbols are redundantly provided 

on a different carrier from at least one additional base station. In a fourth embodiment, multiplexed 

symbols as transmitted on different carriers from the same base station and are redundantly 

transmitted on another set of carriers from a different base station. In a fifth embodiment, code 

symbols are multiplexed onto carriers from a plurality of base stations for increased throughput. In a 

sixth embodiment, code symbols are transmitted on carriers from a first base station and redundantly 

provided on at least one additional base station on the same carriers as used by the first base station.

See, e.g., Chen-868 at Abstract.

See, e.g., Chen-868 at Figure 5.

Case 2:23-cv-00285-JRG-RSP Document 59-11 Filed 07/11/24 Page 124 of 158 PageID #:

3210
124

Claim 17 of the ’802 Patent Prior Art Reference – Chen-868

See, e.g., Chen-868 at Figure 6.

FIG. 6 is a block diagram of a receiver structure which provides for reduced hardware requirement in 

the reception of signals transmitted in accordance with the present invention.

See, e.g., Chen-868 at 3:7-10.

Referring to FIG. 3B, the data is again provided in three bands, although the present invention is 

easily extendible to an arbitrary number of bands. The first signal 160 is transmitted on a frequency 

of 850 MHz, the second signal 162 is transmitted on a frequency of 920 MHz, and the third signal is 

transmitted on a frequency of 928 MHz. In order to demodulate data transmitted on these three bands, 

the signals might first be down converted by 800 MHz and then provided to downconverters 110 aCase 2:23-cv-00285-JRG-RSP Document 59-11 Filed 07/11/24 Page 125 of 158 PageID #:

3211
125

Claim 17 of the ’802 Patent Prior Art Reference – Chen-868

110 j, which would complete the downconversion to a baseband. A first downconverter 104 performs 

a downconversion of 48 MHz to provide a first low frequency signal at 2 MHz. A second 

downconverter 110 performs a downconversion of 68 MHz to provide a second low frequency signal 

at 2 MHz. A third downconverter 110 performs a downconversion of 76 MHz to provide a third low 

frequency signal at 2 MHz.

See, e.g., Chen-868 at 4:56-5:4.

FIG. 5 illustrates a frequency band allotment of two separate 5 MHz (or 3.75 MHz) bands. The first 

group of adjacent carriers is illustrated by frequency bands 250 a, 250 b and 250 c. The second group 

of adjacent carriers is illustrated by carriers 252 a, 252 b and 252 c. The receiver structure illustra ted 

in FIG. 6 is capable of receiving information on the three carriers 250 a, 250 b and 250 c and 

simultaneously searching or receiving data on one of carriers 252 a, 252 b and 252 c.

To illustrate the operation and advantages of the receiver in FIG. 6, it will be assumed that the mobile 

station in which receiver 350 is located is currently receiving data on carriers 250 a, 250 b and 250 c 

and that the mobile station will search band 252 a to determine whether it is capable of receiving 

service from the system providing the signal comprising carriers 252 a, 252 b and 252 c. It will be 

understood by one skilled in the art that data for the mobile station could be provided on carriers 252 

a, 252 b or 252 c by simply changing the searching operation to a demodulation operation.

Signals 250 a, 250 b, 250 c and 252 a are received at antenna 300 and provided through duplexer 302 

to low noise amplifier (LNA) 304. The amplified signal is provided to mixer 306. Mixer 306 down 

converts the signal in accordance with a signal provided by local oscillator 308 which brings the 5 

MHz band consisting of carriers 250 a, 250 b and 250 c down to a MHz wide baseband signal. The 

down converted signal is low pass filtered by filter (BPF1) 314 which is a low pass filter with a 5 

MHz pass band. The received signal is also provided to downconverter 310 which brings the signal 

carried on carrier 252 a down to base band. The down converted signal is low pass filtered by filter 

(BPF2) 316 which is a low pass filter with a 1.23 MHz pass band.

Case 2:23-cv-00285-JRG-RSP Document 59-11 Filed 07/11/24 Page 126 of 158 PageID #:

3212
126

Claim 17 of the ’802 Patent Prior Art Reference – Chen-868

The filtered signal from filter 314 is summed with the filtered signal from filter 316 in summer 318. 

The summed signal is amplified by automatic gain control (AGC) 320. The amplified signal is 

provided to analog to digital (A/D) converter 322. The digital signals are provided to downconverters 

324 a, 324 b and filter (BPF) 328 c. Downconverters 324 a and 324 b bring the signals carried on 

carriers 250 b and 250 c down to base band. The signal carried on carriers 250 a and 252 a are 

already at baseband and is provided directly to filter 328 c. The signals 250 a and 252 a act as 

interference to one another in the demodulation process but given sufficient coding and spreading 

gain, both the signals can be demodulated. In the present context of searching, it more often than not 

be the case that no signal is found and in that case the signal degradation will be minimum.

Downconverter 324 a and downconverter 324 b are driven by local oscillators 326 a and 326 b 

respectively. The down converted signals are provided to filters 328 a and 328 b, which are low pass 

filters with a 1.228 MHz pass band. Similarly, filter 328 c is a low pass filter with a 1.228 MHz pass 

band. The base band signals are then provided to demodulator and searcher 330 which operate as 

described with respect to demodulator and searcher 116 of FIG. 2. The signal provided through filter 

328 c can be demodulated by two demodulators, one to demodulate the signal transmitted from the 

first system (on carrier 250 a) and one to demodulate the signal transmitted by the second system (on 

carrier 252 a). In the alternative, a single demodulator can be time shared demodulating the signal 

from the first system and at certain intervals demodulating the signal transmitted from the second 

system.

See, e.g., Chen-868 at 13:41-14:36.

Furthermore, this claim element is obvious in light of Chen-868 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 59-11 Filed 07/11/24 Page 127 of 158 PageID #:

3213
127

Claim 17 of the ’802 Patent Prior Art Reference – Chen-868

[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.

Chen-868 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.: 

In the present invention, high speed data is provided by transmitting data on multiple carrier 

frequencies, multiple code channels and/or from multiple base stations. In a first embodiment of the 

present invention, multiplexed code symbols are transmitted on a plurality of carrier frequencies from 

the same base station. In second embodiment, code symbols are transmitted on multiple carrier 

frequencies with at least one corner frequency providing the code symbols is a multiple code 

channels. In a third embodiment, a subset of the multiplexed code symbols are redundantly provided 

on a different carrier from at least one additional base station. In a fourth embodiment, multiplexed 

symbols as transmitted on different carriers from the same base station and are redundantly 

transmitted on another set of carriers from a different base station. In a fifth embodiment, code 

symbols are multiplexed onto carriers from a plurality of base stations for increased throughput. In a 

sixth embodiment, code symbols are transmitted on carriers from a first base station and redundantly 

provided on at least one additional base station on the same carriers as used by the first base station.

See, e.g., Chen-868 at Abstract.

See, e.g., Chen-868 at Figure 5.

Case 2:23-cv-00285-JRG-RSP Document 59-11 Filed 07/11/24 Page 128 of 158 PageID #:

3214
128

Claim 17 of the ’802 Patent Prior Art Reference – Chen-868

See, e.g., Chen-868 at Figure 6.

FIG. 6 is a block diagram of a receiver structure which provides for reduced hardware requirement in 

the reception of signals transmitted in accordance with the present invention.

See, e.g., Chen-868 at 3:7-10.

Referring to FIG. 3B, the data is again provided in three bands, although the present invention is 

easily extendible to an arbitrary number of bands. The first signal 160 is transmitted on a frequency 

of 850 MHz, the second signal 162 is transmitted on a frequency of 920 MHz, and the third signal is 

transmitted on a frequency of 928 MHz. In order to demodulate data transmitted on these three bands, 

the signals might first be down converted by 800 MHz and then provided to downconverters 110 a -

Case 2:23-cv-00285-JRG-RSP Document 59-11 Filed 07/11/24 Page 129 of 158 PageID #:

3215
129

Claim 17 of the ’802 Patent Prior Art Reference – Chen-868

110 j, which would complete the downconversion to a baseband. A first downconverter 104 performs 

a downconversion of 48 MHz to provide a first low frequency signal at 2 MHz. A second 

downconverter 110 performs a downconversion of 68 MHz to provide a second low frequency signal 

at 2 MHz. A third downconverter 110 performs a downconversion of 76 MHz to provide a third low 

frequency signal at 2 MHz.

See, e.g., Chen-868 at 4:56-5:4.

FIG. 5 illustrates a frequency band allotment of two separate 5 MHz (or 3.75 MHz) bands. The first 

group of adjacent carriers is illustrated by frequency bands 250 a, 250 b and 250 c. The second group 

of adjacent carriers is illustrated by carriers 252 a, 252 b and 252 c. The receiver structure illustrated 

in FIG. 6 is capable of receiving information on the three carriers 250 a, 250 b and 250 c and 

simultaneously searching or receiving data on one of carriers 252 a, 252 b and 252 c.

To illustrate the operation and advantages of the receiver in FIG. 6, it will be assumed that the mobile 

station in which receiver 350 is located is currently receiving data on carriers 250 a, 250 b and 250 c 

and that the mobile station will search band 252 a to determine whether it is capable of receiving 

service from the system providing the signal comprising carriers 252 a, 252 b and 252 c. It will be 

understood by one skilled in the art that data for the mobile station could be provided on carriers 252 

a, 252 b or 252 c by simply changing the searching operation to a demodulation operation.

Signals 250 a, 250 b, 250 c and 252 a are received at antenna 300 and provided through duplexer 302 

to low noise amplifier (LNA) 304. The amplified signal is provided to mixer 306. Mixer 306 down 

converts the signal in accordance with a signal provided by local oscillator 308 wh ich brings the 5 

MHz band consisting of carriers 250 a, 250 b and 250 c down to a MHz wide baseband signal. The 

down converted signal is low pass filtered by filter (BPF1) 314 which is a low pass filter with a 5 

MHz pass band. The received signal is also provided to downconverter 310 which brings the signal 

carried on carrier 252 a down to base band. The down converted signal is low pass filtered by filter 

(BPF2) 316 which is a low pass filter with a 1.23 MHz pass band.

Case 2:23-cv-00285-JRG-RSP Document 59-11 Filed 07/11/24 Page 130 of 158 PageID #:

3216
130

Claim 17 of the ’802 Patent Prior Art Reference – Chen-868

The filtered signal from filter 314 is summed with the filtered signal from filter 316 in summer 318. 

The summed signal is amplified by automatic gain control (AGC) 320. The amplified signal is 

provided to analog to digital (A/D) converter 322. The digital signals are provided to downconverters 

324 a, 324 b and filter (BPF) 328 c. Downconverters 324 a and 324 b bring the signals carried on 

carriers 250 b and 250 c down to base band. The signal carried on carriers 250 a and 252 a are 

already at baseband and is provided directly to filter 328 c. The signals 250 a and 252 a act as 

interference to one another in the demodulation process but given sufficient coding and spreading 

gain, both the signals can be demodulated. In the present context of searching, it more often than not 

be the case that no signal is found and in that case the signal degradation will be minimum.

Downconverter 324 a and downconverter 324 b are driven by local oscillators 326 a and 326 b 

respectively. The down converted signals are provided to filters 328 a and 328 b, which are low pass 

filters with a 1.228 MHz pass band. Similarly, filter 328 c is a low pass filter with a 1.228 MHz pass 

band. The base band signals are then provided to demodulator and searcher 330 which operate as 

described with respect to demodulator and searcher 116 of FIG. 2. The signal provided through filter 

328 c can be demodulated by two demodulators, one to demodulate the signal transmitted from the 

first system (on carrier 250 a) and one to demodulate the signal transmitted by the second system (on 

carrier 252 a). In the alternative, a single demodulator can be time shared demodulating the signal 

from the first system and at certain intervals demodulating the signal transmitted from the second 

system.

See, e.g., Chen-868 at 13:41-14:36.

Furthermore, this claim element is obvious in light of Chen-868 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 59-11 Filed 07/11/24 Page 131 of 158 PageID #:

3217
131

Claim 21 of the ’802 Patent Prior Art Reference – Chen-868

[21.1] The communication 

system of claim 17

Chen-868 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.

Chen-868 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.: 

In the present invention, high speed data is provided by transmitting data on multiple carrier 

frequencies, multiple code channels and/or from multiple base stations. In a first embodiment of the 

present invention, multiplexed code symbols are transmitted on a plurality of carrier frequencies from 

the same base station. In second embodiment, code symbols are transmitted on multiple carrier 

frequencies with at least one corner frequency providing the code symbols is a multiple code 

channels. In a third embodiment, a subset of the multiplexed code symbols are redundantly provided 

on a different carrier from at least one additional base station. In a fourth embodiment, multiplexed 

symbols as transmitted on different carriers from the same base station and are redundantly 

transmitted on another set of carriers from a different base station. In a fifth embodiment, code 

symbols are multiplexed onto carriers from a plurality of base stations for increased throughput. In a 

sixth embodiment, code symbols are transmitted on carriers from a first base station and redundantly 

provided on at least one additional base station on the same carriers as used by the first base station.

See, e.g., Chen-868 at Abstract.

Case 2:23-cv-00285-JRG-RSP Document 59-11 Filed 07/11/24 Page 132 of 158 PageID #:

3218
132

Claim 21 of the ’802 Patent Prior Art Reference – Chen-868

See, e.g., Chen-868 at Figure 5.

See, e.g., Chen-868 at Figure 6.

FIG. 6 is a block diagram of a receiver structure which provides for reduced hardware requirement in 

the reception of signals transmitted in accordance with the present invention.

See, e.g., Chen-868 at 3:7-10.

Referring to FIG. 3B, the data is again provided in three bands, although the present invention is 

easily extendible to an arbitrary number of bands. The first signal 160 is transmitted on a frequency 

of 850 MHz, the second signal 162 is transmitted on a frequency of 920 MHz, and the third signal is 

transmitted on a frequency of 928 MHz. In order to demodulate data transmitted on these three bands, 

Case 2:23-cv-00285-JRG-RSP Document 59-11 Filed 07/11/24 Page 133 of 158 PageID #:

3219
133

Claim 21 of the ’802 Patent Prior Art Reference – Chen-868

the signals might first be down converted by 800 MHz and then provided to downconverters 110 a -

110 j, which would complete the downconversion to a baseband. A first downconverter 104 performs 

a downconversion of 48 MHz to provide a first low frequency signal at 2 MHz. A second 

downconverter 110 performs a downconversion of 68 MHz to provide a second low frequency signal 

at 2 MHz. A third downconverter 110 performs a downconversion of 76 MHz to provide a third low 

frequency signal at 2 MHz.

See, e.g., Chen-868 at 4:56-5:4.

FIG. 5 illustrates a frequency band allotment of two separate 5 MHz (or 3.75 MHz) bands. The first 

group of adjacent carriers is illustrated by frequency bands 250 a, 250 b and 250 c. The second group 

of adjacent carriers is illustrated by carriers 252 a, 252 b and 252 c. The receiver structure illustrated 

in FIG. 6 is capable of receiving information on the three carriers 250 a, 250 b and 250 c and 

simultaneously searching or receiving data on one of carriers 252 a, 252 b and 252 c.

To illustrate the operation and advantages of the receiver in FIG. 6, it will be assumed that the mobile 

station in which receiver 350 is located is currently receiving data on carriers 250 a, 250 b and 250 c 

and that the mobile station will search band 252 a to determine whether it is capable of receiving 

service from the system providing the signal comprising carriers 252 a, 252 b and 252 c. It will be 

understood by one skilled in the art that data for the mobile station could be provided on carriers 252 

a, 252 b or 252 c by simply changing the searching operation to a demodulation operation.

Signals 250 a, 250 b, 250 c and 252 a are received at antenna 300 and provided through duplexer 302 

to low noise amplifier (LNA) 304. The amplified signal is provided to mixer 306. Mixer 306 down 

converts the signal in accordance with a signal provided by local oscillator 308 wh ich brings the 5 

MHz band consisting of carriers 250 a, 250 b and 250 c down to a MHz wide baseband signal. The 

down converted signal is low pass filtered by filter (BPF1) 314 which is a low pass filter with a 5 

MHz pass band. The received signal is also provided to downconverter 310 which brings the signal 

carried on carrier 252 a down to base band. The down converted signal is low pass filtered by filter 

(BPF2) 316 which is a low pass filter with a 1.23 MHz pass band.

Case 2:23-cv-00285-JRG-RSP Document 59-11 Filed 07/11/24 Page 134 of 158 PageID #:

3220
134

Claim 21 of the ’802 Patent Prior Art Reference – Chen-868

The filtered signal from filter 314 is summed with the filtered signal from filter 316 in summer 318. 

The summed signal is amplified by automatic gain control (AGC) 320. The amplified signal is 

provided to analog to digital (A/D) converter 322. The digital signals are provided to downconverters 

324 a, 324 b and filter (BPF) 328 c. Downconverters 324 a and 324 b bring the signals carried on 

carriers 250 b and 250 c down to base band. The signal carried on carriers 250 a and 252 a are 

already at baseband and is provided directly to filter 328 c. The signals 250 a and 252 a act as 

interference to one another in the demodulation process but given sufficient coding and spreading 

gain, both the signals can be demodulated. In the present context of searching, it more often than not 

be the case that no signal is found and in that case the signal degradation will be minimum.

Downconverter 324 a and downconverter 324 b are driven by local oscillators 326 a and 326 b 

respectively. The down converted signals are provided to filters 328 a and 328 b, which are low pass 

filters with a 1.228 MHz pass band. Similarly, filter 328 c is a low pass filter with a 1.228 MHz pass 

band. The base band signals are then provided to demodulator and searcher 330 which operate as 

described with respect to demodulator and searcher 116 of FIG. 2. The signal provided through filter 

328 c can be demodulated by two demodulators, one to demodulate the signal transmitted from the 

first system (on carrier 250 a) and one to demodulate the signal transmitted by the second system (on 

carrier 252 a). In the alternative, a single demodulator can be time shared demodulating the signal 

from the first system and at certain intervals demodulating the signal transmitted from the second 

system.

See, e.g., Chen-868 at 13:41-14:36.

Furthermore, this claim element is obvious in light of Chen-868 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 59-11 Filed 07/11/24 Page 135 of 158 PageID #:

3221
135

Claim 22 of the ’802 Patent Prior Art Reference – Chen-868

[22.1] The communication 

system of claim 17

Chen-868 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.

Chen-868 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.: 

In the present invention, high speed data is provided by transmitting data on multiple carrier 

frequencies, multiple code channels and/or from multiple base stations. In a first embodiment of the 

present invention, multiplexed code symbols are transmitted on a plurality of carrier frequencies from 

the same base station. In second embodiment, code symbols are transmitted on multiple carrier 

frequencies with at least one corner frequency providing the code symbols is a multiple code 

channels. In a third embodiment, a subset of the multiplexed code symbols are redundantly provided 

on a different carrier from at least one additional base station. In a fourth embodiment, multiplexed 

symbols as transmitted on different carriers from the same base station and are redundantly 

transmitted on another set of carriers from a different base station. In a fifth embodiment, code 

symbols are multiplexed onto carriers from a plurality of base stations for increased throughput. In a 

sixth embodiment, code symbols are transmitted on carriers from a first base station and redundantly 

provided on at least one additional base station on the same carriers as used by the first base station.

See, e.g., Chen-868 at Abstract.

Case 2:23-cv-00285-JRG-RSP Document 59-11 Filed 07/11/24 Page 136 of 158 PageID #:

3222
136

Claim 22 of the ’802 Patent Prior Art Reference – Chen-868

See, e.g., Chen-868 at Figure 5.

See, e.g., Chen-868 at Figure 6.

FIG. 6 is a block diagram of a receiver structure which provides for reduced hardware requirement in 

the reception of signals transmitted in accordance with the present invention.

See, e.g., Chen-868 at 3:7-10.

Referring to FIG. 3B, the data is again provided in three bands, although the present invention is 

easily extendible to an arbitrary number of bands. The first signal 160 is transmitted on a frequency 

of 850 MHz, the second signal 162 is transmitted on a frequency of 920 MHz, and the third signal is 

transmitted on a frequency of 928 MHz. In order to demodulate data transmitted on these three bands, 

Case 2:23-cv-00285-JRG-RSP Document 59-11 Filed 07/11/24 Page 137 of 158 PageID #:

3223
137

Claim 22 of the ’802 Patent Prior Art Reference – Chen-868

the signals might first be down converted by 800 MHz and then provided to downconverters 110 a -

110 j, which would complete the downconversion to a baseband. A first downconverter 104 performs 

a downconversion of 48 MHz to provide a first low frequency signal at 2 MHz. A second 

downconverter 110 performs a downconversion of 68 MHz to provide a second low frequency signal 

at 2 MHz. A third downconverter 110 performs a downconversion of 76 MHz to provide a third low 

frequency signal at 2 MHz.

See, e.g., Chen-868 at 4:56-5:4.

FIG. 5 illustrates a frequency band allotment of two separate 5 MHz (or 3.75 MHz) bands. The first 

group of adjacent carriers is illustrated by frequency bands 250 a, 250 b and 250 c. The second group 

of adjacent carriers is illustrated by carriers 252 a, 252 b and 252 c. The receiver structure illustrated 

in FIG. 6 is capable of receiving information on the three carriers 250 a, 250 b and 250 c and 

simultaneously searching or receiving data on one of carriers 252 a, 252 b and 252 c.

To illustrate the operation and advantages of the receiver in FIG. 6, it will be assumed that the mobile 

station in which receiver 350 is located is currently receiving data on carriers 250 a, 250 b and 250 c 

and that the mobile station will search band 252 a to determine whether it is capable of receiving 

service from the system providing the signal comprising carriers 252 a, 252 b and 252 c. It will be 

understood by one skilled in the art that data for the mobile station could be provided on carriers 252 

a, 252 b or 252 c by simply changing the searching operation to a demodulation operation.

Signals 250 a, 250 b, 250 c and 252 a are received at antenna 300 and provided through duplexer 302 

to low noise amplifier (LNA) 304. The amplified signal is provided to mixer 306. Mixer 306 down 

converts the signal in accordance with a signal provided by local oscillator 308 which brings the 5 

MHz band consisting of carriers 250 a, 250 b and 250 c down to a MHz wide baseband signal. The 

down converted signal is low pass filtered by filter (BPF1) 314 which is a low pass filter with a 5 

MHz pass band. The received signal is also provided to downconverter 310 which brings the signal 

carried on carrier 252 a down to base band. The down converted signal is low pass filtered by filter 

(BPF2) 316 which is a low pass filter with a 1.23 MHz pass band.

Case 2:23-cv-00285-JRG-RSP Document 59-11 Filed 07/11/24 Page 138 of 158 PageID #:

3224
138

Claim 22 of the ’802 Patent Prior Art Reference – Chen-868

The filtered signal from filter 314 is summed with the filtered signal from filter 316 in summer 318. 

The summed signal is amplified by automatic gain control (AGC) 320. The amplified signal is 

provided to analog to digital (A/D) converter 322. The digital signals are provided to downconverters 

324 a, 324 b and filter (BPF) 328 c. Downconverters 324 a and 324 b bring the signals carried on 

carriers 250 b and 250 c down to base band. The signal carried on carriers 250 a and 252 a are 

already at baseband and is provided directly to filter 328 c. The signals 250 a and 252 a act as 

interference to one another in the demodulation process but given sufficient coding and spreading 

gain, both the signals can be demodulated. In the present context of searching, it more often than not 

be the case that no signal is found and in that case the signal degradation will be minimum.

Downconverter 324 a and downconverter 324 b are driven by local oscillators 326 a and 326 b 

respectively. The down converted signals are provided to filters 328 a and 328 b, which are low pass 

filters with a 1.228 MHz pass band. Similarly, filter 328 c is a low pass filter with a 1.228 MHz pass 

band. The base band signals are then provided to demodulator and searcher 330 which operate as 

described with respect to demodulator and searcher 116 of FIG. 2. The signal provided through filter 

328 c can be demodulated by two demodulators, one to demodulate the signal transmitted from the 

first system (on carrier 250 a) and one to demodulate the signal transmitted by the second system (on 

carrier 252 a). In the alternative, a single demodulator can be time shared demodulating the signal 

from the first system and at certain intervals demodulating the signal transmitted from the second 

system.

See, e.g., Chen-868 at 13:41-14:36.

Furthermore, this claim element is obvious in light of Chen-868 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.

Case 2:23-cv-00285-JRG-RSP Document 59-11 Filed 07/11/24 Page 139 of 158 PageID #:

3225
139

Claim 23 of the ’802 Patent Prior Art Reference – Chen-868

[23.1] The communication 

system of claim 17

Chen-868 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.

Chen-868 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.: 

In the present invention, high speed data is provided by transmitting data on multiple carrier 

frequencies, multiple code channels and/or from multiple base stations. In a first embodiment of the 

present invention, multiplexed code symbols are transmitted on a plurality of carrier frequencies from 

the same base station. In second embodiment, code symbols are transmitted on multiple carrier 

frequencies with at least one corner frequency providing the code symbols is a multiple code 

channels. In a third embodiment, a subset of the multiplexed code symbols are redundantly provided 

on a different carrier from at least one additional base station. In a fourth embodiment, multiplexed 

symbols as transmitted on different carriers from the same base station and are redundantly 

transmitted on another set of carriers from a different base station. In a fifth embodiment, c ode 

symbols are multiplexed onto carriers from a plurality of base stations for increased throughput. In a 

sixth embodiment, code symbols are transmitted on carriers from a first base station and redundantly 

provided on at least one additional base station on the same carriers as used by the first base station.

See, e.g., Chen-868 at Abstract.

Case 2:23-cv-00285-JRG-RSP Document 59-11 Filed 07/11/24 Page 140 of 158 PageID #:

3226
140

Claim 23 of the ’802 Patent Prior Art Reference – Chen-868

See, e.g., Chen-868 at Figure 5.

See, e.g., Chen-868 at Figure 6.

Case 2:23-cv-00285-JRG-RSP Document 59-11 Filed 07/11/24 Page 141 of 158 PageID #:

3227
141

Claim 23 of the ’802 Patent Prior Art Reference – Chen-868

FIG. 6 is a block diagram of a receiver structure which provides for reduced hardware requirement in 

the reception of signals transmitted in accordance with the present invention.

See, e.g., Chen-868 at 3:7-10.

Referring to FIG. 3B, the data is again provided in three bands, although the present invention is 

easily extendible to an arbitrary number of bands. The first signal 160 is transmitted on a frequency 

of 850 MHz, the second signal 162 is transmitted on a frequency of 920 MHz, and the third signal is 

transmitted on a frequency of 928 MHz. In order to demodulate data transmitted on these three bands, 

the signals might first be down converted by 800 MHz and then provided to downconverters 110 a -

110 j, which would complete the downconversion to a baseband. A first downconverter 104 performs 

a downconversion of 48 MHz to provide a first low frequency signal at 2 MHz. A second 

downconverter 110 performs a downconversion of 68 MHz to provide a second low frequency signal 

at 2 MHz. A third downconverter 110 performs a downconversion of 76 MHz to provide a third low 

frequency signal at 2 MHz.

See, e.g., Chen-868 at 4:56-5:4.

FIG. 5 illustrates a frequency band allotment of two separate 5 MHz (or 3.75 MHz) bands. The first 

group of adjacent carriers is illustrated by frequency bands 250 a, 250 b and 250 c. The second group 

of adjacent carriers is illustrated by carriers 252 a, 252 b and 252 c. The receiver structure illustrated 

in FIG. 6 is capable of receiving information on the three carriers 250 a, 250 b and 250 c and 

simultaneously searching or receiving data on one of carriers 252 a, 252 b and 252 c.

To illustrate the operation and advantages of the receiver in FIG. 6, it will be assumed that the mobile 

station in which receiver 350 is located is currently receiving data on carriers 250 a, 250 b and 250 c 

and that the mobile station will search band 252 a to determine whether it is capable of receiving 

service from the system providing the signal comprising carriers 252 a, 252 b and 252 c. It will be 

understood by one skilled in the art that data for the mobile station could be provided on carriers 252 

a, 252 b or 252 c by simply changing the searching operation to a demodulation operation.

Case 2:23-cv-00285-JRG-RSP Document 59-11 Filed 07/11/24 Page 142 of 158 PageID #:

3228
142

Claim 23 of the ’802 Patent Prior Art Reference – Chen-868

Signals 250 a, 250 b, 250 c and 252 a are received at antenna 300 and provided through duplexer 302 

to low noise amplifier (LNA) 304. The amplified signal is provided to mixer 306. Mixer 306 down 

converts the signal in accordance with a signal provided by local oscillator 308 which brings the 5 

MHz band consisting of carriers 250 a, 250 b and 250 c down to a MHz wide baseband signal. The 

down converted signal is low pass filtered by filter (BPF1) 314 which is a low pass filter with a 5 

MHz pass band. The received signal is also provided to downconverter 310 which brings the signal 

carried on carrier 252 a down to base band. The down converted signal is low pass filtered by filter 

(BPF2) 316 which is a low pass filter with a 1.23 MHz pass band.

The filtered signal from filter 314 is summed with the filtered signal from filter 316 in summer 318. 

The summed signal is amplified by automatic gain control (AGC) 320. The amplified signal is 

provided to analog to digital (A/D) converter 322. The digital signals are provided to downconverters 

324 a, 324 b and filter (BPF) 328 c. Downconverters 324 a and 324 b bring the signals carried on 

carriers 250 b and 250 c down to base band. The signal carried on carriers 250 a and 252 a are 

already at baseband and is provided directly to filter 328 c. The signals 250 a and 252 a act as 

interference to one another in the demodulation process but given sufficient coding and spreading 

gain, both the signals can be demodulated. In the present context of searching, it more often than not 

be the case that no signal is found and in that case the signal degradation will be minimum.

Downconverter 324 a and downconverter 324 b are driven by local oscillators 326 a and 326 b 

respectively. The down converted signals are provided to filters 328 a and 328 b, which are low pass 

filters with a 1.228 MHz pass band. Similarly, filter 328 c is a low pass filter with a 1.228 MHz pass 

band. The base band signals are then provided to demodulator and searcher 330 which operate as 

described with respect to demodulator and searcher 116 of FIG. 2. The signal provided through filter 

328 c can be demodulated by two demodulators, one to demodulate the signal transmitted from the 

first system (on carrier 250 a) and one to demodulate the signal transmitted by the second system (on 

carrier 252 a). In the alternative, a single demodulator can be time shared demodulating the signal 

from the first system and at certain intervals demodulating the signal transmitted from the second 

system.

Case 2:23-cv-00285-JRG-RSP Document 59-11 Filed 07/11/24 Page 143 of 158 PageID #:

3229
143

Claim 23 of the ’802 Patent Prior Art Reference – Chen-868

See, e.g., Chen-868 at 13:41-14:36.

Furthermore, this claim element is obvious in light of Chen-868 itself, when combined with any of 

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

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

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

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

First Supplemental Ex. A-Obviousness Chart.

Claim 24 of the ’802 Patent Prior Art Reference – Chen-868

[24.1] An electronic circuit 

comprising:

To the extent the preamble is limiting, Chen-868 discloses “An electronic circuit comprising.” See, 

e.g.: 

In the present invention, high speed data is provided by transmitting data on multiple carrier 

frequencies, multiple code channels and/or from multiple base stations. In a first embodiment of the 

present invention, multiplexed code symbols are transmitted on a plurality of carrier frequencies from 

the same base station. In second embodiment, code symbols are transmitted on multiple carrier 

frequencies with at least one corner frequency providing the code symbols is a multiple code 

channels. In a third embodiment, a subset of the multiplexed code symbols are redundantly provided 

on a different carrier from at least one additional base station. In a fourth embodiment, multiplexed 

symbols as transmitted on different carriers from the same base station and are redundantly 

transmitted on another set of carriers from a different base station. In a fifth embodiment, code 

symbols are multiplexed onto carriers from a plurality of base stations for increased throughput. In a 

sixth embodiment, code symbols are transmitted on carriers from a first base station and redundantly 

provided on at least one additional base station on the same carriers as used by the first base station.

See, e.g., Chen-868 at Abstract.

Case 2:23-cv-00285-JRG-RSP Document 59-11 Filed 07/11/24 Page 144 of 158 PageID #:

3230
144

Claim 24 of the ’802 Patent Prior Art Reference – Chen-868

See, e.g., Chen-868 at Figure 5.

See, e.g., Chen-868 at Figure 6.

Case 2:23-cv-00285-JRG-RSP Document 59-11 Filed 07/11/24 Page 145 of 158 PageID #:

3231
145

Claim 24 of the ’802 Patent Prior Art Reference – Chen-868

FIG. 6 is a block diagram of a receiver structure which provides for reduced hardware requirement in 

the reception of signals transmitted in accordance with the present invention.

See, e.g., Chen-868 at 3:7-10.

Furthermore, this claim element is obvious in light of Chen-868 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;

Chen-868 discloses “a first down-converter circuit having a first input coupled to receive a first upconverted signal, a second input coupled to receive a first demodulation signal having a first RF 

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

signal on the first down-converter output.” See, e.g.: 

In the present invention, high speed data is provided by transmitting data on multiple carrier 

frequencies, multiple code channels and/or from multiple base stations. In a first embodiment of the 

present invention, multiplexed code symbols are transmitted on a plurality of carrier frequencies from 

the same base station. In second embodiment, code symbols are transmitted on multiple carrier 

frequencies with at least one corner frequency providing the code symbols is a multiple code 

channels. In a third embodiment, a subset of the multiplexed code symbols are redundantly provided 

on a different carrier from at least one additional base station. In a fourth embodiment, multiplexed 

symbols as transmitted on different carriers from the same base station and are redundantly 

transmitted on another set of carriers from a different base station. In a fifth embodiment, code 

symbols are multiplexed onto carriers from a plurality of base stations for increased throughput. In a 

sixth embodiment, code symbols are transmitted on carriers from a first base station and redundantly 

provided on at least one additional base station on the same carriers as used by the first base station.

Case 2:23-cv-00285-JRG-RSP Document 59-11 Filed 07/11/24 Page 146 of 158 PageID #:

3232
146

Claim 24 of the ’802 Patent Prior Art Reference – Chen-868

See, e.g., Chen-868 at Abstract.

See, e.g., Chen-868 at Figure 5.

Case 2:23-cv-00285-JRG-RSP Document 59-11 Filed 07/11/24 Page 147 of 158 PageID #:

3233
147

Claim 24 of the ’802 Patent Prior Art Reference – Chen-868

See, e.g., Chen-868 at Figure 6.

FIG. 6 is a block diagram of a receiver structure which provides for reduced hardware requirement in 

the reception of signals transmitted in accordance with the present invention.

See, e.g., Chen-868 at 3:7-10.

Referring to FIG. 3B, the data is again provided in three bands, although the present invention is 

easily extendible to an arbitrary number of bands. The first signal 160 is transmitted on a frequency 

of 850 MHz, the second signal 162 is transmitted on a frequency of 920 MHz, and the third signal is 

transmitted on a frequency of 928 MHz. In order to demodulate data transmitted on these three bands, 

the signals might first be down converted by 800 MHz and then provided to downconverters 110 a -

110 j, which would complete the downconversion to a baseband. A first downconverter 104 performs 

Case 2:23-cv-00285-JRG-RSP Document 59-11 Filed 07/11/24 Page 148 of 158 PageID #:

3234
148

Claim 24 of the ’802 Patent Prior Art Reference – Chen-868

a downconversion of 48 MHz to provide a first low frequency signal at 2 MHz. A second 

downconverter 110 performs a downconversion of 68 MHz to provide a second low frequency signal 

at 2 MHz. A third downconverter 110 performs a downconversion of 76 MHz to provide a third low 

frequency signal at 2 MHz.

See, e.g., Chen-868 at 4:56-5:4.

FIG. 5 illustrates a frequency band allotment of two separate 5 MHz (or 3.75 MHz) bands. The first 

group of adjacent carriers is illustrated by frequency bands 250 a, 250 b and 250 c. The second group 

of adjacent carriers is illustrated by carriers 252 a, 252 b and 252 c. The receiver structure illustrated 

in FIG. 6 is capable of receiving information on the three carriers 250 a, 250 b an d 250 c and 

simultaneously searching or receiving data on one of carriers 252 a, 252 b and 252 c.

To illustrate the operation and advantages of the receiver in FIG. 6, it will be assumed that the mobile 

station in which receiver 350 is located is currently receiving data on carriers 250 a, 250 b and 250 c 

and that the mobile station will search band 252 a to determine whether it is capable of receiving 

service from the system providing the signal comprising carriers 252 a, 252 b and 252 c. It will be 

understood by one skilled in the art that data for the mobile station could be provided on carriers 252 

a, 252 b or 252 c by simply changing the searching operation to a demodulation operation.

Signals 250 a, 250 b, 250 c and 252 a are received at antenna 300 and provided through duplexer 302 

to low noise amplifier (LNA) 304. The amplified signal is provided to mixer 306. Mixer 306 down 

converts the signal in accordance with a signal provided by local oscillator 308 which brings the 5 

MHz band consisting of carriers 250 a, 250 b and 250 c down to a MHz wide baseband signal. The 

down converted signal is low pass filtered by filter (BPF1) 314 which is a low pass filter with a 5 

MHz pass band. The received signal is also provided to downconverter 310 which brings the signal 

carried on carrier 252 a down to base band. The down converted signal is low pass filtered by filter 

(BPF2) 316 which is a low pass filter with a 1.23 MHz pass band.

The filtered signal from filter 314 is summed with the filtered signal from filter 316 in summer 318. 

The summed signal is amplified by automatic gain control (AGC) 320. The amplified signal is 

Case 2:23-cv-00285-JRG-RSP Document 59-11 Filed 07/11/24 Page 149 of 158 PageID #:

3235
149

Claim 24 of the ’802 Patent Prior Art Reference – Chen-868

provided to analog to digital (A/D) converter 322. The digital signals are provided to downconverters 

324 a, 324 b and filter (BPF) 328 c. Downconverters 324 a and 324 b bring the signals carried on 

carriers 250 b and 250 c down to base band. The signal carried on carriers 250 a and 252 a are 

already at baseband and is provided directly to filter 328 c. The signals 250 a and 252 a a ct as 

interference to one another in the demodulation process but given sufficient coding and spreading 

gain, both the signals can be demodulated. In the present context of searching, it more often than not 

be the case that no signal is found and in that case the signal degradation will be minimum.

Downconverter 324 a and downconverter 324 b are driven by local oscillators 326 a and 326 b 

respectively. The down converted signals are provided to filters 328 a and 328 b, which are low pass 

filters with a 1.228 MHz pass band. Similarly, filter 328 c is a low pass filter with a 1.228 MHz pass 

band. The base band signals are then provided to demodulator and searcher 330 which operate as 

described with respect to demodulator and searcher 116 of FIG. 2. The signal provided through filter 

328 c can be demodulated by two demodulators, one to demodulate the signal transmitted from the 

first system (on carrier 250 a) and one to demodulate the signal transmitted by the second system (on 

carrier 252 a). In the alternative, a single demodulator can be time shared demodulating the signal 

from the first system and at certain intervals demodulating the signal transmitted from the second 

system.

See, e.g., Chen-868 at 13:41-14:36.

Furthermore, this claim element is obvious in light of Chen-868 itself, when combined with any of 

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

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

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

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

First Supplemental Ex. A-Obviousness Chart.

[24.3] a second downconverter circuit having a first 

input coupled to receive the 

Chen-868 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 down -

Case 2:23-cv-00285-JRG-RSP Document 59-11 Filed 07/11/24 Page 150 of 158 PageID #:

3236
150

Claim 24 of the ’802 Patent Prior Art Reference – Chen-868

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

converter 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.: 

In the present invention, high speed data is provided by transmitting data on multiple carrier 

frequencies, multiple code channels and/or from multiple base stations. In a first embodiment of the 

present invention, multiplexed code symbols are transmitted on a plurality of carrier frequencies from 

the same base station. In second embodiment, code symbols are transmitted on multiple carrier 

frequencies with at least one corner frequency providing the code symbols is a multiple code 

channels. In a third embodiment, a subset of the multiplexed code symbols are redundantly provided 

on a different carrier from at least one additional base station. In a fourth embodiment, multiplexed 

symbols as transmitted on different carriers from the same base station and are redundantly 

transmitted on another set of carriers from a different base station. In a fifth embodiment, code 

symbols are multiplexed onto carriers from a plurality of base stations for increased throughput. In a 

sixth embodiment, code symbols are transmitted on carriers from a first base station and redundantly 

provided on at least one additional base station on the same carriers as used by the first base station.

See, e.g., Chen-868 at Abstract.

See, e.g., Chen-868 at Figure 5.

Case 2:23-cv-00285-JRG-RSP Document 59-11 Filed 07/11/24 Page 151 of 158 PageID #:

3237
151

Claim 24 of the ’802 Patent Prior Art Reference – Chen-868

See, e.g., Chen-868 at Figure 6.

FIG. 6 is a block diagram of a receiver structure which provides for reduced hardware requirement in 

the reception of signals transmitted in accordance with the present invention.

See, e.g., Chen-868 at 3:7-10.

Referring to FIG. 3B, the data is again provided in three bands, although the present invention is 

easily extendible to an arbitrary number of bands. The first signal 160 is transmitted on a frequency 

of 850 MHz, the second signal 162 is transmitted on a frequency of 920 MHz, and the third signal is 

transmitted on a frequency of 928 MHz. In order to demodulate data transmitted on these three bands, 

the signals might first be down converted by 800 MHz and then provided to downconverters 110 a110 j, which would complete the downconversion to a baseband. A first downconverter 104 performs 

Case 2:23-cv-00285-JRG-RSP Document 59-11 Filed 07/11/24 Page 152 of 158 PageID #:

3238
152

Claim 24 of the ’802 Patent Prior Art Reference – Chen-868

a downconversion of 48 MHz to provide a first low frequency signal at 2 MHz. A second 

downconverter 110 performs a downconversion of 68 MHz to provide a second low frequency signal 

at 2 MHz. A third downconverter 110 performs a downconversion of 76 MHz to provide a third low 

frequency signal at 2 MHz.

See, e.g., Chen-868 at 4:56-5:4.

FIG. 5 illustrates a frequency band allotment of two separate 5 MHz (or 3.75 MHz) bands. The first 

group of adjacent carriers is illustrated by frequency bands 250 a, 250 b and 250 c. The second group 

of adjacent carriers is illustrated by carriers 252 a, 252 b and 252 c. The receiver structure illustrated 

in FIG. 6 is capable of receiving information on the three carriers 250 a, 250 b and 250 c and 

simultaneously searching or receiving data on one of carriers 252 a, 252 b and 252 c.

To illustrate the operation and advantages of the receiver in FIG. 6, it will be assumed that the mobile 

station in which receiver 350 is located is currently receiving data on carriers 250 a, 250 b and 250 c 

and that the mobile station will search band 252 a to determine whether it is capable of receiving 

service from the system providing the signal comprising carriers 252 a, 252 b and 252 c. It will be 

understood by one skilled in the art that data for the mobile station could be provided on carriers 252 

a, 252 b or 252 c by simply changing the searching operation to a demodulation operation.

Signals 250 a, 250 b, 250 c and 252 a are received at antenna 300 and provided through duplexer 302 

to low noise amplifier (LNA) 304. The amplified signal is provided to mixer 306. Mixer 306 down 

converts the signal in accordance with a signal provided by local oscillator 308 which brings the 5 

MHz band consisting of carriers 250 a, 250 b and 250 c down to a MHz wide baseband signal. The 

down converted signal is low pass filtered by filter (BPF1) 314 which is a low pass filter with a 5 

MHz pass band. The received signal is also provided to downconverter 310 which brings the signal 

carried on carrier 252 a down to base band. The down converted signal is low pass filtered by filter 

(BPF2) 316 which is a low pass filter with a 1.23 MHz pass band.

The filtered signal from filter 314 is summed with the filtered signal from filter 316 in summer 318. 

The summed signal is amplified by automatic gain control (AGC) 320. The amplified signal is 

Case 2:23-cv-00285-JRG-RSP Document 59-11 Filed 07/11/24 Page 153 of 158 PageID #:

3239
153

Claim 24 of the ’802 Patent Prior Art Reference – Chen-868

provided to analog to digital (A/D) converter 322. The digital signals are provided to downconverters 

324 a, 324 b and filter (BPF) 328 c. Downconverters 324 a and 324 b bring the signals carried on 

carriers 250 b and 250 c down to base band. The signal carried on carriers 250 a an d 252 a are 

already at baseband and is provided directly to filter 328 c. The signals 250 a and 252 a act as 

interference to one another in the demodulation process but given sufficient coding and spreading 

gain, both the signals can be demodulated. In the present context of searching, it more often than not 

be the case that no signal is found and in that case the signal degradation will be minimum.

Downconverter 324 a and downconverter 324 b are driven by local oscillators 326 a and 326 b 

respectively. The down converted signals are provided to filters 328 a and 328 b, which are low pass 

filters with a 1.228 MHz pass band. Similarly, filter 328 c is a low pass filter with a 1.228 MHz pass 

band. The base band signals are then provided to demodulator and searcher 330 which operate as 

described with respect to demodulator and searcher 116 of FIG. 2. The signal provided through filter 

328 c can be demodulated by two demodulators, one to demodulate the signal transmitted from the 

first system (on carrier 250 a) and one to demodulate the signal transmitted by the second system (on 

carrier 252 a). In the alternative, a single demodulator can be time shared demodulating the signal 

from the first system and at certain intervals demodulating the signal transmitted from the second 

system.

See, e.g., Chen-868 at 13:41-14:36.

Furthermore, this claim element is obvious in light of Chen-868 itself, when combined with any of 

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

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

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

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

First Supplemental Ex. A-Obviousness Chart.

[24.4] a filter having an input 

coupled to the output of the 

first down-converter and the 

Chen-868 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.: 

Case 2:23-cv-00285-JRG-RSP Document 59-11 Filed 07/11/24 Page 154 of 158 PageID #:

3240
154

Claim 24 of the ’802 Patent Prior Art Reference – Chen-868

output of the second downconverter, and in accordance 

therewith, the filter receives 

the first and second downconverted signals.

In the present invention, high speed data is provided by transmitting data on multiple carrier 

frequencies, multiple code channels and/or from multiple base stations. In a first embodiment of the 

present invention, multiplexed code symbols are transmitted on a plurality of carrier frequencies from 

the same base station. In second embodiment, code symbols are transmitted on multiple carrier 

frequencies with at least one corner frequency providing the code symbols is a multiple code 

channels. In a third embodiment, a subset of the multiplexed code symbols are redundantly provided 

on a different carrier from at least one additional base station. In a fourth embodiment, multiplexed 

symbols as transmitted on different carriers from the same base station and are redundantly 

transmitted on another set of carriers from a different base station. In a fifth embodiment, code 

symbols are multiplexed onto carriers from a plurality of base stations for increased throughput. In a 

sixth embodiment, code symbols are transmitted on carriers from a first base station and redundantly 

provided on at least one additional base station on the same carriers as used by the first base station.

See, e.g., Chen-868 at Abstract.

See, e.g., Chen-868 at Figure 5.

Case 2:23-cv-00285-JRG-RSP Document 59-11 Filed 07/11/24 Page 155 of 158 PageID #:

3241
155

Claim 24 of the ’802 Patent Prior Art Reference – Chen-868

See, e.g., Chen-868 at Figure 6.

FIG. 6 is a block diagram of a receiver structure which provides for reduced hardware requirement in 

the reception of signals transmitted in accordance with the present invention.

See, e.g., Chen-868 at 3:7-10.

Referring to FIG. 3B, the data is again provided in three bands, although the present invention is 

easily extendible to an arbitrary number of bands. The first signal 160 is transmitted on a frequency 

of 850 MHz, the second signal 162 is transmitted on a frequency of 920 MHz, and the third signal is 

transmitted on a frequency of 928 MHz. In order to demodulate data transmitted on these three bands, 

the signals might first be down converted by 800 MHz and then provided to downconverters 110 a -

110 j, which would complete the downconversion to a baseband. A first downconverter 104 performs 

Case 2:23-cv-00285-JRG-RSP Document 59-11 Filed 07/11/24 Page 156 of 158 PageID #:

3242
156

Claim 24 of the ’802 Patent Prior Art Reference – Chen-868

a downconversion of 48 MHz to provide a first low frequency signal at 2 MHz. A second 

downconverter 110 performs a downconversion of 68 MHz to provide a second low frequency signal 

at 2 MHz. A third downconverter 110 performs a downconversion of 76 MHz to provide a third low 

frequency signal at 2 MHz.

See, e.g., Chen-868 at 4:56-5:4.

FIG. 5 illustrates a frequency band allotment of two separate 5 MHz (or 3.75 MHz) bands. The first 

group of adjacent carriers is illustrated by frequency bands 250 a, 250 b and 250 c. The second group 

of adjacent carriers is illustrated by carriers 252 a, 252 b and 252 c. The receiver structure illustrated 

in FIG. 6 is capable of receiving information on the three carriers 250 a, 250 b and 250 c and 

simultaneously searching or receiving data on one of carriers 252 a, 252 b and 252 c.

To illustrate the operation and advantages of the receiver in FIG. 6, it will be assumed that the mobile 

station in which receiver 350 is located is currently receiving data on carriers 250 a, 250 b and 250 c 

and that the mobile station will search band 252 a to determine whether it is capable of receiving 

service from the system providing the signal comprising carriers 252 a, 252 b and 252 c. It will be 

understood by one skilled in the art that data for the mobile station could be provided on carriers 252 

a, 252 b or 252 c by simply changing the searching operation to a demodulation operation.

Signals 250 a, 250 b, 250 c and 252 a are received at antenna 300 and provided through duplexer 302 

to low noise amplifier (LNA) 304. The amplified signal is provided to mixer 306. Mixer 306 down 

converts the signal in accordance with a signal provided by local oscillator 308 wh ich brings the 5 

MHz band consisting of carriers 250 a, 250 b and 250 c down to a MHz wide baseband signal. The 

down converted signal is low pass filtered by filter (BPF1) 314 which is a low pass filter with a 5 

MHz pass band. The received signal is also provided to downconverter 310 which brings the signal 

carried on carrier 252 a down to base band. The down converted signal is low pass filtered by filter 

(BPF2) 316 which is a low pass filter with a 1.23 MHz pass band.

The filtered signal from filter 314 is summed with the filtered signal from filter 316 in summer 318. 

The summed signal is amplified by automatic gain control (AGC) 320. The amplified signal is 

Case 2:23-cv-00285-JRG-RSP Document 59-11 Filed 07/11/24 Page 157 of 158 PageID #:

3243
157

Claim 24 of the ’802 Patent Prior Art Reference – Chen-868

provided to analog to digital (A/D) converter 322. The digital signals are provided to downconverters 

324 a, 324 b and filter (BPF) 328 c. Downconverters 324 a and 324 b bring the signals carried on 

carriers 250 b and 250 c down to base band. The signal carried on carriers 250 a and 252 a are 

already at baseband and is provided directly to filter 328 c. The signals 250 a and 252 a act as 

interference to one another in the demodulation process but given sufficient coding and spreading 

gain, both the signals can be demodulated. In the present context of searching, it more often than not 

be the case that no signal is found and in that case the signal degradation will be minimum.

Downconverter 324 a and downconverter 324 b are driven by local oscillators 326 a and 326 b 

respectively. The down converted signals are provided to filters 328 a and 328 b, which are low pass 

filters with a 1.228 MHz pass band. Similarly, filter 328 c is a low pass filter with a 1.228 MHz pass 

band. The base band signals are then provided to demodulator and searcher 330 which operate as 

described with respect to demodulator and searcher 116 of FIG. 2. The signal provided through filter 

328 c can be demodulated by two demodulators, one to demodulate the signal transmitted from the 

first system (on carrier 250 a) and one to demodulate the signal transmitted by the second system (on 

carrier 252 a). In the alternative, a single demodulator can be time shared demodulating the signal 

from the first system and at certain intervals demodulating the signal transmitted from the second 

system.

See, e.g., Chen-868 at 13:41-14:36.

Furthermore, this claim element is obvious in light of Chen-868 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 59-11 Filed 07/11/24 Page 158 of 158 PageID #:

3244