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UNITED STATES DISTRICT COURT

EASTERN DISTRICT OF TEXAS

MARSHALL DIVISION

COBBLESTONE WIRELESS, LLC

Plaintiff,

v.

CISCO SYSTEMS, INC.

Defendant.

Case No. 2:23-cv-00454-JRG-RSP

(Lead Case)

COBBLESTONE WIRELESS, LLC

Plaintiff,

v.

HEWLETT PACKARD ENTERPRISE 

COMPANY, ARUBA NETWORKS, LLC

Defendants.

Case No. 2:23-cv-00457-JRG-RSP

(Member Case)

JURY TRIAL DEMANDED

DEFENDANTS’ RESPONSIVE CLAIM CONSTRUCTION BRIEF

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I. INTRODUCTION

Defendants Cisco Systems, Inc., Hewlett Packard Enterprise Company, and Aruba 

Networks, LLC (collectively, “Defendants”) contend that the two claim terms in dispute need not 

be construed. Plaintiff’s first proposed construction would have the Court deviate from the wellworn general rule that a preamble is non-limiting. None of Plaintiff’s arguments support this 

departure. The claim limitations themselves define a structurally complete method and no later 

claim limitations refer back to “in a wireless communication channel” for antecedent basis. There 

is thus no reason to depart from the conventional rule that the preamble does not limit otherwise 

complete claims. The Plaintiff’s second proposed construction would have the Court construe and 

add limitations to the term “center frequency.” But “center frequency” is a well understood term 

in the art and need not be construed, as Plaintiff suggests, to read into the claim the additional 

limitation of “the frequency of the carrier that the baseband signal is upconverted to.” 

Notably, both of Plaintiff’s proposed narrowing constructions are effectively copied and 

pasted from arguments it made in two separate IPRs as part of (misguided) attempts to avoid the 

cited prior art. See Samsung Elecs. Am. v. Cobblestone Wireless, LLC, IPR2024-00606, Paper 8, 

at 2-8 (“in a wireless communication channel” should be construed as limiting and limited to a 

single wireless communication channel); Hewlett Packard Enterprise Co. v. Cobblestone 

Wireless, LLC, IPR2024-00707, Paper 7, at 5-18 (“center frequency” should be construed as the 

“carrier signal frequency the baseband signal is up-converted to”). In its Institution Decisions, the 

PTAB rejected Plaintiff’s first proposed construction in the Samsung matter, and declined to adopt 

the second in the HPE matter, finding construction unnecessary to decide institution. See Samsung 

Elecs. Am. v. Cobblestone Wireless, LLC, IPR2024-00606, Paper 13, at 11 (“Based on the present 

record, we preliminarily determine that Petitioner has made a sufficient showing for purposes of 

institution that the phrase ‘a wireless communication channel’ in the preamble of claim 1 and 10 

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is not limiting.”); Hewlett Packard Enterprise Co. v. Cobblestone Wireless, LLC, IPR2024-00707, 

Paper 17, at 12 (“We determine that we do not need to resolve this claim construction issue for the 

purposes of institution . . . .”)

Likewise, the Court should not adopt Plaintiff’s proposed constructions here.

II. U.S. Patent No. 7,924,802 (“the ’802 Patent”)

The ’802 Patent relates to methods of transmitting information in wireless communication 

channels. As the ’802 Patent explains in the background section, prior art communication systems 

“generally contain one or more transmission channels to transmit data from the transmitter to the

receiver.” Dkt. 64-1 at 1:12-14. Figure 1 of the ’802 Patent illustrates an example of a transmitter

(element 100) used in a prior art wireless communication system:

Dkt. 64-1 at Fig. 1. In the context of Figure 1, element 110 is a “digital-to-analog converter” that 

“receives a digital input signal (“IN”)” and converts it to an analog signal. Dkt. 64-1 at 1:18-24.

Meanwhile, the “filter” (element 120) “may be used to remove undesirable frequencies and signal

images.” Id. The filter is coupled to a “mixer 130” that “may be used to up-convert the frequency 

of the signal by combining it with a local oscillator signal (“LO”).” Dkt. 64-1 at 1:24-29. Finally, 

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the output of the mixer goes to the power amplifier (element 140) to “amplify the signal for 

transmission before it is sent through antenna 150.” Id.

The ’802 Patent identifies a problem with this prior art approach, which is that the “amount

of information transmitted around the center frequency is limited by the bandwidth of the 

transmitter around the center frequency.” Dkt. 64-1 at 1:29-35. The bandwidth thus “limits the 

amount of data that can be transmitted.” Id. According to the ’802 Patent, prior art approaches to 

improving transmission capacity focused on “maximizing the bandwidth around” this single center 

frequency. Dkt. 64-1 at 1:35-40. The ’802 Patent’s specification describes a wireless transmitter 

with two transmitter channels designed to transmit multiple signals at different center frequencies, 

as shown in Figures 2 and 3 (“an example of the frequency content of the transmitted signal 300 

which may result from system 200”):

Dkt. 64-1 at Figs. 2-3, 5:53-6:9, 6:60-63. The two paths of Figure 2 (top and bottom), represent 

different channels that data (251 and 252) can travel through before the multiple signals are 

transmitted ‘simultaneously over a communication channel at different center frequencies’ using 

one or more power amplifier 208 and antenna 209’” being “combined at the input of [power] 

amplifier 208 before amplification to produce a combined up-converted signal” and that “antenna 

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209 is coupled to the output of amplifier 208 to transmit the amplified ups converted signal as an 

electromagnetic signal.” Dkt. 64-1 at 6:57-6:64. 

The ’802 Patent also describesthe ability to “change” the “frequency content” of transmitted

signals “within a bandwidth” of a power amplifier either “at irregular intervals or at regular intervals

(periodically).” Dkt. 64-1 at 7:19-57. Figure 4 of the ’802 Patent purports to illustrate these

frequency changes:

Dkt. 64-1 at Fig. 4. By reference to Figure 3, the specification explains that the “change in 

frequency” may “result in a new frequency content 410 in which the signal 401 has moved in 

frequency as illustrated by signal 411 having an RF center frequency 413 (f1B), and the signal 402 

has moved in frequency as illustrated by signal 412 having an RF center frequency 414 (f2B).” Dkt. 

64-1 at 7:29-33. As a result, the “changes may move the RF signals to adjacent or non-adjacent 

locations,” and the “spacing between the two RF center frequencies may remain the same or may 

vary.” Dkt. 64-1 at 7:44-57.

III. DISPUTED CLAIM TERMS

A. Preamble: “A method of transmitting information in a wireless 

communication channel comprising...” (Claim 1)

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Defendants’ Proposed Construction Plaintiff’s Proposed Construction

No construction necessary The preamble is limiting as to “in a wireless 

communication channel”

Plaintiff proposes a construction that deviates from two general principles of claim 

construction. Specifically, Plaintiff argues that (1) the preamble of claim 1 is limiting, and (2) the 

preamble’s “a wireless communication channel” term is limited to a single channel. Pl’s. Brief 

(Dkt. 64) at 1.

1. The Preamble of Claim 1 Is Not Limiting

“Generally, a preamble is not limiting.” Summit 6, LLC v. Samsung Elecs. Co., 802 F.3d

1283, 1292 (Fed. Cir. 2015). A preamble can be limiting if it “recites essential structure or steps, 

or if it is necessary to give life, meaning, and vitality to the claim.” Catalina Mktg. Int’l, Inc. v.

Coolsavings.com, Inc., 289 F.3d 801, 808 (Fed. Cir. 2002). However, if the patentee “defines a 

structurally complete invention in the claim body and uses the preamble only to state a purpose or 

intended use for the invention,” the preamble is not limiting. Id.

Plaintiff argues, without support, that claim 1 “does not recite a complete structure” and 

further contends that the preamble’s ‘in a wireless communication channel’ phrase is “necessary 

in imparting life and meaning to the claim.” Dkt. 64 at 1-2. But nothing in the limitations of the 

claim requires “in a wireless communication channel” to supply structure to the claim. “In a 

wireless communication channel” does not supply antecedent basis for any term in the body of the 

claim. Moreover, using claim 1 as an example, the method is performed by transmitting 

information across first and second frequency ranges using the same wireless transmitter; no 

additional context, much less a limitation to “in a wireless communication channel” is required for 

the method to be complete. See Dkt. 64-1, at claim 1. Notably, the PTAB reached the same 

conclusion when it rejected the same argument Plaintiff makes here: “Based on the present record, 

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we preliminarily agree with Petitioner that the body of claims 1 and 10 recite a structurally 

complete invention.” Samsung Elecs. Am. v. Cobblestone Wireless, LLC, IPR2024-00606, Paper 

13, at 11.

The specification of the ’802 Patent also makes clear that “a wireless communication 

channel” is not a structurally necessary limitation for method claim 1. For example, Figures 6, 7A 

and 7B are the only figures that depict methods (and map to claim 1). Yet, their corresponding

descriptions in the specification do not mention “a wireless communication channel” at all. Dkt. 

64-1 at 5:27-31, 9:9-10:61. The specification therefore confirms that the body of the claims recite 

a structurally complete invention, without resort to the preamble. There is thus no reason here to 

depart from the general rule that the preamble of an otherwise structurally complete invention is 

not limiting.

Plaintiff’s secondary argument, that “statements of intended purpose in methods of using 

apparatuses” are generally limiting, fares no better. Dkt. 64, at 2. To the contrary, Plaintiff’s 

citation to Eli Lilly & Co. v. Teva Pharms. Int’l GmbH, 8 F.4th 1331, 1341 (Fed. Cir. 2021) actually 

demonstrates why the preamble in this case is not limiting. In Eli Lilly, the claims were to methods 

for treating headaches, “comprising: . . . administering to the individual an effective amount of . . .” 

a drug. Id.at 1335. As the Federal Circuit explained, claims directed to a method of using a 

composition—such as a method of treatment claim—“typically rely entirely on what the method 

‘does’” and “what a method does is usually recited in its preamble.” Id. at 1341. Put in terms of 

the claim at issue there, administering an “effective amount” of a composition can only be read in 

relation to the intended purpose of “administering”: treating a headache. Under those 

circumstances, the Federal Circuit concluded that the “preambles give life and meaning to the 

‘effective amount’ recited in the lone method step of each challenged claim.” Id. at 1343. But the 

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court contrasted that situation with a method claim preamble like the one at issue here, that recites 

“merely a context in which the invention may be used.” Id.at 1341 (quoting Boehringer Ingelheim 

Vetmedica, Inc. v. Schering-Plough Corp., 320 F.3d 1339, 1345 (Fed. Cir. 2003)). A “context in 

which the invention may be used” is, of course, precisely what “in a wireless communication 

channel” is in the ’802 Patent. See Summit 6, LLC v. Samsung Elecs. Co., Ltd., 802 F.3d 1283, 

1292 (Fed. Cir. 2015) (preamble of method claim not limiting where it “merely provides context 

for the limitations”). Indeed, even Plaintiff admits that the preamble provides mere context: “[T]he 

preamble’s ‘in a wireless communication channel’ states the framework of the invention, and the 

context in which the specifically claimed transmission of information must take place.” Dkt. 64, 

at 3. That is precisely why the preamble is non-limiting, not the other way around.1

Accordingly, Plaintiff has not established that the “a wireless communication channel” 

limitation in the preamble of claim 1 is limiting.

2. “A” Means “One Or More”

In addition to arguing incorrectly that the “a wireless communication channel” phrase in the

preamble is limiting, Plaintiff further proposes that this phrase should be limited to a single 

channel.

As a starting point, Plaintiff does not dispute the claim construction principle that “[a]s a 

general rule, the words ‘a’ or ‘an’ in a patent claim carry the meaning of ‘one or more.’” TiVo, 

 1 Likewise, Eli Lilly contrasted claims like the one before it—claims directed to “what a method 

does”—with claims reciting “what the method ‘is,’” i.e., the steps necessary to complete it. In 

those contexts, like the claim here, a mere “statement of intended purpose” is not limiting because 

the method by itself is structurally complete. See Altiris, Inc. v. Symantec Corp., 318 F.3d 1363, 

1371-72 (Fed. Cir. 2003) (preamble reciting a “method of gaining control of the boot procedure of 

a digital computer” not limiting because it “merely recites a purpose of the invention and does not 

add anything to the body of the claims”). The same goes for the claims of the ’802 Patent, which 

recite transmitting steps that define a complete method, without reference to anything outside the 

claim body.

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Inc. v. EchoStar Commc’ns Corp., 516 F.3d 1290, 1303 (Fed. Cir. 2008). The “exceptions to this

rule are extremely limited: a patentee must evince a clear intent to limit ‘a’ or ‘an’ to ‘one.’”

Baldwin Graphic Sys., Inc. v. Siebert, Inc., 512 F.3d 1338, 1342 (Fed. Cir. 2008). Here, there is no 

such clear intent. 

Plaintiff argues this principle “does not apply where the article ‘a’ appears before 

‘comprising,’” relying on the Federal Circuit’s decision in Convolve, Inc. v. Compaq Computer 

Corp., 812 F.3d 1313, 1321 (Fed. Cir. 2016). Dkt. 46, at 4. Plaintiff misunderstands the holding 

in Convolve, which did not turn on the article “a” appearing before “comprising.” Instead, the court 

based its decision on the claim body’s use of “‘the processor,’ referring back to the ‘a processor’

recited in preamble” which “supports a conclusion that the recited user interface is ‘operatively 

working with’ the same processor to perform all of the recited steps.” Id. This was in contrast to 

claim 9, which recited “a processor” but not a subsequent “the processor,” which was thus held to

mean “one or more processors.” Id. Contrary to Plaintiff’s arguments, the court did not attach any 

significance to the term “a processor” appearing before the word “comprising.” Id.; see also 

Salazar v. AT&T Mobility LLC, 64 F.4th 1311, 1317 (Fed. Cir. 2023) (“Claim 9 [in Convolve] ...

had no subsequent reference to ‘the’ or ‘said’ processor [and so] we interpreted ‘a processor’ to

mean ‘one or more processors’). Instead, the court found that the context of the claim as a whole 

evinced a “clear intent” for the “same processor to perform all the recited steps.” See Convolve, 812 

F.3d at 1321. 

Indeed, Plaintiff’s argument and mischaracterization of Convolve would, on its face, be 

such a broad exception that it would swallow the general rule that “a” means “one or more,” and 

is inconsistent with Federal Circuit cases that have construed the article “a” to mean more than 

one even when appearing before “comprising.” See, e.g., Braintree Laboratories, Inc. v. Novel

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Laboratories, 749 F.3d 1349, 1357 (Fed. Cir. 2014) (holding that construction of “a patient” in 

preamble to be a single patient “leads to [an] absurd result”).

Plaintiff’s argument is also inconsistent with the specification of the ’802 Patent, which 

expressly contemplates embodiments that have more than one channel, stating that the received 

signal “may be processed in separate analog receiver channels and combined digitally.” Id., 10:51-

53; see also id. at 1:13-15 (“Communication systems generally contain one or more transmission 

channels to transmit data from the transmitter to the receiver.”). Thus, it is clear that Plaintiff has

not “evince[d] a clear intent to limit ‘a’ or ‘an’ to ‘one.’” Baldwin Graphic Sys., Inc., 512 F.3d at 

1342.

B. “first center frequency / second center frequency” (Claim 1)

Defendants’ Proposed Construction Plaintiff’s Proposed Construction

Plain and ordinary meaning The frequency of the carrier that the baseband 

signal is upconverted to

Plaintiff next asks the Court to redefine the well-understood term “center frequency” as 

“the carrier signal frequency the baseband signal is upconverted to,” despite claim 1 making no 

reference to baseband signals or up-conversion. Plaintiff’s construction is wrong because it 

diverges from the plain and ordinary meaning, attempts to import limitations from the 

specification, and is not supported by lexicography or disclaimer. 

Tellingly, Plaintiff does not contend that it can meet the stringent standards for disclaimer 

or for the patentee acting as its own lexicographer with respect to “center frequency.” Instead, 

Plaintiff tries to import from the specification the concept of an up-converted baseband signal 

based on what it argues is the inclusion of that concept in certain embodiments described in the 

specification. However, “[i]t is [] not enough that the only embodiments, or all of the embodiments, 

contain a particular limitation. We do not read limitations from the specification into claims; we 

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do not redefine words. Only the patentee can do that. To constitute disclaimer, there must be a 

clear and unmistakable disclaimer.” Thorner v. Sony Computer Entertainment America LLC, 669

F.3d 1362, 1366-67 (Fed. Cir. 2012). Notably, the concept of up-conversion and/or up-convertors 

is present in numerous unasserted claims (i.e., claims 10-24), but is absent from all of the asserted 

claims (i.e., claims 1-4 and 7-9). In other words, the patentee understood how to draft claims 

incorporating the concept of up-conversion when it wanted to. Yet, Plaintiff tries to impermissibly 

import that concept into all of the claims, regardless of whether they require “up-converting” or 

not. Dkt. 64 at 6. That is improper. 

As to Plaintiff’s argument that the specification refers to up-converting baseband signals 

to center frequencies in several embodiments, the ’802 Patent never defines or limits the claimed 

“center frequency” in those terms. Nor does the patent define the invention as requiring a first and 

second center frequency that each have been up-converted from a separate baseband signal. 

Instead, the patent uses permissive language (“may”) throughout the specification when referring 

to up-conversion of a baseband signal. Likewise, the patentee disclosed an embodiment in which 

center frequencies are shifted within the frequency bandwidth of the power amplifier, which can 

include post-up-conversion shifting, e.g., “. . . a new frequency content 410 in which the signal 

401 has moved in frequency as illustrated by signal 411 having an RF center frequency 413 . . . .” 

Dkt. 64-1 at 7:29-31. In this embodiment, the center frequency may not be the carrier signal 

frequency to which the baseband signal was up-converted, i.e., signal 401. Plaintiff’s proposed 

construction would contradict the specification.2

 2 Plaintiff’s citation to In re Abbott Diabetes Care Inc., 696 F.3d 1142 (Fed. Cir. 2012) does not 

support its argument. Abbott did not rely solely on the fact that embodiments in the specification 

limited the contested term to wireless sensors. Instead, the specification “contain[ed] only 

disparaging remarks with respect to external cables and wires of the prior-art sensors.” Id. at 1149 

(emphasis added). Where the “only mention” of a wired sensor was to highlight the “primary 

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Plaintiff’s reliance on Professor Cooklev’s Declaration does not save its argument. While 

Dr. Cooklev opines that the use of two center frequencies “is a major focus of the invention” (Dkt. 

64-2 at ¶ 44), his opinion does not support Plaintiff’s construction, which adds up-conversion and 

baseband signals. Claim 1 requires two center frequencies (one being higher than the other) and, 

therefore, center frequencies are part of the claimed invention. But that fact does not justify 

departing from the plain and ordinary meaning of center frequency, which is a frequency at the 

middle of the frequency range. See, e.g., Ex. B, 47 C.F.R. § 22.99 (defining “center frequency” as 

“the frequency of the middle of the bandwidth of a channel”); 59 F.R. 59498, at 59507 (Nov. 17, 

1994). To be sure, the claim language reinforces that plain and ordinary meaning by explicitly 

referring to “frequency range having a first center frequency, a first highest frequency, and a first 

lowest frequency.” Dkt. 64-1, at claim 1. The “center frequency,” then, is the middle of the 

“frequency range,” i.e., between the “first highest frequency” and the “first lowest frequency.” Dr. 

Cooklev does not analyze the term “center frequency” in the context of the surrounding claim 

language at all, and even misleadingly omits the “first highest frequency” and “first lowest 

frequency” language from his discussion of what claim 1 “requires” in a misguided attempt to 

support his opinion. See Dkt. 64-2, at ¶ 37. As such, Dr. Cooklev’s opinion does not support the 

argument that a POSITA would understand the plain and ordinary meaning of center frequency to 

be something other than the middle frequency of the frequency range recited in the claim.

Finally, Plaintiff tries to support its construction by claiming that the specification uses 

“center frequency” and “carrier frequency” “interchangeably” in a single embodiment. Dkt. 64, at 

 

deficiency of the prior art” the court concluded that the patentee had disclaimed wired sensors. In 

contrast, there is no similar disparagement of the ordinary meaning of “center frequency” in the 

specification of the ’802 Patent, and Plaintiff does not identify any. Moreover, as explained above, 

the specification contains embodiments that are not consistent with the narrower definition 

Plaintiff urges.

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11-12. This argument mistakes the proper use of the specification in claim construction. Notably, 

Plaintiff cites case law dealing with when “[d]ifferent terms or phrases in separate claims may be 

construed to cover the same subject matter,” with one instance being where the specification treats 

them as such. Virnetx, Inc. v. Cisco Systems, Inc., 767 F.3d 1308, 1318-19 (Fed. Cir. 2014) 

(concluding that “secure communication link” and “VPN” should be construed consistently based 

on usage in specification).3 That is a very different situation than the one at hand, in which no 

claim uses the term “carrier” or “carrier frequency”; those terms appear only in reference to the 

single embodiment Plaintiff references. Under those circumstances, where a term in an 

embodiment is used as an example of a center frequency, courts routinely decline to import the 

limitation of the narrower term into the more general one unless there is a “clear intention to limit 

the claim scope using words of expressions of manifest restriction or exclusion.” Arlington Indus., 

Inc. v. Bridgeport Fittings, Inc., 632 F.3d 1246, 1254 (Fed. Cir. 2011) (claim term did not include 

limitation referenced in one embodiment and drawings). Put simply, the patentee could have—but 

did not—use the term “carrier frequency” in place of center frequency in the claims. By choosing 

the broader term, its claims must be construed consistent with that usage, and not the self-serving 

limited construction that it now asks the Court to adopt.

Accordingly, the Court should adopt a plain and ordinary meaning for the well-understood 

term “center frequency.”

 3 Similarly, the other two cases cited by Plaintiff for this point, Baran v. Med. Device Techs, Inc., 

616 F.3d 1309 (Fed. Cir. 2010) and Haddad v. United States, 164 Fed. Cl. 28 (2023) addressed 

situations in which the court was asked to determine whether separate terms in a claim were 

interchangeable, not whether to read a claim term as interchangeable with a broader term contained 

only in the specification.

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Respectfully submitted,

/s/ Matthew S. Yungwirth

Matthew S. Yungwirth

GA State Bar No. 783597

msyungwirth@duanemorris.com

DUANE MORRIS LLP

1075 Peachtree Street NE

Suite 1700

Atlanta, Georgia 30309-3929

Telephone: (404)-253-6910

Tyler Marandola

PA State Bar No. 313585

tmarandola@duanemorris.com

DUANE MORRIS LLP

30 S. 17th Street

Philadelphia, PA 19103

Telephone: (215) 979-1000

Jennifer H. Doan

Texas Bar No. 08809050

jdoan@haltomdoan.com

Joshua R. Thane

Texas Bar No. 24060713

jthane@haltomdoan.com

HALTOM & DOAN

6500 Summerhill Rd., Suite 100

Texarkana, TX 75503

Telephone: 903.255.1000

Facsimile: 903.934.9257

Counsel for Defendants Hewlett Packard

Enterprise Company and Aruba Networks, LLC

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/s/ Kyrie K. Cameron

Kyrie K. Cameron (TBN 24079450)

kcameron@pattersonsheridan.com

Randol Wayne Read (TBN 00798457)

rread@pattersonsheridan.com

Archibald Deleon Cruz (TBN 24137564)

acruz@pattersonsheridan.com

PATTERSON + SHERIDAN LLP

24 Greenway Plaza, Suite 1600

Houston, Texas 77046

Telephone: (713) 623-4844

Facsimile: (713) 623-4846

Eric H. Findlay (TBN 00789886)

efindlay@findlaycraft.com

FINDLAY CRAFT, P.C.

7270 Crosswater Avenue, Suite B

Tyler, Texas 75703

Telephone: (903) 534-1100

Facsimile: (903) 534-1137

Holly Engelmann (TBN 24040865)

HEngelmann@duanemorris.com

DUANE MORRIS LLP

Terrace 7

2801 Via Fortuna, Suite 200

Austin, Texas 78746-7567

Telephone: (512) 277-2246

Facsimile: (512) 597-2301

Louis N. Jameson

WJameson@duanemorris.com

Matthew S. Yungwirth

msyungwirth@duanemorris.com

Jayla C. Grant

jcgrant@duanemorris.com

DUANE MORRIS LLP

1075 Peachtree Street NE, Suite 1700

Atlanta, GA 30309

Telephone: (404) 253-6915

Facsimile: (404) 253-6901

msyungwirth@duanemorris.com

JCGrant@duanemorris.com

Counsel for Defendant Cisco Systems, Inc.

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CERTIFICATE OF SERVICE

The undersigned certifies that a true and correct copy of the above and foregoing document 

has been served via the Court’s ECF system on October 22, 2024.

/s/ Kyrie K. Cameron

Kyrie K. Cameron

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