Exhibit D

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Exhibit B 

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Exhibit B - U.S. Patent No. 9,094,888 (“’888 Patent”)

Accused Instrumentalities: cellular base stations that support handover between 4G LTE and 5G NR wireless networks, and all versions and variations 

thereof since the issuance of the asserted patent. Based upon publicly available information and without the benefit of discovery in this case, these base 

stations include, but are not limited to the following products sold by Nokia, Ericsson, and Samsung:

Nokia: AirScale base station, AirScale radio and baseband, AirScale 5G mMIMO base station, ReefShark System on Chip and all products containing 

the same, AirScale Osprey, AirScale Habrok, AirScale mRRH, AirScale pRRH, AirScale 4.5G Pro RRH, AirScale sHUB, FZHR, AHBOA, FSIH, 

FHFB, AZHL, AAFIA, 32TRX, and 64TRX.

Ericsson: 4G AIR products, 4G Baseband products, 4G Radio products, 4G Antenna products, 5G AIR products, 5G Baseband products, 5G Radio 

products, 5G Antenna products, AIR 1279, AIR 3218, AIR 3219, AIR 3229, AIR 3239, AIR 3246, AIR 3258, AIR 3268, AIR 3283, AIR 6419, AIR 

6428, AIR 6468, AIR 6476, AIR 6488, Interleaved AIR, Baseband 5216, Baseband 6502, Baseband 6648, 5G Radio Dot, Radio 4407, Radio 4408, 

Radio 4412, Radio 4418, Radio 4485, Radio 4490, Radio 8808, Radio 8863, Antenna 4600, Antenna 4602, Antenna 5500, and Antenna 6600.

Samsung: 4G base stations, 5G base stations, 4T4R CBRS Radio, 32T32R Radio, 64T64R Radio, C-Band Radio, CDU50, One Antenna Radio, Link 

Hub, and Link HubPro.

Claim 9

Claim 9 Public Documentation

[9pre] A method implemented at a first wireless 

network for a mobile wireless device handoff between a second wireless network and the first wireless network, the method comprising:

To the extent the preamble is found to be limiting, the Accused Instrumentalities perform a method implemented at a first 

wireless network for a mobile wireless device handoff between a second wireless network and the first wireless network.

For example, the Accused Instrumentalities perform a method for handoff of a mobile wireless device between a second 

wireless network, comprising for example a 4G LTE eNodeB or ng-eNodeB base station, and a first wireless network, 

comprising for example a 5G NR gNodeB base station. This method is described, for example, in 3GPP standards documents 

such as TS 38.300, which describe aspects of the operations of the eNodeB/ng-eNodeB and gNodeB and associated components of the Accused Instrumentalities.

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Claim 9 Public Documentation

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Claim 9 Public Documentation

(3GPP TS 38.300 v17.2.0, § 4.1)

The method includes a handover request and an acknowledgement, as illustrated for example in the following figure:

(3GPP TS 38.300 v17.2.0, Figure 9.2.3.1-1.) In this figure, the source node is a gNodeB, but a similar request and acknowledgement will be used when the source node is an eNodeB or ng-eNodeB.

[9a] receiving a handoff request from the second 

wireless network, the handoff request based, at 

least in part, on a determination by the second wireless network that the wireless device is not currently covered by the first wireless network but is 

capable of being covered by the first wireless network;

The Accused Instrumentalities receive a handoff request from the second wireless network, the handoff request based, at 

least in part, on a determination by the second wireless network that the wireless device is not currently covered by the first 

wireless network but is capable of being covered by the first wireless network.

For example, in the Accused Instrumentalities a target NG-RAN node (such as a gNodeB) can receive a handoff request 

from a source eNodeB, based in part on a determination that the wireless device is capable of being covered by the target 

gNodeB:

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Claim 9 Public Documentation

(3GPP TS 38.300 v17.2.0, § 9.3.3.1)

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Claim 9 Public Documentation

As another example, in the Accused Instrumentalities a target gNodeB can receive a handoff request from a source ngeNodeB, based in part on a determination that the wireless device is capable of being covered by the target gNodeB:

(3GPP TS 38.300 v17.2.0, § 9.3.1.2)

[9b] based, at least in part, on the handoff request, 

adapting one or more beams of an antenna array to 

facilitate coverage of the wireless device by the 

first wireless network; and

The Accused Instrumentalities adapt, based at least in part on the handoff request, one or more beams of an antenna array 

to facilitate coverage of the wireless device by the first wireless network.

For example, in the Accused Instrumentalities, a target gNodeB will have one or more antenna arrays, each providing multiple radio beams:

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Claim 9 Public Documentation

(https://www.ericsson.com/en/reports-and-papers/white-papers/advanced-antenna-systems-for-5g-networks)

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Claim 9 Public Documentation

As a further example, the target gNodeB will adapt one or more of the beams of an antenna array to facilitate coverage of 

the mobile wireless device:

(3GPP TS 38.300 v17.2.0, § 9.2.3.1)

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Claim 9 Public Documentation

(3GPP TS 38.300 v17.2.0, § 9.2.4)

[9c] transmitting a confirmation from the first wireless network to the second wireless network to indicate acceptance of the handoff request, wherein 

the wireless device is handed off from the second 

wireless network to the first wireless network.

The Accused Instrumentalities transmit a confirmation from the first wireless network to the second wireless network to 

indicate acceptance of the handoff request, wherein the wireless device is handed off from the second wireless network to 

the first wireless network.

For example, handoff in the Accused Instrumentalities involves steps shown in the following call flow diagram:

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Claim 9 Public Documentation

(3GPP TS 38.300 v17.2.0, Figure 9.2.3.2.1-1.)

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Claim 9 Public Documentation

While the source node in this diagram is labeled “Source gNB,” this source node may be a node with a 4G LTE radio 

interface, such as an ng-eNodeB. The target gNodeB transmits one or more confirmations, e.g., shown in the diagram above, 

to the source node, such as an ng-eNodeB. The wireless device is handed off from the source node wireless network to the 

target node wireless network:

(3GPP TS 38.300 v17.2.0, § 9.2.3.2.1)

Claim 10

Claim 10 Public Documentation

[10] A method according to claim 9, wherein the receiving the handoff request comprises receiving the 

handoff request via a wireless or a wired communication link that communicatively couples the first 

wireless network to the second wireless network.

In the Accused Instrumentalities, receiving the handoff request comprises receiving the handoff request via a wireless or a 

wired communication link that communicatively couples the first wireless network to the second wireless network.

For example, the target gNodeB receives the handoff request over an Xn interface, which is a wireless or wired communications link that couples the first and second wireless networks:

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Claim 10 Public Documentation

(3GPP TS 38.300 v15.5.0, § 9.2.3)

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Claim 10 Public Documentation

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Claim 10 Public Documentation

(3GPP TS 38.300 v15.5.0, Fig. 4.1-1)

Claim 12

Claim 12 Public Documentation

[12] A method according to claim 9, wherein the 

adapting one or more beams comprises adapting 

one or more beams based, at least in part, on one of 

a predetermined network load placed on the first 

In the Accused Instrumentalities, adapting one or more beams comprises adapting one or more beams based, at least in part, 

on one of a predetermined network load placed on the first wireless network due to the handoff of the wireless device or an 

effect of adapting one or more beams on other wireless devices currently communicatively coupled to the first wireless 

network.

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Claim 12 Public Documentation

wireless network due to the handoff of the wireless 

device or an effect of adapting one or more beams 

on other wireless devices currently communicatively coupled to the first wireless network.

For example, on information and belief the Accused Instrumentalities perform load balancing based upon load reporting and 

the effects of handoff and/or adapting beams on other wireless devices:

(3GPP TS 36.300 v17.3.0, § 22.4.1.1)

(3GPP TS 36.300 v17.3.0, § 22.4.1.2)

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Claim 12 Public Documentation

(3GPP TS 36.300 v17.3.0, § 22.4.1.2.2)

Claim 20

Claim 20 Public Documentation

[20pre] A system for a wireless device handoff between a first wireless network and a second wireless network, the system comprising:To the extent the preamble is found to be limiting, the Accused Instrumentalities comprise a system for a wireless device 

handoff between a first wireless network and a second wireless network.

For example, the Accused Instrumentalities contain a system for handoff of a mobile wireless device between a first wireless 

network, comprising for example a 5G NR gNodeB base station, and a second wireless network, comprising for example a 

4G LTE eNodeB or ng-eNodeB base station. This method is described, for example, in 3GPP standards documents such as 

TS 38.300, which describe aspects of the operations of the eNodeB/ng-eNodeB and gNodeB and associated components of 

the Accused Instrumentalities.

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Claim 20 Public Documentation

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Claim 20 Public Documentation

(3GPP TS 38.300 v17.2.0, § 4.1)

The method includes a handover request and an acknowledgement, as illustrated for example in the following figure:

(3GPP TS 38.300 v17.2.0, Figure 9.2.3.1-1.) In this figure, the source node is a gNodeB, but a similar request and acknowledgement will be used when the source node is an eNodeB or ng-eNodeB.

[20a] an antenna array configured to generate one 

or more adaptable beams to modify a coverage area 

for the first wireless network; and

The Accused Instrumentalities comprise an antenna array configured to generate one or more adaptable beams to modify a 

coverage area for the first wireless network.

For example, in the Accused Instrumentalities, a target gNodeB will have one or more antenna arrays, each providing multiple radio beams:

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Claim 20 Public Documentation

(https://www.ericsson.com/en/reports-and-papers/white-papers/advanced-antenna-systems-for-5g-networks)

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Claim 20 Public Documentation

As a further example, the target gNodeB will adapt one or more of the beams of an antenna array to facilitate coverage of 

the mobile wireless device:

(3GPP TS 38.300 v17.2.0, § 9.2.3.1)

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Claim 20 Public Documentation

(3GPP TS 38.300 v17.2.0, § 9.2.4)

[20b] an adaption manager having logic, the logic 

configured to:

receive a handoff request from the second wireless 

network, the handoff request based, at least in part, 

on a determination by the second wireless network 

that the wireless device is capable of being covered 

by the first wireless network,

The Accused Instrumentalities comprise an adaption manager having logic configured to receive a handoff request from the 

second wireless network, the handoff request based, at least in part, on a determination by the second wireless network that 

the wireless device is capable of being covered by the first wireless network.

For example, in the Accused Instrumentalities a target NG-RAN node (such as a gNodeB) containing an adaption manager 

can receive a handoff request from a source eNodeB, based in part on a determination that the wireless device is capable of 

being covered by the target gNodeB:

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Claim 20 Public Documentation

(3GPP TS 38.300 v17.2.0, § 9.3.3.1)

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Claim 20 Public Documentation

As another example, in the Accused Instrumentalities a target gNodeB can receive a handoff request from a source ngeNodeB, based in part on a determination that the wireless device is capable of being covered by the target gNodeB:

(3GPP TS 38.300 v17.2.0, § 9.3.1.2)

[20c] cause a beam from among the one or more 

adaptable beams to be adapted in order to enable 

the wireless device to be covered by the first wireless network, and

In the Accused Instrumentalities the logic causes a beam from among the one or more adaptable beams to be adapted in 

order to enable the wireless device to be covered by the first wireless network.

As a further example, the target gNodeB will adapt one or more of the beams of an antenna array to facilitate coverage of 

the mobile wireless device:

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Claim 20 Public Documentation

(3GPP TS 38.300 v17.2.0, § 9.2.3.1)

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Claim 20 Public Documentation

(3GPP TS 38.300 v17.2.0, § 9.2.4)

[20d] transmit a confirmation to the second wireless network to indicate acceptance of the handoff 

request, wherein the wireless device is handed off 

from the second wireless network to the first wireless network.

In the Accused Instrumentalities the logic transmits a confirmation to the second wireless network to indicate acceptance of 

the handoff request, wherein the wireless device is handed off from the second wireless network to the first wireless network

For example, handoff in the Accused Instrumentalities involves steps shown in the following call flow diagram:

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Claim 20 Public Documentation

(3GPP TS 38.300 v17.2.0, Figure 9.2.3.2.1-1.)

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Claim 20 Public Documentation

While the source node in this diagram is labeled “Source gNB,” this source node may be a node with a 4G LTE radio 

interface, such as an ng-eNodeB. The target gNodeB transmits one or more confirmations, e.g., shown in the diagram above, 

to the source node, such as an ng-eNodeB. The wireless device is handed off from the source node wireless network to the 

target node wireless network:

(3GPP TS 38.300 v17.2.0, § 9.2.3.2.1)

Claim 21

Claim 21 Public Documentation

[21] A system according to claim 20, wherein to receive the handoff request comprises to receive the 

handoff request via a wireless or a wired communication link that communicatively couples the first 

wireless network to the second wireless network.

In the Accused Instrumentalities, receiving the handoff request comprises to receive the handoff request via a wireless or a 

wired communication link that communicatively couples the first wireless network to the second wireless network.

For example, the target gNodeB receives the handoff request over an Xn interface, which is a wireless or wired communications link that couples the first and second wireless networks:

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Claim 21 Public Documentation

(3GPP TS 38.300 v15.5.0, § 9.2.3)

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Claim 21 Public Documentation

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Claim 21 Public Documentation

(3GPP TS 38.300 v15.5.0, Fig. 4.1-1)

Claim 23

Claim 23 Public Documentation

[23] A system according to claim 20, wherein to 

cause the beam to be adapted comprises to cause a 

beam to be adapted based, at least in part, on one of 

a network load placed on the first wireless network 

In the Accused Instrumentalities, causing the beam to be adapted comprises to cause a beam to be adapted based, at least in 

part, on one of a network load placed on the first wireless network due to the handoff of the wireless device or an impact of 

adapting one or more beams on other wireless devices currently communicatively coupled to the first wireless network.

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Claim 23 Public Documentation

due to the handoff of the wireless device or an impact of adapting one or more beams on other wireless devices currently communicatively coupled to 

the first wireless network.

For example, on information and belief the Accused Instrumentalities perform load balancing based upon load reporting and 

the effects of handoff and/or adapting beams on other wireless devices:

(3GPP TS 36.300 v17.3.0, § 22.4.1.1)

(3GPP TS 36.300 v17.3.0, § 22.4.1.2)

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Claim 23 Public Documentation

(3GPP TS 36.300 v17.3.0, § 22.4.1.2.2)

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