EXHIBIT D

Case 2:23-cv-00285-JRG-RSP Document 59-4 Filed 07/11/24 Page 1 of 150 PageID #:

1567
1

Exhibit A-22

Invalidity Claim Chart for U.S. Patent No. 7,924,802 vs. “Analysis of Effects of Clipping and Filtering on the Performance of 

MB-OFDM UWB Signals”

Analysis of Effects of Clipping and Filtering on the Performance of MB-OFDM UWB Signals by K. Deergha Rao (“Rao”) was 

published no later than 2007. Rao 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. Rao 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 Rao 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 Rao and/or to combine the teachings of Rao 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 

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 59-4 Filed 07/11/24 Page 2 of 150 PageID #:

1568
2

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

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

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

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

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

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

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

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

construction, changes in Plaintiff’s infringement contentions, and/or information obtained during discovery as the c ase progresses. 

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

[1.1] A method of 

transmitting information in a 

wireless communication 

channel comprising:

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

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

UWB technology is a wireless protocol for high-speed data transmission over short distances and has 

recently received a lot of interest from the wireless manufacturing and user community [1]. The 

Federal Communications Commission (FCC) has approved to operate UWB in the 3.1- 10.6GHz 

band at a low effective isotropic radiated power(EIRP) of -41.3 dBm/MHz with a minimum signal

bandwidth of 500MHz. In near future, UWB communication system will be extensively used in the 

mobile handsets or consumer device that require real-time transmission of highdefinition multimedia 

data.

See, e.g., Rao at 559.

Furthermore, this claim element is obvious in light of Rao 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 

Case 2:23-cv-00285-JRG-RSP Document 59-4 Filed 07/11/24 Page 3 of 150 PageID #:

1569
3

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

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

Rao 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.: 

See, e.g., Rao at Figure 1.

One approach to designing a UWB system based on OFDM is to combine the modulation technique 

with a multibanding approach, which divides the spectrum into several sub-bands, whose bandwidth 

is approximately 500 MHz [2]. The band allocation is given in Table.1. The relationship between 

center frequency and band number is given by the following equation Band center frequency 2904 +

528 × nb,nb = 1 ... .14(MHz).

This definition provides a unique numbering system for all channels that have a spacing of 528 MHz 

and lie within the band 3.1 – 10.6 GHz. Based on this, five band groups are defined, band group 1 is 

used for mandatory mode and the remaining band groups are reserved for future use. The transmitted 

OFDM symbols are time-interleaved across the sub bands. An advantage of this approach is that the 

average transmitted power is the same as a system designed to operate over the entire bandwidth. 

Case 2:23-cv-00285-JRG-RSP Document 59-4 Filed 07/11/24 Page 4 of 150 PageID #:

1570
4

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

Other advantages of multibanding include processing the information over much smaller bandwidth 

(528 MHz), which reduces power consumption and lowers cost and improving spectral flexibility.

See, e.g., Rao at 559.

The 128-tone (16-QAM symbols) coefficients are inverse transformed to obtain data block samples 

by

dm =

1

N

∑ Dnexp(

j2πmn

N

)

N−1

n=0

;m = 0,1,2,... , N − 1 (1)

where Dn is the n

th QAM symbol and N =128 [3]. The MB-OFDM symbol is formed by placing the 

data block between the 32-sample zero prefix and 5-sample guard interval suffix making the total 

symbol length of L =165 samples. A scheme for MB-OFDM UWB signals is shown in Fig.1.

The k

th MB-OFDM symbol is

uk,l = {

0 1 < l ≤ 32

dl−33 32 < l ≤ 160

0 160 < 6 ≤ 165

(2)

Then the simulated MB-OFDM signal is mathematically described as

u(t) = R (( ∑ ∑uk,lhrect(t − kTOFDM − (l − 1)∆t)

L

l=1

∞

k=−∞

)exp(−j2πfc

t)) (3)

where hrect is a filter with a rectangular frequency response bounded by ±1/(2Δt), TOFDM = L∆t = 

312.5 nanoseconds is the MB-OFDM symbol period, Δt =1/(NΔf ) ≈1.9 nanoseconds, and R

denotes the real part of a complex number.

Case 2:23-cv-00285-JRG-RSP Document 59-4 Filed 07/11/24 Page 5 of 150 PageID #:

1571
5

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

Finally, MB-OFDM signals hop between 14 band center frequencies according to the specified timefrequency code. The band allocation is shown in Table 1 [2].

See, e.g., Rao at 560.

Case 2:23-cv-00285-JRG-RSP Document 59-4 Filed 07/11/24 Page 6 of 150 PageID #:

1572
6

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

See, e.g., Rao at Table 1.

Case 2:23-cv-00285-JRG-RSP Document 59-4 Filed 07/11/24 Page 7 of 150 PageID #:

1573
7

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

Furthermore, this claim element is obvious in light of Rao 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.

Rao 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.: 

See, e.g., Rao at Figure 1.

One approach to designing a UWB system based on OFDM is to combine the modulation technique 

with a multibanding approach, which divides the spectrum into several sub-bands, whose bandwidth 

is approximately 500 MHz [2]. The band allocation is given in Table.1. The relationship between 

center frequency and band number is given by the following equation Band center frequency 2904 +

528 × nb,nb = 1 ... .14(MHz).

Case 2:23-cv-00285-JRG-RSP Document 59-4 Filed 07/11/24 Page 8 of 150 PageID #:

1574
8

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

This definition provides a unique numbering system for all channels that have a spacing of 528 MHz 

and lie within the band 3.1 – 10.6 GHz. Based on this, five band groups are defined, band group 1 is 

used for mandatory mode and the remaining band groups are reserved for future use. The transmitted 

OFDM symbols are time-interleaved across the sub bands. An advantage of this approach is that the 

average transmitted power is the same as a system designed to operate over the entire bandwidth. 

Other advantages of multibanding include processing the information over much smaller bandwidth 

(528 MHz), which reduces power consumption and lowers cost and improving spectral flexibility.

See, e.g., Rao at 559.

The 128-tone (16-QAM symbols) coefficients are inverse transformed to obtain data block samples 

by

dm =

1

N

∑ Dnexp(

j2πmn

N

)

N−1

n=0

;m = 0,1,2,... , N − 1 (1)

where Dn is the n

th QAM symbol and N =128 [3]. The MB-OFDM symbol is formed by placing the 

data block between the 32-sample zero prefix and 5-sample guard interval suffix making the total 

symbol length of L =165 samples. A scheme for MB-OFDM UWB signals is shown in Fig.1.

The k

th MB-OFDM symbol is

uk,l = {

0 1 < l ≤ 32

dl−33 32 < l ≤ 160

0 160 < 6 ≤ 165

(2)

Then the simulated MB-OFDM signal is mathematically described as

Case 2:23-cv-00285-JRG-RSP Document 59-4 Filed 07/11/24 Page 9 of 150 PageID #:

1575
9

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

u(t) = R (( ∑ ∑uk,lhrect(t − kTOFDM − (l − 1)∆t)

L

l=1

∞

k=−∞

)exp(−j2πfc

t)) (3)

where hrect is a filter with a rectangular frequency response bounded by ±1/(2Δt), TOFDM = L∆t = 

312.5 nanoseconds is the MB-OFDM symbol period, Δt =1/(NΔf ) ≈1.9 nanoseconds, and R

denotes the real part of a complex number.

Finally, MB-OFDM signals hop between 14 band center frequencies according to the specified timefrequency code. The band allocation is shown in Table 1 [2].

See, e.g., Rao at 560.

Case 2:23-cv-00285-JRG-RSP Document 59-4 Filed 07/11/24 Page 10 of 150 PageID #:

1576
10

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

See, e.g., Rao at Table 1.

Case 2:23-cv-00285-JRG-RSP Document 59-4 Filed 07/11/24 Page 11 of 150 PageID #:

1577
11

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

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

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

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

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

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

First Supplemental Ex. A-Obviousness Chart.

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

[2.1] The method of claim 1 Rao 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.

Rao 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.: 

See, e.g., Rao at Figure 1.

Case 2:23-cv-00285-JRG-RSP Document 59-4 Filed 07/11/24 Page 12 of 150 PageID #:

1578
12

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

One approach to designing a UWB system based on OFDM is to combine the modulation technique 

with a multibanding approach, which divides the spectrum into several sub-bands, whose bandwidth 

is approximately 500 MHz [2]. The band allocation is given in Table.1. The relationship between 

center frequency and band number is given by the following equation Band center frequency 2904 +

528 × nb,nb = 1 ... .14(MHz).

This definition provides a unique numbering system for all channels that have a spacing of 528 MHz 

and lie within the band 3.1 – 10.6 GHz. Based on this, five band groups are defined, band group 1 is 

used for mandatory mode and the remaining band groups are reserved for future use. The transmitted 

OFDM symbols are time-interleaved across the sub bands. An advantage of this approach is that the 

average transmitted power is the same as a system designed to operate over the entire bandwidth. 

Other advantages of multibanding include processing the information over much smaller bandwidth 

(528 MHz), which reduces power consumption and lowers cost and improving spectral flexibility.

See, e.g., Rao at 559.

The 128-tone (16-QAM symbols) coefficients are inverse transformed to obtain data block samples 

by

dm =

1

N

∑ Dnexp(

j2πmn

N

)

N−1

n=0

;m = 0,1,2,... , N − 1 (1)

where Dn is the n

th QAM symbol and N =128 [3]. The MB-OFDM symbol is formed by placing the 

data block between the 32-sample zero prefix and 5-sample guard interval suffix making the total 

symbol length of L =165 samples. A scheme for MB-OFDM UWB signals is shown in Fig.1.

The k

th MB-OFDM symbol is

uk,l = {

0 1 < l ≤ 32

dl−33 32 < l ≤ 160

0 160 < 6 ≤ 165

(2)

Case 2:23-cv-00285-JRG-RSP Document 59-4 Filed 07/11/24 Page 13 of 150 PageID #:

1579
13

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

Then the simulated MB-OFDM signal is mathematically described as

u(t) = R (( ∑ ∑uk,lhrect(t − kTOFDM − (l − 1)∆t)

L

l=1

∞

k=−∞

)exp(−j2πfc

t)) (3)

where hrect is a filter with a rectangular frequency response bounded by ±1/(2Δt), TOFDM = L∆t = 

312.5 nanoseconds is the MB-OFDM symbol period, Δt =1/(NΔf ) ≈1.9 nanoseconds, and R

denotes the real part of a complex number.

Finally, MB-OFDM signals hop between 14 band center frequencies according to the specified timefrequency code. The band allocation is shown in Table 1 [2].

See, e.g., Rao at 560.

Case 2:23-cv-00285-JRG-RSP Document 59-4 Filed 07/11/24 Page 14 of 150 PageID #:

1580
14

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

See, e.g., Rao at Table 1.

Case 2:23-cv-00285-JRG-RSP Document 59-4 Filed 07/11/24 Page 15 of 150 PageID #:

1581
15

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

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

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

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

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

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

First Supplemental Ex. A-Obviousness Chart.

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

[3.1] The method of claim 1 Rao 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.

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

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

See, e.g., Rao at Figure 1.

One approach to designing a UWB system based on OFDM is to combine the modulation technique 

with a multibanding approach, which divides the spectrum into several sub-bands, whose bandwidth 

Case 2:23-cv-00285-JRG-RSP Document 59-4 Filed 07/11/24 Page 16 of 150 PageID #:

1582
16

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

is approximately 500 MHz [2]. The band allocation is given in Table.1. The relationship between 

center frequency and band number is given by the following equation Band center frequency 2904 +

528 × nb,nb = 1 ... .14(MHz).

This definition provides a unique numbering system for all channels that have a spacing of 528 MHz 

and lie within the band 3.1 – 10.6 GHz. Based on this, five band groups are defined, band group 1 is 

used for mandatory mode and the remaining band groups are reserved for future use. The transmitted 

OFDM symbols are time-interleaved across the sub bands. An advantage of this approach is that the 

average transmitted power is the same as a system designed to operate over the entire bandwidth. 

Other advantages of multibanding include processing the information over much smaller bandwidth 

(528 MHz), which reduces power consumption and lowers cost and improving spectral flexibility.

See, e.g., Rao at 559.

The 128-tone (16-QAM symbols) coefficients are inverse transformed to obtain data block samples 

by

dm =

1

N

∑ Dnexp(

j2πmn

N

)

N−1

n=0

;m = 0,1,2,... , N − 1 (1)

where Dn is the n

th QAM symbol and N =128 [3]. The MB-OFDM symbol is formed by placing the 

data block between the 32-sample zero prefix and 5-sample guard interval suffix making the total 

symbol length of L =165 samples. A scheme for MB-OFDM UWB signals is shown in Fig.1.

The k

th MB-OFDM symbol is

uk,l = {

0 1 < l ≤ 32

dl−33 32 < l ≤ 160

0 160 < 6 ≤ 165

(2)

Then the simulated MB-OFDM signal is mathematically described as

Case 2:23-cv-00285-JRG-RSP Document 59-4 Filed 07/11/24 Page 17 of 150 PageID #:

1583
17

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

u(t) = R (( ∑ ∑uk,lhrect(t − kTOFDM − (l − 1)∆t)

L

l=1

∞

k=−∞

)exp(−j2πfc

t)) (3)

where hrect is a filter with a rectangular frequency response bounded by ±1/(2Δt), TOFDM = L∆t = 

312.5 nanoseconds is the MB-OFDM symbol period, Δt =1/(NΔf ) ≈1.9 nanoseconds, and R

denotes the real part of a complex number.

Finally, MB-OFDM signals hop between 14 band center frequencies according to the specified timefrequency code. The band allocation is shown in Table 1 [2].

See, e.g., Rao at 560.

Case 2:23-cv-00285-JRG-RSP Document 59-4 Filed 07/11/24 Page 18 of 150 PageID #:

1584
18

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

See, e.g., Rao at Table 1.

Case 2:23-cv-00285-JRG-RSP Document 59-4 Filed 07/11/24 Page 19 of 150 PageID #:

1585
19

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

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

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

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

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

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

First Supplemental Ex. A-Obviousness Chart.

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

[4.1] The method of claim 3 Rao 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.

Rao 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.: 

See, e.g., Rao at Figure 1.

One approach to designing a UWB system based on OFDM is to combine the modulation technique 

with a multibanding approach, which divides the spectrum into several sub-bands, whose bandwidth 

Case 2:23-cv-00285-JRG-RSP Document 59-4 Filed 07/11/24 Page 20 of 150 PageID #:

1586
20

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

is approximately 500 MHz [2]. The band allocation is given in Table.1. The relationship between 

center frequency and band number is given by the following equation Band center frequency 2904 +

528 × nb,nb = 1 ... .14(MHz).

This definition provides a unique numbering system for all channels that have a spacing of 528 MHz 

and lie within the band 3.1 – 10.6 GHz. Based on this, five band groups are defined, band group 1 is 

used for mandatory mode and the remaining band groups are reserved for future use. The transmitted 

OFDM symbols are time-interleaved across the sub bands. An advantage of this approach is that the 

average transmitted power is the same as a system designed to operate over the entire bandwidth. 

Other advantages of multibanding include processing the information over much smaller bandwidth 

(528 MHz), which reduces power consumption and lowers cost and improving spectral flexibility.

See, e.g., Rao at 559.

The 128-tone (16-QAM symbols) coefficients are inverse transformed to obtain data block samples 

by

dm =

1

N

∑ Dnexp(

j2πmn

N

)

N−1

n=0

;m = 0,1,2,... , N − 1 (1)

where Dn is the n

th QAM symbol and N =128 [3]. The MB-OFDM symbol is formed by placing the 

data block between the 32-sample zero prefix and 5-sample guard interval suffix making the total 

symbol length of L =165 samples. A scheme for MB-OFDM UWB signals is shown in Fig.1.

The k

th MB-OFDM symbol is

uk,l = {

0 1 < l ≤ 32

dl−33 32 < l ≤ 160

0 160 < 6 ≤ 165

(2)

Then the simulated MB-OFDM signal is mathematically described as

Case 2:23-cv-00285-JRG-RSP Document 59-4 Filed 07/11/24 Page 21 of 150 PageID #:

1587
21

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

u(t) = R (( ∑ ∑uk,lhrect(t − kTOFDM − (l − 1)∆t)

L

l=1

∞

k=−∞

)exp(−j2πfc

t)) (3)

where hrect is a filter with a rectangular frequency response bounded by ±1/(2Δt), TOFDM = L∆t = 

312.5 nanoseconds is the MB-OFDM symbol period, Δt =1/(NΔf ) ≈1.9 nanoseconds, and R

denotes the real part of a complex number.

Finally, MB-OFDM signals hop between 14 band center frequencies according to the specified timefrequency code. The band allocation is shown in Table 1 [2].

See, e.g., Rao at 560.

Case 2:23-cv-00285-JRG-RSP Document 59-4 Filed 07/11/24 Page 22 of 150 PageID #:

1588
22

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

See, e.g., Rao at Table 1.

Case 2:23-cv-00285-JRG-RSP Document 59-4 Filed 07/11/24 Page 23 of 150 PageID #:

1589
23

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

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

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

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

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

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

First Supplemental Ex. A-Obviousness Chart.

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

[6.1] The method of claim 1 Rao 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.

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

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

See, e.g., Rao at Figure 1.

One approach to designing a UWB system based on OFDM is to combine the modulation technique 

with a multibanding approach, which divides the spectrum into several sub-bands, whose bandwidth 

Case 2:23-cv-00285-JRG-RSP Document 59-4 Filed 07/11/24 Page 24 of 150 PageID #:

1590
24

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

is approximately 500 MHz [2]. The band allocation is given in Table.1. The relationship between 

center frequency and band number is given by the following equation Band center frequency 2904 +

528 × nb,nb = 1 ... .14(MHz).

This definition provides a unique numbering system for all channels that have a spacing of 528 MHz 

and lie within the band 3.1 – 10.6 GHz. Based on this, five band groups are defined, band group 1 is 

used for mandatory mode and the remaining band groups are reserved for future use. The transmitted 

OFDM symbols are time-interleaved across the sub bands. An advantage of this approach is that the 

average transmitted power is the same as a system designed to operate over the entire bandwidth. 

Other advantages of multibanding include processing the information over much smaller bandwidth 

(528 MHz), which reduces power consumption and lowers cost and improving spectral flexibility.

See, e.g., Rao at 559.

The 128-tone (16-QAM symbols) coefficients are inverse transformed to obtain data block samples 

by

dm =

1

N

∑ Dnexp(

j2πmn

N

)

N−1

n=0

;m = 0,1,2,... , N − 1 (1)

where Dn is the n

th QAM symbol and N =128 [3]. The MB-OFDM symbol is formed by placing the 

data block between the 32-sample zero prefix and 5-sample guard interval suffix making the total 

symbol length of L =165 samples. A scheme for MB-OFDM UWB signals is shown in Fig.1.

The k

th MB-OFDM symbol is

uk,l = {

0 1 < l ≤ 32

dl−33 32 < l ≤ 160

0 160 < 6 ≤ 165

(2)

Then the simulated MB-OFDM signal is mathematically described as

Case 2:23-cv-00285-JRG-RSP Document 59-4 Filed 07/11/24 Page 25 of 150 PageID #:

1591
25

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

u(t) = R (( ∑ ∑uk,lhrect(t − kTOFDM − (l − 1)∆t)

L

l=1

∞

k=−∞

)exp(−j2πfc

t)) (3)

where hrect is a filter with a rectangular frequency response bounded by ±1/(2Δt), TOFDM = L∆t = 

312.5 nanoseconds is the MB-OFDM symbol period, Δt =1/(NΔf ) ≈1.9 nanoseconds, and R

denotes the real part of a complex number.

Finally, MB-OFDM signals hop between 14 band center frequencies according to the specified timefrequency code. The band allocation is shown in Table 1 [2].

See, e.g., Rao at 560.

Case 2:23-cv-00285-JRG-RSP Document 59-4 Filed 07/11/24 Page 26 of 150 PageID #:

1592
26

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

See, e.g., Rao at Table 1.

Case 2:23-cv-00285-JRG-RSP Document 59-4 Filed 07/11/24 Page 27 of 150 PageID #:

1593
27

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

Furthermore, this claim element is obvious in light of Rao 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 7 of the ’802 Patent Prior Art Reference – Rao

[7.1] The method of claim 1 Rao 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.

Rao discloses “wherein the first information and the second information are the same data transmitted 

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

See, e.g., Rao at Figure 1.

One approach to designing a UWB system based on OFDM is to combine the modulation technique 

with a multibanding approach, which divides the spectrum into several sub-bands, whose bandwidth 

Case 2:23-cv-00285-JRG-RSP Document 59-4 Filed 07/11/24 Page 28 of 150 PageID #:

1594
28

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

is approximately 500 MHz [2]. The band allocation is given in Table.1. The relationship between 

center frequency and band number is given by the following equation Band center frequency 2904 +

528 × nb,nb = 1 ... .14(MHz).

This definition provides a unique numbering system for all channels that have a spacing of 528 MHz 

and lie within the band 3.1 – 10.6 GHz. Based on this, five band groups are defined, band group 1 is 

used for mandatory mode and the remaining band groups are reserved for future use. The transmitted 

OFDM symbols are time-interleaved across the sub bands. An advantage of this approach is that the 

average transmitted power is the same as a system designed to operate over the entire bandwidth. 

Other advantages of multibanding include processing the information over much smaller bandwidth 

(528 MHz), which reduces power consumption and lowers cost and improving spectral flexibility.

See, e.g., Rao at 559.

The 128-tone (16-QAM symbols) coefficients are inverse transformed to obtain data block samples 

by

dm =

1

N

∑ Dnexp(

j2πmn

N

)

N−1

n=0

;m = 0,1,2,... , N − 1 (1)

where Dn is the n

th QAM symbol and N =128 [3]. The MB-OFDM symbol is formed by placing the 

data block between the 32-sample zero prefix and 5-sample guard interval suffix making the total 

symbol length of L =165 samples. A scheme for MB-OFDM UWB signals is shown in Fig.1.

The k

th MB-OFDM symbol is

uk,l = {

0 1 < l ≤ 32

dl−33 32 < l ≤ 160

0 160 < 6 ≤ 165

(2)

Then the simulated MB-OFDM signal is mathematically described as

Case 2:23-cv-00285-JRG-RSP Document 59-4 Filed 07/11/24 Page 29 of 150 PageID #:

1595
29

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

u(t) = R (( ∑ ∑uk,lhrect(t − kTOFDM − (l − 1)∆t)

L

l=1

∞

k=−∞

)exp(−j2πfc

t)) (3)

where hrect is a filter with a rectangular frequency response bounded by ±1/(2Δt), TOFDM = L∆t = 

312.5 nanoseconds is the MB-OFDM symbol period, Δt =1/(NΔf ) ≈1.9 nanoseconds, and R

denotes the real part of a complex number.

Finally, MB-OFDM signals hop between 14 band center frequencies according to the specified timefrequency code. The band allocation is shown in Table 1 [2].

See, e.g., Rao at 560.

Case 2:23-cv-00285-JRG-RSP Document 59-4 Filed 07/11/24 Page 30 of 150 PageID #:

1596
30

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

See, e.g., Rao at Table 1.

Case 2:23-cv-00285-JRG-RSP Document 59-4 Filed 07/11/24 Page 31 of 150 PageID #:

1597
31

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

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

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

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

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

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

First Supplemental Ex. A-Obviousness Chart.

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

[8.1] The method of claim 1 Rao 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.

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

stream.” See, e.g.: 

See, e.g., Rao at Figure 1.

One approach to designing a UWB system based on OFDM is to combine the modulation technique 

with a multibanding approach, which divides the spectrum into several sub-bands, whose bandwidth 

Case 2:23-cv-00285-JRG-RSP Document 59-4 Filed 07/11/24 Page 32 of 150 PageID #:

1598
32

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

is approximately 500 MHz [2]. The band allocation is given in Table.1. The relationship between 

center frequency and band number is given by the following equation Band center frequency 2904 +

528 × nb,nb = 1 ... .14(MHz).

This definition provides a unique numbering system for all channels that have a spacing of 528 MHz 

and lie within the band 3.1 – 10.6 GHz. Based on this, five band groups are defined, band group 1 is 

used for mandatory mode and the remaining band groups are reserved for future use. The transmitted 

OFDM symbols are time-interleaved across the sub bands. An advantage of this approach is that the 

average transmitted power is the same as a system designed to operate over the entire bandwidth. 

Other advantages of multibanding include processing the information over much smaller bandwidth 

(528 MHz), which reduces power consumption and lowers cost and improving spectral flexibility.

See, e.g., Rao at 559.

The 128-tone (16-QAM symbols) coefficients are inverse transformed to obtain data block samples 

by

dm =

1

N

∑ Dnexp(

j2πmn

N

)

N−1

n=0

;m = 0,1,2,... , N − 1 (1)

where Dn is the n

th QAM symbol and N =128 [3]. The MB-OFDM symbol is formed by placing the 

data block between the 32-sample zero prefix and 5-sample guard interval suffix making the total 

symbol length of L =165 samples. A scheme for MB-OFDM UWB signals is shown in Fig.1.

The k

th MB-OFDM symbol is

uk,l = {

0 1 < l ≤ 32

dl−33 32 < l ≤ 160

0 160 < 6 ≤ 165

(2)

Then the simulated MB-OFDM signal is mathematically described as

Case 2:23-cv-00285-JRG-RSP Document 59-4 Filed 07/11/24 Page 33 of 150 PageID #:

1599
33

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

u(t) = R (( ∑ ∑uk,lhrect(t − kTOFDM − (l − 1)∆t)

L

l=1

∞

k=−∞

)exp(−j2πfc

t)) (3)

where hrect is a filter with a rectangular frequency response bounded by ±1/(2Δt), TOFDM = L∆t = 

312.5 nanoseconds is the MB-OFDM symbol period, Δt =1/(NΔf ) ≈1.9 nanoseconds, and R

denotes the real part of a complex number.

Finally, MB-OFDM signals hop between 14 band center frequencies according to the specified timefrequency code. The band allocation is shown in Table 1 [2].

See, e.g., Rao at 560.

Case 2:23-cv-00285-JRG-RSP Document 59-4 Filed 07/11/24 Page 34 of 150 PageID #:

1600
34

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

See, e.g., Rao at Table 1.

Case 2:23-cv-00285-JRG-RSP Document 59-4 Filed 07/11/24 Page 35 of 150 PageID #:

1601
35

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

Furthermore, this claim element is obvious in light of Rao 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 9 of the ’802 Patent Prior Art Reference – Rao

[9.1] The method of claim 1 Rao 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.

Rao 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.: 

One approach to designing a UWB system based on OFDM is to combine the modulation technique 

with a multibanding approach, which divides the spectrum into several sub-bands, whose bandwidth 

is approximately 500 MHz [2]. The band allocation is given in Table.1. The relationship between 

center frequency and band number is given by the following equation Band center frequency 2904 +

528 × nb,nb = 1 ... .14(MHz).

This definition provides a unique numbering system for all channels that have a spacing of 528 MHz 

and lie within the band 3.1 – 10.6 GHz. Based on this, five band groups are defined, band group 1 is 

used for mandatory mode and the remaining band groups are reserved for future use. The transmitted 

OFDM symbols are time-interleaved across the sub bands. An advantage of this approach is that the 

average transmitted power is the same as a system designed to operate over the entire bandwidth. 

Other advantages of multibanding include processing the information over much smaller bandwidth 

(528 MHz), which reduces power consumption and lowers cost and improving spectral flexibility.

Case 2:23-cv-00285-JRG-RSP Document 59-4 Filed 07/11/24 Page 36 of 150 PageID #:

1602
36

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

See, e.g., Rao at 559.

The 128-tone (16-QAM symbols) coefficients are inverse transformed to obtain data block samples 

by

dm =

1

N

∑ Dnexp(

j2πmn

N

)

N−1

n=0

;m = 0,1,2,... , N − 1 (1)

where Dn is the n

th QAM symbol and N =128 [3]. The MB-OFDM symbol is formed by placing the 

data block between the 32-sample zero prefix and 5-sample guard interval suffix making the total 

symbol length of L =165 samples. A scheme for MB-OFDM UWB signals is shown in Fig.1.

The k

th MB-OFDM symbol is

uk,l = {

0 1 < l ≤ 32

dl−33 32 < l ≤ 160

0 160 < 6 ≤ 165

(2)

Then the simulated MB-OFDM signal is mathematically described as

u(t) = R (( ∑ ∑uk,lhrect(t − kTOFDM − (l − 1)∆t)

L

l=1

∞

k=−∞

)exp(−j2πfc

t)) (3)

where hrect is a filter with a rectangular frequency response bounded by ±1/(2Δt), TOFDM = L∆t = 

312.5 nanoseconds is the MB-OFDM symbol period, Δt =1/(NΔf ) ≈1.9 nanoseconds, and R

denotes the real part of a complex number.

Finally, MB-OFDM signals hop between 14 band center frequencies according to the specified timefrequency code. The band allocation is shown in Table 1 [2].

Case 2:23-cv-00285-JRG-RSP Document 59-4 Filed 07/11/24 Page 37 of 150 PageID #:

1603
37

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

See, e.g., Rao at 560.

Furthermore, this claim element is obvious in light of Rao 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 – Rao

[10.1] A method of 

transmitting information in a 

wireless communication 

channel comprising:

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

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

UWB technology is a wireless protocol for high-speed data transmission over short distances and has 

recently received a lot of interest from the wireless manufacturing and user community [1]. The 

Federal Communications Commission (FCC) has approved to operate UWB in the 3.1- 10.6GHz 

band at a low effective isotropic radiated power(EIRP) of -41.3 dBm/MHz with a minimum signal

bandwidth of 500MHz. In near future, UWB communication system will be extensively used in the 

mobile handsets or consumer device that require real-time transmission of highdefinition multimedia 

data.

See, e.g., Rao at 559.

Furthermore, this claim element is obvious in light of Rao 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 

Case 2:23-cv-00285-JRG-RSP Document 59-4 Filed 07/11/24 Page 38 of 150 PageID #:

1604
38

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

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;

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

See, e.g., Rao at Figure 1.

One approach to designing a UWB system based on OFDM is to combine the modulation technique 

with a multibanding approach, which divides the spectrum into several sub-bands, whose bandwidth 

is approximately 500 MHz [2]. The band allocation is given in Table.1. The relationship between 

center frequency and band number is given by the following equation Band center frequency 2904 +

528 × nb,nb = 1 ... .14(MHz).

This definition provides a unique numbering system for all channels that have a spacing of 528 MHz 

and lie within the band 3.1 – 10.6 GHz. Based on this, five band groups are defined, band group 1 is 

used for mandatory mode and the remaining band groups are reserved for future use. The transmitted 

OFDM symbols are time-interleaved across the sub bands. An advantage of this approach is that the 

average transmitted power is the same as a system designed to operate over the entire bandwidth. 

Case 2:23-cv-00285-JRG-RSP Document 59-4 Filed 07/11/24 Page 39 of 150 PageID #:

1605
39

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

Other advantages of multibanding include processing the information over much smaller bandwidth 

(528 MHz), which reduces power consumption and lowers cost and improving spectral flexibility.

See, e.g., Rao at 559.

The 128-tone (16-QAM symbols) coefficients are inverse transformed to obtain data block samples 

by

dm =

1

N

∑ Dnexp(

j2πmn

N

)

N−1

n=0

;m = 0,1,2,... , N − 1 (1)

where Dn is the n

th QAM symbol and N =128 [3]. The MB-OFDM symbol is formed by placing the 

data block between the 32-sample zero prefix and 5-sample guard interval suffix making the total 

symbol length of L =165 samples. A scheme for MB-OFDM UWB signals is shown in Fig.1.

The k

th MB-OFDM symbol is

uk,l = {

0 1 < l ≤ 32

dl−33 32 < l ≤ 160

0 160 < 6 ≤ 165

(2)

Then the simulated MB-OFDM signal is mathematically described as

u(t) = R (( ∑ ∑uk,lhrect(t − kTOFDM − (l − 1)∆t)

L

l=1

∞

k=−∞

)exp(−j2πfc

t)) (3)

where hrect is a filter with a rectangular frequency response bounded by ±1/(2Δt), TOFDM = L∆t = 

312.5 nanoseconds is the MB-OFDM symbol period, Δt =1/(NΔf ) ≈1.9 nanoseconds, and R

denotes the real part of a complex number.

Case 2:23-cv-00285-JRG-RSP Document 59-4 Filed 07/11/24 Page 40 of 150 PageID #:

1606
40

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

Finally, MB-OFDM signals hop between 14 band center frequencies according to the specified timefrequency code. The band allocation is shown in Table 1 [2].

See, e.g., Rao at 560.

Case 2:23-cv-00285-JRG-RSP Document 59-4 Filed 07/11/24 Page 41 of 150 PageID #:

1607
41

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

See, e.g., Rao at Table 1.

Case 2:23-cv-00285-JRG-RSP Document 59-4 Filed 07/11/24 Page 42 of 150 PageID #:

1608
42

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

Furthermore, this claim element is obvious in light of Rao 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;

Rao discloses “receiving a second digital signal comprising second data to be transmitted.” See, e.g.: 

See, e.g., Rao at Figure 1.

One approach to designing a UWB system based on OFDM is to combine the modulation technique 

with a multibanding approach, which divides the spectrum into several sub-bands, whose bandwidth 

is approximately 500 MHz [2]. The band allocation is given in Table.1. The relationship between 

center frequency and band number is given by the following equation Band center frequency 2904 +

528 × nb,nb = 1 ... .14(MHz).

This definition provides a unique numbering system for all channels that have a spacing of 528 MHz 

and lie within the band 3.1 – 10.6 GHz. Based on this, five band groups are defined, band group 1 is 

Case 2:23-cv-00285-JRG-RSP Document 59-4 Filed 07/11/24 Page 43 of 150 PageID #:

1609
43

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

used for mandatory mode and the remaining band groups are reserved for future use. The transmitted 

OFDM symbols are time-interleaved across the sub bands. An advantage of this approach is that the 

average transmitted power is the same as a system designed to operate over the entire bandwidth. 

Other advantages of multibanding include processing the information over much smaller bandwidth 

(528 MHz), which reduces power consumption and lowers cost and improving spectral flexibility.

See, e.g., Rao at 559.

The 128-tone (16-QAM symbols) coefficients are inverse transformed to obtain data block samples 

by

dm =

1

N

∑ Dnexp(

j2πmn

N

)

N−1

n=0

;m = 0,1,2,... , N − 1 (1)

where Dn is the n

th QAM symbol and N =128 [3]. The MB-OFDM symbol is formed by placing the 

data block between the 32-sample zero prefix and 5-sample guard interval suffix making the total 

symbol length of L =165 samples. A scheme for MB-OFDM UWB signals is shown in Fig.1.

The k

th MB-OFDM symbol is

uk,l = {

0 1 < l ≤ 32

dl−33 32 < l ≤ 160

0 160 < 6 ≤ 165

(2)

Then the simulated MB-OFDM signal is mathematically described as

u(t) = R (( ∑ ∑uk,lhrect(t − kTOFDM − (l − 1)∆t)

L

l=1

∞

k=−∞

)exp(−j2πfc

t)) (3)

Case 2:23-cv-00285-JRG-RSP Document 59-4 Filed 07/11/24 Page 44 of 150 PageID #:

1610
44

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

where hrect is a filter with a rectangular frequency response bounded by ±1/(2Δt), TOFDM = L∆t = 

312.5 nanoseconds is the MB-OFDM symbol period, Δt =1/(NΔf ) ≈1.9 nanoseconds, and R

denotes the real part of a complex number.

Finally, MB-OFDM signals hop between 14 band center frequencies according to the specified timefrequency code. The band allocation is shown in Table 1 [2].

See, e.g., Rao at 560.

Case 2:23-cv-00285-JRG-RSP Document 59-4 Filed 07/11/24 Page 45 of 150 PageID #:

1611
45

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

See, e.g., Rao at Table 1.

Case 2:23-cv-00285-JRG-RSP Document 59-4 Filed 07/11/24 Page 46 of 150 PageID #:

1612
46

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

Furthermore, this claim element is obvious in light of Rao 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;.

Rao 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.: 

See, e.g., Rao at Figure 1.

One approach to designing a UWB system based on OFDM is to combine the modulation technique 

with a multibanding approach, which divides the spectrum into several sub-bands, whose bandwidth 

is approximately 500 MHz [2]. The band allocation is given in Table.1. The relationship between 

center frequency and band number is given by the following equation Band center frequency 2904 +

528 × nb,nb = 1 ... .14(MHz).

Case 2:23-cv-00285-JRG-RSP Document 59-4 Filed 07/11/24 Page 47 of 150 PageID #:

1613
47

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

This definition provides a unique numbering system for all channels that have a spacing of 528 MHz 

and lie within the band 3.1 – 10.6 GHz. Based on this, five band groups are defined, band group 1 is 

used for mandatory mode and the remaining band groups are reserved for future use. The transmitted 

OFDM symbols are time-interleaved across the sub bands. An advantage of this approach is that the 

average transmitted power is the same as a system designed to operate over the entire bandwidth. 

Other advantages of multibanding include processing the information over much smaller bandwidth 

(528 MHz), which reduces power consumption and lowers cost and improving spectral flexibility.

See, e.g., Rao at 559.

The 128-tone (16-QAM symbols) coefficients are inverse transformed to obtain data block samples 

by

dm =

1

N

∑ Dnexp(

j2πmn

N

)

N−1

n=0

;m = 0,1,2,... , N − 1 (1)

where Dn is the n

th QAM symbol and N =128 [3]. The MB-OFDM symbol is formed by placing the 

data block between the 32-sample zero prefix and 5-sample guard interval suffix making the total 

symbol length of L =165 samples. A scheme for MB-OFDM UWB signals is shown in Fig.1.

The k

th MB-OFDM symbol is

uk,l = {

0 1 < l ≤ 32

dl−33 32 < l ≤ 160

0 160 < 6 ≤ 165

(2)

Then the simulated MB-OFDM signal is mathematically described as

u(t) = R (( ∑ ∑uk,lhrect(t − kTOFDM − (l − 1)∆t)

L

l=1

∞

k=−∞

)exp(−j2πfc

t)) (3)

Case 2:23-cv-00285-JRG-RSP Document 59-4 Filed 07/11/24 Page 48 of 150 PageID #:

1614
48

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

where hrect is a filter with a rectangular frequency response bounded by ±1/(2Δt), TOFDM = L∆t = 

312.5 nanoseconds is the MB-OFDM symbol period, Δt =1/(NΔf ) ≈1.9 nanoseconds, and R

denotes the real part of a complex number.

Finally, MB-OFDM signals hop between 14 band center frequencies according to the specified timefrequency code. The band allocation is shown in Table 1 [2].

See, e.g., Rao at 560.

Case 2:23-cv-00285-JRG-RSP Document 59-4 Filed 07/11/24 Page 49 of 150 PageID #:

1615
49

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

See, e.g., Rao at Table 1.

Case 2:23-cv-00285-JRG-RSP Document 59-4 Filed 07/11/24 Page 50 of 150 PageID #:

1616
50

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

Furthermore, this claim element is obvious in light of Rao 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.

[10.5] 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;

Rao discloses “converting the second digital signal into a second analog signal using a second digitalto-analog converter, the second analog signal carrying the second data across a second frequency 

range.” See, e.g.: 

See, e.g., Rao at Figure 1.

One approach to designing a UWB system based on OFDM is to combine the modulation technique 

with a multibanding approach, which divides the spectrum into several sub-bands, whose bandwidth 

is approximately 500 MHz [2]. The band allocation is given in Table.1. The relationship between 

center frequency and band number is given by the following equation Band center frequency 2904 +

528 × nb,nb = 1 ... .14(MHz).

Case 2:23-cv-00285-JRG-RSP Document 59-4 Filed 07/11/24 Page 51 of 150 PageID #:

1617
51

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

This definition provides a unique numbering system for all channels that have a spacing of 528 MHz 

and lie within the band 3.1 – 10.6 GHz. Based on this, five band groups are defined, band group 1 is 

used for mandatory mode and the remaining band groups are reserved for future use. The transmitted 

OFDM symbols are time-interleaved across the sub bands. An advantage of this approach is that the 

average transmitted power is the same as a system designed to operate over the entire bandwidth. 

Other advantages of multibanding include processing the information over much smaller bandwidth 

(528 MHz), which reduces power consumption and lowers cost and improving spectral flexibility.

See, e.g., Rao at 559.

The 128-tone (16-QAM symbols) coefficients are inverse transformed to obtain data block samples 

by

dm =

1

N

∑ Dnexp(

j2πmn

N

)

N−1

n=0

;m = 0,1,2,... , N − 1 (1)

where Dn is the n

th QAM symbol and N =128 [3]. The MB-OFDM symbol is formed by placing the 

data block between the 32-sample zero prefix and 5-sample guard interval suffix making the total 

symbol length of L =165 samples. A scheme for MB-OFDM UWB signals is shown in Fig.1.

The k

th MB-OFDM symbol is

uk,l = {

0 1 < l ≤ 32

dl−33 32 < l ≤ 160

0 160 < 6 ≤ 165

(2)

Then the simulated MB-OFDM signal is mathematically described as

u(t) = R (( ∑ ∑uk,lhrect(t − kTOFDM − (l − 1)∆t)

L

l=1

∞

k=−∞

)exp(−j2πfc

t)) (3)

Case 2:23-cv-00285-JRG-RSP Document 59-4 Filed 07/11/24 Page 52 of 150 PageID #:

1618
52

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

where hrect is a filter with a rectangular frequency response bounded by ±1/(2Δt), TOFDM = L∆t = 

312.5 nanoseconds is the MB-OFDM symbol period, Δt =1/(NΔf ) ≈1.9 nanoseconds, and R

denotes the real part of a complex number.

Finally, MB-OFDM signals hop between 14 band center frequencies according to the specified timefrequency code. The band allocation is shown in Table 1 [2].

See, e.g., Rao at 560.

Case 2:23-cv-00285-JRG-RSP Document 59-4 Filed 07/11/24 Page 53 of 150 PageID #:

1619
53

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

See, e.g., Rao at Table 1.

Case 2:23-cv-00285-JRG-RSP Document 59-4 Filed 07/11/24 Page 54 of 150 PageID #:

1620
54

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

Furthermore, this claim element is obvious in light of Rao 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;

Rao 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.: 

See, e.g., Rao at Figure 1.

One approach to designing a UWB system based on OFDM is to combine the modulation technique 

with a multibanding approach, which divides the spectrum into several sub-bands, whose bandwidth 

is approximately 500 MHz [2]. The band allocation is given in Table.1. The relationship between 

center frequency and band number is given by the following equation Band center frequency 2904 +

528 × nb,nb = 1 ... .14(MHz).

Case 2:23-cv-00285-JRG-RSP Document 59-4 Filed 07/11/24 Page 55 of 150 PageID #:

1621
55

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

This definition provides a unique numbering system for all channels that have a spacing of 528 MHz 

and lie within the band 3.1 – 10.6 GHz. Based on this, five band groups are defined, band group 1 is 

used for mandatory mode and the remaining band groups are reserved for future use. The transmitted 

OFDM symbols are time-interleaved across the sub bands. An advantage of this approach is that the 

average transmitted power is the same as a system designed to operate over the entire bandwidth. 

Other advantages of multibanding include processing the information over much smaller bandwidth 

(528 MHz), which reduces power consumption and lowers cost and improving spectral flexibility.

See, e.g., Rao at 559.

The 128-tone (16-QAM symbols) coefficients are inverse transformed to obtain data block samples 

by

dm =

1

N

∑ Dnexp(

j2πmn

N

)

N−1

n=0

;m = 0,1,2,... , N − 1 (1)

where Dn is the n

th QAM symbol and N =128 [3]. The MB-OFDM symbol is formed by placing the 

data block between the 32-sample zero prefix and 5-sample guard interval suffix making the total 

symbol length of L =165 samples. A scheme for MB-OFDM UWB signals is shown in Fig.1.

The k

th MB-OFDM symbol is

uk,l = {

0 1 < l ≤ 32

dl−33 32 < l ≤ 160

0 160 < 6 ≤ 165

(2)

Then the simulated MB-OFDM signal is mathematically described as

u(t) = R (( ∑ ∑uk,lhrect(t − kTOFDM − (l − 1)∆t)

L

l=1

∞

k=−∞

)exp(−j2πfc

t)) (3)

Case 2:23-cv-00285-JRG-RSP Document 59-4 Filed 07/11/24 Page 56 of 150 PageID #:

1622
56

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

where hrect is a filter with a rectangular frequency response bounded by ±1/(2Δt), TOFDM = L∆t = 

312.5 nanoseconds is the MB-OFDM symbol period, Δt =1/(NΔf ) ≈1.9 nanoseconds, and R

denotes the real part of a complex number.

Finally, MB-OFDM signals hop between 14 band center frequencies according to the specified timefrequency code. The band allocation is shown in Table 1 [2].

See, e.g., Rao at 560.

Case 2:23-cv-00285-JRG-RSP Document 59-4 Filed 07/11/24 Page 57 of 150 PageID #:

1623
57

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

See, e.g., Rao at Table 1.

Case 2:23-cv-00285-JRG-RSP Document 59-4 Filed 07/11/24 Page 58 of 150 PageID #:

1624
58

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

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

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

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

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

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

First Supplemental Ex. A-Obviousness Chart.

[10.7] up-converting the 

second analog signal to a 

second RF center frequency 

greater than the first center RF 

frequency to produce a second 

up-converted analog signal, 

wherein the second upconverted analog signal 

comprises a second upconverted frequency range 

from the second RF center 

frequency minus one-half the 

second frequency range to the 

second RF center frequency 

plus one-half the second 

frequency range, and wherein 

a frequency difference 

between the first RF center 

frequency and the second RF 

center frequency is greater 

than the sum of one-half the 

first frequency range and onehalf the second frequency 

range;

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

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

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

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

range and one-half the second frequency range.” See, e.g.: 

See, e.g., Rao at Figure 1.

One approach to designing a UWB system based on OFDM is to combine the modulation technique 

with a multibanding approach, which divides the spectrum into several sub-bands, whose bandwidth 

is approximately 500 MHz [2]. The band allocation is given in Table.1. The relationship between 

Case 2:23-cv-00285-JRG-RSP Document 59-4 Filed 07/11/24 Page 59 of 150 PageID #:

1625
59

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

center frequency and band number is given by the following equation Band center frequency 2904 +

528 × nb,nb = 1 ... .14(MHz).

This definition provides a unique numbering system for all channels that have a spacing of 528 MHz 

and lie within the band 3.1 – 10.6 GHz. Based on this, five band groups are defined, band group 1 is 

used for mandatory mode and the remaining band groups are reserved for future use. The transmitted 

OFDM symbols are time-interleaved across the sub bands. An advantage of this approach is that the 

average transmitted power is the same as a system designed to operate over the entire bandwidth. 

Other advantages of multibanding include processing the information over much smaller bandwidth 

(528 MHz), which reduces power consumption and lowers cost and improving spectral flexibility.

See, e.g., Rao at 559.

The 128-tone (16-QAM symbols) coefficients are inverse transformed to obtain data block samples 

by

dm =

1

N

∑ Dnexp(

j2πmn

N

)

N−1

n=0

;m = 0,1,2,... , N − 1 (1)

where Dn is the n

th QAM symbol and N =128 [3]. The MB-OFDM symbol is formed by placing the 

data block between the 32-sample zero prefix and 5-sample guard interval suffix making the total 

symbol length of L =165 samples. A scheme for MB-OFDM UWB signals is shown in Fig.1.

The k

th MB-OFDM symbol is

uk,l = {

0 1 < l ≤ 32

dl−33 32 < l ≤ 160

0 160 < 6 ≤ 165

(2)

Then the simulated MB-OFDM signal is mathematically described as

Case 2:23-cv-00285-JRG-RSP Document 59-4 Filed 07/11/24 Page 60 of 150 PageID #:

1626
60

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

u(t) = R (( ∑ ∑uk,lhrect(t − kTOFDM − (l − 1)∆t)

L

l=1

∞

k=−∞

)exp(−j2πfc

t)) (3)

where hrect is a filter with a rectangular frequency response bounded by ±1/(2Δt), TOFDM = L∆t = 

312.5 nanoseconds is the MB-OFDM symbol period, Δt =1/(NΔf ) ≈1.9 nanoseconds, and R

denotes the real part of a complex number.

Finally, MB-OFDM signals hop between 14 band center frequencies according to the specified timefrequency code. The band allocation is shown in Table 1 [2].

See, e.g., Rao at 560.

Case 2:23-cv-00285-JRG-RSP Document 59-4 Filed 07/11/24 Page 61 of 150 PageID #:

1627
61

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

See, e.g., Rao at Table 1.

Case 2:23-cv-00285-JRG-RSP Document 59-4 Filed 07/11/24 Page 62 of 150 PageID #:

1628
62

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

Furthermore, this claim element is obvious in light of Rao 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;

Rao 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.: 

See, e.g., Rao at Figure 1.

One approach to designing a UWB system based on OFDM is to combine the modulation technique 

with a multibanding approach, which divides the spectrum into several sub-bands, whose bandwidth 

is approximately 500 MHz [2]. The band allocation is given in Table.1. The relationship between 

center frequency and band number is given by the following equation Band center frequency 2904 +

528 × nb,nb = 1 ... .14(MHz).

This definition provides a unique numbering system for all channels that have a spacing of 528 MHz 

and lie within the band 3.1 – 10.6 GHz. Based on this, five band groups are defined, band group 1 is 

Case 2:23-cv-00285-JRG-RSP Document 59-4 Filed 07/11/24 Page 63 of 150 PageID #:

1629
63

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

used for mandatory mode and the remaining band groups are reserved for future use. The transmitted 

OFDM symbols are time-interleaved across the sub bands. An advantage of this approach is that the 

average transmitted power is the same as a system designed to operate over the entire bandwidth. 

Other advantages of multibanding include processing the information over much smaller bandwidth 

(528 MHz), which reduces power consumption and lowers cost and improving spectral flexibility.

See, e.g., Rao at 559.

The 128-tone (16-QAM symbols) coefficients are inverse transformed to obtain data block samples 

by

dm =

1

N

∑ Dnexp(

j2πmn

N

)

N−1

n=0

;m = 0,1,2,... , N − 1 (1)

where Dn is the n

th QAM symbol and N =128 [3]. The MB-OFDM symbol is formed by placing the 

data block between the 32-sample zero prefix and 5-sample guard interval suffix making the total 

symbol length of L =165 samples. A scheme for MB-OFDM UWB signals is shown in Fig.1.

The k

th MB-OFDM symbol is

uk,l = {

0 1 < l ≤ 32

dl−33 32 < l ≤ 160

0 160 < 6 ≤ 165

(2)

Then the simulated MB-OFDM signal is mathematically described as

u(t) = R (( ∑ ∑uk,lhrect(t − kTOFDM − (l − 1)∆t)

L

l=1

∞

k=−∞

)exp(−j2πfc

t)) (3)

Case 2:23-cv-00285-JRG-RSP Document 59-4 Filed 07/11/24 Page 64 of 150 PageID #:

1630
64

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

where hrect is a filter with a rectangular frequency response bounded by ±1/(2Δt), TOFDM = L∆t = 

312.5 nanoseconds is the MB-OFDM symbol period, Δt =1/(NΔf ) ≈1.9 nanoseconds, and R

denotes the real part of a complex number.

Finally, MB-OFDM signals hop between 14 band center frequencies according to the specified timefrequency code. The band allocation is shown in Table 1 [2].

See, e.g., Rao at 560.

Case 2:23-cv-00285-JRG-RSP Document 59-4 Filed 07/11/24 Page 65 of 150 PageID #:

1631
65

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

See, e.g., Rao at Table 1.

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

other references as charted for this claim element in Exs. A-1–A-31, First Supplemental Ex. ACase 2:23-cv-00285-JRG-RSP Document 59-4 Filed 07/11/24 Page 66 of 150 PageID #:

1632
66

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

Obviousness Chart, and/or when combined with the knowledge of one of ordinary skill in the art. 

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

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

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

First Supplemental Ex. A-Obviousness Chart.

[10.9] amplifying the 

combined up-converted signal 

in a power amplifier resulting 

in an amplified combined upconverted signal; and

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

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

See, e.g., Rao at Figure 1.

One approach to designing a UWB system based on OFDM is to combine the modulation technique 

with a multibanding approach, which divides the spectrum into several sub-bands, whose bandwidth 

is approximately 500 MHz [2]. The band allocation is given in Table.1. The relationship between 

center frequency and band number is given by the following equation Band center frequency 2904 +

528 × nb,nb = 1 ... .14(MHz).

This definition provides a unique numbering system for all channels that have a spacing of 528 MHz 

and lie within the band 3.1 – 10.6 GHz. Based on this, five band groups are defined, band group 1 is 

used for mandatory mode and the remaining band groups are reserved for future use. The transmitted 

OFDM symbols are time-interleaved across the sub bands. An advantage of this approach is that the 

Case 2:23-cv-00285-JRG-RSP Document 59-4 Filed 07/11/24 Page 67 of 150 PageID #:

1633
67

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

average transmitted power is the same as a system designed to operate over the entire bandwidth. 

Other advantages of multibanding include processing the information over much smaller bandwidth 

(528 MHz), which reduces power consumption and lowers cost and improving spectral flexibility.

See, e.g., Rao at 559.

The 128-tone (16-QAM symbols) coefficients are inverse transformed to obtain data block samples 

by

dm =

1

N

∑ Dnexp(

j2πmn

N

)

N−1

n=0

;m = 0,1,2,... , N − 1 (1)

where Dn is the n

th QAM symbol and N =128 [3]. The MB-OFDM symbol is formed by placing the 

data block between the 32-sample zero prefix and 5-sample guard interval suffix making the total 

symbol length of L =165 samples. A scheme for MB-OFDM UWB signals is shown in Fig.1.

The k

th MB-OFDM symbol is

uk,l = {

0 1 < l ≤ 32

dl−33 32 < l ≤ 160

0 160 < 6 ≤ 165

(2)

Then the simulated MB-OFDM signal is mathematically described as

u(t) = R (( ∑ ∑uk,lhrect(t − kTOFDM − (l − 1)∆t)

L

l=1

∞

k=−∞

)exp(−j2πfc

t)) (3)

where hrect is a filter with a rectangular frequency response bounded by ±1/(2Δt), TOFDM = L∆t = 

312.5 nanoseconds is the MB-OFDM symbol period, Δt =1/(NΔf ) ≈1.9 nanoseconds, and R

denotes the real part of a complex number.

Case 2:23-cv-00285-JRG-RSP Document 59-4 Filed 07/11/24 Page 68 of 150 PageID #:

1634
68

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

Finally, MB-OFDM signals hop between 14 band center frequencies according to the specified timefrequency code. The band allocation is shown in Table 1 [2].

See, e.g., Rao at 560.

Case 2:23-cv-00285-JRG-RSP Document 59-4 Filed 07/11/24 Page 69 of 150 PageID #:

1635
69

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

See, e.g., Rao at Table 1.

Case 2:23-cv-00285-JRG-RSP Document 59-4 Filed 07/11/24 Page 70 of 150 PageID #:

1636
70

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

Furthermore, this claim element is obvious in light of Rao 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,

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

e.g.: 

See, e.g., Rao at Figure 1.

One approach to designing a UWB system based on OFDM is to combine the modulation technique 

with a multibanding approach, which divides the spectrum into several sub-bands, whose bandwidth 

is approximately 500 MHz [2]. The band allocation is given in Table.1. The relationship between 

center frequency and band number is given by the following equation Band center frequency 2904 +

528 × nb,nb = 1 ... .14(MHz).

This definition provides a unique numbering system for all channels that have a spacing of 528 MHz 

and lie within the band 3.1 – 10.6 GHz. Based on this, five band groups are defined, band group 1 is 

Case 2:23-cv-00285-JRG-RSP Document 59-4 Filed 07/11/24 Page 71 of 150 PageID #:

1637
71

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

used for mandatory mode and the remaining band groups are reserved for future use. The transmitted 

OFDM symbols are time-interleaved across the sub bands. An advantage of this approach is that the 

average transmitted power is the same as a system designed to operate over the entire bandwidth. 

Other advantages of multibanding include processing the information over much smaller bandwidth 

(528 MHz), which reduces power consumption and lowers cost and improving spectral flexibility.

See, e.g., Rao at 559.

The 128-tone (16-QAM symbols) coefficients are inverse transformed to obtain data block samples 

by

dm =

1

N

∑ Dnexp(

j2πmn

N

)

N−1

n=0

;m = 0,1,2,... , N − 1 (1)

where Dn is the n

th QAM symbol and N =128 [3]. The MB-OFDM symbol is formed by placing the 

data block between the 32-sample zero prefix and 5-sample guard interval suffix making the total 

symbol length of L =165 samples. A scheme for MB-OFDM UWB signals is shown in Fig.1.

The k

th MB-OFDM symbol is

uk,l = {

0 1 < l ≤ 32

dl−33 32 < l ≤ 160

0 160 < 6 ≤ 165

(2)

Then the simulated MB-OFDM signal is mathematically described as

u(t) = R (( ∑ ∑uk,lhrect(t − kTOFDM − (l − 1)∆t)

L

l=1

∞

k=−∞

)exp(−j2πfc

t)) (3)

Case 2:23-cv-00285-JRG-RSP Document 59-4 Filed 07/11/24 Page 72 of 150 PageID #:

1638
72

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

where hrect is a filter with a rectangular frequency response bounded by ±1/(2Δt), TOFDM = L∆t = 

312.5 nanoseconds is the MB-OFDM symbol period, Δt =1/(NΔf ) ≈1.9 nanoseconds, and R

denotes the real part of a complex number.

Finally, MB-OFDM signals hop between 14 band center frequencies according to the specified timefrequency code. The band allocation is shown in Table 1 [2].

See, e.g., Rao at 560.

Case 2:23-cv-00285-JRG-RSP Document 59-4 Filed 07/11/24 Page 73 of 150 PageID #:

1639
73

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

See, e.g., Rao at Table 1.

Case 2:23-cv-00285-JRG-RSP Document 59-4 Filed 07/11/24 Page 74 of 150 PageID #:

1640
74

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

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

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

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

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

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

First Supplemental Ex. A-Obviousness Chart.

[10.11] wherein the 

bandwidth of said power 

amplifier is greater than the 

difference between a lowest 

frequency in the first upconverted frequency range 

and a highest frequency in the 

second up-converted 

frequency range.

Rao 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.: 

See, e.g., Rao at Figure 1.

One approach to designing a UWB system based on OFDM is to combine the modulation technique 

with a multibanding approach, which divides the spectrum into several sub-bands, whose bandwidth 

is approximately 500 MHz [2]. The band allocation is given in Table.1. The relationship between 

center frequency and band number is given by the following equation Band center frequency 2904 +

528 × nb,nb = 1 ... .14(MHz).

Case 2:23-cv-00285-JRG-RSP Document 59-4 Filed 07/11/24 Page 75 of 150 PageID #:

1641
75

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

This definition provides a unique numbering system for all channels that have a spacing of 528 MHz 

and lie within the band 3.1 – 10.6 GHz. Based on this, five band groups are defined, band group 1 is 

used for mandatory mode and the remaining band groups are reserved for future use. The transmitted 

OFDM symbols are time-interleaved across the sub bands. An advantage of this approach is that the 

average transmitted power is the same as a system designed to operate over the entire bandwidth. 

Other advantages of multibanding include processing the information over much smaller bandwidth 

(528 MHz), which reduces power consumption and lowers cost and improving spectral flexibility.

See, e.g., Rao at 559.

The 128-tone (16-QAM symbols) coefficients are inverse transformed to obtain data block samples 

by

dm =

1

N

∑ Dnexp(

j2πmn

N

)

N−1

n=0

;m = 0,1,2,... , N − 1 (1)

where Dn is the n

th QAM symbol and N =128 [3]. The MB-OFDM symbol is formed by placing the 

data block between the 32-sample zero prefix and 5-sample guard interval suffix making the total 

symbol length of L =165 samples. A scheme for MB-OFDM UWB signals is shown in Fig.1.

The k

th MB-OFDM symbol is

uk,l = {

0 1 < l ≤ 32

dl−33 32 < l ≤ 160

0 160 < 6 ≤ 165

(2)

Then the simulated MB-OFDM signal is mathematically described as

u(t) = R (( ∑ ∑uk,lhrect(t − kTOFDM − (l − 1)∆t)

L

l=1

∞

k=−∞

)exp(−j2πfc

t)) (3)

Case 2:23-cv-00285-JRG-RSP Document 59-4 Filed 07/11/24 Page 76 of 150 PageID #:

1642
76

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

where hrect is a filter with a rectangular frequency response bounded by ±1/(2Δt), TOFDM = L∆t = 

312.5 nanoseconds is the MB-OFDM symbol period, Δt =1/(NΔf ) ≈1.9 nanoseconds, and R

denotes the real part of a complex number.

Finally, MB-OFDM signals hop between 14 band center frequencies according to the specified timefrequency code. The band allocation is shown in Table 1 [2].

See, e.g., Rao at 560.

Case 2:23-cv-00285-JRG-RSP Document 59-4 Filed 07/11/24 Page 77 of 150 PageID #:

1643
77

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

See, e.g., Rao at Table 1.

Case 2:23-cv-00285-JRG-RSP Document 59-4 Filed 07/11/24 Page 78 of 150 PageID #:

1644
78

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

Furthermore, this claim element is obvious in light of Rao 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 – Rao

[13.1] The method of claim 10 Rao 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.

Rao 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.: 

See, e.g., Rao at Figure 1.

One approach to designing a UWB system based on OFDM is to combine the modulation technique 

with a multibanding approach, which divides the spectrum into several sub-bands, whose bandwidth 

is approximately 500 MHz [2]. The band allocation is given in Table.1. The relationship between 

Case 2:23-cv-00285-JRG-RSP Document 59-4 Filed 07/11/24 Page 79 of 150 PageID #:

1645
79

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

center frequency and band number is given by the following equation Band center frequency 2904 +

528 × nb,nb = 1 ... .14(MHz).

This definition provides a unique numbering system for all channels that have a spacing of 528 MHz 

and lie within the band 3.1 – 10.6 GHz. Based on this, five band groups are defined, band group 1 is 

used for mandatory mode and the remaining band groups are reserved for future use. The transmitted 

OFDM symbols are time-interleaved across the sub bands. An advantage of this approach is that the 

average transmitted power is the same as a system designed to operate over the entire bandwidth. 

Other advantages of multibanding include processing the information over much smaller bandwidth 

(528 MHz), which reduces power consumption and lowers cost and improving spectral flexibility.

See, e.g., Rao at 559.

The 128-tone (16-QAM symbols) coefficients are inverse transformed to obtain data block samples 

by

dm =

1

N

∑ Dnexp(

j2πmn

N

)

N−1

n=0

;m = 0,1,2,... , N − 1 (1)

where Dn is the n

th QAM symbol and N =128 [3]. The MB-OFDM symbol is formed by placing the 

data block between the 32-sample zero prefix and 5-sample guard interval suffix making the total 

symbol length of L =165 samples. A scheme for MB-OFDM UWB signals is shown in Fig.1.

The k

th MB-OFDM symbol is

uk,l = {

0 1 < l ≤ 32

dl−33 32 < l ≤ 160

0 160 < 6 ≤ 165

(2)

Then the simulated MB-OFDM signal is mathematically described as

Case 2:23-cv-00285-JRG-RSP Document 59-4 Filed 07/11/24 Page 80 of 150 PageID #:

1646
80

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

u(t) = R (( ∑ ∑uk,lhrect(t − kTOFDM − (l − 1)∆t)

L

l=1

∞

k=−∞

)exp(−j2πfc

t)) (3)

where hrect is a filter with a rectangular frequency response bounded by ±1/(2Δt), TOFDM = L∆t = 

312.5 nanoseconds is the MB-OFDM symbol period, Δt =1/(NΔf ) ≈1.9 nanoseconds, and R

denotes the real part of a complex number.

Finally, MB-OFDM signals hop between 14 band center frequencies according to the specified timefrequency code. The band allocation is shown in Table 1 [2].

See, e.g., Rao at 560.

Case 2:23-cv-00285-JRG-RSP Document 59-4 Filed 07/11/24 Page 81 of 150 PageID #:

1647
81

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

See, e.g., Rao at Table 1.

Case 2:23-cv-00285-JRG-RSP Document 59-4 Filed 07/11/24 Page 82 of 150 PageID #:

1648
82

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

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

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

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

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

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

First Supplemental Ex. A-Obviousness Chart.

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

[14.1] The method of claim 10 Rao 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:

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

See, e.g.: 

See, e.g., Rao at Figure 1.

One approach to designing a UWB system based on OFDM is to combine the modulation technique 

with a multibanding approach, which divides the spectrum into several sub-bands, whose bandwidth 

is approximately 500 MHz [2]. The band allocation is given in Table.1. The relationship between 

Case 2:23-cv-00285-JRG-RSP Document 59-4 Filed 07/11/24 Page 83 of 150 PageID #:

1649
83

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

center frequency and band number is given by the following equation Band center frequency 2904 +

528 × nb,nb = 1 ... .14(MHz).

This definition provides a unique numbering system for all channels that have a spacing of 528 MHz 

and lie within the band 3.1 – 10.6 GHz. Based on this, five band groups are defined, band group 1 is 

used for mandatory mode and the remaining band groups are reserved for future use. The transmitted 

OFDM symbols are time-interleaved across the sub bands. An advantage of this approach is that the 

average transmitted power is the same as a system designed to operate over the entire bandwidth. 

Other advantages of multibanding include processing the information over much smaller bandwidth 

(528 MHz), which reduces power consumption and lowers cost and improving spectral flexibility.

See, e.g., Rao at 559.

The 128-tone (16-QAM symbols) coefficients are inverse transformed to obtain data block samples 

by

dm =

1

N

∑ Dnexp(

j2πmn

N

)

N−1

n=0

;m = 0,1,2,... , N − 1 (1)

where Dn is the n

th QAM symbol and N =128 [3]. The MB-OFDM symbol is formed by placing the 

data block between the 32-sample zero prefix and 5-sample guard interval suffix making the total 

symbol length of L =165 samples. A scheme for MB-OFDM UWB signals is shown in Fig.1.

The k

th MB-OFDM symbol is

uk,l = {

0 1 < l ≤ 32

dl−33 32 < l ≤ 160

0 160 < 6 ≤ 165

(2)

Then the simulated MB-OFDM signal is mathematically described as

Case 2:23-cv-00285-JRG-RSP Document 59-4 Filed 07/11/24 Page 84 of 150 PageID #:

1650
84

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

u(t) = R (( ∑ ∑uk,lhrect(t − kTOFDM − (l − 1)∆t)

L

l=1

∞

k=−∞

)exp(−j2πfc

t)) (3)

where hrect is a filter with a rectangular frequency response bounded by ±1/(2Δt), TOFDM = L∆t = 

312.5 nanoseconds is the MB-OFDM symbol period, Δt =1/(NΔf ) ≈1.9 nanoseconds, and R

denotes the real part of a complex number.

Finally, MB-OFDM signals hop between 14 band center frequencies according to the specified timefrequency code. The band allocation is shown in Table 1 [2].

See, e.g., Rao at 560.

Case 2:23-cv-00285-JRG-RSP Document 59-4 Filed 07/11/24 Page 85 of 150 PageID #:

1651
85

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

See, e.g., Rao at Table 1.

Case 2:23-cv-00285-JRG-RSP Document 59-4 Filed 07/11/24 Page 86 of 150 PageID #:

1652
86

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

Furthermore, this claim element is obvious in light of Rao 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;

Rao discloses “receiving the transmitted signal on a second antenna.” See, e.g.: 

See, e.g., Rao at Figure 1.

One approach to designing a UWB system based on OFDM is to combine the modulation technique 

with a multibanding approach, which divides the spectrum into several sub-bands, whose bandwidth 

is approximately 500 MHz [2]. The band allocation is given in Table.1. The relationship between 

center frequency and band number is given by the following equation Band center frequency 2904 +

528 × nb,nb = 1 ... .14(MHz).

This definition provides a unique numbering system for all channels that have a spacing of 528 MHz 

and lie within the band 3.1 – 10.6 GHz. Based on this, five band groups are defined, band group 1 is 

used for mandatory mode and the remaining band groups are reserved for future use. The transmitted 

Case 2:23-cv-00285-JRG-RSP Document 59-4 Filed 07/11/24 Page 87 of 150 PageID #:

1653
87

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

OFDM symbols are time-interleaved across the sub bands. An advantage of this approach is that the 

average transmitted power is the same as a system designed to operate over the entire bandwidth. 

Other advantages of multibanding include processing the information over much smaller bandwidth 

(528 MHz), which reduces power consumption and lowers cost and improving spectral flexibility.

See, e.g., Rao at 559.

The 128-tone (16-QAM symbols) coefficients are inverse transformed to obtain data block samples 

by

dm =

1

N

∑ Dnexp(

j2πmn

N

)

N−1

n=0

;m = 0,1,2,... , N − 1 (1)

where Dn is the n

th QAM symbol and N =128 [3]. The MB-OFDM symbol is formed by placing the 

data block between the 32-sample zero prefix and 5-sample guard interval suffix making the total 

symbol length of L =165 samples. A scheme for MB-OFDM UWB signals is shown in Fig.1.

The k

th MB-OFDM symbol is

uk,l = {

0 1 < l ≤ 32

dl−33 32 < l ≤ 160

0 160 < 6 ≤ 165

(2)

Then the simulated MB-OFDM signal is mathematically described as

u(t) = R (( ∑ ∑uk,lhrect(t − kTOFDM − (l − 1)∆t)

L

l=1

∞

k=−∞

)exp(−j2πfc

t)) (3)

Case 2:23-cv-00285-JRG-RSP Document 59-4 Filed 07/11/24 Page 88 of 150 PageID #:

1654
88

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

where hrect is a filter with a rectangular frequency response bounded by ±1/(2Δt), TOFDM = L∆t = 

312.5 nanoseconds is the MB-OFDM symbol period, Δt =1/(NΔf ) ≈1.9 nanoseconds, and R

denotes the real part of a complex number.

Finally, MB-OFDM signals hop between 14 band center frequencies according to the specified timefrequency code. The band allocation is shown in Table 1 [2].

See, e.g., Rao at 560.

Case 2:23-cv-00285-JRG-RSP Document 59-4 Filed 07/11/24 Page 89 of 150 PageID #:

1655
89

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

See, e.g., Rao at Table 1.

Case 2:23-cv-00285-JRG-RSP Document 59-4 Filed 07/11/24 Page 90 of 150 PageID #:

1656
90

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

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

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

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

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

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

First Supplemental Ex. A-Obviousness Chart.

[14.4] amplifying the received 

signal in a low noise amplifier 

resulting in an amplified 

received up-converted signal, 

wherein the bandwidth of said 

low noise amplifier is greater 

than the difference between 

the lowest frequency in the 

first up-converted frequency 

range and the highest 

frequency in the second upconverted frequency range;

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

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

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

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

See, e.g., Rao at Figure 1.

One approach to designing a UWB system based on OFDM is to combine the modulation technique 

with a multibanding approach, which divides the spectrum into several sub-bands, whose bandwidth 

is approximately 500 MHz [2]. The band allocation is given in Table.1. The relationship between 

center frequency and band number is given by the following equation Band center frequency 2904 +

528 × nb,nb = 1 ... .14(MHz).

Case 2:23-cv-00285-JRG-RSP Document 59-4 Filed 07/11/24 Page 91 of 150 PageID #:

1657
91

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

This definition provides a unique numbering system for all channels that have a spacing of 528 MHz 

and lie within the band 3.1 – 10.6 GHz. Based on this, five band groups are defined, band group 1 is 

used for mandatory mode and the remaining band groups are reserved for future use. The transmitted 

OFDM symbols are time-interleaved across the sub bands. An advantage of this approach is that the 

average transmitted power is the same as a system designed to operate over the entire bandwidth. 

Other advantages of multibanding include processing the information over much smaller bandwidth 

(528 MHz), which reduces power consumption and lowers cost and improving spectral flexibility.

See, e.g., Rao at 559.

The 128-tone (16-QAM symbols) coefficients are inverse transformed to obtain data block samples 

by

dm =

1

N

∑ Dnexp(

j2πmn

N

)

N−1

n=0

;m = 0,1,2,... , N − 1 (1)

where Dn is the n

th QAM symbol and N =128 [3]. The MB-OFDM symbol is formed by placing the 

data block between the 32-sample zero prefix and 5-sample guard interval suffix making the total 

symbol length of L =165 samples. A scheme for MB-OFDM UWB signals is shown in Fig.1.

The k

th MB-OFDM symbol is

uk,l = {

0 1 < l ≤ 32

dl−33 32 < l ≤ 160

0 160 < 6 ≤ 165

(2)

Then the simulated MB-OFDM signal is mathematically described as

u(t) = R (( ∑ ∑uk,lhrect(t − kTOFDM − (l − 1)∆t)

L

l=1

∞

k=−∞

)exp(−j2πfc

t)) (3)

Case 2:23-cv-00285-JRG-RSP Document 59-4 Filed 07/11/24 Page 92 of 150 PageID #:

1658
92

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

where hrect is a filter with a rectangular frequency response bounded by ±1/(2Δt), TOFDM = L∆t = 

312.5 nanoseconds is the MB-OFDM symbol period, Δt =1/(NΔf ) ≈1.9 nanoseconds, and R

denotes the real part of a complex number.

Finally, MB-OFDM signals hop between 14 band center frequencies according to the specified timefrequency code. The band allocation is shown in Table 1 [2].

See, e.g., Rao at 560.

Case 2:23-cv-00285-JRG-RSP Document 59-4 Filed 07/11/24 Page 93 of 150 PageID #:

1659
93

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

See, e.g., Rao at Table 1.

Case 2:23-cv-00285-JRG-RSP Document 59-4 Filed 07/11/24 Page 94 of 150 PageID #:

1660
94

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

Furthermore, this claim element is obvious in light of Rao 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 

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

Rao 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.: 

See, e.g., Rao at Figure 1.

One approach to designing a UWB system based on OFDM is to combine the modulation technique 

with a multibanding approach, which divides the spectrum into several sub-bands, whose bandwidth 

is approximately 500 MHz [2]. The band allocation is given in Table.1. The relationship between 

center frequency and band number is given by the following equation Band center frequency 2904 +

528 × nb,nb = 1 ... .14(MHz).

Case 2:23-cv-00285-JRG-RSP Document 59-4 Filed 07/11/24 Page 95 of 150 PageID #:

1661
95

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

This definition provides a unique numbering system for all channels that have a spacing of 528 MHz 

and lie within the band 3.1 – 10.6 GHz. Based on this, five band groups are defined, band group 1 is 

used for mandatory mode and the remaining band groups are reserved for future use. The transmitted 

OFDM symbols are time-interleaved across the sub bands. An advantage of this approach is that the 

average transmitted power is the same as a system designed to operate over the entire bandwidth. 

Other advantages of multibanding include processing the information over much smaller bandwidth 

(528 MHz), which reduces power consumption and lowers cost and improving spectral flexibility.

See, e.g., Rao at 559.

The 128-tone (16-QAM symbols) coefficients are inverse transformed to obtain data block samples 

by

dm =

1

N

∑ Dnexp(

j2πmn

N

)

N−1

n=0

;m = 0,1,2,... , N − 1 (1)

where Dn is the n

th QAM symbol and N =128 [3]. The MB-OFDM symbol is formed by placing the 

data block between the 32-sample zero prefix and 5-sample guard interval suffix making the total 

symbol length of L =165 samples. A scheme for MB-OFDM UWB signals is shown in Fig.1.

The k

th MB-OFDM symbol is

uk,l = {

0 1 < l ≤ 32

dl−33 32 < l ≤ 160

0 160 < 6 ≤ 165

(2)

Then the simulated MB-OFDM signal is mathematically described as

u(t) = R (( ∑ ∑uk,lhrect(t − kTOFDM − (l − 1)∆t)

L

l=1

∞

k=−∞

)exp(−j2πfc

t)) (3)

Case 2:23-cv-00285-JRG-RSP Document 59-4 Filed 07/11/24 Page 96 of 150 PageID #:

1662
96

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

where hrect is a filter with a rectangular frequency response bounded by ±1/(2Δt), TOFDM = L∆t = 

312.5 nanoseconds is the MB-OFDM symbol period, Δt =1/(NΔf ) ≈1.9 nanoseconds, and R

denotes the real part of a complex number.

Finally, MB-OFDM signals hop between 14 band center frequencies according to the specified timefrequency code. The band allocation is shown in Table 1 [2].

See, e.g., Rao at 560.

Case 2:23-cv-00285-JRG-RSP Document 59-4 Filed 07/11/24 Page 97 of 150 PageID #:

1663
97

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

See, e.g., Rao at Table 1.

Case 2:23-cv-00285-JRG-RSP Document 59-4 Filed 07/11/24 Page 98 of 150 PageID #:

1664
98

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

Furthermore, this claim element is obvious in light of Rao 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.

[14.6] down-converting the 

amplified received upconverted analog signal using 

a second down-converter and 

a signal corresponding to the 

second RF center frequency to 

produce a fifth analog signal 

corresponding to the second 

analog signal.

Rao 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.:

See, e.g., Rao at Figure 1.

One approach to designing a UWB system based on OFDM is to combine the modulation technique 

with a multibanding approach, which divides the spectrum into several sub-bands, whose bandwidth 

is approximately 500 MHz [2]. The band allocation is given in Table.1. The relationship between 

center frequency and band number is given by the following equation Band center frequency 2904 +

528 × nb,nb = 1 ... .14(MHz).

Case 2:23-cv-00285-JRG-RSP Document 59-4 Filed 07/11/24 Page 99 of 150 PageID #:

1665
99

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

This definition provides a unique numbering system for all channels that have a spacing of 528 MHz 

and lie within the band 3.1 – 10.6 GHz. Based on this, five band groups are defined, band group 1 is 

used for mandatory mode and the remaining band groups are reserved for future use. The transmitted 

OFDM symbols are time-interleaved across the sub bands. An advantage of this approach is that the 

average transmitted power is the same as a system designed to operate over the entire bandwidth. 

Other advantages of multibanding include processing the information over much smaller bandwidth 

(528 MHz), which reduces power consumption and lowers cost and improving spectral flexibility.

See, e.g., Rao at 559.

The 128-tone (16-QAM symbols) coefficients are inverse transformed to obtain data block samples 

by

dm =

1

N

∑ Dnexp(

j2πmn

N

)

N−1

n=0

;m = 0,1,2,... , N − 1 (1)

where Dn is the n

th QAM symbol and N =128 [3]. The MB-OFDM symbol is formed by placing the 

data block between the 32-sample zero prefix and 5-sample guard interval suffix making the total 

symbol length of L =165 samples. A scheme for MB-OFDM UWB signals is shown in Fig.1.

The k

th MB-OFDM symbol is

uk,l = {

0 1 < l ≤ 32

dl−33 32 < l ≤ 160

0 160 < 6 ≤ 165

(2)

Then the simulated MB-OFDM signal is mathematically described as

u(t) = R (( ∑ ∑uk,lhrect(t − kTOFDM − (l − 1)∆t)

L

l=1

∞

k=−∞

)exp(−j2πfc

t)) (3)

Case 2:23-cv-00285-JRG-RSP Document 59-4 Filed 07/11/24 Page 100 of 150 PageID #:

1666
100

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

where hrect is a filter with a rectangular frequency response bounded by ±1/(2Δt), TOFDM = L∆t = 

312.5 nanoseconds is the MB-OFDM symbol period, Δt =1/(NΔf ) ≈1.9 nanoseconds, and R

denotes the real part of a complex number.

Finally, MB-OFDM signals hop between 14 band center frequencies according to the specified timefrequency code. The band allocation is shown in Table 1 [2].

See, e.g., Rao at 560.

Case 2:23-cv-00285-JRG-RSP Document 59-4 Filed 07/11/24 Page 101 of 150 PageID #:

1667
101

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

See, e.g., Rao at Table 1.

Case 2:23-cv-00285-JRG-RSP Document 59-4 Filed 07/11/24 Page 102 of 150 PageID #:

1668
102

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

Furthermore, this claim element is obvious in light of Rao 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 17 of the ’802 Patent Prior Art Reference – Rao

[17.1] A wireless 

communication system 

comprising:

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

comprising.” See, e.g.: 

UWB technology is a wireless protocol for high-speed data transmission over short distances and has 

recently received a lot of interest from the wireless manufacturing and user community [1]. The 

Federal Communications Commission (FCC) has approved to operate UWB in the 3.1- 10.6GHz 

band at a low effective isotropic radiated power(EIRP) of -41.3 dBm/MHz with a minimum signal

bandwidth of 500MHz. In near future, UWB communication system will be extensively used in the 

mobile handsets or consumer device that require real-time transmission of highdefinition multimedia 

data.

See, e.g., Rao at 559.

Furthermore, this claim element is obvious in light of Rao 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 59-4 Filed 07/11/24 Page 103 of 150 PageID #:

1669
103

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

[17.2] a baseband digital 

system for providing a first 

digital signal comprising a 

first data to be transmitted and 

a second digital signal 

comprising a second data to 

be transmitted;

Rao 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.: 

See, e.g., Rao at Figure 1.

One approach to designing a UWB system based on OFDM is to combine the modulation technique 

with a multibanding approach, which divides the spectrum into several sub-bands, whose bandwidth 

is approximately 500 MHz [2]. The band allocation is given in Table.1. The relationship between 

center frequency and band number is given by the following equation Band center frequency 2904 +

528 × nb,nb = 1 ... .14(MHz).

This definition provides a unique numbering system for all channels that have a spacing of 528 MHz 

and lie within the band 3.1 – 10.6 GHz. Based on this, five band groups are defined, band group 1 is 

used for mandatory mode and the remaining band groups are reserved for future use. The transmitted 

OFDM symbols are time-interleaved across the sub bands. An advantage of this approach is that the 

average transmitted power is the same as a system designed to operate over the entire bandwidth. 

Other advantages of multibanding include processing the information over much smaller bandwidth 

(528 MHz), which reduces power consumption and lowers cost and improving spectral flexibility.

Case 2:23-cv-00285-JRG-RSP Document 59-4 Filed 07/11/24 Page 104 of 150 PageID #:

1670
104

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

See, e.g., Rao at 559.

The 128-tone (16-QAM symbols) coefficients are inverse transformed to obtain data block samples 

by

dm =

1

N

∑ Dnexp(

j2πmn

N

)

N−1

n=0

;m = 0,1,2,... , N − 1 (1)

where Dn is the n

th QAM symbol and N =128 [3]. The MB-OFDM symbol is formed by placing the 

data block between the 32-sample zero prefix and 5-sample guard interval suffix making the total 

symbol length of L =165 samples. A scheme for MB-OFDM UWB signals is shown in Fig.1.

The k

th MB-OFDM symbol is

uk,l = {

0 1 < l ≤ 32

dl−33 32 < l ≤ 160

0 160 < 6 ≤ 165

(2)

Then the simulated MB-OFDM signal is mathematically described as

u(t) = R (( ∑ ∑uk,lhrect(t − kTOFDM − (l − 1)∆t)

L

l=1

∞

k=−∞

)exp(−j2πfc

t)) (3)

where hrect is a filter with a rectangular frequency response bounded by ±1/(2Δt), TOFDM = L∆t = 

312.5 nanoseconds is the MB-OFDM symbol period, Δt =1/(NΔf ) ≈1.9 nanoseconds, and R

denotes the real part of a complex number.

Finally, MB-OFDM signals hop between 14 band center frequencies according to the specified timefrequency code. The band allocation is shown in Table 1 [2].

Case 2:23-cv-00285-JRG-RSP Document 59-4 Filed 07/11/24 Page 105 of 150 PageID #:

1671
105

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

See, e.g., Rao at 560.

See, e.g., Rao at Table 1.

Case 2:23-cv-00285-JRG-RSP Document 59-4 Filed 07/11/24 Page 106 of 150 PageID #:

1672
106

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

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

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

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

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

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

First Supplemental Ex. A-Obviousness Chart.

[17.3] a first digital-to-analog 

converter for receiving the 

first digital signal and 

converting the first digital 

signal into a first analog 

signal, the first analog signal 

carrying the first data across a 

first frequency range;

Rao 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.: 

See, e.g., Rao at Figure 1.

One approach to designing a UWB system based on OFDM is to combine the modulation technique 

with a multibanding approach, which divides the spectrum into several sub-bands, whose bandwidth 

is approximately 500 MHz [2]. The band allocation is given in Table.1. The relationship between 

center frequency and band number is given by the following equation Band center frequency 2904 +

528 × nb,nb = 1 ... .14(MHz).

Case 2:23-cv-00285-JRG-RSP Document 59-4 Filed 07/11/24 Page 107 of 150 PageID #:

1673
107

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

This definition provides a unique numbering system for all channels that have a spacing of 528 MHz 

and lie within the band 3.1 – 10.6 GHz. Based on this, five band groups are defined, band group 1 is 

used for mandatory mode and the remaining band groups are reserved for future use. The transmitted 

OFDM symbols are time-interleaved across the sub bands. An advantage of this approach is that the 

average transmitted power is the same as a system designed to operate over the entire bandwidth. 

Other advantages of multibanding include processing the information over much smaller bandwidth 

(528 MHz), which reduces power consumption and lowers cost and improving spectral flexibility.

See, e.g., Rao at 559.

The 128-tone (16-QAM symbols) coefficients are inverse transformed to obtain data block samples 

by

dm =

1

N

∑ Dnexp(

j2πmn

N

)

N−1

n=0

;m = 0,1,2,... , N − 1 (1)

where Dn is the n

th QAM symbol and N =128 [3]. The MB-OFDM symbol is formed by placing the 

data block between the 32-sample zero prefix and 5-sample guard interval suffix making the total 

symbol length of L =165 samples. A scheme for MB-OFDM UWB signals is shown in Fig.1.

The k

th MB-OFDM symbol is

uk,l = {

0 1 < l ≤ 32

dl−33 32 < l ≤ 160

0 160 < 6 ≤ 165

(2)

Then the simulated MB-OFDM signal is mathematically described as

u(t) = R (( ∑ ∑uk,lhrect(t − kTOFDM − (l − 1)∆t)

L

l=1

∞

k=−∞

)exp(−j2πfc

t)) (3)

Case 2:23-cv-00285-JRG-RSP Document 59-4 Filed 07/11/24 Page 108 of 150 PageID #:

1674
108

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

where hrect is a filter with a rectangular frequency response bounded by ±1/(2Δt), TOFDM = L∆t = 

312.5 nanoseconds is the MB-OFDM symbol period, Δt =1/(NΔf ) ≈1.9 nanoseconds, and R

denotes the real part of a complex number.

Finally, MB-OFDM signals hop between 14 band center frequencies according to the specified timefrequency code. The band allocation is shown in Table 1 [2].

See, e.g., Rao at 560.

Case 2:23-cv-00285-JRG-RSP Document 59-4 Filed 07/11/24 Page 109 of 150 PageID #:

1675
109

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

See, e.g., Rao at Table 1.

Case 2:23-cv-00285-JRG-RSP Document 59-4 Filed 07/11/24 Page 110 of 150 PageID #:

1676
110

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

Furthermore, this claim element is obvious in light of Rao 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 

converting the second digital 

signal into a second analog 

signal, the second analog 

signal carrying the second 

data across a second 

frequency range;

Rao 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.: 

See, e.g., Rao at Figure 1.

One approach to designing a UWB system based on OFDM is to combine the modulation technique 

with a multibanding approach, which divides the spectrum into several sub-bands, whose bandwidth 

is approximately 500 MHz [2]. The band allocation is given in Table.1. The relationship between 

center frequency and band number is given by the following equation Band center frequency 2904 +

528 × nb,nb = 1 ... .14(MHz).

Case 2:23-cv-00285-JRG-RSP Document 59-4 Filed 07/11/24 Page 111 of 150 PageID #:

1677
111

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

This definition provides a unique numbering system for all channels that have a spacing of 528 MHz 

and lie within the band 3.1 – 10.6 GHz. Based on this, five band groups are defined, band group 1 is 

used for mandatory mode and the remaining band groups are reserved for future use. The transmitted 

OFDM symbols are time-interleaved across the sub bands. An advantage of this approach is that the 

average transmitted power is the same as a system designed to operate over the entire bandwidth. 

Other advantages of multibanding include processing the information over much smaller bandwidth 

(528 MHz), which reduces power consumption and lowers cost and improving spectral flexibility.

See, e.g., Rao at 559.

The 128-tone (16-QAM symbols) coefficients are inverse transformed to obtain data block samples 

by

dm =

1

N

∑ Dnexp(

j2πmn

N

)

N−1

n=0

;m = 0,1,2,... , N − 1 (1)

where Dn is the n

th QAM symbol and N =128 [3]. The MB-OFDM symbol is formed by placing the 

data block between the 32-sample zero prefix and 5-sample guard interval suffix making the total 

symbol length of L =165 samples. A scheme for MB-OFDM UWB signals is shown in Fig.1.

The k

th MB-OFDM symbol is

uk,l = {

0 1 < l ≤ 32

dl−33 32 < l ≤ 160

0 160 < 6 ≤ 165

(2)

Then the simulated MB-OFDM signal is mathematically described as

u(t) = R (( ∑ ∑uk,lhrect(t − kTOFDM − (l − 1)∆t)

L

l=1

∞

k=−∞

)exp(−j2πfc

t)) (3)

Case 2:23-cv-00285-JRG-RSP Document 59-4 Filed 07/11/24 Page 112 of 150 PageID #:

1678
112

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

where hrect is a filter with a rectangular frequency response bounded by ±1/(2Δt), TOFDM = L∆t = 

312.5 nanoseconds is the MB-OFDM symbol period, Δt =1/(NΔf ) ≈1.9 nanoseconds, and R

denotes the real part of a complex number.

Finally, MB-OFDM signals hop between 14 band center frequencies according to the specified timefrequency code. The band allocation is shown in Table 1 [2].

See, e.g., Rao at 560.

Case 2:23-cv-00285-JRG-RSP Document 59-4 Filed 07/11/24 Page 113 of 150 PageID #:

1679
113

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

See, e.g., Rao at Table 1.

Case 2:23-cv-00285-JRG-RSP Document 59-4 Filed 07/11/24 Page 114 of 150 PageID #:

1680
114

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

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

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

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

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

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

First Supplemental Ex. A-Obviousness Chart.

[17.5] a first up-converter 

circuit having a first input 

coupled to receive the first 

analog signal and a second 

input coupled to receive a first 

modulation signal having a 

first RF frequency, wherein 

the first up-converter outputs 

a first up-converted analog 

signal comprising a first upconverted frequency range 

from the first RF frequency 

minus one-half the first 

frequency range to the first 

RF frequency plus one-half 

the first frequency range;

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

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

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

first RF frequency plus one-half the first frequency range.” See, e.g.: 

See, e.g., Rao at Figure 1.

One approach to designing a UWB system based on OFDM is to combine the modulation technique 

with a multibanding approach, which divides the spectrum into several sub-bands, whose bandwidth 

is approximately 500 MHz [2]. The band allocation is given in Table.1. The relationship between 

center frequency and band number is given by the following equation Band center frequency 2904 +

528 × nb,nb = 1 ... .14(MHz).

Case 2:23-cv-00285-JRG-RSP Document 59-4 Filed 07/11/24 Page 115 of 150 PageID #:

1681
115

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

This definition provides a unique numbering system for all channels that have a spacing of 528 MHz 

and lie within the band 3.1 – 10.6 GHz. Based on this, five band groups are defined, band group 1 is 

used for mandatory mode and the remaining band groups are reserved for future use. The transmitted 

OFDM symbols are time-interleaved across the sub bands. An advantage of this approach is that the 

average transmitted power is the same as a system designed to operate over the entire bandwidth. 

Other advantages of multibanding include processing the information over much smaller bandwidth 

(528 MHz), which reduces power consumption and lowers cost and improving spectral flexibility.

See, e.g., Rao at 559.

The 128-tone (16-QAM symbols) coefficients are inverse transformed to obtain data block samples 

by

dm =

1

N

∑ Dnexp(

j2πmn

N

)

N−1

n=0

;m = 0,1,2,... , N − 1 (1)

where Dn is the n

th QAM symbol and N =128 [3]. The MB-OFDM symbol is formed by placing the 

data block between the 32-sample zero prefix and 5-sample guard interval suffix making the total 

symbol length of L =165 samples. A scheme for MB-OFDM UWB signals is shown in Fig.1.

The k

th MB-OFDM symbol is

uk,l = {

0 1 < l ≤ 32

dl−33 32 < l ≤ 160

0 160 < 6 ≤ 165

(2)

Then the simulated MB-OFDM signal is mathematically described as

Case 2:23-cv-00285-JRG-RSP Document 59-4 Filed 07/11/24 Page 116 of 150 PageID #:

1682
116

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

u(t) = R (( ∑ ∑uk,lhrect(t − kTOFDM − (l − 1)∆t)

L

l=1

∞

k=−∞

)exp(−j2πfc

t)) (3)

where hrect is a filter with a rectangular frequency response bounded by ±1/(2Δt), TOFDM = L∆t = 

312.5 nanoseconds is the MB-OFDM symbol period, Δt =1/(NΔf ) ≈1.9 nanoseconds, and R

denotes the real part of a complex number.

Finally, MB-OFDM signals hop between 14 band center frequencies according to the specified timefrequency code. The band allocation is shown in Table 1 [2].

See, e.g., Rao at 560.

Case 2:23-cv-00285-JRG-RSP Document 59-4 Filed 07/11/24 Page 117 of 150 PageID #:

1683
117

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

See, e.g., Rao at Table 1.

Case 2:23-cv-00285-JRG-RSP Document 59-4 Filed 07/11/24 Page 118 of 150 PageID #:

1684
118

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

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

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

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

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

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

First Supplemental Ex. A-Obviousness Chart.

[17.6] a second up-converter 

circuit having a first input 

coupled to receive the second 

analog signal and a second 

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 

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

signal and a second input coupled to receive a second modulation signal having a second RF 

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

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

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

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

sum of one-half the first frequency range and one-half the second frequency range.” See, e.g.: 

See, e.g., Rao at Figure 1.

One approach to designing a UWB system based on OFDM is to combine the modulation technique 

with a multibanding approach, which divides the spectrum into several sub-bands, whose bandwidth 

is approximately 500 MHz [2]. The band allocation is given in Table.1. The relationship between 

Case 2:23-cv-00285-JRG-RSP Document 59-4 Filed 07/11/24 Page 119 of 150 PageID #:

1685
119

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

the second frequency range; 

and

center frequency and band number is given by the following equation Band center frequency 2904 +

528 × nb,nb = 1 ... .14(MHz).

This definition provides a unique numbering system for all channels that have a spacing of 528 MHz 

and lie within the band 3.1 – 10.6 GHz. Based on this, five band groups are defined, band group 1 is 

used for mandatory mode and the remaining band groups are reserved for future use. The transmitted 

OFDM symbols are time-interleaved across the sub bands. An advantage of this approach is that the 

average transmitted power is the same as a system designed to operate over the entire bandwidth. 

Other advantages of multibanding include processing the information over much smaller bandwidth 

(528 MHz), which reduces power consumption and lowers cost and improving spectral flexibility.

See, e.g., Rao at 559.

The 128-tone (16-QAM symbols) coefficients are inverse transformed to obtain data block samples 

by

dm =

1

N

∑ Dnexp(

j2πmn

N

)

N−1

n=0

;m = 0,1,2,... , N − 1 (1)

where Dn is the n

th QAM symbol and N =128 [3]. The MB-OFDM symbol is formed by placing the 

data block between the 32-sample zero prefix and 5-sample guard interval suffix making the total 

symbol length of L =165 samples. A scheme for MB-OFDM UWB signals is shown in Fig.1.

The k

th MB-OFDM symbol is

uk,l = {

0 1 < l ≤ 32

dl−33 32 < l ≤ 160

0 160 < 6 ≤ 165

(2)

Then the simulated MB-OFDM signal is mathematically described as

Case 2:23-cv-00285-JRG-RSP Document 59-4 Filed 07/11/24 Page 120 of 150 PageID #:

1686
120

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

u(t) = R (( ∑ ∑uk,lhrect(t − kTOFDM − (l − 1)∆t)

L

l=1

∞

k=−∞

)exp(−j2πfc

t)) (3)

where hrect is a filter with a rectangular frequency response bounded by ±1/(2Δt), TOFDM = L∆t = 

312.5 nanoseconds is the MB-OFDM symbol period, Δt =1/(NΔf ) ≈1.9 nanoseconds, and R

denotes the real part of a complex number.

Finally, MB-OFDM signals hop between 14 band center frequencies according to the specified timefrequency code. The band allocation is shown in Table 1 [2].

See, e.g., Rao at 560.

Case 2:23-cv-00285-JRG-RSP Document 59-4 Filed 07/11/24 Page 121 of 150 PageID #:

1687
121

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

See, e.g., Rao at Table 1.

Case 2:23-cv-00285-JRG-RSP Document 59-4 Filed 07/11/24 Page 122 of 150 PageID #:

1688
122

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

Furthermore, this claim element is obvious in light of Rao 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.

[17.7] 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.

Rao 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.: 

See, e.g., Rao at Figure 1.

One approach to designing a UWB system based on OFDM is to combine the modulation technique 

with a multibanding approach, which divides the spectrum into several sub-bands, whose bandwidth 

is approximately 500 MHz [2]. The band allocation is given in Table.1. The relationship between 

center frequency and band number is given by the following equation Band center frequency 2904 +

528 × nb,nb = 1 ... .14(MHz).

Case 2:23-cv-00285-JRG-RSP Document 59-4 Filed 07/11/24 Page 123 of 150 PageID #:

1689
123

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

This definition provides a unique numbering system for all channels that have a spacing of 528 MHz 

and lie within the band 3.1 – 10.6 GHz. Based on this, five band groups are defined, band group 1 is 

used for mandatory mode and the remaining band groups are reserved for future use. The transmitted 

OFDM symbols are time-interleaved across the sub bands. An advantage of this approach is that the 

average transmitted power is the same as a system designed to operate over the entire bandwidth. 

Other advantages of multibanding include processing the information over much smaller bandwidth 

(528 MHz), which reduces power consumption and lowers cost and improving spectral flexibility.

See, e.g., Rao at 559.

The 128-tone (16-QAM symbols) coefficients are inverse transformed to obtain data block samples 

by

dm =

1

N

∑ Dnexp(

j2πmn

N

)

N−1

n=0

;m = 0,1,2,... , N − 1 (1)

where Dn is the n

th QAM symbol and N =128 [3]. The MB-OFDM symbol is formed by placing the 

data block between the 32-sample zero prefix and 5-sample guard interval suffix making the total 

symbol length of L =165 samples. A scheme for MB-OFDM UWB signals is shown in Fig.1.

The k

th MB-OFDM symbol is

uk,l = {

0 1 < l ≤ 32

dl−33 32 < l ≤ 160

0 160 < 6 ≤ 165

(2)

Then the simulated MB-OFDM signal is mathematically described as

u(t) = R (( ∑ ∑uk,lhrect(t − kTOFDM − (l − 1)∆t)

L

l=1

∞

k=−∞

)exp(−j2πfc

t)) (3)

Case 2:23-cv-00285-JRG-RSP Document 59-4 Filed 07/11/24 Page 124 of 150 PageID #:

1690
124

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

where hrectis a filter with a rectangular frequency response bounded by ±1/(2Δt), TOFDM = L∆t = 

312.5 nanoseconds is the MB-OFDM symbol period, Δt =1/(NΔf ) ≈1.9 nanoseconds, and R

denotes the real part of a complex number.

Finally, MB-OFDM signals hop between 14 band center frequencies according to the specified timefrequency code. The band allocation is shown in Table 1 [2].

See, e.g., Rao at 560.

Case 2:23-cv-00285-JRG-RSP Document 59-4 Filed 07/11/24 Page 125 of 150 PageID #:

1691
125

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

See, e.g., Rao at Table 1.

Case 2:23-cv-00285-JRG-RSP Document 59-4 Filed 07/11/24 Page 126 of 150 PageID #:

1692
126

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

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

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

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

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

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

First Supplemental Ex. A-Obviousness Chart.

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

[21.1] The communication 

system of claim 17

Rao 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.

Rao 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.: 

See, e.g., Rao at Figure 1.

One approach to designing a UWB system based on OFDM is to combine the modulation technique 

with a multibanding approach, which divides the spectrum into several sub-bands, whose bandwidth 

Case 2:23-cv-00285-JRG-RSP Document 59-4 Filed 07/11/24 Page 127 of 150 PageID #:

1693
127

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

is approximately 500 MHz [2]. The band allocation is given in Table.1. The relationship between 

center frequency and band number is given by the following equation Band center frequency 2904 +

528 × nb,nb = 1 ... .14(MHz).

This definition provides a unique numbering system for all channels that have a spacing of 528 MHz 

and lie within the band 3.1 – 10.6 GHz. Based on this, five band groups are defined, band group 1 is 

used for mandatory mode and the remaining band groups are reserved for future use. The transmitted 

OFDM symbols are time-interleaved across the sub bands. An advantage of this approach is that the 

average transmitted power is the same as a system designed to operate over the entire bandwidth. 

Other advantages of multibanding include processing the information over much smaller bandwidth 

(528 MHz), which reduces power consumption and lowers cost and improving spectral flexibility.

See, e.g., Rao at 559.

The 128-tone (16-QAM symbols) coefficients are inverse transformed to obtain data block samples 

by

dm =

1

N

∑ Dnexp(

j2πmn

N

)

N−1

n=0

;m = 0,1,2,... , N − 1 (1)

where Dn is the n

th QAM symbol and N =128 [3]. The MB-OFDM symbol is formed by placing the 

data block between the 32-sample zero prefix and 5-sample guard interval suffix making the total 

symbol length of L =165 samples. A scheme for MB-OFDM UWB signals is shown in Fig.1.

The k

th MB-OFDM symbol is

uk,l = {

0 1 < l ≤ 32

dl−33 32 < l ≤ 160

0 160 < 6 ≤ 165

(2)

Then the simulated MB-OFDM signal is mathematically described as

Case 2:23-cv-00285-JRG-RSP Document 59-4 Filed 07/11/24 Page 128 of 150 PageID #:

1694
128

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

u(t) = R (( ∑ ∑uk,lhrect(t − kTOFDM − (l − 1)∆t)

L

l=1

∞

k=−∞

)exp(−j2πfc

t)) (3)

where hrect is a filter with a rectangular frequency response bounded by ±1/(2Δt), TOFDM = L∆t = 

312.5 nanoseconds is the MB-OFDM symbol period, Δt =1/(NΔf ) ≈1.9 nanoseconds, and R

denotes the real part of a complex number.

Finally, MB-OFDM signals hop between 14 band center frequencies according to the specified timefrequency code. The band allocation is shown in Table 1 [2].

See, e.g., Rao at 560.

Case 2:23-cv-00285-JRG-RSP Document 59-4 Filed 07/11/24 Page 129 of 150 PageID #:

1695
129

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

See, e.g., Rao at Table 1.

Case 2:23-cv-00285-JRG-RSP Document 59-4 Filed 07/11/24 Page 130 of 150 PageID #:

1696
130

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

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

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

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

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

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

First Supplemental Ex. A-Obviousness Chart.

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

[22.1] The communication 

system of claim 17

Rao 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.

Rao 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 upconverted second analog signal.” See, e.g.: 

See, e.g., Rao at Figure 1.

One approach to designing a UWB system based on OFDM is to combine the modulation technique 

with a multibanding approach, which divides the spectrum into several sub-bands, whose bandwidth 

Case 2:23-cv-00285-JRG-RSP Document 59-4 Filed 07/11/24 Page 131 of 150 PageID #:

1697
131

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

is approximately 500 MHz [2]. The band allocation is given in Table.1. The relationship between 

center frequency and band number is given by the following equation Band center frequency 2904 +

528 × nb,nb = 1 ... .14(MHz).

This definition provides a unique numbering system for all channels that have a spacing of 528 MHz 

and lie within the band 3.1 – 10.6 GHz. Based on this, five band groups are defined, band group 1 is 

used for mandatory mode and the remaining band groups are reserved for future use. The transmitted 

OFDM symbols are time-interleaved across the sub bands. An advantage of this approach is that the 

average transmitted power is the same as a system designed to operate over the entire bandwidth. 

Other advantages of multibanding include processing the information over much smaller bandwidth 

(528 MHz), which reduces power consumption and lowers cost and improving spectral flexibility.

See, e.g., Rao at 559.

The 128-tone (16-QAM symbols) coefficients are inverse transformed to obtain data block samples 

by

dm =

1

N

∑ Dnexp(

j2πmn

N

)

N−1

n=0

;m = 0,1,2,... , N − 1 (1)

where Dn is the n

th QAM symbol and N =128 [3]. The MB-OFDM symbol is formed by placing the 

data block between the 32-sample zero prefix and 5-sample guard interval suffix making the total 

symbol length of L =165 samples. A scheme for MB-OFDM UWB signals is shown in Fig.1.

The k

th MB-OFDM symbol is

uk,l = {

0 1 < l ≤ 32

dl−33 32 < l ≤ 160

0 160 < 6 ≤ 165

(2)

Then the simulated MB-OFDM signal is mathematically described as

Case 2:23-cv-00285-JRG-RSP Document 59-4 Filed 07/11/24 Page 132 of 150 PageID #:

1698
132

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

u(t) = R (( ∑ ∑uk,lhrect(t − kTOFDM − (l − 1)∆t)

L

l=1

∞

k=−∞

)exp(−j2πfc

t)) (3)

where hrect is a filter with a rectangular frequency response bounded by ±1/(2Δt), TOFDM = L∆t = 

312.5 nanoseconds is the MB-OFDM symbol period, Δt =1/(NΔf ) ≈1.9 nanoseconds, and R

denotes the real part of a complex number.

Finally, MB-OFDM signals hop between 14 band center frequencies according to the specified timefrequency code. The band allocation is shown in Table 1 [2].

See, e.g., Rao at 560.

Case 2:23-cv-00285-JRG-RSP Document 59-4 Filed 07/11/24 Page 133 of 150 PageID #:

1699
133

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

See, e.g., Rao at Table 1.

Case 2:23-cv-00285-JRG-RSP Document 59-4 Filed 07/11/24 Page 134 of 150 PageID #:

1700
134

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

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

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

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

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

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

First Supplemental Ex. A-Obviousness Chart.

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

[23.1] The communication 

system of claim 17

Rao 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.

Rao 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.: 

One approach to designing a UWB system based on OFDM is to combine the modulation technique 

with a multibanding approach, which divides the spectrum into several sub-bands, whose bandwidth 

is approximately 500 MHz [2]. The band allocation is given in Table.1. The relationship between 

center frequency and band number is given by the following equation Band center frequency 2904 +

528 × nb,nb = 1 ... .14(MHz).

This definition provides a unique numbering system for all channels that have a spacing of 528 MHz 

and lie within the band 3.1 – 10.6 GHz. Based on this, five band groups are defined, band group 1 is 

used for mandatory mode and the remaining band groups are reserved for future use. The transmitted 

OFDM symbols are time-interleaved across the sub bands. An advantage of this approach is that the 

average transmitted power is the same as a system designed to operate over the entire bandwidth. 

Case 2:23-cv-00285-JRG-RSP Document 59-4 Filed 07/11/24 Page 135 of 150 PageID #:

1701
135

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

Other advantages of multibanding include processing the information over much smaller bandwidth 

(528 MHz), which reduces power consumption and lowers cost and improving spectral flexibility.

See, e.g., Rao at 559.

The 128-tone (16-QAM symbols) coefficients are inverse transformed to obtain data block samples 

by

dm =

1

N

∑ Dnexp(

j2πmn

N

)

N−1

n=0

;m = 0,1,2,... , N − 1 (1)

where Dn is the n

th QAM symbol and N =128 [3]. The MB-OFDM symbol is formed by placing the 

data block between the 32-sample zero prefix and 5-sample guard interval suffix making the total 

symbol length of L =165 samples. A scheme for MB-OFDM UWB signals is shown in Fig.1.

The k

th MB-OFDM symbol is

uk,l = {

0 1 < l ≤ 32

dl−33 32 < l ≤ 160

0 160 < 6 ≤ 165

(2)

Then the simulated MB-OFDM signal is mathematically described as

u(t) = R (( ∑ ∑uk,lhrect(t − kTOFDM − (l − 1)∆t)

L

l=1

∞

k=−∞

)exp(−j2πfc

t)) (3)

where hrect is a filter with a rectangular frequency response bounded by ±1/(2Δt), TOFDM = L∆t = 

312.5 nanoseconds is the MB-OFDM symbol period, Δt =1/(NΔf ) ≈1.9 nanoseconds, and R

denotes the real part of a complex number.

Case 2:23-cv-00285-JRG-RSP Document 59-4 Filed 07/11/24 Page 136 of 150 PageID #:

1702
136

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

Finally, MB-OFDM signals hop between 14 band center frequencies according to the specified timefrequency code. The band allocation is shown in Table 1 [2].

See, e.g., Rao at 560.

Furthermore, this claim element is obvious in light of Rao 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 – Rao

[24.1] An electronic circuit 

comprising:

To the extent the preamble is limiting, Rao discloses “An electronic circuit comprising.” See, e.g.: 

UWB technology is a wireless protocol for high-speed data transmission over short distances and has 

recently received a lot of interest from the wireless manufacturing and user community [1]. The 

Federal Communications Commission (FCC) has approved to operate UWB in the 3.1- 10.6GHz 

band at a low effective isotropic radiated power(EIRP) of -41.3 dBm/MHz with a minimum signal

bandwidth of 500MHz. In near future, UWB communication system will be extensively used in the 

mobile handsets or consumer device that require real-time transmission of highdefinition multimedia 

data.

See, e.g., Rao at 559.

Furthermore, this claim element is obvious in light of Rao 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 59-4 Filed 07/11/24 Page 137 of 150 PageID #:

1703
137

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

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;

Rao 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.: 

See, e.g., Rao at Figure 1.

One approach to designing a UWB system based on OFDM is to combine the modulation technique 

with a multibanding approach, which divides the spectrum into several sub-bands, whose bandwidth 

is approximately 500 MHz [2]. The band allocation is given in Table.1. The relationship between 

center frequency and band number is given by the following equation Band center frequency 2904 +

528 × nb,nb = 1 ... .14(MHz).

This definition provides a unique numbering system for all channels that have a spacing of 528 MHz 

and lie within the band 3.1 – 10.6 GHz. Based on this, five band groups are defined, band group 1 is 

Case 2:23-cv-00285-JRG-RSP Document 59-4 Filed 07/11/24 Page 138 of 150 PageID #:

1704
138

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

used for mandatory mode and the remaining band groups are reserved for future use. The transmitted 

OFDM symbols are time-interleaved across the sub bands. An advantage of this approach is that the 

average transmitted power is the same as a system designed to operate over the entire bandwidth. 

Other advantages of multibanding include processing the information over much smaller bandwidth 

(528 MHz), which reduces power consumption and lowers cost and improving spectral flexibility.

See, e.g., Rao at 559.

The 128-tone (16-QAM symbols) coefficients are inverse transformed to obtain data block samples 

by

dm =

1

N

∑ Dnexp(

j2πmn

N

)

N−1

n=0

;m = 0,1,2,... , N − 1 (1)

where Dn is the n

th QAM symbol and N =128 [3]. The MB-OFDM symbol is formed by placing the 

data block between the 32-sample zero prefix and 5-sample guard interval suffix making the total 

symbol length of L =165 samples. A scheme for MB-OFDM UWB signals is shown in Fig.1.

The k

th MB-OFDM symbol is

uk,l = {

0 1 < l ≤ 32

dl−33 32 < l ≤ 160

0 160 < 6 ≤ 165

(2)

Then the simulated MB-OFDM signal is mathematically described as

u(t) = R (( ∑ ∑uk,lhrect(t − kTOFDM − (l − 1)∆t)

L

l=1

∞

k=−∞

)exp(−j2πfc

t)) (3)

Case 2:23-cv-00285-JRG-RSP Document 59-4 Filed 07/11/24 Page 139 of 150 PageID #:

1705
139

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

where hrect is a filter with a rectangular frequency response bounded by ±1/(2Δt), TOFDM = L∆t = 

312.5 nanoseconds is the MB-OFDM symbol period, Δt =1/(NΔf ) ≈1.9 nanoseconds, and R

denotes the real part of a complex number.

Finally, MB-OFDM signals hop between 14 band center frequencies according to the specified timefrequency code. The band allocation is shown in Table 1 [2].

See, e.g., Rao at 560.

Case 2:23-cv-00285-JRG-RSP Document 59-4 Filed 07/11/24 Page 140 of 150 PageID #:

1706
140

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

See, e.g., Rao at Table 1.

Case 2:23-cv-00285-JRG-RSP Document 59-4 Filed 07/11/24 Page 141 of 150 PageID #:

1707
141

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

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

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

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

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

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

First Supplemental Ex. A-Obviousness Chart.

[24.3] a second downconverter circuit having a first 

input coupled to receive the 

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

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

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

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

modulated at the second RF frequency.” See, e.g.: 

See, e.g., Rao at Figure 1.

One approach to designing a UWB system based on OFDM is to combine the modulation technique 

with a multibanding approach, which divides the spectrum into several sub-bands, whose bandwidth 

is approximately 500 MHz [2]. The band allocation is given in Table.1. The relationship between 

Case 2:23-cv-00285-JRG-RSP Document 59-4 Filed 07/11/24 Page 142 of 150 PageID #:

1708
142

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

center frequency and band number is given by the following equation Band center frequency 2904 +

528 × nb,nb = 1 ... .14(MHz).

This definition provides a unique numbering system for all channels that have a spacing of 528 MHz 

and lie within the band 3.1 – 10.6 GHz. Based on this, five band groups are defined, band group 1 is 

used for mandatory mode and the remaining band groups are reserved for future use. The transmitted 

OFDM symbols are time-interleaved across the sub bands. An advantage of this approach is that the 

average transmitted power is the same as a system designed to operate over the entire bandwidth. 

Other advantages of multibanding include processing the information over much smaller bandwidth 

(528 MHz), which reduces power consumption and lowers cost and improving spectral flexibility.

See, e.g., Rao at 559.

The 128-tone (16-QAM symbols) coefficients are inverse transformed to obtain data block samples 

by

dm =

1

N

∑ Dnexp(

j2πmn

N

)

N−1

n=0

;m = 0,1,2,... , N − 1 (1)

where Dn is the n

th QAM symbol and N =128 [3]. The MB-OFDM symbol is formed by placing the 

data block between the 32-sample zero prefix and 5-sample guard interval suffix making the total 

symbol length of L =165 samples. A scheme for MB-OFDM UWB signals is shown in Fig.1.

The k

th MB-OFDM symbol is

uk,l = {

0 1 < l ≤ 32

dl−33 32 < l ≤ 160

0 160 < 6 ≤ 165

(2)

Then the simulated MB-OFDM signal is mathematically described as

Case 2:23-cv-00285-JRG-RSP Document 59-4 Filed 07/11/24 Page 143 of 150 PageID #:

1709
143

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

u(t) = R (( ∑ ∑uk,lhrect(t − kTOFDM − (l − 1)∆t)

L

l=1

∞

k=−∞

)exp(−j2πfc

t)) (3)

where hrect is a filter with a rectangular frequency response bounded by ±1/(2Δt), TOFDM = L∆t = 

312.5 nanoseconds is the MB-OFDM symbol period, Δt =1/(NΔf ) ≈1.9 nanoseconds, and R

denotes the real part of a complex number.

Finally, MB-OFDM signals hop between 14 band center frequencies according to the specified timefrequency code. The band allocation is shown in Table 1 [2].

See, e.g., Rao at 560.

Case 2:23-cv-00285-JRG-RSP Document 59-4 Filed 07/11/24 Page 144 of 150 PageID #:

1710
144

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

See, e.g., Rao at Table 1.

Case 2:23-cv-00285-JRG-RSP Document 59-4 Filed 07/11/24 Page 145 of 150 PageID #:

1711
145

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

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

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

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

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

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

First Supplemental Ex. A-Obviousness Chart.

[24.4] a filter having an input 

coupled to the output of the 

first down-converter and the 

output of the second downconverter, and in accordance 

therewith, the filter receives 

the first and second downconverted signals.

Rao 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.: 

See, e.g., Rao at Figure 1.

One approach to designing a UWB system based on OFDM is to combine the modulation technique 

with a multibanding approach, which divides the spectrum into several sub-bands, whose bandwidth 

is approximately 500 MHz [2]. The band allocation is given in Table.1. The relationship between 

center frequency and band number is given by the following equation Band center frequency 2904 +

528 × nb,nb = 1 ... .14(MHz).

Case 2:23-cv-00285-JRG-RSP Document 59-4 Filed 07/11/24 Page 146 of 150 PageID #:

1712
146

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

This definition provides a unique numbering system for all channels that have a spacing of 528 MHz 

and lie within the band 3.1 – 10.6 GHz. Based on this, five band groups are defined, band group 1 is 

used for mandatory mode and the remaining band groups are reserved for future use. The transmitted 

OFDM symbols are time-interleaved across the sub bands. An advantage of this approach is that the 

average transmitted power is the same as a system designed to operate over the entire bandwidth. 

Other advantages of multibanding include processing the information over much smaller bandwidth 

(528 MHz), which reduces power consumption and lowers cost and improving spectral flexibility.

See, e.g., Rao at 559.

The 128-tone (16-QAM symbols) coefficients are inverse transformed to obtain data block samples 

by

dm =

1

N

∑ Dnexp(

j2πmn

N

)

N−1

n=0

;m = 0,1,2,... , N − 1 (1)

where Dn is the n

th QAM symbol and N =128 [3]. The MB-OFDM symbol is formed by placing the 

data block between the 32-sample zero prefix and 5-sample guard interval suffix making the total 

symbol length of L =165 samples. A scheme for MB-OFDM UWB signals is shown in Fig.1.

The k

th MB-OFDM symbol is

uk,l = {

0 1 < l ≤ 32

dl−33 32 < l ≤ 160

0 160 < 6 ≤ 165

(2)

Then the simulated MB-OFDM signal is mathematically described as

u(t) = R (( ∑ ∑uk,lhrect(t − kTOFDM − (l − 1)∆t)

L

l=1

∞

k=−∞

)exp(−j2πfc

t)) (3)

Case 2:23-cv-00285-JRG-RSP Document 59-4 Filed 07/11/24 Page 147 of 150 PageID #:

1713
147

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

where hrect is a filter with a rectangular frequency response bounded by ±1/(2Δt), TOFDM = L∆t = 

312.5 nanoseconds is the MB-OFDM symbol period, Δt =1/(NΔf ) ≈1.9 nanoseconds, and R

denotes the real part of a complex number.

Finally, MB-OFDM signals hop between 14 band center frequencies according to the specified timefrequency code. The band allocation is shown in Table 1 [2].

See, e.g., Rao at 560.

Case 2:23-cv-00285-JRG-RSP Document 59-4 Filed 07/11/24 Page 148 of 150 PageID #:

1714
148

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

See, e.g., Rao at Table 1.

Case 2:23-cv-00285-JRG-RSP Document 59-4 Filed 07/11/24 Page 149 of 150 PageID #:

1715
149

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

Furthermore, this claim element is obvious in light of Rao 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 59-4 Filed 07/11/24 Page 150 of 150 PageID #:

1716