Exhibit A 

Case 2:24-cv-00029-JRG-RSP Document 105-1 Filed 12/19/24 Page 1 of 13 PageID

#: 4866
EXHIBIT A 

1 

No. Claim(s) Claim Term ASSIA’s Proposed Construction AT&T’s Propos

U.S. Patent No. 7,428,669

1. 14 “A method of adjusting 

Forward Error Correcting (FEC) coding in a Digital Subscriber Line (DSL) modem in which data is transmitted between a transmitter and a receiver on a channel,” 

No construction necessary; this preamble is non-limiting. 

Preamble is limitin

2. 14 “adjusting the CCR when the 

MEV differs sufficiently from the TEV” 

No construction necessary. Indefinite. 

U.S. Patent No. 7,593,458

3. 1 “A method of evaluating 

operational characteristics of a multi-line, vectored Digital Subscriber Line (DSL) system having a plurality of crosstalking lines in a common communication channel (channel)” 

No construction necessary; this preamble is non-limiting. 

Preamble is limitin

4. 4 “on a periodic basis” at fixed intervals Plain and ordinary 

construction neces

U.S. Patent No. 7,991,122

5. 14-18, 

20 

“DSL line set” set of one or more DSL lines Plain and ordinary 

construction neces

6. 14, 20 “a data collection unit 

configured to collect operational data from a new 

No construction necessary. These terms are not governed by § 112(f). 

Indefinite. 

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EXHIBIT A 

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No. Claim(s) Claim Term ASSIA’s Proposed Construction AT&T’s Propos

DSL line set and an already-operating DSL line set;” “collecting operational data, via a data collection unit, from the new DSL line set and the already-operating DSL line set;” 

In the alternative, if § 112(f) does apply, the function for claim 14 is: collecting operational data from a new DSL line set and an already-operating DSL line set; The corresponding structure includes: a computer, processor, IC, computer module, etc. as described at 13:35-39 If § 112(f) does apply, the function for claim 20 is: collecting operational data from a new DSL line set and an already-operating DSL line set; The corresponding structure includes: a computer, processor, IC, computer module, etc. as described at 13:35-39 

7. 14, 20 “an analysis unit coupled to 

the collection unit, wherein the analysis unit is configured to: analyze the collected operational data; determine an operational configuration for at least one DSL line in the new DSL line set that will 

No construction necessary. These terms are not governed by § 112(f). In the alternative, if § 112(f) does apply, the function for claim 14 is: analyzing the collected operational data; determine an operational configuration for at least one DSL line 

Indefinite. 

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EXHIBIT A 

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No. Claim(s) Claim Term ASSIA’s Proposed Construction AT&T’s Propos

allow the new DSL line set to join the already-operating DSL line set without disrupting the alreadyoperating DSL line set; evaluate data received by the new DSL line set; and evaluate data received by the already-operating DSL line set;” “performing the following operations, via an analysis unit coupled to the collection unit: analyzing the collected operational data; determining an operational configuration for at least one DSL line in the new DSL line set that will allow the new DSL line set to join the already-operating DSL line set without disrupting the alreadyoperating DSL line set; evaluating data received by the new DSL line set; and evaluating data received by the already-operating DSL line set;” 

in the new DSL line set that will allow the new DSL line set to join the already-operating DSL line set without disrupting the already- operating DSL line set; evaluate data received by the new DSL line set; and evaluate data received by the already-operating DSL line set; The corresponding structure includes: a computer, processor, IC, computer module, etc. as described at 13:55-56. If § 112(f) does apply, the function for claim 20 is: analyzing the collected operational data; determining an operational configuration for at least one DSL line in the new DSL line set that will allow the new DSL line set to join the already-operating DSL line set without disrupting the already- operating DSL line set; evaluating data received by the new DSL line set; and evaluating data received by the already-operating DSL line set; The corresponding structure includes: a 

Case 2:24-cv-00029-JRG-RSP Document 105-1 Filed 12/19/24 Page 4 of 13 Pa

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EXHIBIT A 

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No. Claim(s) Claim Term ASSIA’s Proposed Construction AT&T’s Propos

computer, processor, IC, computer module, etc. as described at 13:55-56. 

8. 14, 20 “a control signal generator 

coupled to the analysis unit, wherein the control signal generator is configured to send control signals to the new DSL line set and to the already-operating DSL line set, further wherein the control signals comprise signals controlling operation of at least one of the following: the new DSL line set; or the already-operating DSL line set;” “sending control signals, via a control signal generator coupled to the analysis unit, to the new DSL line set and to the already- operating DSL line set, further wherein the control signals comprise signals controlling operation of at least one of the following: the new DSL line 

set; or the already-operating DSL line set;” 

No construction necessary. These terms are not governed by § 112(f). In the alternative, if § 112(f) does apply, the function for claim 14 is: “sending control signals to the new DSL line set and to the alreadyoperating DSL line set, further wherein the control signals comprise signals controlling operation of at least one of the following: the new DSL line set; or the already-operating DSL line set;” “sending control signals to the new DSL line set and to the alreadyoperating DSL line set, further wherein the control signals comprise signals controlling operation of at least one of the following: the new DSL line set; or the already-operating DSL line set;” The corresponding structure includes: a computer, processor, IC, computer module, etc. as described at 13:65-

Subject to 35 U.S.C. Function: “send connew DSL line set and operating DSL line sthe control signals cocontrolling operation the following: the nethe already-operating (claim 14) “sending control signline set and to the alrline set, further whersignals comprise signoperation of at least the new DSL line setoperating DSL line sStructure: “[A] DSand/or system operagenerating means 35computer, processormodule, etc. of the tknown) inside or ou310.” (13:65-14:2). 

Case 2:24-cv-00029-JRG-RSP Document 105-1 Filed 12/19/24 Page 5 of 13 Pa

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EXHIBIT A 

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No. Claim(s) Claim Term ASSIA’s Proposed Construction AT&T’s Propos

14:18. 

9. 20 “machine readable medium” No construction necessary. 

In the alternative: tangible medium of a computer program product. 

transitory or non-trreadable medium 

U.S. Patent No. 9,954,631

10. 1, 34 “substantially not 

simultaneous” 

No construction necessary. Indefinite. 

11. 1, 9, 

11, 14, 33, 34, 35, 37 

“physical channel” No construction necessary. a channel that tran

upstream or the do

12. 34 “machine-readable medium” No construction necessary. 

In the alternative: tangible medium of a computer program product. 

transitory or non-trreadable medium 

13. 37 “means for scheduling 

upstream time slots for upstream transmission in a first physical channel” 

Under 35 U.S.C. § 112(6), the function for this term is: “scheduling upstream 

time slots for upstream transmission in a first physical channel” The corresponding structure for this term includes: a TDD management system, a scheduling module, and/or equivalents thereof as described in the

Subject to 35 U.S.C

Function: 

“scheduling upstream upstream transmissiochannel” (claim 37) 

Structure: Structure includes a system, which “incl1295 coupled direct

Case 2:24-cv-00029-JRG-RSP Document 105-1 Filed 12/19/24 Page 6 of 13 Pa

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EXHIBIT A 

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No. Claim(s) Claim Term ASSIA’s Proposed Construction AT&T’s Propos

Summary, Fig. 12, 3:22-26; 5:36-56; 5:61-62; 6:6-8; 8:10-13; 9:41-10:42; 11:11-15; 13:7-33; 13:42-47; 13:62-66; 14:24-34; 14:47-15:3; 16:13-19; and 16:45-18:23. 

to a processor or promemory may be a hvolatile memory, soor a combination of types for different pprocessor may also internal memory. Thfor example, store inexecuted and the proexecute the stored inprocessor may also execute implementihaving logic to implmethodologies discuSystem 1200 includcommunications buconnect the various components and to ttransactions, instrucand data within the components and othdevices. The system management interfathe bus and to externdevices, for examplrequests, return respotherwise interface elements located sepsystem. This informOperations Support 

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EXHIBIT A 

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No. Claim(s) Claim Term ASSIA’s Proposed Construction AT&T’s Propos

data and ManagemeDatabase (MIB) parnetwork elements mnodes, a central officrossboxes, TU-Rs, system further incluArea Network) interto the bus and externcommunicate informbased connection, innetwork informationinformation and diaentities within the ninitiating instructionover the network. Tincludes a WAN (WNetwork) interface the bus and to an excommunicate informbased connection foand to reach other mdevices.” ’631 patenOR 

Structure includes analysis module of device, which “is c[and] includes a co

Case 2:24-cv-00029-JRG-RSP Document 105-1 Filed 12/19/24 Page 8 of 13 Pa

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EXHIBIT A 

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No. Claim(s) Claim Term ASSIA’s Proposed Construction AT&T’s Propos

1270, analysis moddiagnostics module implementation moManagement Deviinstalled and conficompatible system depicted by FIG. 1separately so as to conjunction with aimplementing logic software.” Id. at 15modules of the ma1201 may be provicomponents coupleas shown or may bthe processor or mcomponent. The mmay include its owmemory resources the processor and tinterfaces. The mamay include more than those shown. management system provided only as an be modified to suit implementations. Iincorporated into asuch as an access none embodiment, t

Case 2:24-cv-00029-JRG-RSP Document 105-1 Filed 12/19/24 Page 9 of 13 Pa

#: 4874
EXHIBIT A 

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No. Claim(s) Claim Term ASSIA’s Proposed Construction AT&T’s Propos

system is provided system rack with a interface to commuand remote networ16:6-19. 

14. “means for scheduling 

downstream time slots for downstream transmission in a second physical channel subject to crosstalk from the upstream time slots, wherein transmission in the upstream time slots is substantially not simultaneous with transmission in the downstream time slots” 

Under 35 U.S.C. § 112(6), the term under construction should be “means for scheduling downstream time slots for downstream transmission in a second physical channel subject to crosstalk from the upstream time slots.” The function for this term is: “scheduling upstream time slots for upstream transmission in a first physical channel subject to crosstalk from the upstream time slots” The corresponding structure for this term includes: a TDD management system, a scheduling module, and/or equivalents thereof as described in the Summary, Fig. 12, 3:22-26; 5:36-56; 5:61-62; 6:6-8; 8:10-13; 9:41-10:42; 11:11-15; 13:7-33; 13:42-47; 13:62-66; 14:24-34; 

Subject to 35 U.S.CFunction: “scheduling downsfor downstream trasecond physical chcrosstalk from the slots” (claim 37) Structure: Structure includes management systema memory 1295 cothrough a bus to a processors 1296. Tbe a hard drive, nosolid state memoryof different memordifferent purposes. may also include itmemory. The memexample, store instexecuted and the pexecute the stored 

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EXHIBIT A 

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No. Claim(s) Claim Term ASSIA’s Proposed Construction AT&T’s Propos

14:47-15:3; 16:13-19; and 16:45-18:23. processor may also 

execute implementhaving logic to impmethodologies discSystem 1200 inclucommunications buconnect the varioucomponents and to transactions, instruand data within the components and otdevices. The system a management intecoupled to the bus management devicreceive requests, reand otherwise interelements located sesystem. This informinclude Operations (OSS) data and MaInformation Databparameters. These may include access office, vectoring unTU-Rs, and TU-Osfurther includes a LNetwork) interface the bus and externacommunicate infor

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#: 4876
EXHIBIT A 

11 

No. Claim(s) Claim Term ASSIA’s Proposed Construction AT&T’s Propos

based connection, collecting network reporting informatito other entities wiand for initiating incommands over thsystem further incl(Wide Area Netwocoupled to the bus WAN, to communvia a WAN based csimilar purposes anmore remote devic14:47-15:13. OR Structure includes analysis module of device, which “is c[and] includes a co1270, analysis moddiagnostics module implementation moManagement Deviinstalled and conficompatible system depicted by FIG. 1separately so as to 

Case 2:24-cv-00029-JRG-RSP Document 105-1 Filed 12/19/24 Page 12 of 13 P

#: 4877
EXHIBIT A 

12 

No. Claim(s) Claim Term ASSIA’s Proposed Construction AT&T’s Propos

conjunction with aimplementing logic software.” Id. at 15modules of the ma1201 may be provicomponents coupleas shown or may bthe processor or mcomponent. The mmay include its owmemory resources the processor and tinterfaces. The mamay include more than those shown. management system provided only as an be modified to suit implementations. Iincorporated into asuch as an access none embodiment, tsystem is provided system rack with a interface to commuand remote networ16:6-19. 

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#: 4878