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CLOSED, DISCMAG, JURY, PATENT

U.S. District Court [LIVE] Eastern District of TEXAS LIVE (Marshall) CIVIL DOCKET FOR CASE #: 2:06-cv-00507-TJW-CE

Rembrandt Technologies, LP v. Charter Communications, Inc., et al Assigned to: Judge T. John Ward Referred to: Magistrate Judge Charles Everingham Cause: 35:271 Patent Infringement Plaintiff Rembrandt Technologies, LP

Date Filed: 11/30/2006 Jury Demand: Plaintiff Nature of Suit: 830 Patent Jurisdiction: Federal Question

represented by Max Lalon Tribble, Jr Susman Godfrey LLP 1000 Louisiana Street Ste 5100 Houston, TX 77002-5096 713/651-9366 Fax: 17136546666 Email: [email protected] LEAD ATTORNEY ATTORNEY TO BE NOTICED Andrew Wesley Spangler Brown McCarroll - Longview 1127 Judson Rd - Ste 220 PO Box 3999 Longview, TX 75606-3999 903-236-9800 Fax: 19032368787 Email: [email protected] ATTORNEY TO BE NOTICED Brooke Ashley-May Taylor Susman Godfrey, LLP - Seattle 1201 Third Avenue Suite 3800 Seattle, WA 98101 206/516-3880 Fax: 206/516-3883 Email: [email protected] ATTORNEY TO BE NOTICED Charles Ainsworth Parker Bunt & Ainsworth 100 E Ferguson Suite 1114 Tyler, TX 75702

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US 903/531-3535 Fax: 903/533-9687 Email: [email protected] ATTORNEY TO BE NOTICED Collin Michael Maloney Ireland Carroll & Kelley 6101 S Broadway Suite 500 Tyler, TX 75703 903/561-1600 Fax: 9035811071 Email: [email protected] ATTORNEY TO BE NOTICED Edgar G Sargent Susman Godfrey, LLP - Seattle 1201 Third Avenue Suite 3800 Seattle, WA 98101 206/516-3804 Fax: 206/516-3883 Email: [email protected] ATTORNEY TO BE NOTICED Elizabeth L DeRieux Brown McCarroll 1127 Judson Rd - Ste 220 PO Box 3999 Longview, TX 75606-3999 903/236-9800 Fax: 9032368787 Email: [email protected] ATTORNEY TO BE NOTICED Franklin Jones, Jr Jones & Jones - Marshall 201 W Houston St PO Drawer 1249 Marshall, TX 75670 903/938-4395 Fax: 9039383360 Email: [email protected] ATTORNEY TO BE NOTICED James Patrick Kelley Ireland Carroll & Kelley 6101 S Broadway Suite 500

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Tyler, TX 75703 903/561-1600 Fax: 9035811071 Email: [email protected] ATTORNEY TO BE NOTICED Joseph Samuel Grinstein Susman Godfrey - Houston 1000 Louisiana Street Ste 5100 Houston, TX 77002-5096 713/651-9366 Fax: 7136546666 Email: [email protected] ATTORNEY TO BE NOTICED Matthew R Berry Susman Godfrey, LLP - Seattle 1201 Third Avenue Suite 3800 Seattle, WA 98101 206/373-7394 Fax: 206/516-3883 Email: [email protected] ATTORNEY TO BE NOTICED Otis W Carroll, Jr Ireland Carroll & Kelley 6101 S Broadway Suite 500 Tyler, TX 75703 903/561-1600 Fax: 9035811071 Email: [email protected] ATTORNEY TO BE NOTICED Robert Christopher Bunt Parker, Bunt & Ainsworth, P.C. 100 East Ferguson, Ste. 1114 Tyler, TX 75702 903/531-3535 Fax: 903/533-9687 Email: [email protected] ATTORNEY TO BE NOTICED Robert M Parker Parker, Bunt & Ainsworth, P.C. 100 E Ferguson Suite 1114 Tyler, TX 75702

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903/531-3535 Fax: 9035339687 Email: [email protected] ATTORNEY TO BE NOTICED Sidney Calvin Capshaw, III Brown McCarroll - Longview 1127 Judson Rd - Ste 220 PO Box 3999 Longview, TX 75606-3999 903/236-9800 Fax: 19032368787 Email: [email protected] ATTORNEY TO BE NOTICED Tibor L. Nagy Susman Godfrey - Houston 1000 Louisiana Street Ste 5100 Houston, TX 77002-5096 713/653-7850 Fax: 713/654-6102 Email: [email protected] ATTORNEY TO BE NOTICED V. Defendant Charter Communications, Inc. represented by Allen Franklin Gardner Potter Minton PC 110 N College Suite 500 PO Box 359 Tyler, TX 75710-0359 903/597-8311 Email: [email protected] ATTORNEY TO BE NOTICED Bradford P Lyerla Marshall Gerstein & Borun 233 S Wacker Dr 6300 Sears Tower Chicago, IL 60606-6357 312/474-6300 Fax: 312/474-0448 Email: [email protected] ATTORNEY TO BE NOTICED Charles Edward Juister

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Marshall Gerstein & Borun 233 S Wacker Dr 6300 Sears Tower Chicago, IL 60606-6357 312/474-6300 Fax: 312/474-0448 Email: [email protected] ATTORNEY TO BE NOTICED Gregory E Stanton Marshall Gerstein & Borun 233 S Wacker Dr 6300 Sears Tower Chicago, IL 60606-6357 312/474-6300 Fax: 312/474-0448 Email: [email protected] ATTORNEY TO BE NOTICED Jon-Thomas Bloch Marshall Gerstein & Borun 233 S Wacker Dr 6300 Sears Tower Chicago, IL 60606-6357 312/474-6300 Fax: 312/474-0448 Email: [email protected] ATTORNEY TO BE NOTICED Kevin D Hogg Marshall Gerstein & Borun 233 S Wacker Dr 6300 Sears Tower Chicago, IL 60606-6357 312/474-6300 Fax: 317/474-0448 Email: [email protected] ATTORNEY TO BE NOTICED Margaret Lynn Begalle Marshall Gerstein & Borun 233 S Wacker Dr 6300 Sears Tower Chicago, IL 60606-6357 312/474-6300 Fax: 312/474-0448 Email: [email protected] ATTORNEY TO BE NOTICED Michael Edwin Jones

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Potter Minton PC 110 N College Suite 500 PO Box 359 Tyler, TX 75710-0359 903/597/8311 Fax: 9035930846 Email: [email protected] ATTORNEY TO BE NOTICED Paul Bryan Stephens Marshall Gerstein & Borun 233 S Wacker Dr 6300 Sears Tower Chicago, IL 60606-6357 312/474-6300 Fax: 312/474-0448 Email: [email protected] ATTORNEY TO BE NOTICED William Joseph Kramer Marshall Gerstein & Borun 233 S Wacker Dr 6300 Sears Tower Chicago, IL 60606-6357 312/474-6300 Fax: 312/474-0448 Email: [email protected] ATTORNEY TO BE NOTICED Defendant Charter Communications Operating, LLC represented by Allen Franklin Gardner (See above for address) ATTORNEY TO BE NOTICED Bradford P Lyerla (See above for address) ATTORNEY TO BE NOTICED Charles Edward Juister (See above for address) ATTORNEY TO BE NOTICED Gregory E Stanton (See above for address) ATTORNEY TO BE NOTICED Jon-Thomas Bloch (See above for address) ATTORNEY TO BE NOTICED

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Margaret Lynn Begalle (See above for address) ATTORNEY TO BE NOTICED Michael Edwin Jones (See above for address) ATTORNEY TO BE NOTICED Paul Bryan Stephens (See above for address) ATTORNEY TO BE NOTICED William Joseph Kramer (See above for address) ATTORNEY TO BE NOTICED Defendant Coxcom, Inc., represented by Allen Franklin Gardner (See above for address) ATTORNEY TO BE NOTICED Leroy M Toliver Kilpatrick Stockton 1100 Peachtree St Suite 2800 Atlanta, GA 30309 404/815-6483 Fax: 404/541-3274 Email: [email protected] ATTORNEY TO BE NOTICED Michael Edwin Jones (See above for address) ATTORNEY TO BE NOTICED Mitchell G Stockwell Kilpatrick Stockton LLP 1100 Peachtree St Ste 2800 Atlanta, GA 30309-4530 404/815-6214 Fax: 14048156555 Email: [email protected] ATTORNEY TO BE NOTICED Tonya R Deem Kilpatrick Stockton LLP NC

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1001 W Fourth Street Winston-Salem, NC 27101 336-607-7485 Fax: 336-607-7500 Email: [email protected] ATTORNEY TO BE NOTICED Movant Coxcom, Inc., Counter Claimant Charter Communications, Inc. Counter Claimant Charter Communications Operating, LLC V. Counter Defendant Rembrandt Technologies, LP represented by Tibor L. Nagy (See above for address) ATTORNEY TO BE NOTICED

Date Filed 11/30/2006

#

Docket Text 1 COMPLAINT with JURY DEMAND against Charter Communications, Inc., Charter Communications Operating, LLC, Coxcom, Inc., (Filing fee $ 350.) , filed by Rembrandt Technologies, LP. (Attachments: # 1 # 2 # 3 # 4 # 5)(ehs, ) Additional attachment(s) added on 12/1/2006 (ehs, ). (Entered: 12/01/2006) 2 CORPORATE DISCLOSURE STATEMENT filed by Rembrandt Technologies, LP (ehs, ) (Entered: 12/01/2006) E-GOV SEALED SUMMONS Issued as to Charter Communications, Inc., Charter Communications Operating, LLC, Coxcom, Inc.,. (ehs, ) (Entered: 12/01/2006) 3 Form mailed to Commissioner of Patents and Trademarks. (ehs, ) (Entered: 12/01/2006) 4 AMENDED COMPLAINT (First Amended Complaint) against all defendants, filed by Rembrandt Technologies, LP. (Attachments: # (1) Exhibit A# (2) Exhibit B# (3) Exhibit C# (4) Exhibit D# (5) Exhibit E) (DeRieux, Elizabeth) Additional attachment(s) added on 12/1/2006 (ehs, ). (Entered: 12/01/2006) Filing fee: $ 350.00, receipt number 2-1-2128 (ch, ) (Entered: 12/05/2006)

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5 NOTICE of Attorney Appearance by Robert M Parker on behalf of Rembrandt Technologies, LP (Parker, Robert) (Entered: 12/07/2006) 6 NOTICE of Attorney Appearance by Robert Christopher Bunt on behalf of Rembrandt Technologies, LP (Bunt, Robert) (Entered: 12/07/2006) 7 NOTICE of Attorney Appearance by Charles Ainsworth on behalf of Rembrandt Technologies, LP (Ainsworth, Charles) (Entered: 12/07/2006) 8 NOTICE of Attorney Appearance by Franklin Jones, Jr on behalf of Rembrandt Technologies, LP (Jones, Franklin) (Entered: 12/12/2006) 9 E-GOV SEALED SUMMONS Returned Executed by Rembrandt Technologies, LP. Charter Communications, Inc. served on 12/4/2006, answer due 12/26/2006. (ehs, ) (Entered: 12/15/2006) 10 E-GOV SEALED SUMMONS Returned Executed by Rembrandt Technologies, LP. Charter Communications Operating, LLC served on 12/4/2006, answer due 12/26/2006. (ehs, ) (Entered: 12/15/2006) 11 E-GOV SEALED SUMMONS Returned Executed by Rembrandt Technologies, LP. Coxcom, Inc., served on 12/4/2006, answer due 12/26/2006. (ehs, ) (Entered: 12/15/2006) 12 MOTION for Extension of Time to File Answer re 4 Amended Complaint, by Charter Communications, Inc., Charter Communications Operating, LLC. (Attachments: # 1 Text of Proposed Order)(Jones, Michael) (Entered: 12/21/2006) 13 Consent MOTION for Extension of Time to File Answer re 4 Amended Complaint, by Coxcom, Inc.,. (Attachments: # 1 Text of Proposed Order) (Jones, Michael) (Entered: 12/28/2006) 14 APPLICATION to Appear Pro Hac Vice by Attorney Margaret Lynn Begalle for Charter Communications, Inc. and Charter Communications Operating, LLC. (ehs, ) (Entered: 12/29/2006) 15 APPLICATION to Appear Pro Hac Vice by Attorney Jon-Thomas Bloch for Charter Communications, Inc. and Charter Communications Operating, LLC. (ehs, ) (Entered: 12/29/2006) 16 APPLICATION to Appear Pro Hac Vice by Attorney Charles Edward Juister for Charter Communications, Inc. and Charter Communications Operating, LLC. (ehs, ) (Entered: 12/29/2006) 17 APPLICATION to Appear Pro Hac Vice by Attorney William Joseph Kramer for Charter Communications, Inc. and Charter Communications Operating, LLC. (ehs, ) (Entered: 12/29/2006) 18 APPLICATION to Appear Pro Hac Vice by Attorney Bradford P Lyerla for Charter Communications, Inc. and Charter Communications Operating, LLC. (ehs, ) (Entered: 12/29/2006) 19 APPLICATION to Appear Pro Hac Vice by Attorney Gregory E Stanton for Charter Communications, Inc. and Charter Communications

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Operating, LLC. (ehs, ) (Entered: 12/29/2006) 12/28/2006 20 APPLICATION to Appear Pro Hac Vice by Attorney Paul Bryan Stephens for Charter Communications, Inc. and Charter Communications Operating, LLC. (ehs, ) (Entered: 12/29/2006) 28 APPLICATION to Appear Pro Hac Vice by Attorney Kevin D Hogg for Rembrandt Technologies, LP. APPROVED (poa, ) (Entered: 01/04/2007) Filing fee: $ 25., receipt number 618131 (poa, ) (Entered: 01/04/2007) 29 APPLICATION to Appear Pro Hac Vice by Attorney Bradford P Lyerla for Charter Communications, Inc. and Charter Communications Operating, LLC.APPROVED (poa, ) (Entered: 01/04/2007) Filing fee: $ 25., receipt number 618131 (poa, ) (Entered: 01/04/2007) Filing fee: $ 25., receipt number 618131 (poa, ) (Entered: 01/04/2007) Pro Hac Vice Filing fee paid by Juister; Fee: $25, receipt number: 618131 (poa, ) (Entered: 01/04/2007) Pro Hac Vice Filing fee paid by Kramer; Fee: $25, receipt number: 618131 (poa, ) (Entered: 01/04/2007) Pro Hac Vice Filing fee paid by Begalle; Fee: $25, receipt number: 618131 (poa, ) (Entered: 01/04/2007) 33 APPLICATION to Appear Pro Hac Vice by Attorney Jon-Thomas Bloch for Charter Communications, Inc. and Charter Communications Operating, LLC. APPROVED (poa, ) (Entered: 01/04/2007) Pro Hac Vice Filing fee paid by Bloch; Fee: $25, receipt number: 618131 (poa, ) (Entered: 01/04/2007) 34 APPLICATION to Appear Pro Hac Vice by Attorney Paul Bryan Stephens for Charter Communications, Inc. and Charter Communications Operating, LLC.APPROVED (poa, ) (Entered: 01/04/2007) Pro Hac Vice Filing fee paid by Margaret Begalle, Jon-Thomas Bloch, Charles Juister, William Kramer, Bradford Lyerla, Gregory Stanton, Paul Stephens; Fee: $175.00, receipt number: 6-1-8131 (ehs, ) (Entered: 12/29/2006) 21 NOTICE of Attorney Appearance by Matthew R. Berry on behalf of Rembrandt Technologies, LP (Berry, Matthew) (Entered: 01/03/2007) 22 NOTICE of Attorney Appearance by Brooke Ashley-May Taylor on behalf of Rembrandt Technologies, LP (Taylor, Brooke) (Entered: 01/03/2007) 23 NOTICE of Attorney Appearance by Joseph Samuel Grinstein on behalf of Rembrandt Technologies, LP (Grinstein, Joseph) (Entered: 01/03/2007) 24 NOTICE of Attorney Appearance by Sidney Calvin Capshaw, III on

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behalf of Rembrandt Technologies, LP (Capshaw, Sidney) Modified on 1/4/2007 (mpv, ). (Entered: 01/03/2007) 01/03/2007 25 NOTICE of Attorney Appearance by Andrew Wesley Spangler on behalf of Rembrandt Technologies, LP (Spangler, Andrew) (Entered: 01/03/2007) 26 ORDER granting 12 Motion for Extension of Time to Answer re 4 Amended Complaint. The time for Defendant Charter to answer, move or otherwise respond is extended to 1/23/07 . Signed by Judge Leonard Davis on 1/3/07. (kjr, ) (Entered: 01/04/2007) 27 ORDER granting 13 Motion for Extension of Time to Answer re 4 Amended Complaint. The time for Defendant Coxcom Inc. to answer, move or otherwise respond is extended to 1/23/07 . Signed by Judge Leonard Davis on 1/3/07. (kjr, ) (Entered: 01/04/2007) Answer Due Deadline Updated for Charter Communications, Inc. to 1/23/2007; Charter Communications Operating, LLC to 1/23/2007; Coxcom, Inc., to 1/23/2007. (kjr, ) (Entered: 01/04/2007) 30 DOCKETED IN ERROR. SEE CORRECT DOCUMENT #16*** APPLICATION to Appear Pro Hac Vice by Attorney Charles Edward Juister for Charter Communications, Inc. and Charter Communications Operating, LLC.APPROVED (poa, ) Modified on 1/4/2007 (Entered: 01/04/2007) 01/04/2007 31 ***DOCKETED IN ERROR. SEE CORRECT DOCUMENT # 17*** APPLICATION to Appear Pro Hac Vice by Attorney William Joseph Kramer for Charter Communications, Inc. and Charter Communications Operating, LLC. APPROVED (poa, ) Modified on 1/4/2007 (ch, ). (Entered: 01/04/2007) 01/04/2007 32 ***DOCKETED IN ERROR. SEE CORRECT DOCUMENT # 14*** APPLICATION to Appear Pro Hac Vice by Attorney Margaret Lynn Begalle for Charter Communications, Inc. and Charter Communications Operating, LLC. APPROVED (poa, ) Modified on 1/5/2007 (ch, ). (Entered: 01/04/2007) 01/11/2007 01/11/2007 01/11/2007 01/11/2007 38 APPLICATION to Appear Pro Hac Vice by Attorney Leroy M Toliver for Coxcom, Inc.. (ch, ) (Entered: 01/16/2007) Pro Hac Vice Filing fee paid by Toliver; Fee: $25, receipt number: 2-12200 (ch, ) (Entered: 01/16/2007) 39 APPLICATION to Appear Pro Hac Vice by Attorney Mitchell G Stockwell for Coxcom, Inc.. (ch, ) (Entered: 01/16/2007) Pro Hac Vice Filing fee paid by Stockwell; Fee: $25, receipt number: 2-

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1-2201 (ch, ) (Entered: 01/16/2007) 01/12/2007 01/12/2007 01/15/2007 01/15/2007 01/15/2007 01/22/2007 40 APPLICATION to Appear Pro Hac Vice by Attorney Edgar G Sargent for Rembrandt Technologies, LP. (ch, ) (Entered: 01/19/2007) Pro Hac Vice Filing fee paid by Sargent; Fee: $25, receipt number: 2-12207 (ch, ) (Entered: 01/19/2007) 35 NOTICE of Attorney Appearance by Otis W Carroll, Jr on behalf of Rembrandt Technologies, LP (Carroll, Otis) (Entered: 01/15/2007) 36 NOTICE of Attorney Appearance by Collin Michael Maloney on behalf of Rembrandt Technologies, LP (Maloney, Collin) (Entered: 01/15/2007) 37 NOTICE of Attorney Appearance by James Patrick Kelley on behalf of Rembrandt Technologies, LP (Kelley, James) (Entered: 01/15/2007) 41 Consent MOTION for Extension of Time to File Answer re 4 Amended Complaint, by Coxcom, Inc.,. (Attachments: # 1 Text of Proposed Order) (Jones, Michael) (Entered: 01/22/2007) 42 ANSWER to Amended Complaint and, COUNTERCLAIM against Rembrandt Technologies, LP by Charter Communications, Inc., Charter Communications Operating, LLC.(Jones, Michael) (Entered: 01/23/2007) 43 CORPORATE DISCLOSURE STATEMENT filed by Charter Communications, Inc., Charter Communications Operating, LLC identifying Charter Communications, Inc. as Corporate Parent. (Jones, Michael) (Entered: 01/23/2007) 44 ORDER granting 41 Motion for Extension of Time to Answer. Answer deadline extended to 1/26/07 . Signed by Judge Leonard Davis on 1/23/07. (ehs, ) (Entered: 01/23/2007) 45 MOTION to Dismiss for Lack of Subject Matter Jurisdiction, Personal Jurisdiction, or in the Alternative, Transfer, and Brief in Support Thereof by Coxcom, Inc.,. (Attachments: # 1 Declaration of J. Spalding# 2 Exhibit 1# 3 Exhibit 2# 4 Exhibit 3A-C# 5 Exhibit 3D-E# 6 Exhibit 4# 7 Exhibit 5A-C# 8 Exhibit 6# 9 Exhibit 7# 10 Exhibit 8A-D# 11 Exhibit 9# 12 Exhibit 10A-B# 13 Text of Proposed Order Re: Personal Jurisdiction# 14 Text of Proposed Order Re: Subject Matter Jurisdiction# 15 Text of Proposed Order Re: Transfer to Delaware)(Jones, Michael) (Entered: 01/26/2007) 46 MOTION to Change Venue/Transfer case Contained in #45; proposed order attached to #45 by Coxcom, Inc.,. (mpv, ) (Entered: 01/29/2007) 47 NOTICE of Attorney Appearance by Allen Franklin Gardner on behalf of Charter Communications, Inc., Charter Communications Operating, LLC (Gardner, Allen) (Entered: 01/29/2007) 48 NOTICE of Attorney Appearance by Allen Franklin Gardner on behalf of Coxcom, Inc., (Gardner, Allen) (Entered: 01/29/2007) 49 NOTICE of Attorney Appearance by Tibor L. Nagy on behalf of

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Rembrandt Technologies, LP (Nagy, Tibor) (Entered: 01/31/2007) 02/02/2007 50 MOTION for Extension of Time to File Response/Reply as to 45 MOTION to Dismiss for Lack of Subject Matter Jurisdiction, Personal Jurisdiction, or in the Alternative, Transfer, and Brief in Support Thereof by Rembrandt Technologies, LP. (Attachments: # 1 Text of Proposed Order)(Nagy, Tibor) (Entered: 02/02/2007) 51 ORDER granting 50 Rembrandt Technologies, LP to respond to the motion to dismiss filed by dft CoxCom, Inc is moved from 2/12/07 to 2/23/07. Signed by Judge Leonard Davis on 2/5/07. (djh, ) (Entered: 02/05/2007) 52 NOTICE by Rembrandt Technologies, LP Notice of Related Action Currently Pending Before The Honorable T. John Ward (Nagy, Tibor) (Entered: 02/05/2007) 53 Plaintiff's ANSWER to Counterclaim of Defendants, Charter Communications, INc., Charter Communications Operating, LLC and Coxcom, Inc. by Rembrandt Technologies, LP.(Nagy, Tibor) (Entered: 02/12/2007) 54 ORDER - the court Transfers this case to the Honorable T. John Ward. Signed by Judge Leonard Davis on 2/13/07. (ch, ) (Entered: 02/13/2007) 55 APPLICATION to Appear Pro Hac Vice by Attorney Tonya R Deem for Coxcom, Inc.(FEE PAID). (ch, ) (Entered: 02/15/2007) 56 RESPONSE in Opposition re 45 MOTION to Dismiss for Lack of Subject Matter Jurisdiction, Personal Jurisdiction, or in the Alternative, Transfer, and Brief in Support Thereof TO COXCOM, INC.'S MOTION TO DISMISS filed by Rembrandt Technologies, LP. (Attachments: # 1 Affidavit of Tibor L. Nagy# 2 Exhibit A# 3 Exhibit B# 4 Exhibit C# 5 Exhibit D# 6 Exhibit E.1# 7 Exhibit E.2# 8 Exhibit F# 9 Exhibit G# 10 Exhibit H# 11 Exhibit I# 12 Exhibit J)(Nagy, Tibor) (Entered: 02/23/2007) 57 REPLY to Response to Motion re 45 MOTION to Dismiss for Lack of Subject Matter Jurisdiction, Personal Jurisdiction, or in the Alternative, Transfer, and Brief in Support Thereof filed by Coxcom, Inc.,. (Attachments: # 1 Exhibit 1# 2 Exhibit 2)(Jones, Michael) (Entered: 03/05/2007) 58 SUR-REPLY to Reply to Response to Motion re 45 MOTION to Dismiss for Lack of Subject Matter Jurisdiction, Personal Jurisdiction, or in the Alternative, Transfer, and Brief in Support Thereof filed by Rembrandt Technologies, LP. (Nagy, Tibor) (Entered: 03/08/2007) 59 NOTICE by Coxcom, Inc., of Filing Motion for Transfer and Consolidation of Rembrandt Technologies, LP Patent Litigation Pursuant to 28 U.S.C. 1407 (Attachments: # 1 MDL Motion for Transfer and Consolidation# 2 Motion Ex. A# 3 Motion Ex. B# 4 MDL Memorandum# 5 MDL Exhibit List# 6 MDL Notice of Appearance# 7

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MDL Corporate Disclosure# 8 MDL Certificate of Service)(Stockwell, Mitchell) (Entered: 03/09/2007) 03/09/2007 60 Additional Attachments to Main Document: 59 Notice (Other), Notice (Other).. (Attachments: # 1 MDL Ex. 1# 2 MDL Ex. 2# 3 MDL Ex. 3# 4 MDL Ex. 4# 5 MDL Ex. 5# 6 MDL Ex. 6# 7 MDL Ex. 7# 8 MDL Ex. 8# 9 MDL Ex. 9# 10 MDL Ex. 10# 11 MDL Ex. 11# 12 MDL Ex. 12# 13 MDL Ex. 13# 14 MDL Ex. 14# 15 MDL Ex. 15# 16 MDL Ex. 16# 17 MDL Ex. 17# 18 MDL Ex. 18# 19 MDL Ex. 19# 20 MDL Ex. 20# 21 MDL Ex. 21# 22 MDL Ex. 22# 23 MDL Ex. 23# 24 MDL Ex. 24# 25 MDL Ex. 25# 26 MDL Ex. 26# 27 MDL Ex. 27# 28 MDL Ex. 28# 29 MDL Ex. 29# 30 MDL Ex. 30# 31 MDL Ex. 31# 32 MDL Ex. 32# 33 MDL Ex. 33# 34 MDL Ex. 34# 35 MDL Ex. 35# 36 MDL Ex. 36# 37 MDL Ex. 37# 38 MDL Ex. 38# 39 MDL Ex. 39# 40 MDL Ex. 40# 41 MDL Ex. 41# 42 MDL Ex. 42# 43 MDL Ex. 43)(Stockwell, Mitchell) (Entered: 03/09/2007) 61 NOTICE by Coxcom, Inc., re 45 MOTION to Dismiss for Lack of Subject Matter Jurisdiction, Personal Jurisdiction, or in the Alternative, Transfer, and Brief in Support Thereof of Supplemental Authority Supporting its Motion to Transfer (Jones, Michael) (Entered: 03/29/2007) 62 NOTICE by Rembrandt Technologies, LP Joint Notice of Conference Regarding Proposed Discovery Order and Docket Control Order (Attachments: # 1 Exhibit Discovery Order and Docket Control Order) (Taylor, Brooke) (Entered: 03/30/2007) 63 NOTICE by Rembrandt Technologies, LP re 60 Additional Attachments to Main Document,,,, 59 Notice (Other), Notice (Other) Notice of Filing Opposition to CoxComs Motion for Transfer and Consolidation (Attachments: # 1 Exhibit Rembrandts Brief in Opposition to CoxComs Motion For Transfer and Consolidation# 2 Exhibit Exhibit List# 3 Exhibit Opposition Brief Exh 1# 4 Exhibit Opposition Brief Exh 2# 5 Exhibit Opposition Brief Exh 3# 6 Exhibit Opposition Brief Exh 4# 7 Exhibit Opposition Brief Exh 5# 8 Exhibit Opposition Brief Exh 6# 9 Exhibit Opposition Brief Exh 7# 10 Exhibit Opposition Brief Exh 8# 11 Exhibit Opposition Brief Exh 9# 12 Exhibit Opposition Brief Exh 10# 13 Exhibit Exhibit 11# 14 Exhibit Exhibit 12# 15 Exhibit Opposition Brief Exh 13# 16 Exhibit Response to CoxComs Motion for Transfer and Consolidation# 17 Exhibit Reasons Why Oral Argument Should Be Heard# 18 Exhibit Proof of Service)(Taylor, Brooke) (Entered: 04/05/2007) 64 ORDER - referring case to Magistrate Judge Charles Everingham in accordance with the assignments made by General Order 07-03. The magistrate judge shall conduct pre-trial proceedings pursuant to 28 USC 636. Signed by Judge T. John Ward on 4/18/07. (ch, ) (Entered: 04/18/2007) 65 NOTICE by Charter Communications, Inc., Charter Communications Operating, LLC, Coxcom, Inc., Notice of Development (Attachments: # 1 Notice of Hearing)(Gardner, Allen) (Entered: 04/18/2007)

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66 ORDER- REGARDING THE PROTECTIVE ORDER AND DOCUMENT PRODUCTION. Signed by Judge Charles Everingham on 4/19/07. (ch, ) (Entered: 04/19/2007) 67 DOCKET CONTROL ORDER Respond to Amended Pleadings 11/30/07. Amended Pleadings due by 11/16/2007. Discovery due by 5/14/2008. Joinder of Parties due by 5/3/2007. Claims Construction Hearing set for 2/13/2008 - 2/14/08 9:00 AM before Judge T. John Ward. Motions in limine due by 7/21/2008. Proposed Pretrial Order due by 7/24/2008. Jury Selection set for 8/4/2008 9:00AM before Judge T. John Ward. Pretrial Conference set for 7/24/2008 9:30 AM before Judge T. John Ward. Privilege Logs to be exchanged by parties 6/4/07. All other deadlines are set forth herein. Signed by Judge Charles Everingham on 4/19/07. (ch, ) (Entered: 04/19/2007) 68 NOTICE by Rembrandt Technologies, LP Of Proposed Protective Order (Attachments: # 1 Text of Proposed Order Proposed Protective Order) (Taylor, Brooke) CORRECTED PROPOSED PROTECTIVE ORDER added on 4/25/2007 (mpv, ). Modified on 4/25/2007 (mpv, ). (Entered: 04/24/2007) 69 NOTICE by Rembrandt Technologies, LP Re Electronic Production (Taylor, Brooke) (Entered: 04/24/2007) NOTICE re 68 Notice (Other) CORRECTED PROPOSED PROTECTIVE ORDER ADDED BY CLERK (mpv, ) (Entered: 04/25/2007) 70 Minute Entry for proceedings held before Judge Charles Everingham : Scheduling Conference held on 4/30/2007. (Court Reporter Debbie Latham.)(delat, ) (Entered: 04/30/2007) TRANSCRIPT of Proceedings held on 4/3/07 before Judge Chad Everingham. Court Reporter: Transcriber/Susan Simmons. (lss) (Entered: 05/03/2007) 72 NOTICE by Charter Communications, Inc., Charter Communications Operating, LLC of Disclosures (Gardner, Allen) (Entered: 05/03/2007) 73 NOTICE of Disclosure by Coxcom, Inc.,, Coxcom, Inc., Notice of Service of Initial Disclosures (Stockwell, Mitchell) (Entered: 05/04/2007) 74 PROTECTIVE ORDER. Signed by Judge Charles Everingham on 5/4/07. (ehs, ) (Entered: 05/04/2007) 75 NOTICE of Disclosure by Rembrandt Technologies, LP (Berry, Matthew) (Entered: 05/07/2007) 76 NOTICE of Disclosure by Rembrandt Technologies, LP (Taylor, Brooke) (Entered: 05/23/2007) 77 Joint MOTION to Amend/Correct Docket Control Order by Rembrandt Technologies, LP. (Attachments: # 1 Text of Proposed Order Order Granting Motion to Amend)(Taylor, Brooke) (Entered: 06/04/2007)

04/19/2007

04/24/2007

04/24/2007 04/25/2007

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05/03/2007 05/04/2007 05/04/2007 05/07/2007 05/23/2007 06/04/2007

Case 1:07-cv-00404-GMS

Document 91

Filed 06/28/2007

Page 16 of 16

06/06/2007

78 ORDER granting 77 Motion to Amend/Correct. Docket Control Order is amended to move date to exchange privilege logs to 7/10/07. Signed by Judge Charles Everingham on 6/5/07. (ch, ) (Entered: 06/06/2007) 79 NOTICE of Disclosure by Rembrandt Technologies, LP Regarding Compliance with Paragraph 3(b) of the Discovery Order (Berry, Matthew) (Entered: 06/12/2007) 80 **PLEASE IGNORE - PLEADING REFILED AS DOC #82**NOTICE of Disclosure by Coxcom, Inc., (Gardner, Allen) Modified on 6/14/2007 (rml, ). (Entered: 06/13/2007) 81 NOTICE of Disclosure by Charter Communications, Inc., Charter Communications Operating, LLC P.R. 3-3 and P.R. 3-4 (Gardner, Allen) (Entered: 06/14/2007) 82 ***REPLACES #80*** NOTICE of Disclosure by Coxcom, Inc., P.R. 3-3 and P.R. 3-4 (Gardner, Allen) Modified on 6/14/2007 (mpv, ). (Entered: 06/14/2007)

06/12/2007

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***FILED IN ERROR. PLEASE IGNORE Document # 80, Notice of disclosure. DOCUMENT REFILED AS #82.*** (rml, ) (Entered: 06/14/2007)

06/21/2007

83 NOTICE by Charter Communications, Inc., Charter Communications Operating, LLC, Coxcom, Inc., of Multi-District Litigation Developments Pursuant to Local Rule CV-42 (Attachments: # 1 Exhibit A)(Gardner, Allen) (Entered: 06/21/2007) 84 Interdistrict transfer to the District of Delaware, Wilmington DE. Pursuant to letter Elizabth Dinan was notified. Certified copy of Docket Sheet, Complaint, Transfer Order and letter were mailed to the Federal Blding, Lockbox 18, 844 N. King Street,Wilmington, DE (ch, ) Additional attachment(s) added on 6/28/2007 (ch, ). Modified on 6/28/2007 (ch, ). (Entered: 06/27/2007)

06/25/2007

PACER Service Center
Transaction Receipt
06/29/2007 09:21:32 PACER Login: Description: ud0037 Docket Report Client Code: Search Criteria: Cost: 2:06-cv-00507-TJWCE 0.72

Billable Pages: 9

Case 1:07-cv-00404-GMS Case 2:06-cv-00507-TJW-CE Document 91-2 Document 60-23 Filed 06/28/2007 Page 1 of of 18 Filed 03/09/2007 Page 1 18

Exhibit 22

US2000 5490191.1

Case 1:07-cv-00404-GMS Case 2:06-cv-00507-TJW-CE Document 91-2 Document 60-23 Filed 06/28/2007 Page 2 of of 18 Filed 03/09/2007 Page 2 18

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE REMBRANDT TECHNOLOGIES~LP, Plaintiff; v. CBS CORPORATION, Defendant.

) ) ) ) ) ) ) ) ) ) )

C.A. No.

________

COMPLAINT FOR PATENT INFRINGEMENT AND DEMAND FOR JURYTRIAL Rembrandt Technologies, LP ("Rembrandt"), for its complaint against CBS Corporation ("CBS" or "Defendant"), alleges as follows:

PARTIES 1. Rembrandt is a limited partnership organized under the laws ofthe State

ofNew Jersey, having its principal place ofbusiness at 401 City Avenue, Suite 815, Bala Cynwyd, PA 19004. 2. CBS is a corporation organized under the laws ofthe State ofDelaware,

having its principal place ofbusiness at 51 West 52"~ Street, 35th Floor, New York, NY 10019. JURISDICTION AND VENUE 3. This is an action arising under the patent laws ofthe United States, Title

35, United States Code. This Court has subject matter jurisdiction over this case under 28 U.S.C.

§~ and 1338(a). 1331

Case 1:07-cv-00404-GMS Case 2:06-cv-00507-TJW-CE Document 91-2 Document 60-23 Filed 06/28/2007 Page 3 of of 18 Filed 03/09/2007 Page 3 18

4.

This Court has personaljurisdiction over CBS. Defendant is incorporated

in the State ofDelaware, and has conducted and does conduct business within the State of Delaware. Defendant, directly or through subsidiaries or intermediaries, offers for sale, sells, advertises, and markets products and services that infringe the patent-in-suit, as described more specifically below. Therefore, because Defendant has committed acts ofpatent infringement in this district, or is otherwise present or doing business in this district, this Court has personal jurisdiction over Defendant. 5. and 1400(b). INFRINGEMENT OF U.S. PATENT NO. 5243,627 6. Rembrandt realleges and incorporates herein by reference the allegations Venue i~ proper in this judicial district under 28 U.S.C.

§~ 1391(b), (c),

stated in paragraphs 1-5 ofthis Complaint. 7. United States Patent No. 5,243,627 entitled "Signal Point Interleaving

Technique" ("the `627 patent") was duly and legally issued by the United States Patent & Trademark Office on September 7, 1993. A copy ofthe `627 patent is annexed hereto as Exhibit A. 8. Rembrandt is the owner ofall right, title and interest in the `627 patent,

with the right to sue, enforce and recover damages forinfringement. 9. CBS operates television systems and provides television services

throughout the United States.

2

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10.

Defendanthas directly orindirectly infringed the `627 patent, and is

continuing to do so, by practicing the inventions claimed therein, and/or by inducing or contributing to the practice by others ofthe inventions claimed therein, in thisjudicial district. For example, Defendant has infringed, and continues to infringe, the `627 patent by its transmission, orreceipt and retransmission, over its television systems, ofdigital terrestrial broadcast signals that comply with the ATSC Digital Television Standard. 11. Rembrandt has been damaged by Defendant's infringement and will suffer

additional and irreparable damage unless this Court enjoins Defendant from continuing its infringement under 35 U.S.C. § 283. 12. Upon information and belief, such infringement has been, and will

continue to be, willful and deliberate, entitling Rembrandt to increased damages under 35 U.S.C.

§ 284 and making this an exceptional case entitling Rembrandt to an award ofreasonable
attorneys' fees pursuant to 35 U.S.C. § 285. PRAYER FOR RELIEF WHEREFORE, Rembrandt respectfully requests the following relief: (1) the entry ofjudgment in favor ofRembrandt, and against Defendant, that

Defendanthas infringed the `627 patent; (2) a permanent injunction enjoining and restraining Defendant and its

officers, agents, servants, employees, affiliates, divisions, units and subsidiaries, and those in association therewith, from further acts ofinfringement ofthe `627 patent; (3) (4) an award ofdamages; an award ofincreased damages pursuant to 35 U.S.C. § 284;

3

Case 1:07-cv-00404-GMS Case 2:06-cv-00507-TJW-CE Document 91-2 Document 60-23 Filed 06/28/2007 Page 5 of of 18 Filed 03/09/2007 Page 5 18

(5)

an award ofall costs and expenses ofthis action, including reasonable

attorneys' fees, pre-judgment interest, and post-judgment interest; and (6) and proper. JURY DEMAND Rembrandt hereby respectfully requests ajury trial on all issues so triable. such other and further relief, at law and in equity, as the Court deems just

ASHBY & GEDDES

Steven J. Balick~I.D. 2114) # John (I. Day (LD. #2403) LaurenE. Maguire (I.D. #4261) 222 Delaware Avenue, 17th Floor P.O. Box 1150 Wilmington, DE 19899 (302) 654-1888 sbalick~ashby-geddes.com jday~ashby-geddes.com lmaguire~ashby-geddes.com Attorneysfor Plaint~('[ OfCounsel: John F. Sweeney Joseph A. DeGirolarno Michael 0. Cummings MORGAN & FINNEGAN, LLP 3 World Financial Center New York, NY 10281-2101 Telephone: (212) 415-8700 j sweeney~morganfmnegan. corn jdegirolamo@ morganfmnegan.com mcuznmings~morganhinnegan.com Dated: December 1, 2006
175613.1

4

Case 1:07-cv-00404-GMS Case 2:06-cv-00507-TJW-CE Document 91-2 Document 60-23 Filed 06/28/2007 Page 6 of of 18 Filed 03/09/2007 Page 6 18

EXHIBIT A

Case 1:07-cv-00404-GMS Case 2:06-cv-00507-TJW-CE Document 91-2 Document 60-23 Filed 06/28/2007 Page 7 of of 18 Filed 03/09/2007 Page 7 18

111111 IIlIIflIl l hIl 111111011II ! 1111111 1 li i! I JI Il hlI I 1 1 1 1 1
United States Patent
Betts et al..
(54] SIGNAL POINT INTERLEAVING uNiQUE (75j Inventoxa William L Betts, St. Petersburg
C 7 i,i i 5
.

[19]

[iii (451
[56]

Patent Nuniben Date of Patent

U~0O5243627A

5,243,627
Sep. 7, 1993

References Qted U.S. PATENT DOCUMENTS 3,988.677 4,677,624 4945549 ~,029, 185

i.

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6/1987 Bans at al......................... 375/39 7/1990 Simon Ct at. ..._...__.... 375/53 7/1991 Wet ~ 375/39 X

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[73}. Assiguee

AT&3~ Laboratories, MuxTay Bell

4zwin.y~ 4gent~orfinn--Rønald D. Slusky; Gerard A.
deBlasi [57] ABSTRACT Viterbi decoder performance in a data communication system using 2M-dlniensional channel symbols N>1 can be rurther enhanced by an Interleaving technique which uses a distributed treflis encoder In combination with a sipal point interleaver. 24 ClaIms, 4 Drawing Sheets

[21] AppI. No.: 748,594 [221 Filed: Aug. 22, 1991 1104L5/12
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·

&~. , 1993 7

Sheet 1 of 4

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Case 1:07-cv-00404-GMS Case 2:06-cv-00507-TJW-CE Document 91-2 Document 60-23 Filed 06/28/2007 Page 11 of of 18 Filed 03/09/2007 Page 11 18

U.S. Patent
· ·

Sep. 7, 1993

Sheet 4 of 4

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FIG.5
·
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NOT INTERLEAVED ONETREWS STAGE

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Case 1:07-cv-00404-GMS Case 2:06-cv-00507-TJW-CE Document 91-2 Document 60-23 Filed 06/28/2007 Page 12 of of 18 Filed 03/09/2007 Page 12 18

1
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SIGNAL POiNT INTERLEAVING TECHNIQUE

pairs is reduced from what it would have otherwise been.

· ·
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proach thetheoretical limits of the ChaflnaL the Nth signal point ofa respective one ofthe channel It has been found that various channel impairments, ~rmi~ ~ criterion eniiances the accuracy with whoseeffects on theachievable bit rate were relatively which the phase tracking loop in the receiverperforms minor compared to, say, additive white Gaussian noise its ~ 20 and linear distortion, have now become ofgreater conAlso in preferred embodiments, we have found that cern. These include such Impairments as nonlinear ~ the use of three parallel trellis encoders in conjunction tortion and residual (Le., uncmpensated.:for) Pba5e with a signal point interleaving regime in which the jitter. · Such impairments are particularly irksome in signal points ofeach channel symbol are separated from systems which use· trellis coding. Indeed, it has been 25 one another by three signaling intervals (bands) pro. - found that the theoretical improvement in Gaussian videa an optimum or near-optimum tradeoff between noise Immunity promised by at leastsome trellis codes is signal point/channel symbol separation and the decodnot realized in real-world applications where these 1Wlag delay that is caused by the interleaving. pairmeuts are manifest. The principal reason this is so appears to be that thenoise components introducedInto ~ BRIEF DESCRIPTION OFTEE DRAWING the received signal samples are such as to worsen the In the drawing. dfectiveness ofthe Viterbi decoder used in the recmver FiG. I isablock diagram ofthetransmitter section of to recover the transmitted data. a prior art mqdens US. Pat. No. 4,677,625, issued Jun. 30. 1987 to Bells FIG. 2 is shows a signal constellation used by the et al, teaches a method and arrangement in which, ~ ofFIG. I; through the use ofa distributed trellis encoder/Viterbi P10,3 isa block diagram ofthe transmitter section of decoder, the effects of many of these impairments ~ a modem employing four-dimensional channel symbols be reduced. The invention In the Belts et al patent mcand embodying the principles of theinvention; ognizes that a pan ofthe reason that the performance of piG. 4 isa block diagram ofthe receiver section ofa the Viterbi decoder is degraded by these impairments is 40 modem embodying the principles of the invention the fact that the noise components of channel symbols which processes the received four-dimensional channel .wbich closely follow one another in the transmission symbols generated by the transmitter of FIG. 3; channel are highly correlated for many types ofimpairP10.5is a signal point timing/sequencing chart helputerus. And it is that correlation which worsens the ful in explaining the principles of the present Invention effect that these Impairments have on the Viterbi de- ~ FIG. 6 isa signal point interleaver which can be used coder. Among the impairments whose noise is one- in the transmitter of FIG. 3 to `interleave the signal lated in this way are impulse noise, phase "hits" and points of eight-dimensional channel symbols, and gain "hits." All of these typicallyextend over a number pia. 7 Is a signal point deintenleaver which can be ofadjacent chadnel symbols in thechannel, and thus all u~e.jn the receiver of FIG. 4to deinterleave the signal i · rtsult in channel symbol noise components which are ~o points of eight-dimensional channel symbols. highly correlated. The well-known noise enhancement DETAILED DESCRIPT1QN characteristics of lincar equalizers also induce conehoed noiseIii adjacent channel symbols, as does uncomP10.1 depicts the transmitter section of a prior art pensated$or phasejitter..AIsn, the occurrence ofone of modem employing a 2N-diinensional signaling scheme, the relatively high powerpolnts ofthe signal constella- ~ N~1.The modem receives input information In the lion can, In pulse code modulation (PCM) systems, for · form ofa serial bit stream from data terminal equipment · example, give riseto noise on adjacent channel symbols (DTE) 11i--.illus&ratively a host computer. `That bit which, again, is correlated. · streamIs then scrambled, or randomized,by randoinizer The Bans at al patent addresses this issue by distnibut113 whose output bits are provided in serial form to lag the outgoing data to a plurality oftrellis encoders in 60 serial-to-parallel (S/P) converter 115.

BACKGROUND OFTEE INVENTION SUMJ~~YF TEE INVENTION O 5 The present invention relates to the transmission of In accordance with the present inventIon, it baa been digital data over band-limited clssnneh. · realized that the Viterbi decoder performance In a data Over the years, the requirements ofmodeui.day ~. communication system using 2N-dimenslonal channel tal data transmission over band4jmitcd channels--such symbols can be flirther enhanced by an interleaving as voiceband telephone channels--have resulicti in a technique which uses, In combination, a) the aforemenpush for higherand higherbit rates.Ths push baa ~ 10 tioned distributed trellis encoder/Viterbi decoder techthe development and introduction of such innovations ~ causes theb)a signal pointinterleaving technique which constituent signal points ofthe channel symas adaptive equalization, multi-dimensional siznal conbela to be non.adjacent as they traverse the channel. atellallons, echo cancellation (for two-wire applica. dons), and trellis coding. Today, thedatarates achieved ~!` Prefe deznbodinsents ofthe Invention, theInterusing these and other techniques am b~gin,,j,~g ~. l~ ~ lgisputinsuchawaythateveiyNthsignal is point in the signal pointstream traversing the channel

·

round-robin fashion and interleaving thetrelils encoder Sesi4lo-parallel converter 115, in turn, provides, outputs onthe transmission cbanneLInthe receiver, the during each of a succession of symbol Intervals (coinstream of received Interleaved channel symbols is con- prised of N baud Intervals), some predetermined smutrespondingly distributed to a plurality of trellis decod- ben of parallel bits on lead 109 and some number of ens. Since the successive pains of channel symbols ap- 65 parallel bits on lead 108. (1* will be appreciated that plied to a particular trellis decoder are separated from whenever bits are provided in parallel in the modem, one another as they traverse the channel, the correlaseparate leads are required to catty each of the bits.) lion ofthe noise components of these channel symbol The bits on lead 109 are applied to trellis encoder 1190,

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and are referred to as the "incus hits." The bitt on lead Those two signal points are thereupon communicated 108 are applied to modulus converter 116, and are re- · over the chaitnel by QAM encoder 124 and modulator ferred to as the "uncoded bits." 128 as described above. To better understand how trellis encoder 119a and Note that, insplesneniationally, the 2N-dimensional modulus converter 116 work, reference is made to FIG. S channel symbol is generated by having the trellis en2, which shows the two-dimensions! signal consteflacoder fdentl1~,, nterdependently, N subsets of the twoI · tion that formsthe basis ofthe ZN-dimensional signaling dimensional constellation of FIG. 2. then select a twoscheme Illustratively used by the modem. This coastaldimensional signal point front each of the subsets thus lation is comprised of 32 signal points, which are diIdentified. The concatenation of the N two-dimensional vided into tour subsets,A through D, each comprlsód of 10 signal points thusselected is the desired ZN-dimensional eight signal points. The eight points of subset A are channel symboL This process, however, can be underexplicitly labeled as Anthrough A?. ft maybenoted that stood as involving the direct selection of a 2N-diniensubsets C, B and Dean bearrived at by clockwise rotasional channel symboL Viewed inthis context, the set of · lion of subset A by 90,180 and 270 degrees, respec- all possible combinations of N of the two-dimensional tlvely. (Conventional differential encoding circuitry 15 subsets identified by N successive trellis encoder out. within trellisencoder 1190 exploits this symmetry.) For puts can be understood to be a set of 2N-di*nenslonal reference, a single signal point of each ofthose subsets subsets of a 2N-dimenslonal constellation, the latter · is also shown On FIG. 2. · being comprisedofall possible combinations ofNof the Contlder~ first, the case of N~l,Le., atwo-dinien- signal points of the two-dilnensional constellation. A sional signaling scheme. In this case one trellis bit on 20 succession of N outputs from the trellis encoder Identi-- 1 lead 109 would be expanded so two bits by trellis enflesaparticularoneofthe2N-diinensionalsubsetsanda coder 119a on lead 121. The foun possible values of succession of N outputs from the mqdulus converter · those three bits 00,01. 10, and 11 identlI~psubsets A, B, selects a particular 2N-dinsensional signal point from C and D, respectively. The successive 2-bit words on the identified ZN-dimensional subset. lead 121 are represented as a,,, n=0,I.2. - .,where n is 25 Modulus converter 116 is illustratively of the type an index that advances ~t the baud rate. At the same disclosed in co-pending, commonly-assigned U.S. palime, three parallel bits would be provided onlead 108. tent application Sen. No. 588,658 flIed Sep.26, 1990 and These are converted by modulus convener 116 into an allowed on May 21, 1991, hereby incorporated by referindex having a value within the rangc (decimal) 0107. ence, Modulus converter 116 provides the modem with The index value, represented in binary form on lead 30 the abilitytosupport data transmission at various differ117, selects a particular signal point from the subset eatbit rates. Assume, forexample, that therateat which identified on lead 121. Thus If lead 121 carries the two bits arc provided by DTE 111 deOreases. The serial-tobits 00 while lead 117 carries the three bits 001, then parallel converter will continUe to provide Its outputs signal point A of the FIG. 2 constellation has been on leads 108 and 109 at the asme baud rate as before. 1 selected. The words on leads 117 and 121 are applied to 3$ However, the upper limit of the range of index values QAM encoder 174 which generates, on lead 125, values that are provided by modulus converter 116 on lead 117 representing the 1 (in-phase) and Q (quadrature-phase) will be reduced, so that, effectively, each of the four components ofsignal point Ai. The signal point getter. subsets A through D, Instead of having eight signal sted on lead 125 in the ~th baud interval is denoted X,,~, points, will have some smaller number. Conversely if which is passed onto modulator 128 to generate a pass- 40 the rate at which bits are provided by DTE 111 Should - band line signalwhich is applied to the communication Increase oven thatoriginally assumed, the upper limit of channeL The superscript, a, Indicates that the trellis the range ofIndex values, and thusthe numberofparalencoder that was used to Identify the subset for any Id bits, that appear on lead 117 will be increased beyond particular signal point was trellis encoder 119a. That is, eight and the constellation itself will be expanded 10 ofcourse, a trivial notation is far as FIG. I goes inas- 45 accommodate the larger number of signal points thus much as trellis encoder 119a is the only trellis encoder being selected. As an alternative to using a modulus inthe modem. However, it is useful to Introduce this converter, fractions! bit rates can be supporte using, notation because more than one trellis encoder stage is for example, thetechnique disclosed in L.Wei, "Trellisused in preferred embodiments of modems incorporat- Coded Modulation with Multidimensional Cosistellaing the pninciplei of the present invention as shown in so lions." IEEE Trans. on Communication Theory, Vol. later PIGS. · IT-33, No.4, July 1987, pp. 483--501. In the case of N> 1, abe operation Is similar. Now, Turning now to P10.3, the transmitter portion of a howevet. the words on lead 109 are used by trellis en- modem embodying the principles of the invention is coder 119010 sequentially Identify on lead I21N subshown. This embodiment Illustratively uses the aforesets,whfle the words on lead 108 am used to generate N 55 mentioned four-dimensional, I.e., N=2, signaling correspojiding index values on lead 117. The N signal scheme. Many of the components are similar to those points identified In this way are she component signal shown in FIG. L'Thus, in particular, the transmitter of · points of a 2N-dinzenszonaj channel symbol, the fist FIG. 3--which receives its input information In the such symbol being comprised ofthe signal points Xo~, form of a stream of input bits from DTE 311--Includes · - x~_ 11g. Por example, a modem in which the trans- 60 randonsizer 313, whIch supplies its output, on lead 314, niluer of FIG. 1 could be used may be 114,400 bit per to S/P convener 315. The latteroutputs uncoded bits to second modem using four-dimensional coding (i.e., modulus converter 316. The trspsmitter further inN~2) a baud rate of 3200. In this case, nine bits and eludes four-dimensional QAM encoder 324 and modufrom S/P converter 115 are used for each four-thenlator 323. Thetrellis bits, on lead 309, are provided not siona! symboL Specifically, three parallel bits on lead 65 to a standard single trellis encOder, but to a distributed 109 are expanded into four bits on lead 121 to Identify a trellis encoder comprised ofthree trellis encoderstages. pair of subsets while six bits on lead 108 are used to trellis encoder stage 3190, trellis encoder stage 319~, select particular signal points from those two subsets. and trellis encoder ~tage 319w.

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Such a distributed trellis encoder, which is described the opposite function to interleaver 341 in the transmit· In the aforementioned Betts et al patent generates a ter. The output ofdeinterleaver 441 on lead 442 is thus plurality of streams of trellis encoded channel symbols ~ X~"~ ~ Zv, Xs; Xa', - . - , etc. (Although ~ in response to respective portions of the input Informa- not explicitly shown In the drawing, the name well· lion: Specifically, a three-bit word on lead 309 is sup~5 known techniques used in modems of this general kind plied to trellis encoder stage 3190. The next three-bit to identify within the stream of received signal points word on lead 309 is supplied to trellis encoder stage the boundaries between successive symbols is used to 319I~. he next three-bit word Issupplied to trellis en- synchronize the operation of signal' point deinteileaver T coder stage 319y, and then back to trellis encoderstage 441 to ensure that receivedsignal points ~ ~$, Xe" 3$a- This distribution of`the trellis bits to the various 10.. are applied to delay element 4411 while received trellis encoder stages Is performed by switching circuit signal pointsXi" ~3$ X9. - ,are applied to lead 4412.) 331 operating under the control of symbol clock 325. The received 1 signal points on lead 442 are then disThe initial data Word outputs of the trellis encoders are tributed by switching cIrcuit 431 under the control of subsetidentiflers no and at for encoder stage 3190, $~ symbol clock 425(0 a distributed Vitembi decoder cornand $j for encoder stage 319$, and y4 and ~ for en- 15 prised of 4D Viterbi decoder stages 419a, 419$ and · coder stige 319y, followed by as and at for encoder 419y. Specifically, received signal pouts ~ and Ze stage 3190, and sø forth. These are supplied to four-ti- are app~iedto decoder stage 419a received signal ·mensional QAM encoder 324 by switching circuit, points X and X P are applied to decoder stage 419$; 2~ 3 337--also operating under the control of symbol clock and received signal points ~7 and Y~s~ applied to arc 325--on lead 338 çhrcugb a one-symbol delay 364 and 20 decoder stage 419y. The outputs of the thtee decoder lead 363, in orderto compensate for a one-symbol delay stages arc thencombined intoaserial stream on lead 438 caused by modulus converter 316. Thus,, the stream of by switching circuIt 437. also operating under the consubset Identifiers on lead 338 is no. a~, ~, ~, y~, $ $~, a~ trol of symbol clock 423. Those outputs, representing ·. - . . Using the notation introduced above, then, the decisions as to the, v$pcso1 ~hetraqsm4ttedsignal outputofencoder324onlead325isthestreamofsignal 25 points,aredenoledX~X~.X2.X2.X4.X3,X&...,the points Xo", Xia, X~$, P, X.,v, X,i, X~. - , which is X a, $ and y superscripts no longer being needed. 3 comprised of three interleaved streams of trellis enIn conventional fa~blon, hebits that represent each t ·coded channel symbols,8 these streams being ho", X , ofthe decisions on lead 438 can be divided into bits that 1~ Xoe,~ X ". - ; Xa , X P, X~P, P, X 4~ . - ; and . x9 represent a) the trellis bits that appeared on transmitter 3 X7, X~),X 1~ Xit; Xi~7-. . - These, 1 turn, are 30 lead 309 and b) the index values that appeared onhansV, in 10 supplied, in accordance with the invention, to signal mitter lead 317. Those two groups of bits arc provided point interleaver 341 which applies alternate ones ofthe in the receiver on leads 461 and 462, respectively. The `signal points applied thereto to lead 3412--which signal latter group ofbits are deconverted by modulus decon· points appear Iinntediatelyat the1Interleaver output on vinier 416 (also disclosed in the aforementioned `658 lead 342--and toone-symbol (Z- ) delay element 3411. 35 patent application) back to uncoded bit values on lead · which appear on lead 342 after beingdelayed therein by 414. The operation ofthe modulus deconverter imparts one symbolinterval The resulting interleaved stream of a one-symbol delay to thebits on lead 414 Accordingly, trellis encoded signal points Is Xo", X_ 7, XzP, Xic, the bits on lead 461 are caused to be delayed by one 1. · Xiv, X3P, Xe", X~7. X~$, X~, hCio7, X~$. .(thesignal symbol by delay element 464. The resulting combined point X_iv being, of course, the signal point appliedto 40 bits ott lead 415 thus represent the stream of bits that interleaver 341 just ahead of signal point Xe"). appeared at theoutput of randornIzer 313 In the traissA discussion and explanation ofhow theinterleaving mitter. Thcse are derandontized in the receiver by just described is advantageousis set forth hereinbelow. derandomizer 413 and the resulting derandomized bit In order to fully set thestage for that explanation, howstream Is applied so DTh411 WhiCh may be, for exam.ever, It will be first useful so consider the receiver sec- 45 pIe, a computer terminal. · lion of a modemwhich receives the interleaved signal Referring to FIG. 5, one can see the improvement point stream. that is achieved by the present Invention. Thus referring to FIG. 4~ line signal transmitted the Une! shows the stream ofoutput signal points getterby thetransmitter of'P10.3 is rcceived from the chanated and launched into the Channel using one stage of' nd and applied to demo4ulator/equalizer 455 which, in So trellis encoding and no signal point Interleaving, This Is, conventional fashion--including an Input from phase of course, the prior art arrangement shown In FIG. I. tracking ioop 457--generates a stream of outputs on Until shows the effectof providing a three-stage dislead 456 representing the demodulator/equalIzes's best tsibuted trellis encoder but still no signal point Interappsoxisnatlon of thevalues ofthe Land Q components leaving. This Is the arrangementshown in theaforcinenofthe signal points ofthe' transmitted Interleaved signal 55 tinned Betts et hi patent. Note that the signal points of point stream. Theseoutputs are referred to herein as the each channel symbol operated on by a particular treUis "received signal points." (Due to distortion and other encoder stage are adjacent In the output signal point channel Impairments that the demodulator/equalizer is stream. For example, the second signal point of the not able to compensate for, the I and Q components of symbol Xo" Xin~~nasnely signal point Xi"--Is repsthe received signal points, Instead ofhaving exact lute- 60 rated by five baud intervals fromthe first (closer) signal ger values, can have any value. Thus a transmitted point of the symbol X~"X,"~--namely point Xs". signal signal point having coordinates (3, --5) may be output As noted earlier, such separation is advantageous beby the'demodwator/equalizer as the, received signal cause the chainel symbols which are processed one point (2.945, --5.001).) The stream of received signal after the other In a particular Vitesbi decoder stage · pointsonead456Isdenoted~o',X_~v,X~$,~a,Xshave noise components which are not highly cone65 X P, Z", Xsl, Xs$, X ", X i', ~. . -. lated. 7 3The successive received10signal points are deinterNote, however, that the individual signal points of leavedin signal point deinterleaver441, whichprovides each channel symbol. e.g., ho"and Xi", areadjacent to

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one anotheras they passthrough the channel; and since signal points Xa" andXj", Xt"and`X~"--are ow sepan all the signal points of's channel ~ynsbol be promust rated by none baudintervals. ceased serially in the same Viterbi decoder stage, this Using more than three trellis encoder stages in the means that the Viterbi decoder muss process adjacent · distributed trellis encoder and/or a signal point intersignal points that have highly correlated noise compo- 5 leaver that separates signal points from thesame chinnents.. ` nd symbol by more than three baUd intervals would It is to this end that signal point interleaver 341 is provide even greater separation and could, therefore, included .w1thj~ trans*nitter in accordance with the potentially provide even greaser improvement in the Invention. FIrstly, it may be noted from Line HI that Viteebi decoding, Howevee, such improvement comes using the signal pointinterleaverwithoutthe distributed 10 ataptice--that pricebeinglacreased decoding delay-- trellis encoder--an arrangement not depicted hi the particularly as the number of trellis citcoders is indrawing--will, advantageously, cause the signal points creased beyond three. An engineering trade-offcan be made, as suits any particular application. from the same Channel symbol to be non-adjacent. Moreover, there is further advantage hi that a pair of Moreover. it is desirable for the signal point interchannel symbols processed serially by Viterbi decoder ~5 leaver to provide a sequence in which every NM signal stage 419a traverses the channel separated by five baud point In the interleaved signal point stream is the NM intervals rather than three, thereby providing greater signal point of a channel symboL (The reason this is decorrelasion of the noise components thereof. Corn- desirable Is described In detail heitlnbelow.) Inthe case pare, for example, ·the span of baud `intervals occupied of an N=2, four-dimensional signaling scheme, this by signalpoints X "and X ", X "ind X "iu Line land 20 means that every second, that Is "every other," signal 0 1 2 by 3 same signal the span of band Intervals occupied the point intheInterleaved stream is the second signalpoint points In Line III. Disadvantageously, however, theuse ofthe channel symbol front which ii cornea. In thecase ofa single trellis encoding stage brings back the probof an N~4,eight-dlnaepsional signaling scheme, this means that every fourthsignal point In the interleaved lent that the distributed trellis encoder solves, as tiescrIbed above. Thus, for example, although signal 25 stream is the fourth signal point of the channel symbol points Xo~ Xi", which are from the same channel from which it comes.. Indeed, this criterion is In fact and symbol,. are separated from one another when heaverssatisfied in the embodiment of FIG. 3. Note that each ing the channel, we find'that, disadvantageously, signal one of signal points Xo", x P, X 7, Xo", -.. which 2 4 points X2" and X " which are signal points from two appear as every other signal point In the interleaved 11 different channel symbols which will be processed see- 30. stream, Is the second signal point of one of the four.dially by the Viterbi decoder, traverse she channel adjamensional channel symbols. Note that not all rearrange. cent to one another. ments ofthe signal points will, in fact, satisfy this criteLine IV shows that using the signal point interleaver rioti, such as, if thetwo anal points ofa channel syin. with a two-stage trellis encoder--also an arrangement bol are separated by two, ratherthan three, baud internot depicted in the drawing--provides some improve- 35 vals. ment. Firstly, it may be noted that. as in Line III. signal Satisfying the above criterion is advintageous bepoints from the same channel symbol remain separated · cause it enhances the accuracy with.which phase trackby three baud intervals. Additionally, pairs of channel ing loop45lperforsnsIts function. This isso because the 5 symbols processed sequentially by a given Viterbi de- arrival of an N' signal point of a given symbol means coder stage--such as the channel symbols comprised of 40 that all the signal points comprisingthat channel symbol signal points Xo" and X ", Xe" and X~"--aretill nons have arrved. This, In turn, lakes it possible to form a 1 adjacent and, indeed, are now separated by seven baud decision as to the Identity of that channel symbol by intervals, which Is even greater than,the separation of using the niininmm accumulated path metric in the five baud intervals provided In Line ilL Moreover. Viterbidecoderstages. (Those decisionsare fed back to certain signal points that traverse the channel adjacent 4$ the tracking loopby decoder stages 419n, 419$ 419y on to one another and which arc from channel symbols leads 494,495 and 496, rcipectivChy, via switching cuwhich would have been decoded sequentially in the cult 456.) Without having received all of the signal one-trellis-encoding-stage case' are, In the two-trellis- points of a channel symbol, one cannot take advantage encoding-stage case of Line IV, processed by different of the accumulated path metric information but, rather, Viterbi decoding stages. Signal points X2~ X " are 50 must rely on the so.called raw sliced values, which is and 1 such a pair ofsignalpoints. Note, however, that, disadless accurate. By having every Nm signal point in the vantageously, signal points Xe" and X~" traverse the jut ricaved stream be the Nm slgn4l point of a channel channel serially, and are from channel symbols which symbol, We arc guaranteed that the