Free Remark - District Court of Delaware - Delaware

Case 1:07-cv-00402-GMS

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Case 2:06-cv-00369-TJW-CE Document 59-2 Case 1:07-cv-00402-GMS Document 23-24 Filed 06/28/2007 Page 1 of of 4 Filed 03/09/2007 Page 1 4

Exhibit 23

US2000 5490191 1

CM/ECF LIVE U S Distnct Court ded Docket Report 59-2 Case 2:06-cv-00369-TJW-CE Document 23-24 Filed 06/28/2007 Page 2 of of 4 Case 1:07-cv-00402-GMS Document Filed 03/09/2007 Page 2 4
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PATENT

U S District Court District of Delaware (Wilmington) CIVIL DOCKET FOR CASE #: 1:06-cv-00727-GMS
Rembrandt Technologies LP v CBS Corporation Assigned to Honorable Gregory M Sleet Related Case I 06-cv-00635-GMS Cause: 35:271 Patent Infringement Plaintiff Rembrandt Technologies LP represented by Steven J. Balick Ashby & Geddes 500 Delaware Avenue, 8th Floor P.O. Box 1150 Wilmington, DE 19899 (302) 654-1888 Email: sbalick~ashby-geddes.com LEAD ATTORNEY ATTORNEY TO BE NOTICED Lauren E. Maguire Ashby & Geddes 500 Delaware Avenue, 8th Floor P.O.Box 1150 Wilmington, DE 19899 (302) 654-1888 Email: [email protected] ATTORNEY TO BE NOTICED V Defendant CBS Corporation represented by Jack B. Blumenfeld Morris, Nichols, Arsht & Tunnell LLP 1201 North Market Street P.O. Box 1347 Wilmington, DE 19899 (302) 658-9200 Email: jbbefihing~mnat.com LEAD ATTORNEY Date Filed 12/01/2006 Jury Demand Both Nature of Suit 830 Patent Jurisdiction: Federal Question

Counter c~jaimant CBS Corporation represented by Jack B. Blumenfeld (See above for address) LEAD ATTORNEY

https ://ecf.ded.uscourts.gov/cgi-binlDktRpt.pl?778250667357481 -L_353_0- 1

3/2/2007

CM/ECF LIVE U.S. District Court:ded Docket Report Case 2:06-cv-00369-TJW-CE Document 59-2 Case 1:07-cv-00402-GMS Document 23-24 Filed 06/28/2007 Page 3 of of 4 Filed 03/09/2007 Page 3 4
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V. Counter Defendant Rembrandt Technologies LP represented by Steven J. Balick (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED Lauren E. Maguire (See above for address) ATTORNEY TO BE NOTICED

Date Filed 12/01/2006

#

Docket Text 1 COMPLAINT filed with Jury Demand against CBS Corporation Magistrate Consent Notice to Pltf. (Filing fee $ 350, receipt number 145541.) filed by Rembrandt Technologies LP. (Attachments: # 1 Civil Cover Sheet #2 Acknowledgement of Consent Form)(ead) (Entered: 12/04/2006)
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12/01/2006 12/01/2006 ____________ 12/04/2006
____________ ________

Summons Issued as to CBS Corporation on 12/1/2006. (ead) (Entered: 12/04/2006)

2 Notice ofAvailability of a U.S. Magistrate Judge to Exercise Jurisdiction (ead)
________

(Entered: 12/04/2006)

3 Report to the Commissioner of Patents and Trademarks for Patent Number 5,243,627;
(ead) (Entered: 12/04/2006) 4 SUMMONS Returned Executed by Rembrandt Technologies LP. CBS Corporation served on 12/4/2006, answer due 12/27/2006. (Maguire, Lauren) (Entered: 12/04/2006)
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12/04/2006 12/06/2006 _____________ 12/11/2006
_____________ _________

5 Disclosure Statement pursuant to Rule 7.1 filed by Rembrandt Technologies LP. (Maguire, Lauren) (Entered: 12/06/2006) ~ MOTION for Pro Hac Vice Appearance of Attorney John F. Sweeney, Joseph A. DeGirolamo, and Michael 0. Cummings filed by Rembrandt Technologies LP. (Maguire, Lauren) (Entered: 12/11/2006)
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12/13/2006 12/14/2006 12/22/2006
________

Case assigned to Judge Gregory M. Sleet. Please include the initials ofthe Judge (GMS) after the case number on all documents filed. (rjb) (Entered: 12/13/2006) 2 NOTICE of Change of Address by Steven J. Balick (Balick, Steven) (Entered: 12/14/2006) 8 Joint STIPULATION TO EXTEND TIME to answer complaint to January 26, 2007 filed by Rembrandt Technologies LP, CBS Corporation. (Blumenfeld, Jack) (Entered: 12/22/2006)
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12/28/2006
____________ ________

50 ORDERED, re 8 Joint STIPULATION TO EXTEND TIME to answer complaint to January 26, 2007 filed by Rembrandt Technologies LP, CBS Corporation. Signed by Judge Gregory M. Sleet on 12/28/06. (mmm) (Entered: 12/28/2006) Set/Reset Answer Deadlines: CBS Corporation answer due 1/26/2007. (mmm) (Entered:

12/28/2006

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____________

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12/28/2006) 9 MOTION for Pro Hac Vice Appearance ofAttorney Timothy E. DeMasi, Matthew D. Powers, Edward R. Reines, Anne M. Cappella and Sonal N. Mehta filed by CBS Corporation. (Blumenfeld, Jack) (Entered: 01/24/2007)
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0 1/24/2007
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0 1/25/2007

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SO ORDERED, re 9 MOTION for Pro Hac Vice Appearance ofAttorney Timothy E. DeMasi, Matthew D. Powers, Edward R. Reines, Anne M. Cappella and Sonal N. Mehta filed by CBS Corporation. Ordered by Judge Gregory M. Sleet on 1/25/2007. (asw) (Entered: 0 1/25/2007) SO ORDERED, re ~ MOTION for Pro Hac Vice Appearance of Attorney John F. Sweeney, Joseph A. DeGirolamo, and Michael 0. Cummings filed by Rembrandt Technologies LP. Ordered by Judge Gregory M. Sleet on 1/25/2007. (asw) (Entered: 01/25/2007) 10 ANSWER to Complaint with Jury Demand, COUNTERCLAIM and Affirmative Defenses against Rembrandt Technologies LP by CBS Corporation.(Blumenfeld, Jack) (Entered: 01/26/2007) 11 Disclosure Statement pursuant to Rule 7.1 filed by CBS Corporation. (Blumenfeld, Jack) (Entered: 0 1/26/2007) 12 ANSWER to Counterclaim by Rembrandt Technologies LP. (Attachments: # I Exhibit A# 2 Exhibit B)(Balick, Steven) (Entered: 02/15/2007)

0 1/25/2007

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________

01/26/2007
_____________ ________

0 1/26/2007
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02/15/2007

PACER Service Center Transaction Receipt
03/02/2007 09:32:34 PACER Login: Description: Billable Pages: ps0067 Docket Report 2
________ ________

Client Code: Search Criteria: Cost:

331049 _________________________ 1 :06-cv-00727-GMS Start date: 1/1/1970 End date: 3/212007 0.16 __________________________

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Case 2:06-cv-00369-TJW-CE Document 59-3 Case 1:07-cv-00402-GMS Document 23-25 Filed 06/28/2007 Page 1 of of 18 Filed 03/09/2007 Page 1 18

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IN TIlE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE REMBRANDT TECHNOLOGIES, LP, Plaintiff, v. NBC UNIVERSAL, INC., Defendant.

) ) ) ) )
) ) ) ) ) C.A.No. _______

COMPLAINT FOR PATENT INFRINGEMENT AND DEMAND FOR JURY TRIAL Rembrandt Technologies, LP ("Rembrandt"), for its complaint against NBC Universal, Inc. ("NBC" or ~Defendant"), alleges as follows:

PARTIES 1. Rembrandt is a lini.ited partnership organized under the lawsofthe State

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

having its principal place of business at 30 RockefellerPlaza, 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. §~ 1331 and 1338(a).

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4.

This Court has personaljurisdiction over NBC. 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 cothmitted 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. 5,243,627 6. Rembrandt realleges and incorporates hereinby reference the allegations Venue is proper in thisjudicial 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 annexedhereto as Exhibit A. 8. Rembrandt is the owner ofall right, title and interest in the `627 patent,

with the right to sue, enforceand recover damages for infringement. 9. NBC operates television systems and provides television services

throughout the United States.

2

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10.

Defendant has directly or indirectlyinfringed the `627 patent, and is

continuing to do so, by practicing the inventions claimedtherein, and/or by inducing or contributing to the practice by others ofthe inventions claimedtherein, in this judicial 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 irreparabledamage unless this Court enjoins Defendant from continuing its infringementunder 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 of reasonable 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) an award ofdamages;

3

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(4) (5)

an award of increased damages pursuant to 35 U.S.C. § 284; an award of all 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 a jury trial on all issues so triable. such other and further relief, at law and in equity, as the Court deems just

ASHBY & GEDDES

4~4~

Steven J. thrlidc (LD. #2114) John G. Day (LD. #2403) LaurenE. Maguire (I.D. #4261) 222 Delaware Avenue, 1 7th Floor P.O. Box 1150 Wilmington, DE 19899 (302)654-1888 sbalick~ashby-geddes.com jday~ashby-geddes.com lmaguire~ashby-geddes.com Attorneysfor Plaintiff

OfCounsel: John F. Sweeney Joseph A. DeGirolamo Michael 0. Cummings MORGAN & FiNNEGAN, LLP 3 World Financial Center NewYork, NY 10281-2101 Telephone: (212) 415-8700 j sweeney~morganf Innegan.corn jdegirolamo~ morganfinnegan.corn mcummings~morganñnnegan.com Dated: December 1, 2006
175611.1

4

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EXHIBIT A

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liftI 011111111 1 1 1 1111111111 lUl 1111111 1 1 1 1 11111111111II!11 1 li i
United States Patent
Betts et a!.
f~4] SIGNAL PoINT INTERLEAVING
US005243627A

(19]

[Ii]
[45] [56)

Patent Number: Date of Patent:
References cited

5,243,627
Sep. 7, 1993

~IIMQUE

u.s. ~*~r~r DOCUMENTS
3,988.677 10/3976 fletcher Ct a) _.._. 373/45 X 4,945,549 7/1990 Simon et *1. .........._...-...... 375/53
~,O29,185 7/199~Wd
.___........._..............

(751 Invencoro William L. Befts, St. Petersburg;
· (7.3J, Aasignee~ AT&TBellLaboratoiies,Muzuy · (21] AppL No.~748,594 [22] Filed: Aug. 22, 1991
__. .........

375/39 X

Axambter-TesfaldetBocure 4uonze~ 4gern~ finn--Ronald D. Slusky Gerard A. or
defliasi [57] ABsrRAcr Vizerbi decoder perfonnancc in a data communication system using 2Nihnensional channel symbols N> I can be Iurthe enhanced by an interleaving technique which uSes a distxibuted trellis encoder in combination with a signal point interleaver. 24 (Iahns, 4 DrawIng Sheets

[51). InS. CL'
(51]

1104L 5/fl

375/39; 375/6Q~ 375/99; 60, 99 [58] Field of Search ........,.........,.... 375/39, 58, 371/43 371/43, 37.5, 2.~, 5; 341/81 4

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U.S. Patent

·

Sep. 7, 1993

Sheet 1 of4

·

5,243,627

FIG~1
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·

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INDEX VALUES

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Case 2:06-cv-00369-TJW-CE Document 59-3 Case 1:07-cv-00402-GMS Document 23-25 Filed 06/28/2007 Page 10 of of 18 Filed 03/09/2007 Page 10 18

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U.S. Patent
· ·

Sep. 7, 1993

Sheet 4

of 4

5,243,627

FIG.5
40 40 40.40 4041) $YV8~SYMBOL SYMBOL SYMBOL SYMBOL SYMBOL NOT INTERLEAVED ~a va~.,a~ a11 a ~ra ~jlrj~ ONE TREUJS STAGE A~ *~ *2 X *~ X X X X X X 3 5 6 7 5 9 10~·· NOT INTERLEAVED Xa.Xa ~P ~v~i Xa ~ ~ ~ XP THREETRELUS~TAGEs 01234 5.6 18910 · INTERLEAVED ONE TREWS STAGE INTERLEAVED Th'O TRELLIS STAGES INTERLEAVED THREE TREWS STAGES Xa Xa Xa Xa ya ~,u ,~u ~a ~a Xa 0 --l 2 1 4 "3 "6 "5 "8 7 "10 Xa X~ X~Xa XU XP X~Xa Xa Xp X~ 0 --1 2 1 4 3 6 5 8 7 10 a 7 p ~ a 7 a 7 X0 X1 X2 ~ X4 X3 X6 X5 X8 X7 X10...
·

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1
·

5,243,627
·

2

· ·
·

SIGNAL POINT INTERLEAVING TECHNIQUE

·

·

·

·

·
· ·

BACICOROUN]) OF THE INVENTION The present Invention relates to the transmission of ~ ~" ~ with the present invention, It has becn digital dat, over baud-limited ~ · realized that the Viterbi decoder performance in a data Over the years. the requirements of niodern.day ~ connnnnication s3'slem using 2N.dimensional channel tal data Itansinimion over band.limiced channels--such symbols can be further enhanced by an interleaving as voiceband telephone channels--have resulted in a tecluwiue which uses, in combination, a) the aforemenpush for higherand higher bit rates. This push hasled to ~ honed distributed trellis encoder/Viterbi decoder techthe development and introduction ofsuch innovations niqueand b)a signal point interleavingtechnique which causes the constituent signal points of the channel symas adaptive equahzauon. mUItl-dunenstOnal signal Con- bols to be non.adjaccnt as they traverse the chanjiel. iteRations, echo cancellation (for two-wire applica'. lions), and tr~flis oding. Today, the data ratesachieved c ~ Prefet~edeznb0dinieuts f the Invention, the intero 15 using these and other techniques are beginning to apleaving iscarried put in such away thateverychannel is point in the signal pointstream traversing the Nthsigual proach the theoretical lii~~ the.Nth signal point of a respective one of the channel It has been found that various channel impairments. symbois. This criterion enhances the accuracy with whoseeffects on the achievable'bit rate were relatively w~icl, phase tracking loop in the receiver performs the minor compared to, say, additive white Gaussian noise ~ function. and linear distortion, have now become ofgreater cofl Also in preferred embodiments, we have found that cern. These include such impairments as nonlinear ~ ~ use of three ~aral1elrellis encoders in conjunction t 1~ tuition and residual (i.e., uncmpensated-lbr) P with a signal point interleaving regime in which the jitter. Such finpainnents are particularly irksome in systems which use trellis coding. Indeed, it has been 25 one another by three signaling intervals (bands) profound that the theoretical Improvement in Gaussian noise humunitypromised by at least some trellis codes is not realized in real.world applications where these inspainneuts are manifest The principal reason this is so appears to be that the noisecomponents introduced into ~ the received signal samples are such as to worsen the diectiveness ofthe Viterbi decoderused in the receiver to recover the transmitted data. US. Pat. No. 4,677,625. issued Jun. 30, 1987 to Betts et a), teaches a method and arrangement In which. ~ through the use ofa distributed trellis encoder/Viterbi decoder, the effects of many of these lmpairtsents ~ be reduced. The pivention in the Betts et alpatent recognizes that a part of thereason that the performance of the Viterbi decoder isdegraded by these impairments is 40 the fact that the noise components of channel symbáls ·whicb closely follow one another in the transmission channel are highly correlated for many types of impairsnout. And it is that correlation which worsens the effect that these impairments have on the Viterbi de-45 coder. Among the impairments whose noise is correhoed in this way are impulse noise, phase "hits~' nd a gain "bits." AU ofthese typically extend over a number ofadjacent cbadnelaymbols in the channel, and thus all · result in channel symbol noise components which are so highly correlated The well-known noise enhancement an optimum or neax.optimum tradeoff between ~igus1 point/channel symbol separation and the decoding delay that is caused bythe interleaving. BRIEF DESCRIFFION OFTHE DRAWIMG In the drawing. FIG. 1 isablock diagram ofthe transmitter section of ~ modem HG. 2 is shows a signal constellation used by the tzammiuer ofFIG. 1; PIG. 31s a blockdiagram ofthe transmitter section of a modem employing (our~disnensionalchannel symbols and embodying the principles of the invention; PIG. 4 Isa block diagram ofthe receiversection of a modem embodying the principtes of the invention which processes the received four-dimensional channel SYinbOIS generated by the tnnsmitter ofFIG. 3; PIG. Sit asignal point timing/sequencing chart help. ful in explainingthe principles ofthe present invention; PIG.6ianalpointinterleaverwbichcanbeused in the transmitter of· FIG. 3 to interleave the signal points ofeight-dimensional channel symbols; and FIG. 7 I~ signal point deinterleaver which can be a usedin the receiver of FIG. 4 to delnterlesve the signal points of elght.dimeusional channel symbols.

pairs is reduced from whet it would have otherwise been. SUMMARY OF THE INVENTION

·

·

·

·

DETAILED DESCRIPTIQN characteristics o linear equalizers also induce coreWed noiselit adjacent channelsymbols, as doesuncomPIG. I depicts the transmitter section ofa prior art pesisated-for phasejitter.Also, the occurrenceofone of modem employing a 2N-dlsnensioual signaling scheme, the relatively high powerpoints of the signal cpnstefla- 5~ N~.l.The modem receives input Information in the tion can, in pulse code modulation (PCI~f)ystems, for · form ofa serial bitstream from data tenninal equipment s · example, give rise to noise on adjacent channel symbols (DTE) flI--.illusuatively a host computer. That bit which, again, Is correlated. · stream is thentcrambled, orrandosnlzed,byrandomizer The Betts eta) patent addressesthis issue by disuibut113 whose output bits are provided in serial form to lug theoutgoing data to a plurality of trellis encoders in 60 serial-to-parallel (SIP) converter 115. round-robin fashion and interleaving thetrelils encoder Serial-to-parallel converter 11$, in turn, provides, outputs on the transmission channeL In thereceiver, the during each of * succession of symbol Intervals (coinstream of received Interleaved channel symbols is curprised of N baud intervals), some predetermined numrcspondiu~ly distributed to a plurality oftrellis decod- bar of parallel bits on lead 109 and some number of em Since the successive pairs o(cbannel symbols ap.. 65 parallel bits on lead 108. (Ii will be appreciated that plied to a particular trellis decoder are separated from whenever bits are provided in parallel in the modem,

lion another as they traverse the these channelcorrelsone of the noise components of channel, the symbol

The bits on lead 109 are appliedcarry each of theUPcr, separate leads are required to to trellisencoder bits-)

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and arc referred to as the "trellisbits." The bits on lead Those two signal points are thereupon communicated 108 are applied to modulus converter 116, and arc re- · over Ike chaitnel by QAM encoder 124 and modulator ferred to as the "wicoded bits." 128 as described above. To better understand how trellis encoder lIPtx and Note that~Implementadoually, the 2N-dimensional modulus converter 116 work, reference isxnadc to PIG. S channel symbol Is genea*ted by having the trellis en2. which shows the two-dimensional signal constellacoder identil~p,Interdependently, N subsets of the twodon that formsthe batla ofthe 2N-dimensional signaling dimensional constellation of FIG. 2, then select a twoscheme Illustratively used by the modem. This consteldimensional signal point from each of the subsets thus lation is comprised of 32 signal points, which are diIdentified. The concatenation ofthe N two-dimensional vided into foursubsets, A through D,each comprlsód of 10 signal points thus selected is the desired 2N-dimensional eight signal points. The eight points of subset A are channel symboL This process, howevet, can be underexplicitly labeled asA~ throughA7. It maybe noted that stood as involving the direct selection of a 2N-dimensubsets C, B and I) can be arrived at by clockwiserota- sionalchannel symboL Viewed in-this context, the act of · don of subset A by 90. 180 and 270 degrees. respec- all possible combinations of N of the two-dimensional tlvcly. (Conventional differential encoding circuitry 15 subsets identified by N successive trellis encoder outwithin trellis encoder 119a exploits this symmetry.) For puts can be understood to be a set of 2Nditnenslonal reference, a single signal point ofeach ofthose subsets subsets of a 2N-dlinensional constellation, the latter · is alio shown tin FIG. 2. · beingcomprised ofall possiblecombinations ofNofthe Consider~ first, the case of N~=, i.e., a two-dinien- signal points of the two-dimensional constellation. A 1 sional signaling scheme. In this case, one trellis bit on 20 successionofN outputs from the trellis encoder Identilead 109 would be expanded so two bits by trellis en- · flesaparlicularoneofthe2N-dumcnsional subsets anda coder 119a on lead 121. The four possible values of succession of N outputs from the modulus converter those three bits 00,01,10, and 12 identlf~pubsets A, B, s selects a particular 2N-dimensional signal point from C and D~ respectively. The successive 2-bit-words on the identified 2N-dixnensional subset lead 121 are represented as a , n=0,l,2. . .,where nit 25 Modulus converter 116 is Illustratively of the type 5 an index that advances ~ the baud rate. At the same disclosed in co-pending, commonly-assigned -U.S. patints, three parallel bits would be provided on lead 108. tens application 8cr. No. 588,658 flIed Sep. 26, 1990 and These are converted by modulus converter 116 Into an allowed onMay 21, 1991, herebyincorporated by referindex having a value within the rangc (decimal) 0107. ence. Modulus converter116 provides the modem with The index value, represented in binary form on lead 30 theability to support data transmission atvarious differ117, selects a particular signal point from the subset entbit rates. Assume, forexample,that the rateatwhich identified on lead 121. Thus if lead 121 carries the two bits are provided by DTE UI detireases. 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 10$ and 109 at the same baud rate as before. 1 selected. The words on leads 117 and 121 are applied so 35 However, the upper lImit of the range of index values QAM encoder 124 which generates, on lead 125, values that are providedbymodulus converter 116 on lead 117 representing the-I (in-phase) and Q (quadrature-phase) will be reduced, so that, effectively, each of the four componentsof signal point Ai. The signal point gener. subsets A through D, Instead of having eight signal 5 ated on lead 125 in the n' baud interval is denoted X~, points, will have some smaller number. Conversely If which is passedOnto modulator 128 to generate a pass- 40 the rate at which bits are provided by DIE 111 should band line signal which is applied to the conimunication increase over that originally assumed, the upperlimit of channeL The superscript, a, Indicates that the trellis the range ofindex values, and thus the numberofparalencoder that was used to identify the subset for any Id bits,that appear onlend 117 will be increased beyond particular signal point was trellis encoder119a. That is, eight and the constellation itself will be expanded to of course, a trivial notation as far as P10.1 goes Inns- 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 in-the modem. However, it is wieful to introduce this converter, fractional bit rates can be supported using, notation because more thanone trellis encoder stage is forexample, thetechniquedisclosed in L Wel, "Trellisused in preferred embodiments of modems Incorporat. Coded Modulation v.4th Multidimensional Cosistdflaing the principles of the present invention as shown in 50 lions," IEEE Traan on Commrrnlcatlon Themy, VoL later PIGS. · 11-33, No.4, July 1987, pp. 483--501. In the case of N>1,the operation Issimilar. Now, TuruingnowtoPlG.3,thetraosmltterportionofa however, the wonls on lead 109 are used by trellis en- modem embodying the principles of the invention is coder 119a to sequentially Identify on lead 121N sub- shown. This embodiment Illustratively uses the aforesets,whlle thewordson lead 108 sic 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 arc the component signal shown in FIG. L'Thus, in particular, thetransmitter of points of a 2N-dimensionaj channel symbol, the fl~st FIG. 3--which receives its input Information In the such symbol being comprised of the signal points Xoa. form ofa stream ofinput bits from DIE 311--Includes . -X~. ~.For example, a modem in which the trans. 60 randosnizer 313, whIch supplies its output, on lead 314~ mitterofFlG. 1-could beused maybea 14,400bltper toS/Pco~vener315.The1atteroutputsuncodedbitsto second modem using four-dunenuonal coding (Ic, modulus converter 316 The transmitter further ni N=2) and.a band rate of 3200. In this case, nine bits dudes four-dimensional QAM encoder 324 and modnfrom S/P convertcr 115 are used for each four-dimen- lator 328. The trellis bits, on lead 309, are provided not sional symboL Specifically, three parallel bits on lead 65 to a standard single trellis encoder, but to a distributed 309 are expended into four bits on lead 121 to Identify a trellis encoder comprised ofthree trellisencoder Stages. pair of subsets while six bits on lead 108 are used to trellis encoder stage 319a, trellis encoder stage 319$, select particular signal points from those two subsets. and trellis encoder 5tage 319)'.

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Such a distributed trellis encoder, which is dcscnbed the opposite function to interleaver341 in the transmitIn 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 so", Z"~ ~#, Z; Z; X ",. . . , etc. (Although ~ 6 In response to-respectiveportions of theinput Informa- not explicitly shown in the drawing, the saint welltion. Specifically, a three-bit word on lead 309 is sup- S known techniques used in modems of this general kind plied to trellis encoder stage 319a. The next three-bit to identify wIthin the stream of received signal points word on lead 309-is supplied to trellis encoder stage the bounduies between successive symbols is used to -319g. The next three-bit word Issupplied to trellis en- synchronize the operation of signal point deinterleaver coder stage 319y. and then back to trellis encoder stage 441 to ensure that received signal points Xc's, X P, X~v 2 319a. 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 points Xi~~ ~ -. arcapplied to lead 4412) ~ 331 operating under the control of symbol clock 325. The received signal points on lead 442 arc then disTheinitial data word outputs ofthe trellisencoders are tributed by swltchi~gcircuit 431 under the control of subset identifiers no and at for encoder stage 319a, $2 symbol clock 425 to a distributed Viterbi decoderconsand $~ encoder stage 319$, and y4 and ~ for en- 15 prised of 41) VitetbI decoder stages 419a, 419/3 and for · coder stige 319)~,followed by a6 and U~for encoder 419y. Specifically, received signal 9 4 pants ~ and Z" stage 319a, snd to-forth. These are supplied to four..di- are app!ied to decoder stage 1 e, received signal 0 mensional QAM encoder 324 by switching circuit- points ~ and Xa are applied to decoder stage 419$; 337--also operating under the control o(sysnbol clock and received signal points ~7 and 1~~i applied to arc 325--on lead 338 hrough a one-symbol delay 364 and 20 decoder stage.40y. The outputs of the three decoder lead 363, in orderto compensate for aone-symbol delay stages arethencombinedinto a serial Streamon Lead 438 caused by modulus converter 316. Thus,,the stream of by switching circuIt 437. also operating under the consubset identifiers onlead 338 is no, a~, $~. ys. a~ trol of symbol clock 425. Those outputs, representing $2. ~4. .. . . . Using the notation introduced above, then, the decisiosta as to thc,valj2esofthe~transmittedsignal outputofencoder324onlead325isthestreamof.slgnal 25 poInts, sredenotedXo,X1,X2.X3,X4,Xs,X~....,the pointsXoe, ~ X,$, ~ x~X'v, Xe'. . . ,which is a, /3 and y superscripts-no longer being needed. comprised of three interleaved streams of trellis enIn conventional fashion, the bits that represent each - coded channel symbols, these streams being X~X a, of thedecisions on lead 438 can bedivided into bits that 1 X X~°, , X~... ; Xis, X3P, x P, Xg~, jiP - . - ; and X represent a) the trellis bits that appeared on transmitter 6~ X~Xgt, ~ X 7, Xitl. . 1 . These, in turn, are 30 lead 309andb) the index values that appeared on trans. 11 supplied, in accordance with the Invention, to signal niftier lead 317. Those two groups ofbits are provided pointinterleaver 341 which applies alternate ones ofthe in the receiver on leads 461 and 462, respectively. The signal points applied thereto to lead 3412--whichsignal latter groupofbits are decouverted by modulus decon- points appear Immediately at the interleaver output on valet 416 (also disclosed in the aforementioned `658 lead 342--and to one-symbol (Z.-.1) dday element3411, 33 patent application) back to uncoded bit values on lead which appear on lead 342 afterbeing-delayed therein by -414. The operation of the modulus deconverter imparts one symbol intervaL The resulting interleavedstreamof a one-symbol delay tothe bits on lead 414. Accordingly, trellis encoded signal points is X c, X_ X~$, is, X the bits -on lead 461 are caused to be delayed by one X~313$, X~X 7, 3C~P, t~ 0 X9$. 1- (the signal X Xi~7, . symbol by delay element 46& The resulting combined 5 ofcourse, the signal point applied-to 40 bits on lead 415 thus represent the stream of bits that pointX.i7 being. interleaver 341 just ahead of signal point Xe). appeared at the output -of randoznizer 313 in the traiisA discussion and explanation ofhow theinterleaving mutter. These are derandomized in the receiver by just described is advantageous is set forth hereinbelow. derandomizer 413 and the resulting derandomized bit In order so fully set thestage for that explanation, how- stream Is applied so DTE411 which may be, for exam.ever, It will be first useful to consider the receiver sec- 45 plc, a computer terminallion of a modem which 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, the line signal transmitted Line Ishows thestream of output signal points generby thetransmitter ofPIG. ~is received from the chan- med and launched Into the channel using onestage of nd and applied to demo lulator/equalizer 455 which, in 50 trellis encodingand no lignal point Iflterlesviug. This Is, conventional fashion--includIng an input from phase of course, the prior art arrangement shown In FIG. 1. tracking loop 457--generates a stream of outputs on lAne U shows the effect of providinga three-stage duslead 456 representing the demodulator/equalize?s best tributed trellis encoder but still no signal point Interapprctxhnatlon ofthe valuesof the-I and Q components leaving.This lathe arrangementshown intheaforesnenofthe ilgnal points of thetransmitted Interleaved signal 55 tioned Betts et 4 patent. Note that the signal points of point stream. These outputs sri referred to hereinas th~ each channel symbol operated on by a particular treljis "received signal points."-(Due to distortion and other encoder stage are adjacent In the output sips1 point channel Impairmentsjhat the demodulator/equalizer is stream. For example, the second signal point of the not able to compensate for, theI and Q components of symbol Xo~ X~--name)ysignal point Xie~~is sepathe received signal points, insteadof having exact lute- 60 rated by five baud intervals from thefirst (closer) signal ger values, can have any value. Thus a transmitted point ofthe symbol Xa'X,"~--namdysignal point Xe". signal point having coordinates (3, --5) may be output As noted earlier, such separation is advantageous beby the demodulator/equalizer as the, received signal cause the ch*incl symbols which are processed one point (2.945, --5.001).) The stream of received s1~ial after the other In a particular Viterbi decoder stage points on lead-456 is denoted.~, ~ ~ X~65 have noise components which are not highly correZ"~ X8$, X,', ~ioY. - -. ~s7, Xg$. lated. The successive received signal points are deinterNote, however,, that the individual signal points of leaved in signalpoint deinterleaver 441, which provides each channel symbol, e.g., Xe"and Xi", are adjacent to

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one anotheras they passthrough thechannel; and since signalpoints Xo"and X 0, Xt"and -X~"---are ow sepan 1 all the signal points of a channel symbol must be prorated 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 must 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 chartnerns.. eel 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 within the transmitter In accordance with the potentially ptovicIe even greater improvement in invention. Firstly, it may be noted from Uric Ill that Viterbi decodin& Eowevm, such improvement comes using thesignal pointhiterleaver witboutthe distributed 10 atapsice--that pricebeinglncreaseddecoding delay-- trellis encoder--an arrangement not depicted In the particularly as the number of trellis encoders is indrawing--will, advantageously, cause the signal points creased beyond three. An engineering trade-offcan be from the same channel symbol to be non-adjacent. made, as suits any particular application. Moreover, there is further advantage hi that * pair of Moreover, ic is desirable for the signal point interchannçl symbols processed serially by Viterbi decoder 15 leaver toprovide a sequence In whiclIevaty N~ 5 signal stage419cr traverses thechannel separatea by five baud point lit the interleaved signal point stream is the N' - intervals rather than three, thereby providing greater signal point of a channel ayuiboL (The reason this Is decorrelation of the noise components thereol Corn- desirable Isdescribed in detail hethinbelow.) Inthe case pare, for example, the span of baud -intervals occupied of an N=2. four-dimensional signaling scheme, this by signalpoints Xo"and X "~ X~"and "in Line I and 20 means that every second, that is `every other," signal X 1 3 same signal - pointin theInterleaved stream is thesecond signal point the span of baud intervals occupied by the points In Unc III. Disadvantageously, however, the use ofthe channel symbol from which it comes. In thecase of a single trellis encoding stage brings back the probof an Na'.4, eight-dimensional signaling scheme, this lem that the distributed trellis encoder solves, as demeans that every fourthsignal point in the interleaved scribed above. Thus. for example, although signal 25 stream is thefourth signal point of the channel symbol points X~fnd Xi", which are from the same channel froin which it comes.- Indeed, this criterion is In fact a symbol,- are separated from one another when traverssatisfied in the embodiment of FIG. 3. Nate that each jug-The channel, we flndthat, dIsadvantageously, signal one of signal points Xe", X3$, X 1, X6", - . - ,wbich 4 points X" and X °, which are 4na1 points from two appear as every other signal point In the interleaved 1 different channel symbols which will be processed scri- 30. stream, Is the second signal point of one of the (our-di. ally by the Viterbi decoder, traverse the channel adja- menslonal channel symbols. Notethat not all rearrangecent to one another. men's ofthasignal points will, in fact, satisfy this criteLine IV shows that using the signal point interleaver non, such as, ifthe two signal points ofa channel syrnwith a twa-stage trellis encoder--also an arrangement bol are separated by two, ratherthan three, baud internot depicted in the drawing--provides some improve- 35 vais. merit Firstly, it may be noted that, as in Line IlL 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 loop 457performs Its function. This isso becausethe symbols processed sequentially by a given Viterbi dearrival of an N'~ signal pOint of a given symbol means - coder stage--such as thechannel symbols comprised of 40 that all the signal pointsoo~~gthat channel symbol signal points X~4 X ", X" and X~"--aretill non- have arrived. This, in.hiui, rñakes it possible to form a and s 1 adjacent and, indeed, are now separated byseven baud decision as so the Identity of that channel symbol by intervals~ which is even greater thauthe separation of using the minimum accumulated path metric in the five baud intervals provided In Line ilL Moreover, Viterbidecoder stages. (Those decisions arcfed back to certain signal points that traverse thechannCl adjaCent 45 the tracking loopby decoder stages419a, 419fl419y on to one another and which are from channel symbols leads 494,495 and 496, reipectivély, via switching dr. which 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 ofLine IV, processed by different ofthe accumulatedpath-metric Information bus, rather, Viterbi decoding stages. Signal points X3$ and Xj"are so must rely on the so-called raw sliced values, which Is such a pair ofsignal points. Note, however, that, disail. less accurate. fly having every Nit signal point in the vsnsageously, signal points X " and X~"raverse the interleaved stream be Ike N~ t signal point of a channel channel serially, and are from1channel symbols which symbol. tve are guaranteed that the time between adjaareserially processed bythe "a" Viterbi decoderstage. cent such path metric "decisions" supplied to the phase bferring, however, to Line V, which depicts the 55. tracking loop Is, advantageously, never more than N streamofsignalpoints output by the transmitter ofFIG. baud intervals. -3,11 wIllbe seen that, in accordance with the Invention, The foregoing merely illustrates the principles ofthe there Isstills non-adjacency--indeed, a separation ofat Invention. Thus although the Illustrative embodiment least three baud lntervalr--between a) the signal points utilizes a four-dImensional signaling scheme, the invertwhich belong winy particular channel symbol (and 60 iron can be used with signaling schemes of any lumenwhich, therefore, are processed serially by a particular sionality. In the general, 2N.dimenslonal, case each - Viterbi decoder stage) and b) the signal points which stageofthe distributed trellis encoder would provide N belong to channel symbols which are processed serially - two.dimensional subset identifiers to switching circuit by a Vlserbi decoder-stage. Thus,- for example, signal 337before the latter movesonto the next stage. And, of points X " and X Y ar~now processed by dIfferent 65 course, each stage of the distributed Viterbi decoder 1 4 Viterbi decoder stages. Moreover, pairs of channel would receive N successive received signal points. The symbols processed sequentially by a given Viterbi dedistributed trellis-encoder ~nddistribptedVitett'i decoderstage--such as the channel symbols comprised of coder can, however, continue to include three trellis

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encoders and still maintaIn, Independent ofthe value of although not explicitly shown-ordescribed herein, emN, a separation of three baud intervals in the channel body the principles of the invention and are within its between signal points that are front channel symbols spirit and scope. that are adjacenthi the trellisencoder. Ifs grcater:sepaWe claini ration ofauchaignal pointsisdesircd,morestagescan 5- 1.Apparatus forformingastreamo(trellisencoded be added to the distributed trellis encoder/Viterbi sic- signal points Inresponse to input Information, said appacoder, just as wasnoted above for the four-dimensional talus comprising -cue. However, when dealing with 2N-dlmenslonal means for generating a plurality of streams of trellis signaling where N>2, it Is necessary to add additional encoded channel symbols In responseto respective delay elements to the signal point interleaver/debster- 10 portions of said input Information, each of said leaver in order toinaintalu a three-baud-interval separachannel symbols being comprised of a plurality of zion among the signal points from any given channel sIgnal pOInts~and symbol. means forInterleaving the signal points of said gauntConsider, forexample, theeaseofN=4, ic, aneightated channel symbols to form said stream oftrellis dimensional case. Looking again at FIG. 3, the three IS encoded signal points, said-interleaving being car(8D) stages of the distributed trellis encoder, would riedoutinsucbawaythatthcslgnalpointsofeach generate thethree streams ofsubset identifiers do as a~ channel symbol are non-adjacent In said stream of a3a12...,P4P5P6fl7P16...,andysysylo7Izylo. trdlisencodedsjgnslpolntsandsucbthatthesig- . , respectively. This would lead to the following na! points of adjacent symbols in any one otuld - attests of signal points of eIght-dimensional trellis en- 20 channel symbol streams ste non-adjacent in said coded channel symbols at the output of the QAM enstream of trellis encoded signal points. coder on lead 325 ~ X X~ x P X P Xt~ 0 X~ X 2. The apparatus of claim I wherein said means for 1~Signal point interleaving 4 5 7 Xi" X91'X 7 Xii" Xii".. . generatinggenerates three ofsaid streams of trellis en- 10 could be carried out by substituting signal point Intercoded channel symbols, and wherein said means for leaver 641. of FIG. 6for interleaver 343. Interleaver ~5 interleaving causes there to be interleaved between 641, in addition to direct connection 6414, Includes each o(thesignal points ofeach channelsymbol at least one-1 two-, and three-symbol delay`elements 6413.6412 two signal points from other channel symbols of said · and 6411, respectively, streams of trellis encoded channel symbols. - The signal points on lead 323, 4fter passing through 3. The apparatus of claim I wherein said channel interleaves 641. would appear on lead 342 in the follow- 30 symbols are IN-dimensional channel symbols, N>1, ing order; IC " X_3Y X_~B X~xB Xi" X_ V X_~l~ and wherein said means for interleaving causes every 1 X v X X "0X...i" X "X~v x e X 69 X " X101 saidInterleaved signal pointstream to 5 .~ 2 signal points with negative1 5~ 12 Xis 3 subscripts are, Nthsignal pointinpoint ofa respectIve one of said chin13 X,$. where be the Nth signal ofcourse, signalpoints that arrived before signal point rid symbols. - Xtfand were alreadystored In the delay elements 6(11,35 4. The apparatus of claim 2 wherein said channel - 6412 and 6(13. Examination of this signal point stream symbols are 2N-dimensiooal channel symbols, N)!, will reveal that there Is either a three- or five-baud and wheiein said means for Interleaving causes every separation between signal points of channel symbols Nthsignal point insaid Interleaved signalpoint streamto that are processed sequentially by the same trellis enbe the Nmsignal point of.a respective one of said chancoder stage, eg~, e And X f; that adjacent signal 40 nd symbols, X 3 1 e.g., Xrj'and X~°, points of any one channelsymbol, are 6. A modem comprising separated by fivebaudintervals, and that thefoursignal means for receiving a stream ofinput bits, - points comprising any particular one channel symbol means for dividing said stream of input bits into a arc separated by fifteen baud Intervals. streamofuncoded bits and a plurality otatreanisof FIG. 7 showsthe structure ofa deinteijeaver 741 that 45 trellis bits, could be used In the receiver ofFIG. 4 in place of dein- - means for independendy trellis encoding each ofsaid terle*vr 441 in order to restore the signal points of the plurality of streams of trellis bits to generate xcelght-dimAnslonal channel symbols to their original spectivestreams ofdata wordseach identifying one order; Tins structure, which Is theinverseofinterleaver of a plurality ofpredetcrmlncd subsets of the ciran641, Includes delay stages 7411,7412 and 7413, as well 50 sic! symbols of a predetermined ZN-dimensional as direct connection 7414 constellation, N being an integer greater than `It will-be appreciated -that, although various cocipounJty, each of said channel symbols being cornrents of the modern transmitter and receiver are dii·psIsed of a plurality ofsignal points, closed herein for pedagogic clarity as discrete tunic- means for selecting an individual channel symbol donal- elements and indeed--In the case of the various 55 from each Identified subset In response to said switching circuits--is mechanical elements, those stream ofuncoded bits to (cnna streamofchannel ikulled in the art will recognize that the function ofany symbols, and one or more of those elements could be implemented meansfor generatinga stream ofoutput signal points, with any appropriate available technology, including said signal point stream being comprised of the one or more appropriately programmed processors, 60 signal points of the selected channel symbols, the digital signal processing (DSP) chips, etc~ example, -For signal points of'said signal point stream being se- multiple trellis encodez~and decoders can be realized queried in such a way that signal points that are using a single program routine which, through the either a) part ofdiesamechannelsymbol, orb) part -mechanism of indirect addressing of multiple arrays ofchannel aynrbolsthat arcadjacent to oneanother within memory, serves toprovide the function of each 65 in said channelsymbol stream, are separated In said ofthe multIpiC devices. output stream by at Least one cthçr signal point · 1* will thus be appreciated-thatthose skilled in the art 6. TIre apparatus ofchin 5 wherein saidtrellis encodwill be able to devise numerous arrangements which, lug means -Includes a plurality of trellis encoder stage

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means for trellis encoding respective - ones of said the NIh signal point ofa respective oneof said channel streams of trellis bits. symbols. 1. The apparatus of claim 5 wherein said means for 14. -The method of claim 12 wherein said channel selecting includes means for modulus converting said symbols are 2N-dimcnsional channel symbols, N) I, scream ofuncoded bits. S and wherein said interleaving step causes every NM 6. The apparatus of claim S wherein said channel signal point insaid interleaved signal point stream to be symbols are 2N-dirnenslonsl channel symbols, N>!, the NIh signalpoint of a respective one of said channel and whereinsaid means for generatingcauses everyNM symbols. · signalpoint in said stream ofoutput signal points to be 1$. A method (or use ins modem~said method cornthcNth signal point- ofa respective one of said channel 10 prinng the steps of symbols. receiving a stream of input bits, 9. Receiver apparatus for -recovering information dividing said stream of input bits into a stream of from a received stteazn of trellis encoded signal points, - uncoded bits and a plurality of streams of trellis - :addsignalpoinuhIngbcentra~itwdtoadare~ cehier apparatus by transmitter apparatus which gener- ~ independently trdlis encoding each ofsaid plurality ates said -signal points by generating a plurality of of atreanis- of trellis bits to generate respective streams of trellis encoded channel symbols in response streams of data words each Identifying one of a to respective portions at said ~ ~1i or~ai~ plurality of predetermined subsets of the channel channel symbols being comprIsed ofaplutilityofsignal symbols of a predetermined 2W-dimensional con10 points, and by interleaving the signal points said stelladon, N being an Integer greater than unity, generated channel symbols to form said stream ottrellis each of said channel symbolsbeing comprIsed ofa encoded signal points, said interleaving being carried ~ibt~ of signal Points, out in such away that the signalpoints ofeach channel 5~laCthi5an individual channel symbol from each symbol are non-adjacent in said stream of trellis enidentified subset in response to said stream of Uncoded signal -points ad such that the signal points of ~ i~ bits to form a stream of channel symbols. adjacent symbols in any one of said channel symbol generatinga streamofoutput sIgnalpoints, saidsignal streams are non-adjacent In said stream of trellis en~ point streambeing comprisedo(thesignal points of coded signal points, the selected channel symbols, the signal points Of said receiver apparatus comprising means for deinterleavimigtiw b'ledeaved ~ ~ that signal points that arc scque~din such a POInt ~ beng way channelsymbol, orb)parteither a) part of the to recover said plurality of streams of trellis ensame ofchannel symbols coded channel symbols, and that are adjacent to one another in said channel a distributed Viterbi decoder for recovering said ~bol ~eam, are separated in said output stream information from the deinterleaved signalpoints. 35 by at leastone other signal point 10. The apparatus ofclaim P further comprising 16. The method of claim IS wherein in said trellis a phase tracking ioop, and encoding step a plurality oftrellis encoder stages trellis means for-adapting the operation ofsaid phase trackencode respective ones ofsaid streams of trellis bits. lug ioop in response to minimum accumulatedpath 17 The method of claIm 15 wherein said selecting metrics in said distributed Viterbi decoder; 40 steplnclüdesthestepofmodulusconvertingsaidstream · 11.Amethodfwformingastreamoftrellisencoded of~bj~s signal points in response to input Information, said IS. The method of claim IS wherein said channel method comprising the steps of symbols are 2W-dimensional channel symbols, 5N> 1, generating a plurality of streams of trellis encoded and wherein said generatingstep causesevery N' signal channel symbols In response to respective portions 45 pointin said stream ofoutput signal points to be ~~qM of ~sidinput information, each of said - channel - signal point ofa respective one ofsaid channel symbols~ symbols being comprised of a plurality of signal - 16. A method for use in a receiver to recover Inforpoints, and · madon from areceived stream of trellis encoded signal Interleavingthe signal points of said generated than- points, saldslgnal points having been transmitted to said nd symbols to form said stream of trellis encoded ~oreceiver apparatus by a method which includes the signal points, said interleaving being carried out In 5t~p~ · of such away that thesignal points of each channel generating a plurality of streams of-trellis encoded symbol are non-adjacent in said stream of trellis channel symbols in response to respective portions encoded signal points and mach that the signal of said Information, each of said channel symbols points ofadjacent symbols In any one ofsaid chin- ss being comprised of a plwisliiyof signal points, and sic! symbol streams are non-adjacent in saId stream Interleavingthe signal points of said generated chariot trellis enac ded signal points. nd symbols toform said stream of trellis encoded 12. The method of claIm 11 wherein said generating signal points, said interleavIng being carried out in step generates three of said streams of trellis encoded such a way that the signal points ofeach channel channel - symbols, and wherein said interleaving step to syiobol are non-adjacent In said stream of trellis - - causes there to be interleaved between each of the sigencoded signal points and such that the signal nal points of each channel symbol at least two signal -polntso(adJaccntsynnbâlsloanyoneofsaidchanpoints from -other channel symbols of said streams of nel symbol streams are non-adjacent in said Stream - trellis encoded channel symbols. of trellis encoded signal points, 13. The method of claim 11 wherein said channel 65 saId method comprising the steps of symbols are 2W-dimensional channel syntbols N>!, deinterleaving the interleaved signal points to reand wherein said interleaving step causes every NIh cover said plurality of streams of trellis encoded signal point in said interleaved signal point stream to be channel symbols, and

11

5,243,627

12

Case 1:07-cv-00402-GMS Document 59-3 Case 2:06-cv-00369-TJW-CE

Document 23-25 Filed 03/09/2007 Filed 06/28/2007 Page 18 of 18

Page 18 of

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using a distributed Viterbi decoder to recovcr said - information (roan the deinterleaved signal points. 20. The method of claim 19 wherein said receiver · includes a phase tracking loopand wherein saidmethod comprises the further step of adapting the operation of S said phase tracking inc~ inr~~ ~ - -mulated path metrics in said distributed Viterbi ~ coder. 21, Data communication apparatus comprising means for receiving input Information, 10 means for generating i plurality of streams oftrellis encoded channelsymbols in resinonsetorespective portions of said input information, each of said channel symbols being comprised ala plurality 15 signal points, meansfor interleaving the.signal points ofsaid g~sled channel symbols to farina a stream of'trellis encoded signal paints, said interleaving beang ~ ned outin such iwaythat the signalpoints ofeach channel symbol arenon-adjacent in said stream of30 trellis encoded signas!points and such that the slgus! points of adjacent symbols in any one of said channel symbol streams are non-adjacent in said - stream oftrellis encoded signal points. 25 means for appl~~Ing stream of trellis encoded sigthe
· us! points faa transmission channel, 30

13

5,243,627
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means for receiving the stream of trellis encoded signal points front the channel, means for deinterleaving theinterleaved signal points - to recover said plurality of streams of trellis enooddd Chanindi symbols, and

14

a distributed Viterbi decoder for recovering said InfonnanOn from the deinterleaved signs! points. 22. The apparatus ofclaim 21 wherein said means for generating generates three of said streams of trellis encoded channel symbols, and wherein said means for interleaving causes there to- be Interleaved between each oldie signal points ofeach channel symbol at least two signal points from other channel symbols of said Streams dtrdllis encoded channel symbols. 23. The apparatus of claim 21 wherein said channel symbols are 2W-dimensional channel symbols, N> 1, and wherein said means for interleaving Causes every NIh signal point lewd interleaved signalpoint stream to be the NIh signal point ala respective one of said channel symbols. 24. The apparatus of claim 22 wherein said channel symbols are 2W-dimensional chgnnd symbols, N> I, and wherein said means for interleavingoauses every NIhsagnalpoint in said interleaved signal point stream to be the NIhsignal point ofa respective one ofsaid cbsn-

net symbols.
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50

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65

Case 2:06-cv-00369-TJW-CE Document 59-4 Case 1:07-cv-00402-GMS Document 23-26 Filed 06/28/2007 Page 1 of of 4 Filed 03/09/2007 Page 1 4

Exhibit 25

US2000 5490191.1

CM/ECF LIVE U.S. District Court:ded Docket Report 59-4 Case 2:06-cv-00369-TJW-CE Document 23-26 Filed 06/28/2007 Page 2 of of 4 Case 1:07-cv-00402-GMS Document Filed 03/09/2007 Page 2 4
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Page 1 of 3

PATENT

U.S. District Court District of Delaware (Wilmington) CIVIL DOCKET FOR CASE #: 1:06-cv-00729-GMS

Rembrandt Technologies LP v. NBC Universal Inc. Assigned to: Honorable Gregory M. Sleet Related Case: l:06-cv-00635-GMS Cause: 35:271 Patent Infringement Plain tiff Rembrandt Technologies LP

Date Filed: 12/01/2006 Jury Demand: Plaintiff Nature of Suit: 830 Patent Jurisdiction: Federal Question represented by Steven J. Balick Ashby & Geddes 500 Delaware Avenue, 8th Floor P.O. Box 1150 Wilmington, DE 19899 (302)654-1888 Email: sbalick~ashby-geddes.com LEAD ATTORNEY ATTORNEY TO BE NOTICED Lauren E. Maguire Ashby & Geddes 500 Delaware Avenue, 8th Floor P.O. Box 1150 Wilmington, DE 19899 (302)654-1888 Email: lmaguire~ashby-geddes.com ATTORNEY TO BE NOTICED

V Defendant NBC Universal Inc represented by Jack B Blumenfeld Moms, Nichols, Arsht & Tunnell LLP 1201 North Market Street P.O. Box 1347 Wilmington, DE 19899 (302) 658-9200 Email: jbbefiling~mnat.com LEAD ATTORNEY

Counter Claimant NBC Universal Inc. represented by Jack B. Blumenfeld (See above for address) LEAD ATTORNEY

https //ecf ded uscourts gov/cgi-brnlDktRpt pl793023233148 8756-L_353_0-1

3/2/2007

CM/ECF LIVE U.S. District Court:ded Docket Report Case 2:06-cv-00369-TJW-CE Document 59-4 Case 1:07-cv-00402-GMS Document 23-26 Filed 06/28/2007 Page 3 of of 4 Filed 03/09/2007 Page 3 4
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Page 2 of3

V. Counter Defendant Rembrandt Technologies LP represented by Steven J. Balick (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Lauren E. Maguire
(See above for address) ATTORNEY TO BE NOTICED

Date Filed 12/01/2006

#

Docket Text

1 COMPLAINT filed with Jury Demand against NBC Universal Inc. Magistrate Consent
-

Notice to Pltf. (Filing fee $ 350, receipt number 145541.) filed by Rembrandt Technologies LP. (Attachments: # 1 Civil Cover Sheet #2 Acknowledgement of Consent Form)(ead) (Entered: 12/04/2006)
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12/01/2006 12/01/2006
____________ ________

Summons Issued as to NBC Universal Inc. on 12/1/2006. (ead) (Entered: 12/04/2006) 2 Notice of Availability ofa U.S. Magistrate Judge to Exercise Jurisdiction (ead) (Entered: 12/04/2006) 3 Report to the Commissioner of Patents and Trademarks for Patent Number 5,243,627; (ead) (Entered: 12/04/2006) 4 SUMMONS Returned Executed by Rembrandt Technologies LP. NBC Universal Inc. served on 12/4/2006, answer due 12/27/2006. (Maguire, Lauren) (Entered: 12/04/2006) 5 Disclosure Statement pursuant to Rule 7.1 filed by Rembrandt Technologies LP. (Maguire, Lauren) (Entered: 12/06/2006) 6 MOTION for Pro Hac Vice Appearance of Attorney John F. Sweeney, Joseph A. DeGirolamo, and Michael 0. Cummings filed by Rembrandt Technologies LP. (Maguire, Lauren) (Entered: 12/11/2006)
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12/04/2006
_____________ ________

12/04/2006 12/06/2006
____________ ________

12/11/2006
_____________ _________

12/13/2006 12/14/2006
____________ ________

Case assigned to Judge Gregory M. Sleet. Please include the initials of the Judge (GMS) after the case number on all documents filed. (rjb) (Entered: 12/13/2006) 7 NOTICE of Change of Address by Steven J Balick (Balick, Steven) (Entered 12/14/2006) 8 Joint STIPULATION TO EXTEND TIME to answer complaint to January 26, 2007 filed by Rembrandt Technologies LP, NBC Universal Inc.. (Blumenfeld, Jack) (Entered: 12/22/2006)
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12/22/2006
________

12/28/2006
____________ ________

SO ORDERED, re 8 Joint STIPULATION TO EXTEND TIME to answer complaint to January 26, 2007 filed by NBC Universal Inc., Rembrandt Technologies LP. Signed by Judge Gregory M. Sleet on 12/28/06. (mnim) (Entered: 12/28/2006) Set/Reset Answer Deadlines: NBC Universal Inc. answer due 1/26/2007. (mmm)

12/28/2006

https //ecf ded uscourts gov/cgi-binlDktRpt pP93O23233l 488756-L_353_0-1

3/2/2007

CM/ECF LIVE U.S. District Court:ded Docket Report Case 2:06-cv-00369-TJW-CE Document 59-4 Case 1:07-cv-00402-GMS Document 23-26 Filed 06/28/2007 Page 4 of of 4 Filed 03/09/2007 Page 4 4
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Page 3 of 3

_____________

________

(Entered 12/28/2006) 9 MOTION for Pro Hac Vice Appearance of Attorney Timothy E DeMasi, Matthew D Powers, Edward R. Reines, Anne M. Cappella and Sonal N. Mehta filed by NBC Universal Inc.. (Blumenfeld, Jack) (Entered: 0 1/24/2007)
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01/24/2007

0 1/25/2007

_____________

________

50 ORDERED, re 9 MOTION for Pro Hac Vice Appearan