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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE In re: REMBRANDT TECHNOLOGIES, LP PATENT LITIGATION ) ) ) MDL Docket No. 07-md-1848 (GMS) ) CHIEF JUDGE GREGORY M. SLEET ) ) )

PARTIES' JOINT CLAIM CONSTRUCTION CHART FOR U.S. PATENT 5,243,627

/s/ Collins J. Seitz, Jr. . Collins J. Seitz, Jr., Esquire (#2237) Francis DiGiovanni, Esquire (#3189) Connolly Bove Lodge & Hutz LLP 1007 N. Orange Street P.O. Box 2207 Wilmington, Delaware 19899 (302) 658-9141 [email protected] [email protected] Attorneys for Rembrandt Technologies, LP and Rembrandt Technologies, LLC d/b/a Remstream

/s/ Jack B. Blumenfeld . Jack B. Blumenfeld (#1014) Karen Jacobs Louden (#2881) Morris, Nichols, Arsht & Tunnell, LLP 1201 N. Market Street P.O. Box 1347 Wilmington, DE 19899 (302) 658-9200 [email protected] [email protected] Liaison Co-Counsel for All Other Parties

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In re: REMBRANDT TECHNOLOGIES, LP PATENT LITIGATION MDL Docket No. 07-md-1848 (GMS) JOINT CLAIM CONSTRUCTION CHART FOR THE `627 PATENT
Claim Limitation Claim at Issue Parties' Agreed Construction1 Means plus function, to be construed per 35 U.S.C. § 112, ¶ 6 Function: Applying the stream of trellis encoded signal points to a transmission channel. Structure: A modulator. means for receiving input information, Claims 21, 22 Means plus function, to be construed per 35 U.S.C. § 112, ¶ 6 Function: Receiving input information. Structure: Input component of a transmitter apparatus. means for receiving the stream Claims 21, 22 of trellis encoded signal points from the channel, Means plus function, to be construed per 35 U.S.C. § 112, ¶ 6 Function: Receiving the stream of trellis encoded signal points from the channel. Structure: Input component of a receiver apparatus.

means for applying the stream Claims 21, 22 of trellis encoded signal points to a transmission channel

1

The parties jointly and respectfully submit that, if the Court deems it appropriate, the Court include the agreed-upon claim construction in its Claim Construction Order, or in the alternative, that this agreed upon construction is a binding stipulation between the parties.

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In re: REMBRANDT TECHNOLOGIES, LP PATENT LITIGATION MDL Docket No. 07-md-1848 (GMS) JOINT CLAIM CONSTRUCTION CHART FOR THE `627 PATENT
Italicized: Rembrandt's proposed terms Underlined: All Other Parties' proposed terms

REMBRANDT `627 Patent Claim 1(a) INTRINSIC EVIDENCE Abstract; Figs. 1, 2, 3, 4, 5, 6, and 7; 2:5-50; 3:4-4:51; 5:1-6:26; 6:48-9:66; Claims 35, 8, 13-15, 18, and 22-24.

ALL OTHER PARTIES INTRINSIC EVIDENCE 2:5-13; 2:53-55; 3:44:24; 4:54-56; 5:1-66; 8:18-26; 8:61-64; 9:815; Figs. 1, 2, 3 & 4.

1(b)

Element An apparatus for forming a stream of trellis encoded signal points in response to input information, said apparatus comprising means for generating a plurality of streams of trellis encoded channel symbols in response to respective portions of said input information, each of said channel symbols being comprised of a plurality of signal points, and

Claim Term signal point

CONSTRUCTION A value that is transmitted by a modulator in one signaling interval.

CONSTRUCTION A point on a 2-dimensional constellation having a pair of coordinates representing two components of a corresponding signal.

trellis encoded channel symbol

A set of one or more trellis encoded signal points that corresponds to a group of bits that is treated as a unit by an encoding system.

Abstract; Figs. 1, 2, 3, 4, 5, 6, and 7; 1:342:2; 2:30-2:50; 2:613:60; 4:9-11; 5:1-41; 6:46-10:3; Claims 35, 8, 13-15, 18, and 22-24. Abstract; Figs. 1, 2, 3, 4, 5, 6, and 7; 1:342:2; 2:30-2:50; 2:613:3; 3:56-60; 4:9-11; 5:1-41; 6:46-10:3; Claims 3-5, 8, 13-15, 18, and 22-24.

See construction of: "trellis encoded channel symbol ... comprised of a plurality of signal points."

See intrinsic evidence for "trellis encoded channel symbol ... comprised of a plurality of signal points"

trellis encoded channel symbol ... comprised of a plurality of signal points

A set of two or more trellis encoded signal points that corresponds to a group of bits that is treated as a unit by an encoding system.

Two or more signal points all selected using the same group of parallel input bits as expanded once by a trellis encoder.

1:8-15; 1:41-58; 2:513; 2:59-4:24; 4:46-51 (citing Wei paper); 4:52-5:30; 8:18-19; 8:22-23; 8:61-64; 9:1423; Figs. 3, 4 & 5; Abstract.

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In re: REMBRANDT TECHNOLOGIES, LP PATENT LITIGATION MDL Docket No. 07-md-1848 (GMS) JOINT CLAIM CONSTRUCTION CHART FOR THE `627 PATENT
REMBRANDT `627 Patent Claim INTRINSIC EVIDENCE Abstract; Figs. 1, 2, 3, 4, 5, 6, and 7; 1:342:2; 2:30-2:50; 2:613:3; 3:56-60; 4:9-11; 5:1-41; 6:46-10:3; Claims 3-5, 8, 13-15, 18, and 22-24. See claim 1(a) above. Abstract; Figs. 3, 4, 5, 6, and 7; 1:59-62; 4:52-5:41; 9:4-8; 9:52-66; Claims 2-5, 8, 12-15, 18, and 2224; Refer also to intrinsic evidence cited in "trellis encoded channel symbol" and "trellis encoded channel symbol ... comprised of a plurality of signal points." ALL OTHER PARTIES INTRINSIC EVIDENCE 1:34-2:13; 5:1-30; 5:37-41; 5:64-66; 6:468:2; 9:14-23; Figs. 3 & 5.

Element

Claim Term stream[] of trellis encoded channel symbols

CONSTRUCTION A sequence of trellis encoded channel symbols.

CONSTRUCTION A sequence of trellis encoded channel symbols in which each symbol's signal points are adjacent.

signal point means for generating a plurality of streams of trellis encoded channel symbols in response to respective portions of said input information

See claim 1(a) above. Means plus function, to be construed per 35 U.S.C. § 112, ¶ 6 Function: Generating a plurality of streams of trellis encoded channel symbols in response to respective portions of said input information. Structure: A distributed trellis encoder that implements multiple trellis encoding processes operating on respective portions of input information.

See claim 1(a) above.

See claim 1(a) above.

Means plus function, to be 5:1-30; 9:14-23; Fig. 3. construed per 35 U.S.C. § 112, ¶ 6 Function: Generating a plurality of streams of trellis encoded channel symbols in response to respective portions of said input information. Structure: Parallel trellis encoders and an encoder that generates signal points.

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In re: REMBRANDT TECHNOLOGIES, LP PATENT LITIGATION MDL Docket No. 07-md-1848 (GMS) JOINT CLAIM CONSTRUCTION CHART FOR THE `627 PATENT
REMBRANDT `627 Patent Claim 1(c) INTRINSIC EVIDENCE Fig. 3 (337, 341), Fig. 5, and Fig. 6 (641); 1:59-62; 5:1-47; 6:469:66; Claims 1-5, 8-9, 11-15, 18-19, and 2124; Refer also to intrinsic evidence cited in "trellis encoded channel symbol," "trellis encoded channel symbol ... comprised of a plurality of signal points," and "signal point." ALL OTHER PARTIES INTRINSIC EVIDENCE 2:5-13; 5:24-41; 6:468:2; 9:14-44; Figs. 3 & 6; Abstract.

Element means for interleaving the signal points of said generated channel symbols to form said stream of trellis encoded signal points, said interleaving being carried out in such a way that the signal points of each channel symbol are non-adjacent in said stream of trellis encoded signal points and such that the signal points of adjacent symbols in any one of said channel symbol streams are nonadjacent in said stream of trellis encoded signal points.

Claim Term means for interleaving the signal points of said generated channel symbols to form said (a) stream of trellis encoded signal points

CONSTRUCTION Means plus function, to be construed per 35 U.S.C. § 112, ¶ 6 Function: Interleaving the signal points of said generated channel symbols to form said stream of trellis encoded signal points. Structure: Signal point interleaver and/or a switching circuit, or a processor programmed to interleave the signal points of the trellis encoded channel symbols.

CONSTRUCTION Means plus function, to be construed per 35 U.S.C. § 112, ¶ 6 Function: Interleaving the signal points of said generated channel symbols to form said stream of trellis encoded signal points. Structure: Signal Point Interleaver 341 including delay element 3411 or Signal Point Interleaver 641 including delay elements 6411, 6412 and 6413.

signal point

See claim 1(a) above.

See claim 1(a) above.

See claim 1(a) above.

See claim 1(a) above.

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In re: REMBRANDT TECHNOLOGIES, LP PATENT LITIGATION MDL Docket No. 07-md-1848 (GMS) JOINT CLAIM CONSTRUCTION CHART FOR THE `627 PATENT
REMBRANDT `627 Patent Claim 2 INTRINSIC EVIDENCE ALL OTHER PARTIES INTRINSIC EVIDENCE

9(a)

Element The apparatus of claim 1 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 of the signal points of each channel symbol at least two signal points from other channel symbols of said streams of trellis encoded channel symbols. Receiver apparatus for recovering information from a received stream of trellis encoded signal points, said

Claim Term [contains several terms construed elsewhere in this chart]

CONSTRUCTION

CONSTRUCTION

receiver apparatus

A device that receives a transmission signal.

Fig. 4; 1:62-65; 2:3942; 5:48-6:45; 9:5266; Claim 20.

A device that demodulates a received signal and recovers information in the form of a serial bit stream.

2:39-42; 2:55-57; 4:4759; 5:42-6:45; Fig. 4.

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In re: REMBRANDT TECHNOLOGIES, LP PATENT LITIGATION MDL Docket No. 07-md-1848 (GMS) JOINT CLAIM CONSTRUCTION CHART FOR THE `627 PATENT
REMBRANDT `627 Patent Claim INTRINSIC EVIDENCE See claim 1(a) above. ALL OTHER PARTIES INTRINSIC EVIDENCE See claim 1(a) above.

Element signal points having been transmitted to said receiver apparatus by transmitter apparatus which generates said signal points by generating a plurality of streams of trellis encoded channel symbols in response to respective portions of said information, each of said channel symbols being comprised of a plurality of signal points, and by interleaving the signal points of said generated channel symbols to form said stream of trellis encoded signal points, said interleaving being

Claim Term signal point

CONSTRUCTION See claim 1(a) above.

CONSTRUCTION See claim 1(a) above.

interleaving the signal points of said generated channel symbols to form said stream of trellis encoded signal points

To interleave signal points of trellis encoded channel symbols to form a stream of trellis encoded signal points.

trellis encoded channel symbol

See claim 1(b) above.

Abstract; Figs. 3, 5, and 6; 5:1-47; 6:469:44; 9:52-66; Claims 1-5, 8-9; 11-15, 1819, and 21-24; Refer also to intrinsic evidence cited in "trellis encoded channel symbol," "trellis encoded channel symbol ... comprised of a plurality of signal points," and "signal point." See claim 1(b) above.

Separating the adjacent signal points of each generated trellis encoded channel symbol using other signal points.

2:5-13;5:24-41; 6:468:2; 9:14-44; 10:24-28; 11:60-64; Figs. 3, 5 & 6.

See claim 1(b) above.

See claim 1(b) above.

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In re: REMBRANDT TECHNOLOGIES, LP PATENT LITIGATION MDL Docket No. 07-md-1848 (GMS) JOINT CLAIM CONSTRUCTION CHART FOR THE `627 PATENT
REMBRANDT `627 Patent Claim INTRINSIC EVIDENCE See claim 1(b) above. ALL OTHER PARTIES INTRINSIC EVIDENCE See claim 1(b) above.

Element carried out in such a way that the signal points of each channel symbol are non-adjacent in said stream of trellis encoded signal points and such that the signal points of adjacent symbols in any one of said channel symbol streams are nonadjacent in said stream of trellis encoded signal points, said receiver apparatus comprising

Claim Term trellis encoded channel symbol ... comprised of a plurality of signal points stream[] of trellis encoded channel symbols

CONSTRUCTION See claim 1(b) above.

CONSTRUCTION See claim 1(b) above.

See claim 1(b) above.

See claim 1(b) above.

See claim 1(b) above.

See claim 1(b) above.

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In re: REMBRANDT TECHNOLOGIES, LP PATENT LITIGATION MDL Docket No. 07-md-1848 (GMS) JOINT CLAIM CONSTRUCTION CHART FOR THE `627 PATENT
REMBRANDT `627 Patent Claim 9(b) INTRINSIC EVIDENCE Fig. 4 (431, 441) and Fig. 7 (741); 1:62-2:2; 5:67-6:45; 9:52-66; Claims 2-5, 8, 12-15, 18, and 22-24; Refer also to intrinsic evidence cited in "trellis encoded channel symbol," "trellis encoded channel symbol ... comprised of a plurality of signal points," and "signal point." ALL OTHER PARTIES INTRINSIC EVIDENCE 2:5-13; 5:67-6:13; 6:46-8:2; 9:45-51; Figs. 4 & 7. See "means for interleaving . . ." 1(c) above and "stream[] of trellis encoded channel symbols" 1(b) above.

Element means for deinterleaving the interleaved signal points to recover said plurality of streams of trellis encoded channel symbols, and

Claim Term means for deinterleaving the interleaved signal points to recover said plurality of streams of trellis encoded channel symbols

CONSTRUCTION Means plus function, to be construed per 35 U.S.C. § 112, ¶ 6 Function: Deinterleaving the interleaved signal points to recover said plurality of streams of trellis encoded channel symbols. Structure: Signal point deinterleaver and/or a switching circuit, or a processor programmed to deinterleave the interleaved signal points.

CONSTRUCTION Means plus function, to be construed per 35 U.S.C. § 112, ¶ 6 Function: Deinterleaving the interleaved signal points to recover said plurality of streams of trellis encoded channel symbols. Structure: Signal Point Deinterleaver 441 including delay element 4411 or Signal Point Deinterleaver 741 including delay elements 7411, 7412 and 7413. See claim 1(b) above.

trellis encoded channel symbol stream[] of trellis encoded channel symbols signal point

See claim 1(b) above.

See claim 1(b) above.

See claim 1(b) above.

See claim 1(b) above.

See claim 1(b) above.

See claim 1(b) above.

See claim 1(b) above.

See claim 1(a) above.

See claim 1(a) above.

See claim 1(a) above.

See claim 1(a) above.

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In re: REMBRANDT TECHNOLOGIES, LP PATENT LITIGATION MDL Docket No. 07-md-1848 (GMS) JOINT CLAIM CONSTRUCTION CHART FOR THE `627 PATENT
REMBRANDT `627 Patent Claim 9(c) INTRINSIC EVIDENCE Abstract; Figs. 3, 4, 5, 6, and 7; 1:34-2:20; 4:52-5:41; 6:12-26; 6:48-8:13; 8:57-9:28; 9:52-66; Prosecution History; and Office Action Response dated Dec. 21, 1992 at TKHR0000886 ­ TKHR0000890. Abstract; Figs. 3, 4, 5, 6, and 7; 1:34-2:2; 4:52-5:41; 5:67-6:45; 6:48-8:13; 8:14-56; 8:57-9:28; 9:29-51; 9:52-66; Claims 2-5, 8, 12-15, 18, and 2224; Prosecution History; and Office Action Response dated December 21, 1992 at TKHR0000886 ­ TKHR0000890. See claim 1(a) above. ALL OTHER PARTIES INTRINSIC EVIDENCE See intrinsic evidence for "distributed Viterbi decoder for recovering (to recover) said information from the deinterleaved signal points"

Element a distributed Viterbi decoder for recovering said information from the deinterleaved signal points.

Claim Term CONSTRUCTION A Viterbi decoder having distributed Viterbi multiple Viterbi decoding decoder processes operating on separate portions of a stream of data to be decoded.

CONSTRUCTION See construction of: "distributed Viterbi decoder for recovering (to recover) said information from the deinterleaved signal points"

distributed Viterbi decoder for recovering (to recover) said information from the deinterleaved signal points

A Viterbi decoder having multiple Viterbi decoding processes operating on separate portions of a stream of deinterleaved signal points to recover the information encoded therein.

Multiple stage decoder in which each stage receives all of the deinterleaved signal points of a trellis encoded channel symbol before deciding their values together using the Viterbi algorithm.

1:34-2:2 (citing Betts `625); 4:64-68; 6:1226; 8:36-56; 8:64-66; 9:61-66; Fig. 4.

signal point

See claim 1(a) above.

See claim 1(a) above.

See claim 1(a) above.

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In re: REMBRANDT TECHNOLOGIES, LP PATENT LITIGATION MDL Docket No. 07-md-1848 (GMS) JOINT CLAIM CONSTRUCTION CHART FOR THE `627 PATENT
REMBRANDT `627 Patent Claim 10(a) INTRINSIC EVIDENCE ALL OTHER PARTIES INTRINSIC EVIDENCE

10(b)

11(a)

11(b)

Element The apparatus of claim 9 further comprising a phase tracking loop, and means for adapting the operation of said phase tracking loop in response to minimum accumulated path metrics in said distributed Viterbi decoder. A method for forming a stream of trellis encoded signal points in response to input information, said method comprising the steps of generating a plurality of streams of trellis encoded

Claim Term

CONSTRUCTION

CONSTRUCTION

distributed Viterbi See claim 9(c) above. decoder

See claim 9(c) above.

See claim 9(c) above.

See claim 9(c) above.

signal point

See claim 1(a) above.

See claim 1(a) above.

See claim 1(a) above.

See claim 1(a) above.

trellis encoded channel symbol

See claim 1(b) above.

See claim 1(a) above.

See claim 1(b) above.

See claim 1(b) above.

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In re: REMBRANDT TECHNOLOGIES, LP PATENT LITIGATION MDL Docket No. 07-md-1848 (GMS) JOINT CLAIM CONSTRUCTION CHART FOR THE `627 PATENT
REMBRANDT `627 Patent Claim INTRINSIC EVIDENCE See claim 1(b) above. ALL OTHER PARTIES INTRINSIC EVIDENCE See claim 1(b) above.

Element channel symbols in response to respective portions of said input information, each of said channel symbols being comprised of a plurality of signal points, and

Claim Term trellis encoded channel symbol ... comprised of a plurality of signal points stream[] of trellis encoded channel symbols signal point

CONSTRUCTION See claim 1(b) above.

CONSTRUCTION See claim 1(b) above.

See claim 1(b) above.

See claim 1(b) above.

See claim 1(b) above.

See claim 1(b) above.

See claim 1(a) above.

See claim 1(a) above.

See claim 1(a) above.

See claim 1(a) above.

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In re: REMBRANDT TECHNOLOGIES, LP PATENT LITIGATION MDL Docket No. 07-md-1848 (GMS) JOINT CLAIM CONSTRUCTION CHART FOR THE `627 PATENT
REMBRANDT `627 Patent Claim 11(c) INTRINSIC EVIDENCE See claim 9(a) above. ALL OTHER PARTIES INTRINSIC EVIDENCE See claim 9(a) above.

Element interleaving the signal points of said generated channel symbols to form said stream of trellis encoded signal points, said interleaving being carried out in such a way that the signal points of each channel symbol are non-adjacent in said stream of trellis encoded signal points and such that the signal points of adjacent symbols in any one of said channel symbol streams are nonadjacent in said stream of trellis encoded signal points.

Claim Term interleaving the signal points of said generated channel symbols to form said stream of trellis encoded signal points

CONSTRUCTION See claim 9(a) above.

CONSTRUCTION See claim 9(a) above.

signal point

See claim 1(a) above.

See claim 1(a) above.

See claim 1(a) above.

See claim 1(a) above.

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In re: REMBRANDT TECHNOLOGIES, LP PATENT LITIGATION MDL Docket No. 07-md-1848 (GMS) JOINT CLAIM CONSTRUCTION CHART FOR THE `627 PATENT
REMBRANDT `627 Patent Claim 12 INTRINSIC EVIDENCE ALL OTHER PARTIES INTRINSIC EVIDENCE

19(a)

Element The method of claim 11 wherein said generating step generates three of said streams of trellis encoded channel symbols, and wherein said interleaving step causes there to be interleaved between each of the signal points of each channel symbol at least two signal points from other channel symbols of said streams of trellis encoded channel symbols. A method for use in a receiver to recover information from a received stream of

Claim Term [contains several terms construed elsewhere in this chart]

CONSTRUCTION

CONSTRUCTION

receiver apparatus

See claim 9(a) above.

See claim 9(a) above.

See claim 9(a) above.

See claim 9(a) above.

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In re: REMBRANDT TECHNOLOGIES, LP PATENT LITIGATION MDL Docket No. 07-md-1848 (GMS) JOINT CLAIM CONSTRUCTION CHART FOR THE `627 PATENT
REMBRANDT `627 Patent Claim INTRINSIC EVIDENCE See claim 1(a) above. ALL OTHER PARTIES INTRINSIC EVIDENCE See claim 1(a) above.

19(b)

Element trellis encoded signal points, said signal points having been transmitted to said receiver apparatus by a method which includes the steps of generating a plurality of streams of trellis encoded channel symbols in response to respective portions of said information, each of said channel symbols being comprised of a plurality of signal points, and

Claim Term signal point

CONSTRUCTION See claim 1(a) above.

CONSTRUCTION See claim 1(a) above.

trellis encoded channel symbol trellis encoded channel symbol ... comprised of a plurality of signal points stream[] of trellis encoded channel symbols signal point

See claim 1(b) above.

See claim 1(b) above.

See claim 1(b) above.

See claim 1(b) above.

See claim 1(b) above.

See claim 1(b) above.

See claim 1(b) above.

See claim 1(b) above.

See claim 1(b) above.

See claim 1(b) above.

See claim 1(b) above.

See claim 1(b) above.

See claim 1(a) above.

See claim 1(a) above.

See claim 1(a) above.

See claim 1(a) above.

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In re: REMBRANDT TECHNOLOGIES, LP PATENT LITIGATION MDL Docket No. 07-md-1848 (GMS) JOINT CLAIM CONSTRUCTION CHART FOR THE `627 PATENT
REMBRANDT `627 Patent Claim 19(c) INTRINSIC EVIDENCE See claim 9(a) above. ALL OTHER PARTIES INTRINSIC EVIDENCE See claim 9(a) above.

Element interleaving the signal points of said generated channel symbols to form said stream of trellis encoded signal points, said interleaving being carried out in such a way that the signal points of each channel symbol are non-adjacent in said stream of trellis encoded signal points and such that the signal points of adjacent symbols in any one of said channel symbol streams are nonadjacent in said stream of trellis encoded signal points, said method comprising the steps of

Claim Term interleaving the signal points of said generated channel symbols to form said stream of trellis encoded signal points signal point

CONSTRUCTION See claim 9(a) above.

CONSTRUCTION See claim 9(a) above.

See claim 1(a) above.

See claim 1(a) above.

See claim 1(a) above.

See claim 1(a) above.

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In re: REMBRANDT TECHNOLOGIES, LP PATENT LITIGATION MDL Docket No. 07-md-1848 (GMS) JOINT CLAIM CONSTRUCTION CHART FOR THE `627 PATENT
REMBRANDT `627 Patent Claim 19(d) INTRINSIC EVIDENCE Abstract; Figs. 4 and 7; 5:67-6:45; 9:52-66; Claims 2-5, 8, 12-15, 18, and 22-24; Refer also to intrinsic evidence cited in "trellis encoded channel symbol," "trellis encoded channel symbol ... comprised of a plurality of signal points," and "signal point." See claim 1(b) above. ALL OTHER PARTIES INTRINSIC EVIDENCE 2:5-13; 5:48-6:3; 6:468:2; 9:45-51; Figs. 4 & 7. See "stream[] of trellis encoded channel symbols" 1(b) above and "interleaving the signal points. . ." 9(a) above.

Element deinterleaving the interleaved signal points to recover said plurality of streams of trellis encoded channel symbols, and

Claim Term deinterleaving the interleaved signal points to recover said plurality of streams of trellis encoded channel symbols

CONSTRUCTION To reverse the process of interleaving performed in the transmitter to recover multiple streams of trellis encoded channel symbols from the interleaved signal points.

CONSTRUCTION Restoring the adjacency of the separated signal points of each trellis encoded channel symbol to recover the two or more streams of trellis encoded channel symbols.

trellis encoded channel symbol stream[] of trellis encoded channel symbols signal point 19(e) using a distributed Viterbi decoder to recover said

See claim 1(b) above.

See claim 1(b) above.

See claim 1(b) above.

See claim 1(b) above.

See claim 1(b) above.

See claim 1(b) above.

See claim 1(b) above.

See claim 1(a) above.

See claim 1(a) above. See claim 9(c) above.

See claim 1(a) above. See claim 9(c) above.

See claim 1(a) above. See claim 9(c) above.

distributed Viterbi See claim 9(c) above. decoder

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In re: REMBRANDT TECHNOLOGIES, LP PATENT LITIGATION MDL Docket No. 07-md-1848 (GMS) JOINT CLAIM CONSTRUCTION CHART FOR THE `627 PATENT
REMBRANDT `627 Patent Claim INTRINSIC EVIDENCE See claim 9(c) above. ALL OTHER PARTIES INTRINSIC EVIDENCE See claim 9(c) above.

Element information from the deinterleaved signal points.

Claim Term CONSTRUCTION See claim 9(c) above. distributed Viterbi decoder for recovering (to recover) said information from the deinterleaved signal points signal point See claim 1(a) above.

CONSTRUCTION See claim 9(c) above.

See claim 1(a) above.

See claim 1(a) above.

See claim 1(a) above.

20

The method of claim 19 wherein said receiver includes a phase tracking loop and wherein said method comprises the further step of adapting the operation of said phase tracking loop in response to minimum accumulated path metrics in said distributed Viterbi decoder.

[contains several terms construed elsewhere in this chart]

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In re: REMBRANDT TECHNOLOGIES, LP PATENT LITIGATION MDL Docket No. 07-md-1848 (GMS) JOINT CLAIM CONSTRUCTION CHART FOR THE `627 PATENT
REMBRANDT `627 Patent Claim 21(a) INTRINSIC EVIDENCE ALL OTHER PARTIES INTRINSIC EVIDENCE

Element Data communication apparatus comprising: means for receiving input information,

Claim Term

CONSTRUCTION

CONSTRUCTION

21(b)

means for receiving input information signal point

See Parties' Agreed Construction above.

Figs. 1 and 3; 2:5558; 4:57-59.

See Parties' Agreed Construction above.

2:53-60; 4:52-61; Figs. 1 & 3.

21(c)

means for generating a plurality of streams of trellis encoded channel symbols in response to respective portions of said input information, each of said channel symbols being comprised of a plurality of signal points, and

See claim 1(a) above.

See claim 1(a) above.

See claim 1(a) above.

See claim 1(a) above.

trellis encoded channel symbol trellis encoded channel symbol ... comprised of a plurality of signal points stream[] of trellis encoded channel symbols

See claim 1(b) above.

See claim 1(b) above.

See claim 1(b) above.

See claim 1(b) above.

See claim 1(b) above.

See claim 1(b) above.

See claim 1(b) above.

See claim 1(b) above.

See claim 1(b) above.

See claim 1(b) above.

See claim 1(b) above.

See claim 1(b) above.

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In re: REMBRANDT TECHNOLOGIES, LP PATENT LITIGATION MDL Docket No. 07-md-1848 (GMS) JOINT CLAIM CONSTRUCTION CHART FOR THE `627 PATENT
REMBRANDT `627 Patent Claim INTRINSIC EVIDENCE See claim 1(b) above. ALL OTHER PARTIES INTRINSIC EVIDENCE See claim 1(b) above.

Element

21(d)

means for interleaving the signal points of said generated channel symbols to form a stream of trellis encoded signal points, said interleaving being

Claim Term means for generating a plurality of streams of trellis encoded channel symbols in response to respective portions of said input information means for interleaving the signal points of said generated channel symbols to form said (a) stream of trellis encoded signal points

CONSTRUCTION See claim 1(b) above.

CONSTRUCTION See claim 1(b) above.

See claim 1(c) above.

See claim 1(c) above.

See claim 1(c) above.

See claim 1(c) above.

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In re: REMBRANDT TECHNOLOGIES, LP PATENT LITIGATION MDL Docket No. 07-md-1848 (GMS) JOINT CLAIM CONSTRUCTION CHART FOR THE `627 PATENT
REMBRANDT `627 Patent Claim INTRINSIC EVIDENCE See claim 1(a) above. ALL OTHER PARTIES INTRINSIC EVIDENCE See claim 1(a) above.

21(e)

Element carried out in such a way that the signal points of each channel symbol are non-adjacent in said stream of trellis encoded signal points and such that the signal points of adjacent symbols in any one of said channel symbol streams are nonadjacent in said stream of trellis encoded signal points, means for applying the stream of trellis encoded signal points to a transmission channel,

Claim Term signal point

CONSTRUCTION See claim 1(a) above.

CONSTRUCTION See claim 1(a) above.

means for applying the stream of trellis encoded signal points to a transmission channel signal point

See Parties' Agreed Construction above.

Figs. 1 and Fig. 3:3842; 4:1-3, 4:63-64; 8: 38-42; 9:52-66.

See Parties' Agreed Construction above.

3:38-42; 4:62-64; Figs. 1 & 3.

See claim 1(a) above.

See claim 1(a) above.

See claim 1(a) above.

See claim 1(a) above.

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In re: REMBRANDT TECHNOLOGIES, LP PATENT LITIGATION MDL Docket No. 07-md-1848 (GMS) JOINT CLAIM CONSTRUCTION CHART FOR THE `627 PATENT
REMBRANDT `627 Patent Claim 21(f) INTRINSIC EVIDENCE Fig. 4; 5:44-56; 9:5266. ALL OTHER PARTIES INTRINSIC EVIDENCE 5:48-56; Fig. 4.

Element means for receiving the stream of trellis encoded signal points from the channel,

Claim Term means for receiving the stream of trellis encoded signal points from the channel signal point

CONSTRUCTION See Parties' Agreed Construction above.

CONSTRUCTION See Parties' Agreed Construction above.

See claim 1(a) above. See claim 9(b) above.

See claim 1(a) above. See claim 9(b) above.

See claim 1(a) above. See claim 9(b) above.

See claim 1(a) above. See claim 9(b) above.

21(g)

means for deinterleaving the interleaved signal points to recover said plurality of streams of trellis encoded channel symbols, and

means for deinterleaving the interleaved signal points to recover said plurality of streams of trellis encoded channel symbols trellis encoded channel symbol stream[] of trellis encoded channel symbols signal point

See claim 1(b) above.

See claim 1(b) above.

See claim 1(b) above.

See claim 1(b) above.

See claim 1(b) above.

See claim 1(b) above.

See claim 1(b) above.

See claim 1(b) above.

See claim 1(a) above.

See claim 1(a) above.

See claim 1(a) above.

See claim 1(a) above.

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In re: REMBRANDT TECHNOLOGIES, LP PATENT LITIGATION MDL Docket No. 07-md-1848 (GMS) JOINT CLAIM CONSTRUCTION CHART FOR THE `627 PATENT
REMBRANDT `627 Patent Claim 21(h) INTRINSIC EVIDENCE See claim 9(c) above. ALL OTHER PARTIES INTRINSIC EVIDENCE See claim 9(c) above.

Element a distributed Viterbi decoder for recovering said information from the deinterleaved signal points.

Claim Term CONSTRUCTION See claim 9(c) above. distributed Viterbi decoder See claim 9(c) above. distributed Viterbi decoder for recovering (to recover) said information from the deinterleaved signal points signal point See claim 1(a) above.

CONSTRUCTION See claim 9(c) above.

See claim 9(c) above.

See claim 9(c) above.

See claim 9(c) above.

See claim 1(a) above.

See claim 1(a) above.

See claim 1(a) above.

22

The apparatus of claim 21 wherein said means for generating generates three of said streams

stream[] of trellis encoded channel symbols signal point

See claim 1(b) above.

See claim 1(b) above.

See claim 1(b) above.

See claim 1(b) above.

See claim 1(a) above.

See claim 1(a) above.

See claim 1(a) above.

See claim 1(a) above.

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In re: REMBRANDT TECHNOLOGIES, LP PATENT LITIGATION MDL Docket No. 07-md-1848 (GMS) JOINT CLAIM CONSTRUCTION CHART FOR THE `627 PATENT
REMBRANDT `627 Patent Claim INTRINSIC EVIDENCE See claim 1(b) above. ALL OTHER PARTIES INTRINSIC EVIDENCE See claim 1(b) above.

Element of trellis encoded channel symbols, and wherein said interleaving step causes there to be interleaved between each of the signal points of each channel symbol at least two signal points from other channel symbols of said streams of trellis encoded channel symbols.

Claim Term trellis encoded channel symbol

CONSTRUCTION See claim 1(b) above.

CONSTRUCTION See claim 1(b) above.

/jc

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