`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE EASTERN DISTRICT OF TEXAS
`MARSHALL DIVISION
`
`HUAWEI TECHNOLOGIES CO. LTD.,
`Plaintiff,
`
`v.
`
`CIVIL ACTION NO.
`
`2:20-cv-00030
`
`JURY TRIAL DEMANDED
`
`VERIZON COMMUNICATIONS, INC.,
`VERIZON BUSINESS NETWORK
`SERVICES, INC., VERIZON ENTERPRISE
`SOLUTIONS, LLC, CELLCO
`PARTNERSHIP D/B/A VERIZON
`WIRELESS, INC., VERIZON DATA
`SERVICES LLC, VERIZON BUSINESS
`GLOBAL, LLC, AND VERIZON
`SERVICES CORP.
`Defendants.
`
`ORIGINAL COMPLAINT
`
`Plaintiff Huawei Technologies Co. Ltd. (“Huawei”) files this Original Complaint
`
`against Defendants Verizon Communications, Inc., Verizon Business Network Services,
`
`Inc., Verizon Enterprise Solutions LLC, Cellco Partnership d/b/a Verizon Wireless, Inc.,
`
`Verizon Data Services LLC, Verizon Business Global, LLC, and Verizon Services Corp.
`
`(collectively “Defendants” or “Verizon”) for patent infringement under 35 U.S.C. § 271.
`
`Plaintiff alleges, based on its own personal knowledge with respect to its own actions and
`
`based upon information and belief with respect to all others’ actions, as follows:
`
`THE PARTIES
`
`1.
`
`Huawei Technologies Co. Ltd. is a Chinese corporation with its principal
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`place of business at Bantian, Longgang District, Shenzhen, People’s Republic of China.
`
`2.
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`Defendant Verizon Communications, Inc. is a Delaware corporation with
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`1
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`its principal place of business at 1095 Avenue of the Americas, New York, NY 10036.
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`Verizon Communications, Inc. has designated The Corporation Trust Company,
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`Corporation Trust Center, 1209 Orange Street, Wilmington, Delaware 19801 as its agent
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`for service of process.
`
`3.
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`Defendant Verizon Business Network Services, Inc. is a Delaware
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`corporation with its principal place of business at 22001 Loudoun County Parkway,
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`Ashburn, Virginia 20147. Verizon Business Network Services, Inc. has designated CT
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`Corporation System, 1999 Bryan St., Suite 900, Dallas, Texas 75201 as its agent for
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`service of process.
`
`4.
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`Defendant Verizon Enterprise Solutions LLC is a Delaware limited
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`liability company with its principal place of business at One Verizon Way, Basking
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`Ridge, New Jersey 07920. Verizon Enterprise Solutions LLC has designated The
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`Corporation Trust Company, Corporation Trust Center, 1209 Orange Street, Wilmington,
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`Delaware 19801 as its agent for service of process.
`
`5.
`
`Defendant Cellco Partnership d/b/a Verizon Wireless, Inc. is a General
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`Partnership with its principal place of business at One Verizon Way, Basking Ridge, New
`
`Jersey 07920. Cellco Partnership d/b/a Verizon Wireless, Inc. has designated The
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`Corporation Trust Company, Corporation Trust Center, 1209 Orange Street, Wilmington,
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`Delaware 19801 as its agent for service of process.
`
`6.
`
`Defendant Verizon Data Services LLC is a Delaware limited liability
`
`company with its principal place of business at One East Telecom Parkway, B3E, Temple
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`Terrace, Florida 33637. Verizon Data Services LLC has designated CT Corporation
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`System, 1999 Bryan St., Suite 900, Dallas, Texas 75201 as its agent for service of
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`2
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`process.
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`7.
`Defendant Verizon Business Global, LLC is a Delaware corporation with
`its principal place of business at One Verizon Way, Basking Ridge, New Jersey. Verizon
`Business Global, LLC may be served with process via its registered agent Corporation
`Trust Company, Corporation Trust Company Center, 1209 Orange Street, Wilmington,
`Delaware 19801.
`8.
`Defendant Verizon Services Corp. is a Delaware corporation with its
`principal place of business at 1717 Arch Street, 21st Floor, Philadelphia, PA 19103.
`Verizon Services Corp. may be served with process via its registered agent CT
`Corporation System, 1999 Bryan Street, Suite 900, Dallas, Texas 75201.
`9.
` On information and belief, Verizon Business Network Services, Inc.,
`
`Verizon Enterprise Solutions LLC, Cellco Partnership d/b/a Verizon Wireless, Inc.,
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`Verizon Data Services LLC, Verizon Business Global, LLC, and Verizon Services Inc.
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`are direct or indirect subsidiaries of Verizon Communications Inc. On information and
`
`belief, Verizon Communications Inc. directs or controls the actions of these entities
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`including by inducing and contributing to the actions complained of herein.
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`JURISDICTION AND VENUE
`
`10.
`
`This action includes a claim of patent infringement arising under the
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`patent laws of the United States, 35 U.S.C. §§ 1 et seq. This Court has jurisdiction over
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`this action pursuant to 28 U.S.C. §§ 1331 and 1338(a).
`
`11.
`
`This Court has personal jurisdiction over Defendants. Defendants conduct
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`business and have committed acts of patent infringement and have induced acts of patent
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`infringement by others in this district and have contributed to patent infringement by
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`others in this district, the State of Texas, and elsewhere in the United States.
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`12.
`
`Venue is proper in this district pursuant to 28 U.S.C. § 1400(b) because,
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`3
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`defendants have committed acts of infringement and have regular and established places
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`of business in this judicial district.
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`ASSERTED PATENTS
`
`13.
`
`On September 18, 2012, the United States Patent and Trademark Office
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`duly and legally issued U.S. Patent No. 8,270,433 (“the ’433 patent”), entitled “Sending
`
`Method, Receiving and Processing Method and Apparatus for Adapting Payload
`
`Bandwidth for Data Transmission.” A copy of the ’433 patent is attached as Exhibit A.
`
`14.
`
`On April 21, 2015, the United States Patent and Trademark Office duly
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`and legally issued U.S. Patent No. 9,014,151 (“the ’151 patent”), entitled “Method and
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`Apparatus for Transmitting Low-Rate Traffic Signal in Optical Transport Network.” A
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`copy of the ’151 patent is attached as Exhibit B.
`
`15.
`
`On March 26, 2013, the United States Patent and Trademark Office duly
`
`and legally issued U.S. Patent No. 8,406,236 (“the ’236 patent”), entitled “Method and
`
`Apparatus for Transporting Client Signal in Optical Transport Network.” A copy of
`
`the ’236 patent is attached as Exhibit C.
`
`16.
`
`On September 2, 2014, the United States Patent and Trademark Office
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`duly and legally issued U.S. Patent No. 8,824,505 (“the ’505 patent”), entitled “Method
`
`and Apparatus for Transporting Client Signals in an Optical Transport Network.” A copy
`
`of the ’505 patent is attached as Exhibit D.
`
`17.
`
`On April 12, 2016, the United States Patent and Trademark Office duly
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`and legally issued U.S. Patent No. 9,312,982 (“the ’982 patent”), entitled “Method and
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`Apparatus for Mapping and De-Mapping in an Optical Transport Network.” A copy of
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`the ’982 patent is attached as Exhibit E.
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`
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`4
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`FACTUAL ALLEGATIONS
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`18.
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`By way of background, Huawei was founded in 1987 and has become a
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`global leader of information and communication technology. Huawei’s telecom network
`
`equipment, IT products and solutions, and smart devices, such as telepresence products,
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`transport and core network equipment, fixed and radio access products, and fiber
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`infrastructure products, are deployed and used in 170 countries and regions and serve
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`more than three billion people around the world. Indeed, together with telecom carriers,
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`Huawei has built over 1,500 networks. In fiscal year 2019, Huawei was recognized as a
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`world technology leader with over $100 billion in sales, ranking in the top 61 of the
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`Global Fortune 500 in 2019.
`
`19.
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`Huawei has heavily invested in research and development (“R&D”),
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`routinely spending over 10% of its annual revenue on innovation. In 2018 alone, Huawei
`
`invested over $14 billion in research and development. About 45% of Huawei’s global
`
`workforce – over 80,000 employees in 2018 – work in R&D. And, in the past decade
`
`through 2018, Huawei has invested near $73 billion in research and development.
`
`20.
`
`Huawei’s dedication to R&D in the telecommunications industry over the
`
`past three decades has been a major contributor to telecommunication advances from the
`
`Wired Communication Age, into the Wireless Age, and developing from 2G to 3G to 4G
`
`to 5G.
`
`21.
`Similarly, Huawei has dedicated significant R&D resources in the optical
`networking field for over 20 years. As a result, Huawei has developed an end-to-end
`wavelength division multiplexing (“WDM”) and OTN intelligent optical transport
`solution that is applicable to the backbone core layer, metro core layer, metro aggregation
`layer, and metro edge access layer along with Data Center Interconnect (DCI) scenarios.
`
`
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`5
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`Huawei’s WDM / OTN solution allows carriers to provide a variety of services and can
`support 200G–600G ultra-high rates, 200G 5000 km ultra-long transmission, new Super
`C-band spectrum, OXC/ROADM all-optical grooming, single-subrack 64T (over 100T in
`clusters) ultra-large electrical cross-connect capacity. In 2018, Huawei introduced the
`industry's first ultra-large-capacity all-optical cross-connect architecture, which enables
`networks to carry 10 times as much data as with the traditional electric cross-connect
`architecture. The all-optical cross-connect architecture also uses 10 times less energy,
`meaning a 100-fold improvement in overall energy efficiency. Huawei has maintained
`the largest market share in the WDM domain and in 100G+ high-speed networks for a
`number of years and was the first in the world to deploy a 600G commercial network.
`Huawei has also contributed as a key leader in the standardization of wavelength
`switched optical network (“WSON”) and automatically switched optical network
`(“ASON”) technologies.
`22.
`Indeed, R&D has been at the core of Huawei’s business. Huawei started
`
`its business reselling third-party telecommunication products, but shortly thereafter
`
`Huawei chose to shift its focus by expanding its own R&D and developing its own
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`products. As a result, Huawei has been identified as one of the top 5 companies in the
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`world for R&D as reported in The 2019 EU Industrial R&D Investment Scoreboard.
`
`23.
`
`Specifically, Huawei has been recognized for its innovation and
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`achievements in the optical network industry, as a result of Huawei’s substantial R&D
`
`investments, including for example in the past three years:
`
`
`
`in 2017, winning the Best New Cloud-Optical Solution
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`award at the SDN NFV World Congress;
`
`
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`in 2018, winning the Best Single-Channel Programmable
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`400G Product Award at the 20th Next Generation Optical Networking
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`
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`6
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`(“NGON”), and in 2019, winning the Best All Rounder Award for
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`Huawei’s Optical Networking 2.0 (“ON2.0”) solution;
`
`
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`in 2019, winning three “Outstanding Innovation” optical
`
`network awards at the Optical Fiber Communication Conference and
`
`Exhibition for its 600G, Optical Cross Connection, and Optical
`
`Intelligence solutions.
`
`24.
`
`During the past 20 years, Huawei has driven the information and
`
`communications technology industry forward through collaborations on
`
`commercialization, innovation, and standardization. Huawei actively contributes to
`
`network-related standards through its participation in worldwide Standard Setting
`
`Organizations (“SSOs”), such as ETSI/3GPP, IETF, ITU-T, OIF, IEEE, GSMA, CCSA,
`
`IMTC, SIP Forum, MSF, NGMN, OMA, 3GPP2, and oneM2M.
`
`25.
`
`By the end of 2018, Huawei was engaged in over 400 SSOs, industry
`
`alliances, and open source communities. In 2018 alone, Huawei submitted more than
`
`5,000 proposals, bringing its total number of submissions to nearly 60,000. See
`
`(Huawei’s 2018 Annual Report at 59). In addition, Huawei has obtained more than 400
`
`key positions, such as chairs, rapporteurs, and editors, in these network technology
`
`related SSOs.
`
`26.
`
`As a result of its investments in innovation and contributions to the
`
`industry, Huawei and its affiliates have developed a substantial patent portfolio of over
`
`85,000 issued patents worldwide, including around 40,000 granted patents in US and
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`Europe.
`
`27.
`
`In particular, since 2005, Huawei has participated in and submitted
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`
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`7
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`contributions to the standardization process for the Telecommunication Standardization
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`Sector of the International Telecommunications Union (“ITU-T”), including the ITU-T’s
`
`G.709: Interfaces for the optical transport network standard (“G.709” or “the G.709
`
`Standard”). See Ex. F (ITU-T G.709/Y.1331 (06/2016)). The G.709 Standard relates to
`
`optical transport networks. More specifically, “[R]ecommendation ITU-T G.709/Y.1331
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`defines the requirements for the optical transport network (OTN) interface signals of the
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`optical transport network, in terms of:
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`– OTN hierarchy
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`– functionality of the overhead in support of multi-wavelength optical
`
`networks
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`– frame structures
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`– bit rates
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`– formats for mapping client signals.”
`
`See (G.709 Standard) at page i.
`
`28.
`
`As part of its standardization efforts, Huawei made a number of
`
`contributions to the G.709 standardization process that were adopted by ITU-T and
`
`became part of the G.709 Standard.
`
`29.
`
`Some of Huawei’s contributions that were adopted in the G.709 Standard
`
`were Huawei inventions, described in patents and/or patent applications.
`
`30.
`
`Consistent with the ITU-T’s Common Patent Policy, Huawei declared that
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`it was willing to negotiate licenses on a nondiscriminatory basis on reasonable terms and
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`conditions for its granted patents and/or pending applications, the use of which would be
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`required to implement the G.709 Standard.
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`8
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`31.
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`The Asserted Patents are required to implement the G.709 Standard.
`
`32.
`Verizon has committed and continues to commit acts of infringement
`under 35 U.S.C. § 271. Verizon has made, used, sold, offered to sell and/or imported into
`the United States systems and/or devices that comply with the G.709 Standard in
`connection with Verizon’s optical transport network systems, including systems relying
`on or using Verizon’s various types of networks such as optical backbone network, metro
`fiber-optic network, mobile backhaul network, packet-optical network, and/or devices
`involved in providing services such as Wavelength Services, FiOS, IntelliLight Optical
`Transport Service, Metro Wavelength Services, Optical Wave Service, U.S. Wavelength
`Service, Metro Private Line Optical Wave Service, Ethernet Private Line Service, and
`Dedicated Internet Services. (collectively as to the optical transport network systems and
`the devices they employ, “Accused G.709 Instrumentalities”). As a result, Verizon has
`infringed Huawei’s patents that are required to implement the G.709 Standard.
`33.
`Optical network transport technology, including the technology of the
`patents-in-suit, has become a key component in meeting the modern demand for high
`speed, reliable communication over various type of networks (e.g., long-haul networks).
`Verizon uses this technology to transmit massive amounts of data in a stable and safe
`way from numerous base stations or access points to remote destinations. Thus, the
`technology is important to the core of Verizon’s business—enabling individuals and
`businesses to place calls, access the Internet, and transport data safely, reliably, and
`quickly.
`34.
`
`Upon information and belief, Verizon has also sold or provided and
`
`continues to sell or provide the Accused G.709 Instrumentalities, directly and/or
`
`indirectly, to third parties, including but not limited to customers (e.g., Metro Network
`
`customers, mobile backhaul customers, Optical Networking customers, Private Line
`
`customers, FiOS customers, Wavelength Services customers), users, distributors, and/or
`
`
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`9
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`resellers (collectively, “downstream parties”).
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`35.
`
`Upon information and belief, the downstream parties directly infringe one
`
`or more claims of the Asserted Patents by making, using, offering to sell, selling (directly
`
`or through intermediaries), importing, and/or supplying Accused G.709 Instrumentalities
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`in this District and elsewhere in the United States.
`
`36.
`
`Verizon has induced and/or contributed to the infringement of the
`
`downstream parties by advertising, encouraging, installing devices for, providing support
`
`for, and/or operating the Accused G.709 Instrumentalities.
`
`37.
`
`Prior to filing this lawsuit, Huawei took specific steps to protect its
`
`intellectual property in light of Verizon’s infringement.
`
`38.
`In particular, on February 7, 2019, Huawei contacted Verizon to discuss
`Verizon’s need for a license to Huawei’s patents. Huawei specifically identified patents
`from its portfolio and specific services offered by Verizon that infringed Huawei’s patents,
`including those at issue in this case.
`39.
`On March 28, 2019, Huawei representatives from China met in person with
`Verizon representatives to discuss Verizon’s need for a license to Huawei’s patents.
`Huawei further explained its intellectual property rights and also identified additional
`patents from its portfolio and services offered by Verizon that require a license to Huawei’s
`patents.
`40.
`On March 29, 2019, Huawei provided a number of claim charts to Verizon
`with even more detailed information regarding Verizon’s infringement. Those claim charts
`included the ’433 Patent, the ’151 Patent, the ‘236 Patent, the ‘505 Patent and the ’982
`Patent.
`
`41.
`Thus, to the extent Verizon was not already aware of Huawei’s intellectual
`property rights, Verizon has been aware of the ’433, ’151, ‘236, ‘505 and’982 Patents, and
`Huawei’s infringement allegations related to those patents, at least as early as March 29,
`10
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`2019.
`
`42.
`On June 4th and 5th, 2019, Huawei representatives from China again met in-
`person with representatives from Verizon in New York and discussed claim charts selected
`by Verizon concerning a variety of technologies.
`43.
`On June 18, 2019, Huawei representatives spoke with Verizon
`representatives via telephone. Verizon committed to identifying issues and concerns
`regarding the claim charts discussed during the June 4th and 5th meeting. Huawei agreed
`to travel for yet another in-person meeting in New York, and Verizon advised it would
`identify more Huawei claim charts to be discussed at their next meeting.
`44.
`On July 30-31, 2019, and September 3-4, 2019, and November 21-22, 2019,
`Huawei representatives from China met in-person with representatives from Verizon in
`New York and discussed the additional claim charts. Those claim charts included the ’151
`Patent discussed on November 21.
`45.
`On January 21, 2020, Huawei representatives from China met in-person
`with representatives from Verizon in New York again, but there was no substantial
`progress and thus no licensing agreement was reached.
`46.
`Throughout this year-long process, Huawei has offered to license its
`patents that are required to implement the G.709 Standard (including the Asserted
`Patents) to Verizon on terms that comply with its ITU-T Patent Statement and Licensing
`Declaration. Despite Huawei’s good faith efforts to resolve this matter, Verizon has not
`entered into a license with respect to Huawei’s patent portfolio including the Asserted
`Patents. Thus, Huawei doesn’t see any hope of making substantial progress via
`negotiation, and it must now seek relief from the Court for Verizon’s infringing conduct.
`47.
`In light of Verizon’s knowledge and the history between the parties,
`
`Verizon’s infringement of the Asserted Patents is willful. Verizon continues to commit
`
`acts of infringement despite a high likelihood that its actions constitute infringement, and
`
`Verizon knew or should have known that its actions constituted an unjustifiably high risk
`
`
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`11
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`of infringement.
`
`48.
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`In accordance with 35 U.S.C. § 287, Verizon has had actual notice and
`
`knowledge of all of the Patents-in-Suit and its infringement no later than the filing of this
`
`Complaint and/or the date this Complaint was served upon Verizon. Moreover, Verizon
`
`had actual notice of all the Patents-in-Suit and its infringement as early as March 2019,
`
`when Huawei provided Verizon with claim charts mapped to the G.709 Standard,
`
`including charts for all of the Patents-in-Suit. On information and belief, Verizon
`
`continues without license to make, use, import/export into/from, market, offer for sale,
`
`and/or sell in the United States products that infringe the Patents-in-Suit.
`
`49.
`
`In the interest of providing detailed averments of infringement, Huawei
`
`has identified below at least one claim per patent to demonstrate infringement. However,
`
`the selection of claims should not be considered limiting, and additional claims of the
`
`Patents-in-Suit (including method, system, and apparatus claims) that are infringed by
`
`Verizon will be disclosed in compliance with the Court’s rules related to infringement
`
`contentions.
`
`COUNT ONE: INFRINGEMENT OF THE ’433 PATENT
`
`50.
`
`Huawei incorporates by reference the preceding paragraphs as if fully set
`
`forth herein.
`
`51.
`
`U.S. Patent No. 8,270,433 (“the ’433 patent”), entitled “Sending Method,
`
`Receiving and Processing Method and Apparatus for Adapting Payload Bandwidth for
`
`Data Transmission,” was legally and duly issued on September 18, 2012, naming
`
`Zhangzhen Jiang as the inventor. See (the ’433 patent).
`
`52.
`
`The ’433 patent is valid and enforceable. See generally (the ’433 patent).
`
`
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`12
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`53.
`
`The ’433 patent is directed to patentable subject matter. See generally
`
`(the ’433 patent); (the G.709 Standard).
`
`54.
`
`Huawei owns all rights, title, and interest in the ’433 patent, and holds all
`
`substantial rights pertinent to this suit, including the right to sue and recover for all past,
`
`current, and future infringement.
`
`55.
`
`Verizon has and continues to directly infringe and/or indirectly infringe by
`
`inducement and/or contributory infringement, literally and/or under the doctrine of
`
`equivalents, the ’433 patent under 35 U.S.C. § 271.
`
`56.
`
`Verizon directly infringes the ’433 patent because it has made, used, sold,
`
`offered to sell and/or imported the Accused G.709 Instrumentalities in the United States.
`
`57.
`
`58.
`
`59.
`
`The Accused G.709 Instrumentalities comply with the G.709 Standard.
`
`The ’433 patent is required to implement the G.709 Standard.
`
`The Accused G.709 Instrumentalities infringe one or more claims of
`
`the ’433 patent, including, for example, claim 1 of the ’433 patent.
`
`60.
`
`Claim 1 of the ’433 patent recites:
`
`1. A sending method for adapting a payload bandwidth for data
`
`transmission, comprising:
`
`encoding scheme, N is an integer and 5≦N≦8;
`
`acquiring N 66B coding blocks each of which contains 64B,
`wherein the N 66B coding blocks are obtained through a 64B/66B
`
`
`encoding the acquired N 66B coding blocks into a (64*N+1)B
`coding block; and
`
`sending the (64*N+1)B coding block obtained by encoding;
`
`wherein encoding the acquired N 66B coding blocks into the
`(64*N+1)B coding block comprises:
`
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`13
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`decoding the N 66B coding blocks to obtain data blocks containing
`data only and different types of control blocks each of which
`contains at least one control characters;
`
`placing the control blocks into a control block buffer as a control
`block group, setting a first identifier to identify the control block
`group, setting a second identifier to identify a last control block in
`the control block group, and placing the data blocks, as a data
`block group, into a data block buffer;
`
`setting a third identifier by using four bits of each control block to
`identify a block type of each of the control blocks; and
`
`setting a fourth identifier by using a space smaller than or equal to
`three bits of each control block to identify positions of each of the
`control blocks in the N 66B coding blocks.
`
`61.
`
`To the extent the preamble is considered a limitation, the Accused G.709
`
`Instrumentalities meet the preamble of claim 1 of the ’433 patent that recites “A sending
`
`method for adapting a payload bandwidth for data transmission, comprising.” See, e.g.,:
`
`40GBASE-R multi-lane processing and transcoding
`17.7.4.1
`The 40GBASE-R client signal (64B/66B encoded, nominal aggregate bit-
`rate of 41 250 000 kbit/s, ±100 ppm) is recovered using the process
`described in Annex E for parallel 64B/66B interfaces. The lane(s) of the
`physical interface are bit-disinterleaved, if necessary, into four streams of
`10 312 500 kbit/s. 66B block lock and lane alignment marker lock are
`acquired on each PCS lane, allowing the 66B blocks to be de-skewed and
`reordered.
`
`The resulting sequence is descrambled and transcoded according to the
`process described in Annex B into 513B code blocks. Each pair of two 513B
`code blocks is combined according to the process described in Annex F into
`a 1027B block, resulting in a bit stream of 1027/1024×40 000 000
`kbit/s±100 ppm (40,117,187.500 kbit/s±100 ppm). This process is referred
`to as "timing transparent transcoding (TTT)", mapping a bit stream which
`is 1027/1056 times the bit-rate of the aggregate Ethernet signal.
`
` (G.709 Standard) at section 17.7.
`
`
`17.8.2 Mapping an FC-1200 signal into OPU2e
`The nominal line rate for FC-1200 is 10 518 750 kbit/s ± 100 ppm, and must
`therefore be compressed to a suitable rate to fit into an OPU2e.
`
`
`
`14
`
`
`
`Case 2:20-cv-00030-JRG Document 1 Filed 02/05/20 Page 15 of 69 PageID #: 15
`
`
`The adaptation of the 64B/66B encoded FC-1200 client is done by
`transcoding a group of eight 66B blocks into one 513B block (as described
`in Annex B), assembling eight 513B blocks into one 516-octet superblock
`and encapsulating seventeen 516-octet superblocks into an 8800 octet GFP
`frame as illustrated in Figure 17-17. The GFP frame consists of 2200 rows
`with 32 bits per row. The first row contains the GFP core header, the second
`row the GFP payload header.
`
`
` (G.709 Standard) at section 17.8.
`
`
`Annex B
`
`Adapting 64B/66B encoded clients via transcoding into 513B code
`blocks
`(This annex forms an integral part of this Recommendation.)
`
`
` (G.709 Standard) at Annex B.
`
`
`62.
`
`The Accused G.709 Instrumentalities meet the first element of claim 1 of
`
`the ’433 patent that recites “acquiring N 66B coding blocks each of which contains 64B,
`
`wherein the N 66B coding blocks are obtained through a 64B/66B encoding scheme, N is
`
`an integer and 5≦N≦8.” See, e.g.,:
`
`Transcoding from 66B blocks to 513B blocks
`B.3
`The transcoding process at the encoder operates on an input sequence of
`66B code blocks.
`
`66B control blocks (after descrambling) follow the format shown in Figure
`B.2.
`A group of eight 66B blocks is encoded into a single 513B block. The
`format is illustrated in Figure B.3.
`
`
`
`
`15
`
`
`
`Case 2:20-cv-00030-JRG Document 1 Filed 02/05/20 Page 16 of 69 PageID #: 16
`
`
`
`
`Figure B.2 – 66B Block coding
`
`
` (G.709 Standard) Annex B.
`
`
`40GBASE-R multi-lane processing and transcoding
`17.7.4.1
`The 40GBASE-R client signal (64B/66B encoded, nominal aggregate bit-
`rate of 41 250 000 kbit/s, ± 100 ppm) is recovered using the process
`described in Annex E for parallel 64B/66B interfaces. The lane(s) of the
`physical interface are bit-disinterleaved, if necessary, into four streams of
`10 312 500 kbit/s. 66B block lock and lane alignment marker lock are
`acquired on each PCS lane, allowing the 66B blocks to be de-skewed and
`reordered.
`
` (G.709 Standard) section 17.7.
`
`
`17.8.2 Mapping an FC-1200 signal into OPU2e
`The nominal line rate for FC-1200 is 10 518 750 kbit/s ± 100 ppm, and must
`therefore be compressed to a suitable rate to fit into an OPU2e.
`
`The adaptation of the 64B/66B encoded FC-1200 client is done by
`transcoding a group of eight 66B blocks into one 513B block (as described
`in Annex B), assembling eight 513B blocks into one 516-octet superblock
`and encapsulating seventeen 516-octet superblocks into an 8800 octet GFP
`frame as illustrated in Figure 17-17. The GFP frame consists of 2200 rows
`with 32 bits per row. The first row contains the GFP core header, the second
`row the GFP payload header.
`
` (G.709 Standard) at section 17.8.
`
`
`63.
`The Accused G.709 Instrumentalities meet the next element of claim 1 of
`the ’433 patent that recites “encoding the acquired N 66B coding blocks into a
`
`
`
`16
`
`
`
`Case 2:20-cv-00030-JRG Document 1 Filed 02/05/20 Page 17 of 69 PageID #: 17
`Case 2:20-cv-00030-JRG Document 1 Filed 02/05/20 Page 17 of 69 PageID #: 17
`
`(64*N+1)B coding block; and sending the (64*N+1)B coding block obtained by
`
`encoding; wherein encoding the acquired N 66B coding blocks into the (64*N+1)B
`
`coding block comprises.” See, e.g.,:
`
`Transcoding from 66B blocks to 513B blocks
`B.3
`The transcoding process at the encoder operates on an input sequence of
`66B code blocks.
`
`66B control blocks (afler descrambling) follow the format shown in Figure
`B2.
`
`A group of eight 66B blocks is encoded into a single 513B block. The
`format is illustrated in Figure B.3.
`
`1234515789me
`
`Ell WWWWMH’HMW —
`PAWWWWWWWW
`WWWWWWWWW 2mm
`Bl Wflflflflflflfl\‘HW
`EHWWW ‘liWWWWWWWW
`EH “mmmm
`immflflflflflfl
`mm mmwwmmflww
`EH
`m
`mmmmwmmw
`EH wwwmmwmw mmwwmwwm
`I234WI9Tl-Hl—IIW
`1234511156me
`E_____1g}-..Em
`L____‘1g}-..Em
`8 x 663 blocks
`5133 block
`
`Figure B.3 — 513B block code format
`
`(G.709 Standard) Annex B.
`
`Table 17-10 —m, n and Cup for CBR clients into OPU3
`
`Client signal
`
`Nominal
`
`Bit rate
`
`bit rate
`
`(kbit/s)
`
`tolerance
`
`17.7.4.1)
`
`Transcoded
`
`1027/1024 x 64/66 x
`
`40GBASE-R 41250 000
`
`(see clause
`
`(G.709 Standard) at section 17.
`
`17.8.2 Mapping an FC-1200 signal into OPU2e
`The nominal line rate for FC-1200 is 10 518 750 kbit/s i 100 ppm, and
`must therefore be compressed to a suitable rate to fit into an OPU2e.
`
`l7
`
`
`
`Case 2:20-cv-00030-JRG Document 1 Filed 02/05/20 Page 18 of 69 PageID #: 18
`Case 2:20-cv-00030-JRG Document 1 Filed 02/05/20 Page 18 of 69 PageID #: 18
`
`(G.709 Standard) at section 17.8.
`
`Optical transport unit (OTU)
`11
`The OTUk[V] conditions the ODUk for transport over an OCh network
`connection. The OTUk frame structure, including the OTUk FEC is
`completely standardized.
`
`(6.709 Standard) at section 11.
`
`64.
`
`The Accused 6.709 Instmmentalities meet the next element of claim 1 of
`
`the ’433 patent that recites “decoding the N 66B coding blocks to obtain data blocks
`
`containing data only and different types of control blocks each of which contains at least
`
`one control characters.” See, e.g.,:
`
`Transcoding from 66B blocks to 513B blocks
`B.3
`The transcoding process at the encoder operates on an input sequence of 66B code
`blocks.
`
`66B control blocks (after descrambling) follow the format shown in Figure B2.
`A group of eight 66B blocks is encoded into a single 513B block. The format is
`illustrated in Figure B.3.
`
`'13450739Tl-Ilm'lion0lh
`
`EH mmmummmmmu
`WWWWWWWWW .HW""""" “an“...mm,
`
`l
`H'] WWWWHH’HMW Vt“
`“mud-mama)
`EH mmmmmwmmNHW
`EH
`t’gflmflflflflflflflfl
`EH
`\mmmmmmmm
`EH
`mmmmmmmw
`EH mmmmmmmm mmwmmmwm
`Ezmngarmou
`Emm?—)Tl-imofi
`i______'$ lSB} inEEm
`i____::f g} maroon
`8 x 668 blocks
`51 BB block
`
`Figure B.3 — 513B block code format
`
`18
`
`
`
`Case 2:20-cv-00030-JRG Document 1 Filed 02/05/20 Page 19 of 69 PageID #: 19
`Case 2:20-cv-00030-JRG Document 1 Filed 02/05/20 Page 19 of 69 PageID #: 19
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