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You have to have a band limited signal to sample anyways, where it's at in the spectrum doesn't matter. The first thing you'll do before feeding anything to an ADC is running it through a filter to make _sure_ it's band limited. Whether that filter's at DC or some Rf doesn't matter.

Here's the result from his original paper where he specifically says that it doesn't have to be at DC:

https://imgur.com/uSywML7

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My point is that practically speaking, it does matter where the signal is, depending on how you filter it. If you lowpass filter an RF- (or, more realistically, IF-) centered signal, you can't just sample it at 2X bandwidth because you'll get aliases from the unwanted content between DC and the bottom frequency edge of the signal.

It may not be a common scenario anymore, but it was very common in the early GSM days when the signal wasn't mixed to DC but near-DC.

Ah yes you're right that you have to be careful, it'll fold at multiples of the nyquist frequency and you want to make sure your SOI is entirely contained in one of those zones.

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