Presuming that only the 2nd argument of the kronecker product term is an optimization variable, and everything else is input data, this should be straightforward to enter using kron, which CVX supports in such case, as discussed in my answer to your previous question Some questions about kron in CVX? - #2 by Mark_L_Stone . And use square_pos(norm(...)). I’ll let you figure out what all the indexing is, and how to deal with that.