Case 6:20-cv-00108-ADA Document 75 Filed 01/28/21 Page 1 of 8
`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE WESTERN DISTRICT OF TEXAS
`WACO DIVISION
`
`PARKERVISION, INC.,
`Plaintiff
`
`-v-
`INTEL CORPORATION,
`Defendant
`
`§
`§
`§
`§
`§
`§
`§
`
`W-20-CV-00108-ADA
`
`CLAIM CONSTRUCTION ORDER
`
`The Court held a Markman hearing on January 26, 2021. During that hearing, the Court
`
`provided its final constructions. The Court now enters those claim constructions.
`
`SIGNED this 26th day of January, 2021.
`
`ALAN D ALBRIGHT
`UNITED STATES DISTRICT JUDGE
`
`ParkerVision Ex. 2012
`Intel Corp. v. ParkerVision, Inc.
`IPR2020-01265
`
`

`

`Case 6:20-cv-00108-ADA Document 75 Filed 01/28/21 Page 2 of 8
`
`Term
`
`“universal frequency down-
`converter (UFD)”
`(’518 patent, claim 50)
`
`Plaintiff’s Proposed
`Construction
`“circuitry that generates a
`down converted output signal
`from an input signal”
`
`“energy transfer module”
`(’902 patent, claim 1)
`
`Plain and ordinary meaning
`
`“frequency down-conversion
`module”
`(’444 patent, claims 2, 3; ’474
`patent, claim 1)
`
`Plain and ordinary meaning
`
`“aliasing module”
`(’725 patent, claim 1)
`
`Plain and ordinary meaning
`
`Court’s Final Construction
`
`“circuitry that generates a
`down converted output signal
`from an input signal from a
`wide range of electromagnetic
`frequencies”
`
`Plain-and-ordinary meaning
`
`Plain-and-ordinary meaning
`
`Plain-and-ordinary meaning
`
`Defendants’ Proposed
`Construction
`“A down-converter that down-
`converts a carrier signal at an
`aliasing rate (i.e., by sampling
`at less than or equal to twice
`the frequency of the carrier
`signal)”
`
`“A module that down-converts
`an electromagnetic signal by
`transferring energy at an
`aliasing rate (i.e., by sampling
`at less than or equal to twice
`the frequency of the
`electromagnetic signal)”
`
`“A module that down-converts
`an input signal at an aliasing
`rate (i.e., by sampling at less
`than or equal to twice the
`frequency of the input signal)”
`
`“A module that down-converts
`an RF information signal at an
`aliasing rate (i.e., by sampling
`at less than or equal to twice
`the frequency of the RF
`information signal)”
`
`ParkerVision Ex. 2012
`Intel Corp. v. ParkerVision, Inc.
`IPR2020-01265
`
`

`

`Case 6:20-cv-00108-ADA Document 75 Filed 01/28/21 Page 3 of 8
`
`Term
`
`“system for frequency
`down-converting”
`(’513 patent, claim 19; ’528
`patent, claim 1; ’736 patent,
`claim 1)
`
`“frequency down-conversion
`module”
`(’673 patent, claim 1)
`
`Plaintiff’s Proposed
`Construction
`Plain and ordinary meaning
`
`Plain and ordinary meaning
`
`“apparatus for down-
`converting”
`(’673 patent, claim 13)
`
`Plain and ordinary meaning
`
`“under-samples”
`(’444 patent, claim 2;
`’474 patent, claim 6)
`
`“sampling at an aliasing rate”
`or “sampling at less than or
`equal to twice the frequency of
`the input signal”
`
`Defendants’ Proposed
`Construction
`“A system that down-converts
`a modulated carrier signal at an
`aliasing rate (i.e., by sampling
`at less than or equal to twice
`the frequency of the modulated
`carrier signal)”
`
`“A module that down-converts
`an input modulated carrier
`signal at an aliasing rate (i.e.,
`by sampling at less than or
`equal to twice the frequency of
`the input modulated carrier
`signal)”
`
`“An apparatus that down-
`converts a modulated carrier
`signal at an aliasing rate (i.e.,
`by sampling at less than or
`equal to twice the frequency of
`the modulated carrier signal)”
`
`“samples at less than or equal
`to twice the frequency of the
`input signal using negligible
`apertures (i.e., pulse widths)
`that tend towards zero time in
`duration”
`
`Court’s Final Construction
`
`Preamble is limiting. Plain-
`and-ordinary meaning.
`
`Plain-and-ordinary meaning
`
`Preamble is limiting. Plain-
`and-ordinary meaning.
`
`“sampling at less than or equal
`to twice the frequency of the
`input signal”
`
`ParkerVision Ex. 2012
`Intel Corp. v. ParkerVision, Inc.
`IPR2020-01265
`
`

`

`Case 6:20-cv-00108-ADA Document 75 Filed 01/28/21 Page 4 of 8
`
`Plaintiff’s Proposed
`Construction
`Plain and ordinary meaning
`
`Plain and ordinary meaning
`
`Term
`
`“the [] switch is coupled to the
`[] storage element at a [] node
`and coupled to a [] reference
`potential”
`(’474 patent, claim 1)
`
`[wherein said storage elements
`comprises] “a capacitor that
`reduces a DC offset voltage in
`said first-down converted
`signal and said second down-
`converted signal”
`(’444 patent, claim 4)
`
`Defendants’ Proposed
`Construction
`“the switch receives current
`from a storage element via a
`node, and shunts (i.e., diverts)
`current to a point held at a
`constant reference voltage”
`
`Court’s Final Construction
`
`Plain-and-ordinary meaning
`wherein “coupled” is directly
`connected or connected
`through a conductor (or a
`closed switch).
`
`[wherein said storage elements
`comprises] “a capacitor that
`reduces a DC offset voltage in
`both said first down-converted
`signal and said second down-
`converted signal”
`
`Plain-and-ordinary meaning
`wherein the “a capacitor” in
`each of the storage elements
`reduces a DC offset voltage in
`the corresponding down-
`converted signal
`
`“DC offset voltage”
`(’444 patent, claim 4)
`
`“a deviation of DC voltage
`from a reference voltage”
`
`“a DC voltage level that is
`added to a signal of interest by
`related circuitry”
`
`“energy storage element”
`(’513 patent, claim 19; ’528
`patent, claim 1;’736 patent,
`claims 1, 11, 21)
`
`“an element of an energy
`transfer system that stores non-
`negligible amounts of energy
`from an input electromagnetic
`signal for driving a low
`impedance load”
`
`“an element that stores non-
`negligible amounts of energy
`from an input electromagnetic
`(EM) signal”
`
`Plain-and-ordinary meaning
`wherein the plain-and-ordinary
`meaning is “the difference
`between the DC voltage of a
`signal and a reference voltage,
`e.g., ground”
`
`“an element of an energy
`transfer system that stores non-
`negligible amounts of energy
`from an input electromagnetic
`signal”
`
`ParkerVision Ex. 2012
`Intel Corp. v. ParkerVision, Inc.
`IPR2020-01265
`
`

`

`Case 6:20-cv-00108-ADA Document 75 Filed 01/28/21 Page 5 of 8
`
`Term
`
`“energy storage device”
`(’673 patent, claim 13)
`
`“energy storage module”
`(’902 patent, claim 1)
`
`“storage element”
`(’444 patent, claim 3; ’474
`patent, claim 1)
`
`“storage module”
`(’725 patent, claim 1)
`
`Plaintiff’s Proposed
`Construction
`“a device of an energy transfer
`system that stores non-
`negligible amounts of energy
`from an input electromagnetic
`signal for driving a low
`impedance load”
`
`“a module of an energy
`transfer system that stores non-
`negligible amounts of energy
`from an input electromagnetic
`signal for driving a low
`impedance load”
`
`“an element of an energy
`transfer system that stores non-
`negligible amounts of energy
`from an input electromagnetic
`signal for driving a low
`impedance load”
`
`“a module of an energy
`transfer system that stores non-
`negligible amounts of energy
`from an input electromagnetic
`signal for driving a low
`impedance load”
`
`Defendants’ Proposed
`Construction
`“a device that stores a non-
`negligible amount of energy
`from an input electromagnetic
`(EM) signal”
`
`Court’s Final Construction
`
`“a device of an energy transfer
`system that stores non-
`negligible amounts of energy
`from an input electromagnetic
`signal”
`
`“a module that stores a non-
`negligible amount of energy
`from an input electromagnetic
`(EM) signal”
`
`“a module of an energy
`transfer system that stores non-
`negligible amounts of energy
`from an input electromagnetic
`signal”
`
`“an element that stores a
`nonnegligible amount of
`energy from an input
`electromagnetic (EM) signal”
`
`“an element of an energy
`transfer system that stores non-
`negligible amounts of energy
`from an input electromagnetic
`signal”
`
`“a module that stores a non-
`negligible amount of energy
`from an input electromagnetic
`(EM) signal”
`
`“a module of an energy
`transfer system that stores non-
`negligible amounts of energy
`from an input electromagnetic
`signal”
`
`ParkerVision Ex. 2012
`Intel Corp. v. ParkerVision, Inc.
`IPR2020-01265
`
`

`

`Case 6:20-cv-00108-ADA Document 75 Filed 01/28/21 Page 6 of 8
`
`Term
`
`“modulated carrier signal”
`(’513 patent, claim 19; ’528
`patent, claim 1; ’736 patent,
`claim 1; ’673 patent, claims 1,
`13)
`
`Plaintiff’s Proposed
`Construction
`“electromagnetic signal at
`transmission frequency having
`at least one characteristic that
`has been modulated by a
`baseband signal”
`
`“sampling aperture”
`(’513 patent, claim 19; ’528
`patent, claim 1; ’736 patent,
`claims 1, 11;
`’673 patent, claim 13)
`
`“a period of time during which
`the switch is in its closed (on)
`state, thereby reducing a
`continuous-time signal to a
`discrete-time signal”
`
`“an electronic device for
`opening and closing a circuit
`as dictated by an independent
`control input”
`
`“switch” / “switching device” /
`“switching module”
`(’528 patent, claims 1, 5, 8, 17;
`’444 patent, claim 3; ’474
`patent; claim 1; ’513 patent,
`claim 19; ’518 patent, claim
`50; ’736 patent, claims 1, 11;
`’673 patent, claims 1, 13; ’725
`patent, claim 1; ’902 patent,
`claim 1)
`
`Defendants’ Proposed
`Construction
`“a carrier signal that is
`modulated by a baseband
`signal”
`
`“a period of time during which
`the switch is in its closed (i.e.,
`on) state as part of the process
`of reducing a continuous-time
`signal to a discrete-time
`signal”
`
`“an electronic device for
`opening and closing a circuit”
`
`Court’s Final Construction
`
`“an electromagnetic signal at a
`transmission frequency having
`at least one characteristic that
`has been modulated by a
`baseband signal”
`
`“a period of time during which
`the switch is in its closed (i.e.,
`on) state”
`
`Plain-and-ordinary meaning
`wherein the plain-and-ordinary
`meaning is “an electronic
`device for opening and closing
`a circuit as dictated by an
`independent control input”
`
`ParkerVision Ex. 2012
`Intel Corp. v. ParkerVision, Inc.
`IPR2020-01265
`
`

`

`Case 6:20-cv-00108-ADA Document 75 Filed 01/28/21 Page 7 of 8
`
`Plaintiff’s Proposed
`Construction
`“a lower frequency signal
`formed from sampled energy
`transferred from the
`electromagnetic signal when
`the switch module is closed
`and from sampled energy
`discharged from the storage
`module when the switch
`module is open”
`
`Plain and ordinary meaning
`
`
`Defendants’ Proposed
`Construction
`“a down-converted signal
`being created from sampled
`energy stored in the energy
`storage module”
`
`
`Indefinite
`
`
`Plain and ordinary meaning
`
`
`Indefinite
`
`
`Court’s Final Construction
`
`“a lower frequency signal
`formed from sampled energy
`transferred from the
`electromagnetic signal when
`the switch module is closed
`and from sampled energy
`discharged from the storage
`module when the switch
`module is open”
`
`Not indefinite.
`
`Plain-and-ordinary meaning
`wherein the plain-and-ordinary
`meaning is “the energy that
`could potentially be discharged
`during any given discharge
`cycle is not completely
`discharged”
`
`Not indefinite. Plain-and-
`ordinary meaning.
`
`
`Term
`
`“a down-converted signal
`being generated from said
`sampled energy”
`(’902 patent, claim 1)
`
`
`“the energy discharged during
`any given discharge cycle is
`not completely discharged”
`(’736 patent, claims 1
`and 11; ’528 patent, claim 9)
`
`
`“between six and fifty percent
`of the energy transferred from
`the RF information signal to
`the storage module is
`discharged from the storage
`module”
`(’725 patent, claim 17)
`
`
`ParkerVision Ex. 2012
`Intel Corp. v. ParkerVision, Inc.
`IPR2020-01265
`
`

`

`Case 6:20-cv-00108-ADA Document 75 Filed 01/28/21 Page 8 of 8
`
`Term
`
`“between six and twenty-five
`percent of the energy
`transferred from the RF
`information signal to the
`storage module when is
`discharged
`(’725 patent, claim 18)
`
`“between ten and twenty
`percent of the energy
`transferred from the RF
`information signal to the
`storage module discharged
`from the storage module”
`(’725 patent, claim 19)
`
`“separate integration module”
`(’528 patent, claim 17)
`
`“substantially the same size”
`(’902 patent, claim 5)
`
`
`
`
`Plaintiff’s Proposed
`Construction
`Plain and ordinary meaning
`
`
`Defendants’ Proposed
`Construction
`Indefinite
`
`
`Court’s Final Construction
`
`Not indefinite. Plain-and-
`ordinary meaning.
`
`
`Plain and ordinary meaning
`
`
`Indefinite
`
`
`Not indefinite. Plain-and-
`ordinary meaning.
`
`
`Plain and ordinary meaning
`
`
`Plain and ordinary meaning
`
`
`Indefinite
`
`
`Indefinite
`
`
`Not indefinite. Plain-and-
`ordinary meaning.
`
`Not indefinite. Plain-and-
`ordinary meaning.
`
`
`ParkerVision Ex. 2012
`Intel Corp. v. ParkerVision, Inc.
`IPR2020-01265
`
`