Case 6:20-cv-00108 Document 1 Filed 02/11/20 Page 1 of 27
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`UNITED STATES DISTRICT COURT
`WESTERN DISTRICT OF TEXAS
`WACO DIVISION
`
` Plaintiff,
`
`
`
`PARKERVISION, INC.,
`
`
`
` v.
`
`INTEL CORPORATION,
`
` Defendant.
`
`
`Case No. 6:20-cv-00108
`
`JURY TRIAL DEMANDED
`
`COMPLAINT FOR PATENT INFRINGEMENT
`
`Plaintiff ParkerVision, Inc. (“ParkerVision”), by and through its counsel, files this
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`
`
`
`
`
`
`
`
`Complaint against Defendant Intel Corporation (“Intel”) for patent infringement of
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`United States Patent Nos. 6,049,706; 6,580,902; 7,110,444; 7,539,474; 8,588,725; 8,660,513;
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`9,246,736 and 9,444,673 (the “patents-in-suit”) (Exhibits 1-8) and alleges as follows:
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`NATURE OF THE ACTION
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`1.
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`This is an action for patent infringement arising under the patent laws of
`
`the United States, 35 U.S.C. §§ 1 et seq.
`
`PARTIES
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`2.
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`Plaintiff ParkerVision is a Florida corporation with its principal place of
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`business at 9446 Philips Highway, Jacksonville, Florida 32256.
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`3.
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`On information and belief, Defendant Intel is a Delaware corporation with
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`a place of business at 2200 Mission College Boulevard, Santa Clara, California 95054.
`
`
`
`ParkerVision Ex. 2001
`Intel Corp. v. ParkerVision, Inc.
`IPR No. 2020-01265
`
`
`
`UNITED STATES DISTRICT COURT
`WESTERN DISTRICT OF TEXAS
`WACO DIVISION
`
` Plaintiff,
`
`
`
`PARKERVISION, INC.,
`
`
`
` v.
`
`INTEL CORPORATION,
`
` Defendant.
`
`
`Case No. 6:20-cv-00108
`
`JURY TRIAL DEMANDED
`
`COMPLAINT FOR PATENT INFRINGEMENT
`
`Plaintiff ParkerVision, Inc. (“ParkerVision”), by and through its counsel, files this
`
`
`
`
`
`
`
`
`
`Complaint against Defendant Intel Corporation (“Intel”) for patent infringement of
`
`United States Patent Nos. 6,049,706; 6,580,902; 7,110,444; 7,539,474; 8,588,725; 8,660,513;
`
`9,246,736 and 9,444,673 (the “patents-in-suit”) (Exhibits 1-8) and alleges as follows:
`
`NATURE OF THE ACTION
`
`1.
`
`This is an action for patent infringement arising under the patent laws of
`
`the United States, 35 U.S.C. §§ 1 et seq.
`
`PARTIES
`
`2.
`
`Plaintiff ParkerVision is a Florida corporation with its principal place of
`
`business at 9446 Philips Highway, Jacksonville, Florida 32256.
`
`3.
`
`On information and belief, Defendant Intel is a Delaware corporation with
`
`a place of business at 2200 Mission College Boulevard, Santa Clara, California 95054.
`
`
`
`ParkerVision Ex. 2001
`Intel Corp. v. ParkerVision, Inc.
`IPR No. 2020-01265
`
`
`
`Case 6:20-cv-00108 Document 1 Filed 02/11/20 Page 2 of 27
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`4.
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`On information and belief, Intel has places of business in this judicial
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`district: 1300 S Mopac Expressway, Austin, Texas 78746; 6500 River Place Blvd, Bldg
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`7, Austin, Texas 78730 and 5113 Southwest Parkway, Austin, Texas 78735 (collectively,
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`“Austin Offices”). https://www.intel.com/content/www/us/en/location/usa.html.
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`5.
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`Intel can be served with process through its registered agent for service in
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`Texas: CT Corporation System, 1999 Bryan Street, Suite 900, Dallas, Texas 75201.
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`6.
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`On information and belief, since April 1989, Intel has been registered to do
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`business in the State of Texas under Texas Taxpayer Number 19416727436.
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`JURISDICTION AND VENUE
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`7.
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`This Court has jurisdiction over the subject matter of this action pursuant
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`to 28 U.S.C. §§ 1331 and 1338(a) because the action arises under the patent laws of the
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`United States, 35 U.S.C. §§ 1 et seq.
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`8.
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`Venue is proper in this judicial district pursuant to 28 U.S.C. §§ 1391(b),
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`(c), (d) and/or 1400(b).
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`9.
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`Intel is subject to this Court’s personal jurisdiction, in accordance with due
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`process and/or the Texas Long Arm Statute because Intel “[r]ecruits Texas residents,
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`directly or through an intermediary located in this state, for employment inside or
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`outside this state.” See Tex. Civ. Prac. & Rem. Code § 17.042.
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`10.
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`This Court has personal jurisdiction over Intel because Intel has sufficient
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`minimum contacts with this forum as a result of business conducted within the State of
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`Texas and this judicial district. In particular, this Court has personal jurisdiction over
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`Intel because, inter alia, Intel, on information and belief: (1) has substantial, continuous,
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`2
`
`ParkerVision Ex. 2001
`Intel Corp. v. ParkerVision, Inc.
`IPR No. 2020-01265
`
`
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`Case 6:20-cv-00108 Document 1 Filed 02/11/20 Page 3 of 27
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`and systematic business contacts in this judicial district; (2) owns, manages and
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`operates facilities in this judicial district; (3) enjoys substantial income from its
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`operations in this judicial district, and (4) employs Texas residents in this judicial
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`district.
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`11.
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`Intel has purposefully availed itself of the privileges of conducting
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`business within this judicial district; has established sufficient minimum contacts with
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`this judicial district such that it should reasonably and fairly anticipate being hauled
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`into court in this judicial district; has purposefully directed activities at residents of this
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`judicial district; and at least a portion of the patent infringement claims alleged in this
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`Complaint arise out of or are related to one or more of the foregoing activities.
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`12.
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`This Court also has personal jurisdiction over Intel because Intel, directly
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`and/or through its subsidiaries, affiliates, or intermediaries, makes, uses, offers for sale,
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`sells, imports, advertises, makes available and/or markets infringing products in the
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`United States, the State of Texas and/or this judicial district, as described more
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`particularly below.
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`13. On information and belief, Intel maintains a significant physical presence
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`in this judicial district.
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`14. On information and belief, Intel uses its Austin Offices as a regular and
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`established place of business. On information and belief, Intel has employed over 1700
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`current and former employees in the Austin area.
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`https://www.linkedin.com/company/intel-corporation/people/?facetGeoRegion=
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`us%3A64.
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`3
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`ParkerVision Ex. 2001
`Intel Corp. v. ParkerVision, Inc.
`IPR No. 2020-01265
`
`
`
`Case 6:20-cv-00108 Document 1 Filed 02/11/20 Page 4 of 27
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`15.
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`Intel describes its operations in Austin on its website: “Located in the
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`capitol city of Texas, Intel Austin is an important research and development center for
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`the Intel technology that is changing the way we live, work, and play. Among the
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`innovations developed in Austin are core technologies for next-generation
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`microprocessors, platforms and base software; groundbreaking silicon solutions for
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`computing and communications devices, which include handheld computing and
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`cellular communications; and cutting-edge network storage products.”
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`https://www.intel.com/content/www/us/en/jobs/locations/united-
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`states/sites/austin.html.
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`16. On information and belief, Intel has hundreds of H-1B labor condition
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`applications for people employed in Austin, Texas. https://h1bsalary.online/search?
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`searchtext=INTEL+CORPORATION&year=&minsalary=&state=&worksite_city=AUST
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`IN&job_title=. Employees holding an H-1B visa are employed in a specialty occupation
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`that requires “theoretical and practical application of a body of highly specialized
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`knowledge . . . and attainment of a bachelor’s or higher degree in the specific specialty.”
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`See generally 8 U.S.C. § 1184. As such, Intel employees in Austin, Texas are highly
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`specialized and important to the operation of Intel.
`
`17.
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`Intel lists job openings on its website for positions in Austin, Texas.
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`4
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`ParkerVision Ex. 2001
`Intel Corp. v. ParkerVision, Inc.
`IPR No. 2020-01265
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`
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`Case 6:20-cv-00108 Document 1 Filed 02/11/20 Page 5 of 27
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`https://jobs.intel.com/ListJobs/All/Search/state/tx/ (visited on 1/7/2020).
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`18. On information and belief, Intel has litigated/is litigating cases before this
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`Court in which it admitted that venue was proper, did not contest personal jurisdiction,
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`and/or filed counterclaims. See, e.g., Flash-Control, LLC v. Intel Corp., Case No. 1:19-cv-
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`01107 (W.D. Tex.); VLSI Tech. LLC v. Intel Corp., Case No. 1:19-cv-00977 (W.D. Tex.).
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`BACKGROUND
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`19.
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`In 1989, Jeff Parker and David Sorrells started ParkerVision in
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`Jacksonville, Florida. Through the mid-1990s, ParkerVision focused on developing
`
`5
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`ParkerVision Ex. 2001
`Intel Corp. v. ParkerVision, Inc.
`IPR No. 2020-01265
`
`
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`Case 6:20-cv-00108 Document 1 Filed 02/11/20 Page 6 of 27
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`
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`commercial video cameras, e.g., for television broadcasts. The cameras used radio
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`frequency (RF) technology to automatically track the camera’s subject.
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`20. When developing consumer video cameras, however, ParkerVision,
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`encountered a problem – the power and battery requirements for RF communications
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`made a cost effective, consumer-sized product impractical. So, Mr. Sorrels and
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`ParkerVision’s engineering team began researching ways to solve this problem.
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`21. At the time, a decade’s-old RF technology called super-heterodyne
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`dominated the consumer products industry. But this technology was not without its
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`own problems – the circuity was large and required significant power.
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`22.
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`From 1995 through 1998, ParkerVision engineers developed an innovative
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`method of RF direct conversion by a process of sampling a RF carrier signal and
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`transferring energy to create a down-converted baseband signal.
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`23. After creating prototype chips and conducting tests, ParkerVision soon
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`realized that its technology led to improved RF receiver performance, lower power
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`consumption, reduced size and integration benefits. In other words, RF receivers could
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`be built smaller, cheaper and with greater improved performance.
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`24.
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`ParkerVision’s innovations did not stop there. ParkerVision went on to
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`develop additional RF down-conversion technologies, RF up-conversion technologies
`
`and other related direct-conversion technologies. ParkerVision also developed
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`complementary wireless communications technologies that involved interactions,
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`processes, and controls between the baseband processor and the transceiver, which
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`improved and enhanced the operation of transceivers that incorporate ParkerVision’s
`
`6
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`ParkerVision Ex. 2001
`Intel Corp. v. ParkerVision, Inc.
`IPR No. 2020-01265
`
`
`
`Case 6:20-cv-00108 Document 1 Filed 02/11/20 Page 7 of 27
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`
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`down-converter and up-converter technologies. To date, ParkerVision has been granted
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`over 200 patents related to its innovations including, the patents-in-suit.
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`25. After spending millions of dollars developing RF technologies,
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`ParkerVision sought to partner with larger, well-established companies who could use
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`ParkerVision’s innovations to manufacture highly integrated circuits on a large scale for
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`the consumer market. In the late 1990s, ParkerVision began meeting with companies
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`such as Qualcomm, an industry leader in RF chip technology.
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`26. Qualcomm quickly recognized the significance of ParkerVision’s direct-
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`conversion technology. In internal communications, Qualcomm engineers and senior
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`executives lauded ParkerVision’s technology: “This is virtually the holy grail of RF
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`receiver designs –- achievable and within practical limits!”; “[w]e are very impressed
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`with the performance! We can make a phone with [ParkerVision’s] parts with higher
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`dynamic range than today’s phones” and “[t]he truth is Parker Vision have [sic]
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`stumbled on something revolutionary.” After testing ParkerVision’s technology, a
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`Qualcomm senior executive and former engineer stated “[t]o tell you the truth, I am
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`more of a believer now than when I started talking with [ParkerVision]” and
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`Qualcomm’s then-division President stated “this is critical technology that we must
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`land based on what we have seen so far. It offers revolutionary rf versus power
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`performa[n]ce based on early te[s]t resul[t]s.”
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`27. Qualcomm and ParkerVision never entered into an agreement.
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`7
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`ParkerVision Ex. 2001
`Intel Corp. v. ParkerVision, Inc.
`IPR No. 2020-01265
`
`
`
`Case 6:20-cv-00108 Document 1 Filed 02/11/20 Page 8 of 27
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`28.
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`Then, in the mid-2000s, with the rise in popularity of smartphones, there
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`became a critical need for smaller, more efficient receivers capable of supporting
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`multiple frequency bands. ParkerVision’s technology addressed this need.
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`29.
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`In 2011, a ParkerVision engineer found a Qualcomm conference paper
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`describing Qualcomm’s then-current RF technology. The technology was strikingly
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`similar to the technology that ParkerVision disclosed to Qualcomm years earlier.
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`Through reverse engineering of Qualcomm’s RF chips, ParkerVision confirmed that
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`Qualcomm had been using ParkerVision’s patented technology. And, Qualcomm has
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`enjoyed great financial success by doing so. ParkerVision sued Qualcomm and its
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`customers for patent infringement and has been locked in litigation ever since.
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`30.
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`The damage to ParkerVision, however, was already done. On information
`
`and belief, seeing Qualcomm’s success, other chip manufacturers such as Intel shifted to
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`using ParkerVision’s technology. This shift in the industry ultimately led to the
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`abandonment of super-heterodyne technology.
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`31.
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`ParkerVision’s technology helped make today’s mobile devices, such as
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`smart phones and tablets, a reality by enabling RF chips used in these devices to be
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`smaller, cheaper, and more efficient, and with higher performance.
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`INTEL CHIPS
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`32. Until recently, Intel (or those acting on its behalf) made, used, sold,
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`offered to sell and/or imported RF transceiver chips/modems, for example, for use in
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`smartphones. These chips include, without limitation, the Intel PMB 5750, PMB 5757
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`and PMB 5762 (each an “Intel Chip”; collectively, the “Intel Chips”).
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`8
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`ParkerVision Ex. 2001
`Intel Corp. v. ParkerVision, Inc.
`IPR No. 2020-01265
`
`
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`Case 6:20-cv-00108 Document 1 Filed 02/11/20 Page 9 of 27
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`33.
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`Intel Chips provide cellular connectivity for devices such as Apple
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`iPhones.
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`34. On information and belief, the PMB 5750 was incorporated into devices
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`including, without limitation, the Apple iPhone 7 and 7 Plus.1 On information and
`
`belief, the PMB 5757 was incorporated into devices including, without limitation, the
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`Apple iPhone 8, 8 Plus and X.2 On information and belief, the PMB 5762 was
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`incorporated into devices including, without limitation, the Apple iPhone XR, XS and
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`XS Max. 3
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`35. On information and belief, in December 2019, Apple acquired Intel’s
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`smartphone modem business for $1 billion. https://www.engadget.com/2019/12/02/
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`apple-owns-intel-modem-business/.
`
`THE ASSERTED PATENTS
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`United States Patent No. 6,049,706
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`36. On April 11, 2000, the United States Patent and Trademark Office duly
`
`and legally issued United States Patent No. 6,049,706 (“the ‘706 patent”) entitled
`
`
`1 See Wegner et al., Apple iPhone 7 Teardown, TechInsights (Sept. 15, 2016),
`https://techinsights.com/blog/apple-iphone-7-teardown; see also Srivatsan Sridhar, Apple iPhone 7 and 7
`Plus teardown confirms bigger battery, Intel LTE modem in some models and more, FoneArena (Sept. 16, 2016),
`https://www.fonearena.com/blog/197580/apple-iphone-7-and-7-plus-teardown-confirms-bigger-
`battery-intel-lte-modem-in-some-models-and-more.html.
`2 See Yang et al., Apple iPhone X Teardown, TechInsights (last modified Nov. 8, 2017),
`https://www.techinsights.com/blog/apple-iphone-x-teardown.
`3 See iPhone XS and XS Max Teardown, iFixit (Sept. 21, 2018),
`https://www.ifixit.com/Teardown/iPhone+XS+and+XS+Max+Teardown/113021; iPhone XR Teardown,
`iFixit (Oct. 26, 2018), https://www.ifixit.com/Teardown/iPhone+XR+Teardown/114123.
`
`
`9
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`ParkerVision Ex. 2001
`Intel Corp. v. ParkerVision, Inc.
`IPR No. 2020-01265
`
`
`
`Case 6:20-cv-00108 Document 1 Filed 02/11/20 Page 10 of 27
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`
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`“Integrated Frequency Translation and Selectivity” to inventor Robert W. Cook et al. A
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`true and correct copy of the ‘706 patent is attached as Exhibit 1.
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`37.
`
`The ‘706 patent is presumed valid under 35 U.S.C. §282.
`
`38.
`
`ParkerVision owns all rights, title, and interest in the ‘706 patent.
`
`United States Patent No. 6,580,902
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`39. On June 17, 2003, the United States Patent and Trademark Office duly and
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`legally issued United States Patent No. 6,580,902 (“the ‘902 patent”) entitled “Frequency
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`Translation Using Optimized Switch Structures” to inventor David F. Sorrells et al. A
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`true and correct copy of the ‘902 patent is attached as Exhibit 2.
`
`40.
`
`The ‘902 patent is presumed valid under 35 U.S.C. §282.
`
`41.
`
`ParkerVision owns all rights, title, and interest in the ‘902 patent.
`
`United States Patent No. 7,110,444
`
`42. On September 19, 2006, the United States Patent and Trademark Office
`
`duly and legally issued United States Patent No. 7,110,444 (“the ‘444 patent”) entitled
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`“Wireless Local Area Network (WLAN) Using Universal Frequency Translation
`
`Technology Including Multi-Phase Embodiments and Circuit Implementations” to
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`inventor David F. Sorrells et al. A true and correct copy of the ‘444 patent is attached as
`
`Exhibit 3.
`
`43.
`
`The ‘444 patent is presumed valid under 35 U.S.C. §282.
`
`44.
`
`ParkerVision owns all rights, title, and interest in the ‘444 patent.
`
`10
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`ParkerVision Ex. 2001
`Intel Corp. v. ParkerVision, Inc.
`IPR No. 2020-01265
`
`
`
`Case 6:20-cv-00108 Document 1 Filed 02/11/20 Page 11 of 27
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`United States Patent No. 7,539,474
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`45. On May 26, 2009, the United States Patent and Trademark Office duly and
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`legally issued United States Patent No. 7,539,474 (“the ‘474 patent”) entitled “DC Offset,
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`Re-Radiation, and I/Q Solutions Using Universal Frequency Translation Technology”
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`to inventor David F. Sorrells et al. A true and correct copy of the ‘474 patent is attached
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`as Exhibit 4.
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`46.
`
`The ‘474 patent is presumed valid under 35 U.S.C. §282.
`
`47.
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`ParkerVision owns all rights, title, and interest in the ‘474 patent.
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`United States Patent No. 8,588,725
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`48. On November 19, 2013, the United States Patent and Trademark Office
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`duly and legally issued United States Patent No. 8,588,725 (“the ‘725 patent”) entitled
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`“Apparatus, System, and Method For Down Converting and Up-Converting
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`Electromagnetic Signals” to inventor David F. Sorrells et al. A true and correct copy of
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`the ‘725 patent is attached as Exhibit 5.
`
`49.
`
`The ‘725 patent is presumed valid under 35 U.S.C. §282.
`
`50.
`
`ParkerVision owns all rights, title, and interest in the ‘725 patent.
`
`United States Patent No. 8,660,513
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`51. On February 25, 2014, the United States Patent and Trademark Office duly
`
`and legally issued United States Patent No. 8,660,513 (“the ‘513 patent”) entitled
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`“Method and System for Down-Converting an Electromagnetic Signal, and Transforms
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`for Same, and Aperture Relationships” to inventor David F. Sorrells et al. A true and
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`correct copy of the ‘513 patent is attached as Exhibit 6.
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`11
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`ParkerVision Ex. 2001
`Intel Corp. v. ParkerVision, Inc.
`IPR No. 2020-01265
`
`
`
`Case 6:20-cv-00108 Document 1 Filed 02/11/20 Page 12 of 27
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`52.
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`The ‘513 patent is presumed valid under 35 U.S.C. §282.
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`53.
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`ParkerVision owns all rights, title, and interest in the ‘513 patent.
`
`United States Patent No. 9,246,736
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`54. On January 26, 2016, the United States Patent and Trademark Office duly
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`and legally issued United States Patent No. 9,246,736 (“the ‘736 patent”) entitled
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`“Method and System for Down-Converting an Electromagnetic Signal” to inventor
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`David F. Sorrells et al. A true and correct copy of the ‘736 patent is attached as Exhibit 7.
`
`55.
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`The ‘736 patent is presumed valid under 35 U.S.C. §282.
`
`56.
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`ParkerVision owns all rights, title, and interest in the ‘736 patent.
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`United States Patent No. 9,444,673
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`57. On September 13, 2016, the United States Patent and Trademark Office
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`duly and legally issued United States Patent No. 9,444,673 (“the ‘673 patent”) entitled
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`“Methods and Systems for Down-Converting a Signal Using a Complementary
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`Transistor Structure” to inventor David F. Sorrells et al. A true and correct copy of the
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`‘673 patent is attached as Exhibit 8.
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`58.
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`The ‘673 patent is presumed valid under 35 U.S.C. §282.
`
`59.
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`ParkerVision owns all rights, title, and interest in the ‘673 patent.
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`CLAIMS FOR RELIEF
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`COUNT I - Infringement of United States Patent No. 6,049,706
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`60.
`
`The allegations set forth above are re-alleged and incorporated by
`
`reference as if they were set forth fully here.
`
`12
`
`ParkerVision Ex. 2001
`Intel Corp. v. ParkerVision, Inc.
`IPR No. 2020-01265
`
`
`
`Case 6:20-cv-00108 Document 1 Filed 02/11/20 Page 13 of 27
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`61.
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`Intel directly infringes (literally and/or under the doctrine of equivalents)
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`the ’706 patent by making, using, selling, offering for sale, and/or importing into the
`
`United States products covered by at least claim 1 of the ’706 patent.
`
`62.
`
`Intel products that infringe one or more claims of the ’706 patent include,
`
`but are not limited to, the Intel Chips, and any other Intel device that is capable of
`
`filtering and down-converting a higher-frequency signal to a lower-frequency signal as
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`claimed in the ’706 patent. On information and belief, Intel uses the Intel Chips at least
`
`by testing the Intel Chips in the United States.
`
`63.
`
`Each Intel Chip is/includes an apparatus for filtering and down-
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`converting (e.g., a higher frequency RF signal to a lower frequency signal). Each Intel
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`Chip includes a frequency translator, comprising a down-convert and delay module to
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`under-sample an input signal (e.g., high frequency RF signal) to produce an input
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`sample of a down-converted image of said input signal, and to delay said input sample.
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`Each Intel Chip also includes a filter, comprising at least a portion of said down-convert
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`and delay module, at least one delay module to delay instances of an output signal, and
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`an adder (e.g., operational amplifier with parallel resistor-capacitor feedback) to
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`combine at least said delayed input sample with at least one of said delayed instances of
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`said output signal to generate an instance of said output signal.
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`64.
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`The down-convert and delay module under-samples (e.g., at a sample rate
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`below the Nyquist rate) said input signal according to a control signal (e.g., local
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`oscillator (LO) signal), wherein a frequency of said control signal is equal to a frequency
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`13
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`ParkerVision Ex. 2001
`Intel Corp. v. ParkerVision, Inc.
`IPR No. 2020-01265
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`
`
`Case 6:20-cv-00108 Document 1 Filed 02/11/20 Page 14 of 27
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`of said input signal plus or minus a frequency of said down-converted image, divided
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`by n, where n represents a harmonic or sub-harmonic of said input signal.
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`65.
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`ParkerVision has been damaged by the direct infringement of Intel and is
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`suffering and will continue to suffer irreparable harm and damages as a result of this
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`infringement.
`
`COUNT II - Infringement of United States Patent No. 6,580,902
`
`66.
`
`The allegations set forth above are re-alleged and incorporated by
`
`reference as if they were set forth fully here.
`
`67.
`
`Intel directly infringes (literally and/or under the doctrine of equivalents)
`
`the ’902 patent by making, using, selling, offering for sale, and/or importing into the
`
`United States products covered by at least claim 1 of the ’902 patent.
`
`68.
`
`Intel products that infringe one or more claims of the ’902 patent include,
`
`but are not limited to, the Intel Chips, and any other Intel device that is capable of
`
`down-converting a higher-frequency signal to a lower-frequency signal as claimed in
`
`the ’902 patent. On information and belief, Intel uses the Intel Chips at least by testing
`
`the Intel Chips in the United States.
`
`69.
`
`Each Intel Chip is/includes a circuit for down-converting an
`
`electromagnetic signal (e.g., high frequency RF signal) to a lower frequency signal. Each
`
`Intel Chip includes an energy transfer module having a switch module (e.g., module
`
`with one or more transistors) and an energy storage module (e.g., module with one or
`
`more capacitors). The energy transfer module of the Intel Chip samples the
`
`electromagnetic signal at an energy transfer rate (e.g., LO rate with a 25% duty cycle),
`
`14
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`ParkerVision Ex. 2001
`Intel Corp. v. ParkerVision, Inc.
`IPR No. 2020-01265
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`
`
`Case 6:20-cv-00108 Document 1 Filed 02/11/20 Page 15 of 27
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`according to an energy transfer signal (e.g., LO signal), to obtain sampled energy. The
`
`sampled energy is stored by said energy storage module (e.g., one or more capacitors).
`
`A down-converted signal (e.g., baseband signal) is generated from the sampled energy.
`
`70.
`
`The energy transfer module of each Intel Chip has transistors coupled
`
`together. The transistors have a common first port, a common second port, and a
`
`common control port. The electromagnetic signal is accepted at the common first port
`
`and the sampled energy is present at the common second port.
`
`71.
`
`The common control port accepts the energy transfer signal, which has a
`
`control frequency that is substantially equal to said energy transfer rate.
`
`72.
`
`Each of the transistors of the Intel Chip has a drain, a source, and a gate.
`
`The common first port couples together drains of the transistors, the common second
`
`port couples together sources of the transistors, and the common control port couples
`
`together gates of the transistors.
`
`73.
`
`ParkerVision has been damaged by the direct infringement of Intel and is
`
`suffering and will continue to suffer irreparable harm and damages as a result of this
`
`infringement.
`
`COUNT III - Infringement of United States Patent No. 7,110,444
`
`74.
`
`The allegations set forth above are re-alleged and incorporated by
`
`reference as if they were set forth fully here.
`
`75.
`
`Intel directly infringes (literally and/or under the doctrine of equivalents)
`
`the ’444 patent by making, using, selling, offering for sale, and/or importing into the
`
`United States products covered by at least claim 2 of the ‘444 patent.
`
`15
`
`ParkerVision Ex. 2001
`Intel Corp. v. ParkerVision, Inc.
`IPR No. 2020-01265
`
`
`
`Case 6:20-cv-00108 Document 1 Filed 02/11/20 Page 16 of 27
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`
`
`76.
`
`Intel products that infringe one or more claims of the ’444 patent include,
`
`but are not limited to, the Intel Chips, and any other Intel device that is capable of
`
`down-converting a higher-frequency signal to a lower-frequency signal as claimed in
`
`the ’444 patent. On information and belief, Intel uses the Intel Chips at least by testing
`
`the Intel Chips in the United States.
`
`77.
`
`Each Intel Chip is/includes a wireless modem apparatus (e.g., a
`
`modulation/demodulation device providing bi-directional, over-the-air data
`
`transmission) having a receiver for frequency down-converting an input signal (e.g.,
`
`high frequency RF signal). The receiver for frequency down-converting an input signal
`
`includes a first frequency down-conversion module to down-convert the input signal,
`
`wherein said first frequency down-conversion module down-converts said input signal
`
`according to a first control signal (e.g., LO signal) and outputs a first down-converted
`
`signal (e.g., baseband signal); a second frequency down-conversion module to down-
`
`convert said input signal, wherein said second frequency down-conversion module
`
`down-converts said input signal according to a second control signal (e.g., LO signal)
`
`and outputs a second down-converted signal (e.g., baseband signal); and a subtractor
`
`module (e.g., module with differential amplifier) that subtracts said second down-
`
`converted signal from said first down-converted signal and outputs a down-converted
`
`signal.
`
`78.
`
`The first frequency down-conversion module under-samples (e.g., at a
`
`sample rate below the Nyquist rate) the input signal according to the first control signal,
`
`and the second frequency down-conversion module under-samples samples (e.g., at a
`
`16
`
`ParkerVision Ex. 2001
`Intel Corp. v. ParkerVision, Inc.
`IPR No. 2020-01265
`
`
`
`Case 6:20-cv-00108 Document 1 Filed 02/11/20 Page 17 of 27
`
`
`
`sample rate below the Nyquist rate) the input signal according to said second control
`
`signal.
`
`79.
`
`ParkerVision has been damaged by the direct infringement of Intel, and is
`
`suffering and will continue to suffer irreparable harm and damages as a result of this
`
`infringement.
`
`COUNT IV - Infringement of United States Patent No. 7,539,474
`
`80.
`
`The allegations set forth above are re-alleged and incorporated by
`
`reference as if they were set forth fully here.
`
`81.
`
`Intel directly infringes (literally and/or under the doctrine of equivalents)
`
`the ‘474 patent by making, using, selling, offering for sale, and/or importing into the
`
`United States products covered by at least claim 1 of the ‘474 patent.
`
`82.
`
`Intel products that infringe one or more claims of the ‘474 patent include,
`
`but are not limited to, the Intel Chips, and any other Intel device that is capable of
`
`down-converting a higher-frequency signal to a lower-frequency signal as claimed in
`
`the ‘474 patent. On information and belief, Intel uses the Intel Chips at least by testing
`
`the Intel Chips in the United States.
`
`83.
`
`Each Intel Chip is/includes an apparatus for down-converting an input
`
`signal (e.g., high frequency RF signal) to a lower frequency signal. Each Intel Chip
`
`includes a first frequency down-conversion module that receives an input signal (e.g.,
`
`high frequency RF signal), wherein the first frequency down-conversion module down-
`
`converts the input signal according to a first control signal (e.g., LO signal) and outputs
`
`a first down-converted signal (e.g., baseband signal); a second frequency down-
`
`17
`
`ParkerVision Ex. 2001
`Intel Corp. v. ParkerVision, Inc.
`IPR No. 2020-01265
`
`
`
`Case 6:20-cv-00108 Document 1 Filed 02/11/20 Page 18 of 27
`
`
`
`conversion module that receives the input signal, wherein the second frequency down-
`
`conversion module down-converts the input signal according to a second control signal
`
`(e.g., LO signal) and outputs a second down-converted signal (e.g., baseband signal);
`
`and a combining module (e.g., module with a differential amplifier) that combines the
`
`second down-converted signal with the first down-converted signal and outputs a
`
`single channel down-converted signal.
`
`84.
`
`The first frequency down-conversion module of each Intel Chip includes a
`
`first switch (e.g., transistor) and a first storage element (e.g., one or more capacitors),
`
`wherein the first switch is coupled to the first storage element at a first node (e.g., port)
`
`and coupled to a first reference potential (e.g., ground).
`
`85.
`
`The second frequency down-conversion module of each Intel Chip
`
`includes a second switch (e.g., transistor) and a second storage element (e.g., one or
`
`more capacitors), wherein the second switch is coupled to the second storage element at
`
`a second node (e.g., port) and coupled to a second reference potential (e.g., ground).
`
`86.
`
`ParkerVision has been damaged by the direct infringement of Intel, and is
`
`suffering and will continue to suffer irreparable harm and damages as a result of this
`
`infringement.
`
`COUNT V - Infringement of United States Patent No. 8,588,725
`
`87.
`
`The allegations set forth above are re-alleged and incorporated by
`
`reference as if they were set forth fully here.
`
`18
`
`ParkerVision Ex. 2001
`Intel Corp. v. ParkerVision, Inc.
`IPR No. 2020-01265
`
`
`
`Case 6:20-cv-00108 Document 1 Filed 02/11/20 Page 19 of 27
`
`
`
`88.
`
`Intel directly infringes (literally and/or under the doctrine of equivalents)
`
`the ’725 patent by making, using, selling, offering for sale, and/or importing into the
`
`United States products covered by at least claim 1 of the ’725 patent.
`
`89.
`
`Intel products that infringe one or more claims of the ’725 patent include,
`
`but are not limited to, the Intel Chips and any other Intel device that is capable of
`
`down-converting a higher-frequency signal to a lower-frequency signal as claimed in
`
`the ’725 patent. On information and belief, Intel uses the Intel Chips at least by testing
`
`the Intel Chips in the United States.
`
`90.
`
`Each Intel Chip is/includes an apparatus for down-converting an
`
`electromagnetic signal (e.g., high frequency RF signal) to a lower frequency signal. Each
`
`Intel Chip has an aliasing module comprising a switching device (e.g., transistor) and a
`
`storage module (e.g., capacitor). The aliasing module receives as an input an RF
`
`information signal and provides as an output a down-converted signal. The switching
`
`device of the aliasing module receives as an input a control signal (e.g., LO signal) that
`
`controls a charging and discharging cycle of the storage module by controlling the
`
`switching device so that a portion of energy is transferred from the RF information
`
`signal to the storage module during a charging part of the cycle and a portion of the
`
`transferred energy is discharged during a discharging part of the cycle.
`
`91.
`
`The control signal operates at an aliasing rate (e.g., LO rate with a 25%
`
`duty cycle) selected so that energy of the RF information signal is sampled and applied
`
`to the storage module at a frequency that is equal to or less than twice the frequency of
`
`the RF information signal. The storage module generates the down-converted signal
`
`19
`
`ParkerVision Ex. 2001
`Intel Corp. v. ParkerVision, Inc.
`IPR No. 2020-01265
`
`
`
`Case 6:20-cv-00108 Document 1 Filed 02/11/20 Page 20 of 27
`
`
`
`from the alternate charging and discharging applied to the storage module using the
`
`control signal.
`
`92.
`
`ParkerVision has been damaged by the direct infringement of Intel, and is
`
`suffering and will continue to suffer irreparable harm and damages as a result of this
`
`infringement.
`
`COUNT VI
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