`
`UNITED STATES DISTRICT COURT
`WESTERN DISTRICT OF TEXAS
`WACO DIVISION
`
`PARKERVISION, INC.,
`
`Plaintiff,
`
`v.
`
`HISENSE CO., LTD. and HISENSE
`VISUAL TECHNOLOGY CO., LTD.
`(F/K/A QINGDAO HISENSE
`ELECTRONICS CO., LTD. and
`HISENSE ELECTRIC CO., LTD.)
`
`Defendants.
`
`Case No. 6:20-cv-00870
`
`JURY TRIAL DEMANDED
`
`COMPLAINT FOR PATENT INFRINGEMENT
`
`Plaintiff ParkerVision, Inc. (“ParkerVision”), by and through its undersigned
`
`counsel, files this Complaint against Defendants Hisense Co., Ltd. and Hisense Visual
`
`Technology Co., Ltd. (f/k/a Qingdao Hisense Electronics Co., Ltd. and Hisense
`
`Electric Co., Ltd.) (collectively, “Hisense” or “Defendants”) for patent infringement of
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`United States Patent Nos. 6,049,706; 6,266,518; 6,580,902; 7,110,444; 7,292,835; 8,588,725;
`
`8,660,513; 9,118,528; 9,246,736 and 9,444,673 (the “patents-in-suit”) and alleges as
`
`follows:
`
`NATURE OF THE ACTION
`
`1.
`
`This is an action for patent infringement arising under the patent laws of
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`the United States, 35 U.S.C. §§ 1 et seq.
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`ParkerVision Ex. 2001
`IPR2021-00985
`Page 1 of 31
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`Case 6:20-cv-00870 Document 1 Filed 09/24/20 Page 2 of 31
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`PARTIES
`
`2.
`
`Plaintiff ParkerVision is a Florida corporation with its principal place of
`
`business at 9446 Philips Highway, Jacksonville, Florida 32256.
`
`3.
`
`Defendant Hisense Co., Ltd. is a foreign corporation duly organized and
`
`existing under the laws of the People’s Republic of China, with a principal place of
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`business at Hisense Tower, No. 17 Donghaixi Road, Qingdao, Shandong Province,
`
`266071, P.R. China. Hisense Co., Ltd. is a parent corporation of Defendant Hisense
`
`Visual Technology Co., Ltd.
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`4.
`
`Defendant Hisense Visual Technology Co., Ltd. is a foreign corporation
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`duly organized and existing under the laws of the People’s Republic of China, with a
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`principal place of business at No. 218, Qianwangang Road, Economic and Technological
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`Development Zone, Qingdao, Shandong Province, 266555, P.R. China. Hisense Visual
`
`Technology Co., Ltd. formerly did business under the names Qingdao Hisense
`
`Electronics Co., Ltd. and Hisense Electric Co., Ltd.
`
`5.
`
`On information and belief, Defendants act in concert to design,
`
`manufacture, sell, offer for sale, import, distribute, advertise, and/or otherwise promote
`
`the accused infringing products in the United States, the State of Texas, and this judicial
`
`district.
`
`JURISDICTION AND VENUE
`
`6.
`
`This Court has jurisdiction over the subject matter of this action pursuant
`
`to 28 U.S.C. §§ 1331 and 1338(a) because the action arises under the patent laws of the
`
`United States, 35 U.S.C. §§ 1 et seq.
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`2
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`Case 6:20-cv-00870 Document 1 Filed 09/24/20 Page 3 of 31
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`7.
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`Hisense is subject to this Court’s personal jurisdiction in accordance with
`
`due process and/or the Texas Long-Arm Statute. See Tex. Civ. Prac. & Rem. Code §§
`
`17.041 et seq.
`
`8.
`
`This Court has personal jurisdiction over Hisense because Hisense has
`
`sufficient minimum contacts with this forum as a result of business conducted within
`
`the State of Texas and this judicial district. In particular, this Court has personal
`
`jurisdiction over Hisense because, inter alia, Hisense, on information and belief, has
`
`substantial, continuous, and systematic business contacts in this judicial district, and
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`derives substantial revenue from goods provided to individuals in this judicial district.
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`9.
`
`Hisense has purposefully availed itself of the privileges of conducting
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`business within this judicial district, has established sufficient minimum contacts with
`
`this judicial district such that it should reasonably and fairly anticipate being hauled
`
`into court in this judicial district, has purposefully directed activities at residents of this
`
`judicial district, and at least a portion of the patent infringement claims alleged in this
`
`Complaint arise out of or are related to one or more of the foregoing activities.
`
`10.
`
`This Court has personal jurisdiction over Hisense because Hisense
`
`(directly and/or through its subsidiaries, affiliates, or intermediaries) has committed
`
`and continues to commit acts of infringement in this judicial district in violation of at
`
`least 35 U.S.C. § 271(a). In particular, on information and belief, Hisense uses, sells,
`
`offers for sale, imports, advertises, and/or otherwise promotes infringing products in
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`the United States, the State of Texas, and this judicial district.
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`3
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`Case 6:20-cv-00870 Document 1 Filed 09/24/20 Page 4 of 31
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`11.
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`Venue is proper in this judicial district under 28 U.S.C. §§ 1391(b) – (d)
`
`and/or 1400(b). Hisense is registered to do business in the State of Texas, maintains a
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`regular and established place of business within this judicial district, and has committed
`
`acts of infringement in this judicial district.
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`BACKGROUND
`
`12.
`
`In 1989, Jeff Parker and David Sorrells started ParkerVision in
`
`Jacksonville, Florida. Through the mid-1990s, ParkerVision focused on developing
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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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`13. 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.
`
`14. At the time, a decade’s-old RF technology called super-heterodyne
`
`dominated the consumer products industry. But this technology was not without its
`
`own problems – the circuity was large and required significant power.
`
`15.
`
`From 1995 through 1998, ParkerVision engineers developed an innovative
`
`method of RF direct conversion by a process of sampling a RF carrier signal and
`
`transferring energy to create a down-converted baseband signal.
`
`16. After creating prototype chips and conducting tests, ParkerVision soon
`
`realized that its technology led to improved RF receiver performance, lower power
`
`4
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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.
`
`17.
`
`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,
`
`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
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`down-converter and up-converter technologies. To date, ParkerVision has been granted
`
`over 200 patents related to its innovations including, the patents-in-suit.
`
`18.
`
`ParkerVision’s technology helped make today’s wireless devices, such as
`
`televisions, a reality by enabling RF chips used in these devices to be smaller, cheaper,
`
`and more efficient, and with higher performance.
`
`HISENSE
`
`19. Hisense Co., Ltd. is a Chinese multinational electronics company
`
`headquartered in Qingdao, China. On information and belief, Hisense Visual
`
`Technology Co., Ltd. is a subsidiary of Hisense Co., Ltd.
`
`20. On information and belief, since at least 2010, Hisense (or those acting on
`
`its behalf) has made, used, sold, offered for sale and/or imported televisions (“Hisense
`
`TVs”) in/into the United States. https://hdguru.com/hisense-targets-the-us-hdtv-
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`market/.
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`5
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`Case 6:20-cv-00870 Document 1 Filed 09/24/20 Page 6 of 31
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`21. On information and belief, from 2015 to 2019, Hisense entered into a
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`brand licensing agreement with Sharp Electronics Corporation and/or Sharp
`
`Corporation through which Hisense sold Sharp-branded televisions (“Sharp TVs”) in
`
`the United States. https://www.lifewire.com/hisense-now-has-sharp-assets-1847076.
`
`Hereinafter Hisense TVs and Sharp TVs are collectively referred to as “Hisense
`
`Products.”
`
`22. Hisense Products can be purchased through retailers throughout the
`
`United States including, without limitation, Best Buy, Target, Walmart, Costco, BJ
`
`Wholesale, B&H and PC Richards & Sons.
`
`23.
`
`In 2019, Hisense was the fastest growing Top 6 TV brand in the United
`
`States by units and dollars. https://www.hisense-usa.com/televisions/all-tvs.
`
`24. Hisense Products include modules containing Wi-Fi chips including,
`
`without limitation, MediaTek MT7612UN and Realtek RTL8812BU (each a “Hisense
`
`Chip”; collectively, the “Hisense Chips”). Hisense Chips provide wireless connectivity
`
`for Hisense Products.
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`Case 6:20-cv-00870 Document 1 Filed 09/24/20 Page 7 of 31
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`25.
`
`Below is an image from a Sharp-branded Hisense television model no. LC-
`
`55P6000U.
`
`
`
`26.
`
`The label on the Sharp TV indicates the inclusion of a 2AJVQ-
`
`ZDGFMT7612U module (shown in the red box (above)). On information and belief, the
`
`2AJVQ-ZDGFMT7612U module includes a MediaTek MT7612UN chip.
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`7
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`https://fccid.io/2AJVQ-ZDGFMT7612U/Internal-
`Photos/Internal-Photos-3377285
`
`
`
`27. On information and belief, Hisense Products also include modules (e.g.,
`
`PPQ-WN4519L) containing Realtek Wi-Fi chips. On information and belief, the PPQ-
`
`WN4519L module includes a Realtek RTL8812BU chip.
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`
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`8
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`https://fccid.io/PPQ-WN4519L/Internal-
`Photos/Internal-Photos-3283972
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`THE ASSERTED PATENTS
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`United States Patent No. 6,049,706
`
`28. 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
`
`“Integrated Frequency Translation and Selectivity” to inventor Robert W. Cook et al.
`
`29.
`
`The ‘706 patent is presumed valid under 35 U.S.C. § 282.
`
`30.
`
`ParkerVision owns all rights, title, and interest in the ‘706 patent.
`
`United States Patent No. 6,266,518
`
`31. On July 24, 2001, the United States Patent and Trademark Office duly and
`
`legally issued United States Patent No. 6,266,518 (“the ‘518 patent”) entitled “Method
`
`and System for Down-Converting Electromagnetic Signals by Sampling and Integrating
`
`Over Apertures” to inventor David F. Sorrells et al.
`
`32.
`
`The ‘518 patent is presumed valid under 35 U.S.C. § 282.
`
`33.
`
`ParkerVision owns all rights, title, and interest in the ‘518 patent.
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`Case 6:20-cv-00870 Document 1 Filed 09/24/20 Page 10 of 31
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`United States Patent No. 6,580,902
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`34. On June 17, 2003, the United States Patent and Trademark Office duly and
`
`legally issued United States Patent No. 6,580,902 (“the ‘902 patent”) entitled “Frequency
`
`Translation Using Optimized Switch Structures” to inventor David F. Sorrells et al.
`
`35.
`
`The ‘902 patent is presumed valid under 35 U.S.C. § 282.
`
`36.
`
`ParkerVision owns all rights, title, and interest in the ‘902 patent.
`
`United States Patent No. 7,110,444
`
`37. 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
`
`“Wireless Local Area Network (WLAN) Using Universal Frequency Translation
`
`Technology Including Multi-Phase Embodiments and Circuit Implementations” to
`
`inventor David F. Sorrells et al.
`
`38.
`
`The ‘444 patent is presumed valid under 35 U.S.C. § 282.
`
`39.
`
`ParkerVision owns all rights, title, and interest in the ‘444 patent.
`
`United States Patent No. 7,292,835
`
`40. On November 6, 2007, the United States Patent and Trademark Office
`
`duly and legally issued United States Patent No. 7,292,835 (“the ‘835 patent”) entitled
`
`“Wireless and Wired Cable Modem Applications of Universal Frequency Translation
`
`Technology” to inventor David F. Sorrells et al.
`
`41.
`
`The ‘835 patent is presumed valid under 35 U.S.C. § 282.
`
`42.
`
`ParkerVision owns all rights, title, and interest in the ‘835 patent.
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`Case 6:20-cv-00870 Document 1 Filed 09/24/20 Page 11 of 31
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`United States Patent No. 8,588,725
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`43. 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
`
`“Apparatus, System, and Method For Down Converting and Up-Converting
`
`Electromagnetic Signals” to inventor David F. Sorrells et al.
`
`44.
`
`The ‘725 patent is presumed valid under 35 U.S.C. § 282.
`
`45.
`
`ParkerVision owns all rights, title, and interest in the ‘725 patent.
`
`United States Patent No. 8,660,513
`
`46. 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
`
`“Method and System for Down-Converting an Electromagnetic Signal, and Transforms
`
`for Same, and Aperture Relationships” to inventor David F. Sorrells et al.
`
`47.
`
`The ‘513 patent is presumed valid under 35 U.S.C. § 282.
`
`48.
`
`ParkerVision owns all rights, title, and interest in the ‘513 patent.
`
`United States Patent No. 9,118,528
`
`49. On August 25, 2015, the United States Patent and Trademark Office duly
`
`and legally issued United States Patent No. 9,118,528 (“the ‘528 patent”) entitled
`
`“Method and System for Down-Converting an Electromagnetic Signal, and Transforms
`
`for Same, and Aperture Relationships” to inventor David F. Sorrells et al.
`
`50.
`
`The ‘528 patent is presumed valid under 35 U.S.C. § 282.
`
`51.
`
`ParkerVision owns all rights, title, and interest in the ‘528 patent.
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`Case 6:20-cv-00870 Document 1 Filed 09/24/20 Page 12 of 31
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`United States Patent No. 9,246,736
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`52. On January 26, 2016, the United States Patent and Trademark Office duly
`
`and legally issued United States Patent No. 9,246,736 (“the ‘736 patent”) entitled
`
`“Method and System for Down-Converting an Electromagnetic Signal” to inventor
`
`David F. Sorrells et al.
`
`53.
`
`The ‘736 patent is presumed valid under 35 U.S.C. § 282.
`
`54.
`
`ParkerVision owns all rights, title, and interest in the ‘736 patent.
`
`United States Patent No. 9,444,673
`
`55. On September 13, 2016, the United States Patent and Trademark Office
`
`duly and legally issued United States Patent No. 9,444,673 (“the ‘673 patent”) entitled
`
`“Methods and Systems for Down-Converting a Signal Using a Complementary
`
`Transistor Structure” to inventor David F. Sorrells et al.
`
`56.
`
`The ‘673 patent is presumed valid under 35 U.S.C. § 282.
`
`57.
`
`ParkerVision owns all rights, title, and interest in the ‘673 patent.
`
`CLAIMS FOR RELIEF
`
`COUNT I - Infringement of United States Patent No. 6,049,706
`
`58.
`
`The allegations set forth above are re-alleged and incorporated by
`
`reference as if they were set forth fully here.
`
`59. Hisense directly infringes (literally and/or under the doctrine of
`
`equivalents) the ’706 patent by making, using, selling, offering for sale, and/or
`
`importing in/into the United States products covered by at least claim 1 of the ’706
`
`patent.
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`60. Hisense products that infringe one or more claims of the ’706 patent
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`include, but are not limited to, the Hisense Products and any other Hisense device that
`
`is capable of filtering and down-converting a higher-frequency signal to a lower-
`
`frequency signal as claimed in the ’706 patent.
`
`61.
`
`Each Hisense Chip is/includes an apparatus for filtering and down-
`
`converting (e.g., a higher frequency RF signal to a lower frequency signal). Each
`
`Hisense Chip includes a frequency translator, comprising a down-convert and delay
`
`module to under-sample an input signal (e.g., high frequency RF signal) to produce an
`
`input sample of a down-converted image of said input signal, and to delay said input
`
`sample. Each Hisense Chip also includes a filter, comprising at least a portion of said
`
`down-convert and delay module, at least one delay module to delay instances of an
`
`output signal, and an adder (e.g., operational amplifier with parallel resistor-capacitor
`
`feedback) to combine at least said delayed input sample with at least one of said
`
`delayed instances of said output signal to generate an instance of said output signal.
`
`62.
`
`The down-convert and delay module under-samples (e.g., at a sample rate
`
`below the Nyquist rate) said input signal according to a control signal (e.g., local
`
`oscillator (LO) signal), wherein a frequency of said control signal is equal to a frequency
`
`of said input signal plus or minus a frequency of said down-converted image, divided
`
`by n, where n represents a harmonic or sub-harmonic of said input signal.
`
`63.
`
`ParkerVision has been damaged by the direct infringement of Hisense and
`
`is suffering and will continue to suffer irreparable harm and damages as a result of this
`
`infringement.
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`Case 6:20-cv-00870 Document 1 Filed 09/24/20 Page 14 of 31
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`COUNT II – Infringement of United States Patent No. 6,266,518
`
`64.
`
`The allegations set forth above are re-alleged and incorporated by
`
`reference as if they were set forth fully here.
`
`65. Hisense directly infringes (literally and/or under the doctrine of
`
`equivalents) the ‘518 patent by making, using, selling, offering for sale, and/or
`
`importing in/into the United States products covered by at least claim 67 of the ‘518
`
`patent.
`
`66. Hisense products that infringe one or more claims of the ‘518 patent
`
`include, but are not limited to, the Hisense Products and any other Hisense device that
`
`is capable of down-converting a higher-frequency signal to a lower-frequency signal as
`
`claimed in the ‘518 patent.
`
`67.
`
`Each Hisense Chip is/includes an apparatus for down-converting a
`
`carrier signal (e.g., high frequency RF signal) to a lower frequency signal (e.g., baseband
`
`signal). Each Hisense Chip has a universal frequency down-converter (UFD), including
`
`a switch (e.g., transistor), an integrator (e.g., capacitor) coupled to said switch, a pulse
`
`generator (e.g., LO and/or LO circuitry) coupled to said switch; and a reactive structure
`
`(e.g., filter(s)) coupled to said UFD.
`
`68.
`
`The pulse generator (e.g., LO and/or LO circuitry) outputs pulses (e.g.,
`
`LO signal) to said switch at an aliasing rate that is determined according to a frequency
`
`of the carrier signal +/− a frequency of the lower frequency signal) divided by N.
`
`69.
`
`The pulses have apertures (e.g., 25% duty cycle) and cause said switch to
`
`close and sample said carrier signal (e.g., high frequency RF signal). Energy is
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`transferred from said carrier signal and integrated using said integrator (e.g., capacitor)
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`during apertures of said pulses, and said lower frequency signal (e.g., baseband signal)
`
`is generated from the transferred energy.
`
`70.
`
`The energy is transferred to a load (e.g., resistor) during an off-time (e.g.,
`
`when the switch is open).
`
`71.
`
`ParkerVision has been damaged by the direct infringement of Hisense,
`
`and is suffering and will continue to suffer irreparable harm and damages as a result of
`
`this infringement.
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`COUNT III – Infringement of United States Patent No. 6,580,902
`
`72.
`
`The allegations set forth above are re-alleged and incorporated by
`
`reference as if they were set forth fully here.
`
`73. Hisense directly infringes (literally and/or under the doctrine of
`
`equivalents) the ’902 patent by making, using, selling, offering for sale, and/or
`
`importing in/into the United States products covered by at least claim 1 of the ’902
`
`patent.
`
`74. Hisense products that infringe one or more claims of the ’902 patent
`
`include, but are not limited to, the Hisense Products and any other Hisense device that
`
`is capable of down-converting a higher-frequency signal to a lower-frequency signal as
`
`claimed in the ’902 patent.
`
`75.
`
`Each Hisense Chip is/includes a circuit for down-converting an
`
`electromagnetic signal (e.g., high frequency RF signal) to a lower frequency signal. Each
`
`Hisense Chip includes an energy transfer module having a switch module (e.g., module
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`with one or more transistors) and an energy storage module (e.g., module with one or
`
`more capacitors). The energy transfer module of the Hisense Chip samples the
`
`electromagnetic signal at an energy transfer rate (e.g., LO rate with a 25% duty cycle),
`
`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., module with one or more
`
`capacitors). A down-converted signal (e.g., baseband signal) is generated from the
`
`sampled energy.
`
`76.
`
`The energy transfer module of each Hisense 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.
`
`77.
`
`The common control port accepts the energy transfer signal, which has a
`
`control frequency that is substantially equal to said energy transfer rate.
`
`78.
`
`Each of the transistors of the Hisense 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.
`
`79.
`
`ParkerVision has been damaged by the direct infringement of Hisense and
`
`is suffering and will continue to suffer irreparable harm and damages as a result of this
`
`infringement.
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`COUNT IV - Infringement of United States Patent No. 7,110,444
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`80.
`
`The allegations set forth above are re-alleged and incorporated by
`
`reference as if they were set forth fully here.
`
`81. Hisense directly infringes (literally and/or under the doctrine of
`
`equivalents) the ’444 patent by making, using, selling, offering for sale, and/or
`
`importing in/into the United States products covered by at least claim 2 of the ‘444
`
`patent.
`
`82. Hisense products that infringe one or more claims of the ’444 patent
`
`include, but are not limited to, the Hisense Products and any other Hisense device that
`
`is capable of down-converting a higher-frequency signal to a lower-frequency signal as
`
`claimed in the ’444 patent.
`
`83.
`
`Each Hisense 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
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`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
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`signal.
`
`84.
`
`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
`
`sample rate below the Nyquist rate) the input signal according to said second control
`
`signal.
`
`85.
`
`ParkerVision has been damaged by the direct infringement of Hisense,
`
`and is suffering and will continue to suffer irreparable harm and damages as a result of
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`this infringement.
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`COUNT V - Infringement of United States Patent No. 7,292,835
`
`86.
`
`The allegations set forth above are re-alleged and incorporated by
`
`reference as if they were set forth fully here.
`
`87. Hisense directly infringes the ’835 patent by making, using, selling,
`
`offering for sale, and/or importing in/into the United States products covered by at
`
`least claims 1 and 17 of the ’835 patent.
`
`88. Hisense products that infringe one or more claims of the ’835 patent
`
`include, but are not limited to, the Hisense Products and any other Hisense device that
`
`is capable of down-converting a higher-frequency signal to a lower-frequency signal as
`
`claimed in the ’835 patent.
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`89. Hisense Products enable users to watch live TV and on demand
`
`programming from their cable service providers over a wireless network.
`
`https://www.hisense-usa.com/televisions/. Hisense Chips are configured to
`
`function/capable of functioning as wireless cable modems. For example, Hisense Chips
`
`provide a wireless connection to cable services.
`
`90.
`
`Each Hisense Chip is/includes a cable modem (e.g., wireless modem for
`
`communicating with a cable television network) for down-converting an
`
`electromagnetic signal (e.g., a high frequency RF signal), having complex modulations
`
`(e.g., QAM)), to a lower frequency signal. The electromagnetic signal is transmitted by a
`
`wireless method to the cable modem.
`
`91.
`
`Each Hisense Chip has (a) an oscillator (e.g., LO) to generate an in-phase
`
`oscillating signal (e.g., in-phase LO signal), (b) a phase shifter (e.g., a flip-flop) to receive
`
`the in-phase oscillating signal and to create a quadrature-phase oscillating signal (e.g.,
`
`quadrature-phase LO signal), (c) a first frequency down-conversion module (e.g., a first
`
`module that includes at least one switch and at least one capacitor) to receive the
`
`electromagnetic signal and the in-phase oscillating signal and (d) a second frequency
`
`down-conversion module (e.g., a second module that includes at least one switch and at
`
`least one capacitor) to receive the electromagnetic signal and the quadrature-phase
`
`oscillating signal.
`
`92.
`
`The first frequency down-conversion module includes a first frequency
`
`translation module (e.g., a module having one or more switches) and a first storage
`
`module (e.g., a module having one or more capacitors). The first frequency translation
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`module samples the electromagnetic signal at a rate (e.g., LO rate with a 25% duty
`
`cycle) that is a function of the in-phase oscillating signal, thereby creating a first
`
`sampled signal.
`
`93.
`
`The second frequency down-conversion module includes a second
`
`frequency translation module (e.g., a module having one or more switches) and a
`
`second storage module (e.g., a module having one or more capacitors). The second
`
`frequency translation module samples the electromagnetic signal at a rate (e.g., LO rate
`
`with a 25% duty cycle) that is a function of the quadrature-phase oscillating signal,
`
`thereby creating a second sampled signal.
`
`94.
`
`ParkerVision has been damaged by the direct infringement of Hisense,
`
`and is suffering and will continue to suffer irreparable harm and damages as a result of
`
`this infringement.
`
`COUNT VI - Infringement of United States Patent No. 8,588,725
`
`95.
`
`The allegations set forth above are re-alleged and incorporated by
`
`reference as if they were set forth fully here.
`
`96. Hisense directly infringes (literally and/or under the doctrine of
`
`equivalents) the ’725 patent by making, using, selling, offering for sale, and/or
`
`importing in/into the United States products covered by at least claim 1 of the ’725
`
`patent.
`
`97. Hisense products that infringe one or more claims of the ’725 patent
`
`include, but are not limited to, the Hisense Products and any other Hisense device that
`
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`is capable of down-converting a higher-frequency signal to a lower-frequency signal as
`
`claimed in the ’725 patent.
`
`98.
`
`Each Hisense Chip is/includes an apparatus for down-converting an
`
`electromagnetic signal (e.g., high frequency RF signal) to a lower frequency signal. Each
`
`Hisense Chip has an aliasing module comprising a switching device (e.g., one or more
`
`transistors) and a storage module (e.g., one or more capacitors). 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.
`
`99.
`
`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
`
`from the alternate charging and discharging applied to the storage module using the
`
`control signal.
`
`100. ParkerVision has been damaged by the direct infringement of Hisense,
`
`and is suffering and will continue to suffer irreparable harm and damages as a result of
`
`this infringement.
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`COUNT VII - Infringement of United States Patent No. 8,660,513
`
`101. The allegations set forth above are re-alleged and incorporated by
`
`reference as if they were set forth fully here.
`
`102. Hisense directly infringes (literally and/or under the doctrine of
`
`equivalents) the ‘513 patent by making, using, selling, offering for sale, and/or
`
`importing in/into the United States products covered by at least claim 19 of the ’513
`
`patent.
`
`103. Hisense products that infringe one or more claims of the ‘513 patent
`
`include, but are not limited to, the Hisense Products and any other Hisense device that
`
`is capable of down-converting a higher-frequency signal to a lower-frequency signal as
`
`claimed in the ’513 patent.
`
`104. Each Hisense Chip is/includes a system for frequency down-converting a
`
`modulated carrier signal (e.g., a high frequency RF signal) to a lower frequency signal.
`
`Each Hisense Chip has (a) a first switch (e.g., transistor), (b) a first control signal (e.g.,
`
`LO signal) which comprises a sampling aperture (e.g., 25% duty cycle) with a specified
`
`frequency, and (c) a first energy storage element (e.g., one or more capacitors) that
`
`down-converts the modulated carrier signal according to the first control signal and
`
`outputs a down-converted in-p