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`UNITED STATES DISTRICT COURT
`WESTERN DISTRICT OF TEXAS
`WACO DIVISION
`
` Plaintiff,
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`
`
`PARKERVISION, INC.,
`
`
`
` 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
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`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
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`the United States, 35 U.S.C. §§ 1 et seq.
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`
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`TCL & Hisense
`Ex. 1023
`Page 1
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`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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`Defendant Hisense Co., Ltd. is a foreign corporation duly organized and
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`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,
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`266071, P.R. China. Hisense Co., Ltd. is a parent corporation of Defendant Hisense
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`Visual Technology Co., Ltd.
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`4.
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`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
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`Technology Co., Ltd. formerly did business under the names Qingdao Hisense
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`Electronics Co., Ltd. and Hisense Electric Co., Ltd.
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`5.
`
`On information and belief, Defendants act in concert to design,
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`manufacture, sell, offer for sale, import, distribute, advertise, and/or otherwise promote
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`the accused infringing products in the United States, the State of Texas, and this judicial
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`district.
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`JURISDICTION AND VENUE
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`6.
`
`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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`2
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`TCL & Hisense
`Ex. 1023
`Page 2
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`7.
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`Hisense is subject to this Court’s personal jurisdiction in accordance with
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`due process and/or the Texas Long-Arm Statute. See Tex. Civ. Prac. & Rem. Code §§
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`17.041 et seq.
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`8.
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`This Court has personal jurisdiction over Hisense because Hisense has
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`sufficient minimum contacts with this forum as a result of business conducted within
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`the State of Texas and this judicial district. In particular, this Court has personal
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`jurisdiction over Hisense because, inter alia, Hisense, on information and belief, has
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`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.
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`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
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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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`10.
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`This Court has personal jurisdiction over Hisense because Hisense
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`(directly and/or through its subsidiaries, affiliates, or intermediaries) has committed
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`and continues to commit acts of infringement in this judicial district in violation of at
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`least 35 U.S.C. § 271(a). In particular, on information and belief, Hisense uses, sells,
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`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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`TCL & Hisense
`Ex. 1023
`Page 3
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`11.
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`Venue is proper in this judicial district under 28 U.S.C. §§ 1391(b) – (d)
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`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
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`acts of infringement in this judicial district.
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`BACKGROUND
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`12.
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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
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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.
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`14. 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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`15.
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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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`16. 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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`4
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`TCL & Hisense
`Ex. 1023
`Page 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.
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`17.
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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
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`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
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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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`18.
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`ParkerVision’s technology helped make today’s wireless devices, such as
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`televisions, a reality by enabling RF chips used in these devices to be smaller, cheaper,
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`and more efficient, and with higher performance.
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`HISENSE
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`19. Hisense Co., Ltd. is a Chinese multinational electronics company
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`headquartered in Qingdao, China. On information and belief, Hisense Visual
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`Technology Co., Ltd. is a subsidiary of Hisense Co., Ltd.
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`20. On information and belief, since at least 2010, Hisense (or those acting on
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`its behalf) has made, used, sold, offered for sale and/or imported televisions (“Hisense
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`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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`TCL & Hisense
`Ex. 1023
`Page 5
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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
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`Corporation through which Hisense sold Sharp-branded televisions (“Sharp TVs”) in
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`the United States. https://www.lifewire.com/hisense-now-has-sharp-assets-1847076.
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`Hereinafter Hisense TVs and Sharp TVs are collectively referred to as “Hisense
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`Products.”
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`22. Hisense Products can be purchased through retailers throughout the
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`United States including, without limitation, Best Buy, Target, Walmart, Costco, BJ
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`Wholesale, B&H and PC Richards & Sons.
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`23.
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`In 2019, Hisense was the fastest growing Top 6 TV brand in the United
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`States by units and dollars. https://www.hisense-usa.com/televisions/all-tvs.
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`24. Hisense Products include modules containing Wi-Fi chips including,
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`without limitation, MediaTek MT7612UN and Realtek RTL8812BU (each a “Hisense
`
`Chip”; collectively, the “Hisense Chips”). Hisense Chips provide wireless connectivity
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`for Hisense Products.
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`6
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`TCL & Hisense
`Ex. 1023
`Page 6
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`25.
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`Below is an image from a Sharp-branded Hisense television model no. LC-
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`55P6000U.
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`
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`26.
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`The label on the Sharp TV indicates the inclusion of a 2AJVQ-
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`ZDGFMT7612U module (shown in the red box (above)). On information and belief, the
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`2AJVQ-ZDGFMT7612U module includes a MediaTek MT7612UN chip.
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`7
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`TCL & Hisense
`Ex. 1023
`Page 7
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`https://fccid.io/2AJVQ-ZDGFMT7612U/Internal-
`Photos/Internal-Photos-3377285
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`
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`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-
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`WN4519L module includes a Realtek RTL8812BU chip.
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`8
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`TCL & Hisense
`Ex. 1023
`Page 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
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`28. On April 11, 2000, the United States Patent and Trademark Office duly
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`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.
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`ParkerVision owns all rights, title, and interest in the ‘706 patent.
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`United States Patent No. 6,266,518
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`31. On July 24, 2001, the United States Patent and Trademark Office duly and
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`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
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`Over Apertures” to inventor David F. Sorrells et al.
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`32.
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`The ‘518 patent is presumed valid under 35 U.S.C. § 282.
`
`33.
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`ParkerVision owns all rights, title, and interest in the ‘518 patent.
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`9
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`Ex. 1023
`Page 9
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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
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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.
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`35.
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`The ‘902 patent is presumed valid under 35 U.S.C. § 282.
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`36.
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`ParkerVision owns all rights, title, and interest in the ‘902 patent.
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`United States Patent No. 7,110,444
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`37. On September 19, 2006, the United States Patent and Trademark Office
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`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
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`Technology Including Multi-Phase Embodiments and Circuit Implementations” to
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`inventor David F. Sorrells et al.
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`38.
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`The ‘444 patent is presumed valid under 35 U.S.C. § 282.
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`39.
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`ParkerVision owns all rights, title, and interest in the ‘444 patent.
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`United States Patent No. 7,292,835
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`40. On November 6, 2007, the United States Patent and Trademark Office
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`duly and legally issued United States Patent No. 7,292,835 (“the ‘835 patent”) entitled
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`“Wireless and Wired Cable Modem Applications of Universal Frequency Translation
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`Technology” to inventor David F. Sorrells et al.
`
`41.
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`The ‘835 patent is presumed valid under 35 U.S.C. § 282.
`
`42.
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`ParkerVision owns all rights, title, and interest in the ‘835 patent.
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`10
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`TCL & Hisense
`Ex. 1023
`Page 10
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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
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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.
`
`44.
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`The ‘725 patent is presumed valid under 35 U.S.C. § 282.
`
`45.
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`ParkerVision owns all rights, title, and interest in the ‘725 patent.
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`United States Patent No. 8,660,513
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`46. On February 25, 2014, the United States Patent and Trademark Office duly
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`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.
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`47.
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`The ‘513 patent is presumed valid under 35 U.S.C. § 282.
`
`48.
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`ParkerVision owns all rights, title, and interest in the ‘513 patent.
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`United States Patent No. 9,118,528
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`49. On August 25, 2015, the United States Patent and Trademark Office duly
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`and legally issued United States Patent No. 9,118,528 (“the ‘528 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.
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`50.
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`The ‘528 patent is presumed valid under 35 U.S.C. § 282.
`
`51.
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`ParkerVision owns all rights, title, and interest in the ‘528 patent.
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`11
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`Ex. 1023
`Page 11
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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
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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.
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`53.
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`The ‘736 patent is presumed valid under 35 U.S.C. § 282.
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`54.
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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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`55. 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.
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`56.
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`The ‘673 patent is presumed valid under 35 U.S.C. § 282.
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`57.
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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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`58.
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`The allegations set forth above are re-alleged and incorporated by
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`reference as if they were set forth fully here.
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`59. Hisense directly infringes (literally and/or under the doctrine of
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`equivalents) the ’706 patent by making, using, selling, offering for sale, and/or
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`importing in/into the United States products covered by at least claim 1 of the ’706
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`patent.
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`12
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`Ex. 1023
`Page 12
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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
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`is capable of filtering and down-converting a higher-frequency signal to a lower-
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`frequency signal as claimed in the ’706 patent.
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`61.
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`Each Hisense 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
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`Hisense Chip includes a frequency translator, comprising a down-convert and delay
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`module to under-sample an input signal (e.g., high frequency RF signal) to produce an
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`input sample of a down-converted image of said input signal, and to delay said input
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`sample. Each Hisense Chip also includes a filter, comprising at least a portion of said
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`down-convert and delay module, at least one delay module to delay instances of an
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`output signal, and an adder (e.g., operational amplifier with parallel resistor-capacitor
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`feedback) to combine at least said delayed input sample with at least one of said
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`delayed instances of said output signal to generate an instance of said output signal.
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`62.
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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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`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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`63.
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`ParkerVision has been damaged by the direct infringement of Hisense and
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`is suffering and will continue to suffer irreparable harm and damages as a result of this
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`infringement.
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`13
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`TCL & Hisense
`Ex. 1023
`Page 13
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`COUNT II – Infringement of United States Patent No. 6,266,518
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`64.
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`The allegations set forth above are re-alleged and incorporated by
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`reference as if they were set forth fully here.
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`65. Hisense directly infringes (literally and/or under the doctrine of
`
`equivalents) the ‘518 patent by making, using, selling, offering for sale, and/or
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`importing in/into the United States products covered by at least claim 67 of the ‘518
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`patent.
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`66. Hisense products that infringe one or more claims of the ‘518 patent
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`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
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`claimed in the ‘518 patent.
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`67.
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`Each Hisense Chip is/includes an apparatus for down-converting a
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`carrier signal (e.g., high frequency RF signal) to a lower frequency signal (e.g., baseband
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`signal). Each Hisense Chip has a universal frequency down-converter (UFD), including
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`a switch (e.g., transistor), an integrator (e.g., capacitor) coupled to said switch, a pulse
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`generator (e.g., LO and/or LO circuitry) coupled to said switch; and a reactive structure
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`(e.g., filter(s)) coupled to said UFD.
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`68.
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`The pulse generator (e.g., LO and/or LO circuitry) outputs pulses (e.g.,
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`LO signal) to said switch at an aliasing rate that is determined according to a frequency
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`of the carrier signal +/− a frequency of the lower frequency signal) divided by N.
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`69.
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`The pulses have apertures (e.g., 25% duty cycle) and cause said switch to
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`close and sample said carrier signal (e.g., high frequency RF signal). Energy is
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`Page 14
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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)
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`is generated from the transferred energy.
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`70.
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`The energy is transferred to a load (e.g., resistor) during an off-time (e.g.,
`
`when the switch is open).
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`71.
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`ParkerVision has been damaged by the direct infringement of Hisense,
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`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 III – Infringement of United States Patent No. 6,580,902
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`72.
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`The allegations set forth above are re-alleged and incorporated by
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`reference as if they were set forth fully here.
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`73. Hisense directly infringes (literally and/or under the doctrine of
`
`equivalents) the ’902 patent by making, using, selling, offering for sale, and/or
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`importing in/into the United States products covered by at least claim 1 of the ’902
`
`patent.
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`74. Hisense products that infringe one or more claims of the ’902 patent
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`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
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`claimed in the ’902 patent.
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`75.
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`Each Hisense Chip is/includes a circuit for down-converting an
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`electromagnetic signal (e.g., high frequency RF signal) to a lower frequency signal. Each
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`Hisense Chip includes an energy transfer module having a switch module (e.g., module
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`Page 15
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`with one or more transistors) and an energy storage module (e.g., module with one or
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`more capacitors). The energy transfer module of the Hisense Chip samples the
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`electromagnetic signal at an energy transfer rate (e.g., LO rate with a 25% duty cycle),
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`according to an energy transfer signal (e.g., LO signal), to obtain sampled energy. The
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`sampled energy is stored by said energy storage module (e.g., module with one or more
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`capacitors). A down-converted signal (e.g., baseband signal) is generated from the
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`sampled energy.
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`76.
`
`The energy transfer module of each Hisense Chip has transistors coupled
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`together. The transistors have a common first port, a common second port, and a
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`common control port. The electromagnetic signal is accepted at the common first port
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`and the sampled energy is present at the common second port.
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`77.
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`The common control port accepts the energy transfer signal, which has a
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`control frequency that is substantially equal to said energy transfer rate.
`
`78.
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`Each of the transistors of the Hisense Chip has a drain, a source, and a
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`gate. The common first port couples together drains of the transistors, the common
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`second port couples together sources of the transistors, and the common control port
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`couples together gates of the transistors.
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`79.
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`ParkerVision has been damaged by the direct infringement of Hisense and
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`is suffering and will continue to suffer irreparable harm and damages as a result of this
`
`infringement.
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`16
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`Ex. 1023
`Page 16
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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.
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`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
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`modulation/demodulation device providing bi-directional, over-the-air data
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`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
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`signal (e.g., baseband signal); a second frequency down-conversion module to down-
`
`convert said input signal, wherein said second frequency down-conversion module
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`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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`17
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`TCL & Hisense
`Ex. 1023
`Page 17
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`
`
`
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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
`
`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
`
`this infringement.
`
`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.
`
`18
`
`TCL & Hisense
`Ex. 1023
`Page 18
`
`
`
`
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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
`
`19
`
`TCL & Hisense
`Ex. 1023
`Page 19
`
`
`
`
`
`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
`
`20
`
`TCL & Hisense
`Ex. 1023
`Page 20
`
`
`
`
`
`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.
`
`21
`
`TCL & Hisense
`Ex. 1023
`Page 21
`
`
`
`
`
`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-phase signal portion of the modulated carrier signal.
`
`105. Each Hisense Chip has (a) a second switch (e.g., transistor), (b) a second
`
`control signal (e.g., LO signal) which comprises a sampling aperture (e.g., 25% duty
`
`cycle) with a specified frequency, and (c) a second energy storage element (e.g., one or
`
`more capacitors) that down-converts the modulated carrier signal according to the
`
`22
`
`TCL & Hisense
`Ex. 1023
`Page 22
`
`
`
`
`
`second control signal and outputs a down-converted inverted in-phase signal portion of
`
`the modulated carrier signal.
`
`106. Each Hisense Chip has a first differential amplifier circuit that combines
`
`the down-converted in-phase signal portion with the inverted in-phase signal portion
`
`and outputs a first channel down-converted differential in-phase signal.
`
`107. Each Hisense Chip has (a) a third switch (e.g., transistor), (b) a third
`
`control signal (e.g., LO signal) which comprises a sampling aperture (e.g., 25% duty
`
`cycle) with a specified frequency, and (c) a third energy storage element (e.g., one or
`
`more capacitors) that down-converts the modulated carrier signal according to the third
`
`control signal and outputs a down-converted quadrature-phase signal portion of the
`
`modulated carrier signal.
`
`108. Each Hisense Chip has (a) a fourth switch (e.g., transistor), (b) a fourth
`
`aperture signal (e.g., LO signal), and (c) a fourth energy storage element (e.g., one or
`
`more capacitors) that down-converts the modulated carrier signal according to the
`
`fourth control signal and outputs a down-converted inverted quadrature-phase signal
`
`portion of the modulated carrier signal.
`
`109. Each Hisense Chip has a second di
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