Case 5:20-cv-01030 Document 1 Filed 05/14/20 Page 1 of 26 Page ID #:1
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`Peter J. Woo (SBN 306083)
` pwoo@goldbergsegalla.com
`David Y. Choi (SBN 263917)
` dchoi@goldbergsegalla.com
`Goldberg Segalla LLP
`777 S. Figueroa Street, Suite 2000
`Los Angeles, CA 90017
`Mailing Address:
`P. O. Box 17220
`Los Angeles, CA 90017
`Telephone: 213.415.7200
`Facsimile: 213.415.7299
`Attorneys for Plaintiff ParkerVision, Inc.
`
`UNITED STATES DISTRICT COURT
`CENTRAL DISTRICT OF CALIFORNIA
`PARKERVISION, INC.,
`Case No.
`
`Plaintiff,
`
`v
`TCL TECHNOLOGY GROUP CORP.
`and TTE TECHNOLOGY, INC.,
`Defendants.
`
`COMPLAINT FOR PATENT
`INFRINGEMENT
`
`JURY TRIAL DEMANDED
`
`Plaintiff ParkerVision, Inc. (“ParkerVision”), by and through its undersigned
`counsel, files this Complaint against Defendants TCL Technology Group Corp.
`and TTE Technology, Inc. (collectively, “TCL”) for patent infringement of 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”)
`(Exhibits 1-10) and alleges as follows:
`NATURE OF THE ACTION
`This is an action for patent infringement arising under the patent laws
`1.
`of the United States, 35 U.S.C. §§ 1 et seq.
`/ / /
`
`COMPLAINT FOR PATENT INFRINGEMENT
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`Case 5:20-cv-01030 Document 1 Filed 05/14/20 Page 2 of 26 Page ID #:2
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`PARTIES
`Plaintiff ParkerVision is a Florida corporation with its principal place
`2.
`of business at 9446 Philips Highway, Jacksonville, Florida 32256.
`3.
`On information and belief, TCL Technology Group Corp. (f/k/a TCL
`Corporation) (“TCL Group”) is a foreign corporation duly organized under the
`laws of the People’s Republic of China with a principal place of business located at
`22/F, TCL Technology Bldg., No. 17, Huifeng 3rd Rd., Zhongkai Hi-Tech
`Development District, Huizhou, Guangdong, 516000 China. On information and
`belief, TCL Group is a parent of Defendant TTE Technology, Inc.
`4.
`On information and belief, Defendant TTE Technology, Inc. (d/b/a
`TCL North America and TCL USA) (“TCL USA”) is a Delaware corporation with
`its principal place of business at 1860 Compton Avenue, Corona, California 92881.
`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
`California, and this judicial district.
`JURISDICTION AND VENUE
`This Court has jurisdiction over the subject matter of this action
`6.
`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.
`7.
`TCL is subject to this Court’s personal jurisdiction in accordance
`with due process and/or the California Long-Arm Statute, California Code of Civil
`Procedure § 410.10.
`8.
`This Court has personal jurisdiction over TCL because TCL has
`sufficient minimum contacts with this forum as a result of business conducted
`within the State of California and this judicial district. In particular, this Court has
`personal jurisdiction over TCL because, inter alia, TCL, on information and belief,
`has substantial, continuous, and systematic business contacts in this judicial
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`COMPLAINT FOR PATENT INFRINGEMENT
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`district, and derives substantial revenue from goods provided to individuals in this
`judicial district.
`9.
`TCL has purposefully availed itself of the privileges of conducting
`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 TCL because TCL (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, TCL uses, sells,
`offers for sale, imports, advertises, and/or otherwise promotes infringing products
`in the United States, the State of California, and this judicial district.
`11. Venue is proper in this judicial district under 28 U.S.C. §§ 1391(b) –
`(d) and/or 1400(b). TCL is registered to do business in the State of California,
`maintains a regular and established place of business within this judicial district,
`and has committed acts of infringement in this judicial district.
`BACKGROUND
`In 1989, Jeff Parker and David Sorrells started ParkerVision in
`12.
`Jacksonville, Florida. Through the mid-1990s, ParkerVision focused on developing
`commercial video cameras, e.g., for television broadcasts. The cameras used radio
`frequency (RF) technology to automatically track the camera’s subject.
`13. When developing consumer video cameras, however, ParkerVision,
`encountered a problem – the power and battery requirements for RF
`communications made a cost effective, consumer-sized product impractical. So,
`Mr. Sorrels and ParkerVision’s engineering team began researching ways to solve
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`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 consumption, reduced size and integration benefits. In other words, RF
`receivers could be built smaller, cheaper and with greater improved performance.
`17.
`ParkerVision’s innovations did not stop there. ParkerVision went on
`to develop additional RF down-conversion technologies, RF up-conversion
`technologies and other related direct-conversion technologies. ParkerVision also
`developed complementary wireless communications technologies that involved
`interactions, processes, and controls between the baseband processor and the
`transceiver, which improved and enhanced the operation of transceivers that
`incorporate ParkerVision’s 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.
`TCL
`TLC Group is a Chinese multinational electronics company
`19.
`headquartered in Huizhou, Guangdong Province, China. On information and belief,
`TCL USA is the United States subsidiary of TCL Group.
`20. On information and belief, since 2014, TCL USA (or those acting on
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`Case 5:20-cv-01030 Document 1 Filed 05/14/20 Page 5 of 26 Page ID #:5
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`its behalf) has made, used, sold, offered for sale and/or imported televisions (“TCL
`Products”) in/into the United States. https://www.tclusa.com/about-us/press-
`releases/tcl-celebrates-five-years; https://www.tclusa.com/products.
`21.
`TCL 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.
`22. On information and belief, as of 2019, TCL was the second largest
`brand of smart televisions in the United States. https://www.tclusa.com/about-
`us/press-releases/tcl-celebrates-five-years.
`23.
`TCL Products include modules (e.g., WCOHR2601) containing Wi-Fi
`chips including, without limitation, Realtek RT8812BU (each a “TCL Chip”;
`collectively, the “TCL Chips”). TCL Chips provide wireless connectivity for TCL
`Products.
`24. Below are images from a TCL television model no. 43S425 purchased
`from Best Buy.
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`25.
`below.
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`TCL Products include, without limitation, the televisions set forth
`
`TV Model No.
`
`65S427
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`43S423
`
`55S426
`
`75Q825
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`65R625
`
`FCC ID
`
`W8U65S427
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`W8U43S423
`
`W8U55S426
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`W8U75Q825
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`W8U65R625
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`COMPLAINT FOR PATENT INFRINGEMENT
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`W8U55S427
`
`W8U55R625
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`W8U43S525
`
`W8U65S525
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`W8U55S525
`
`W8U55S423
`
`W8U43S421
`
`W8U50S525
`
`W8U50S423
`
`W8U65S423
`
`W8U75S425
`
`W8U75R615
`
`W8U32S301
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`W8U55S421
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`W8U32S325
`
`W8U49S325
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`W8U43S325
`
`W8U40S325
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`W8U32S327
`
`W8U43S425
`
`W8U50S425
`
`W8U49S425
`
`W8U32S321
`
`W8U65S425
`
`W8U55S425
`
`W8U49S403
`
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`COMPLAINT FOR PATENT INFRINGEMENT
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`55S427
`
`55R625
`
`43S525
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`65S525
`
`55S525
`
`55S423
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`43S421
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`50S525
`
`50S423
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`65S423
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`75S425
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`75R615
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`32S301
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`55S421
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`32S325
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`49S325
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`43S325
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`40S325
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`32S327
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`32S425
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`50S425
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`49S425
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`32S321
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`65S425
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`55S425
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`49S403
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`Case 5:20-cv-01030 Document 1 Filed 05/14/20 Page 8 of 26 Page ID #:8
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`65S401
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`43S403
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`55S401
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`65S517
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`55S517
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`65R613
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`55R613
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`49S517
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`43S517
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`75C807
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`49S303
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`43S303
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`40S303
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`28S303
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`32S303
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`55C807
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`65C807
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`W8U65S401
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`W8U43S403
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`W8U55S401
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`W8U65S517
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`W8U55S517
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`W8U65R613
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`W8U55R613
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`W8U49S517
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`W8U43S517
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`W8U75C807
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`W8U49S303
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`W8U43S303
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`W8U40S303
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`W8U28S303
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`W8U32S303
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`W8U55C807
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`W8U65C807
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`THE ASSERTED PATENTS
`United States Patent No. 6,049,706
`26. 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. A true and correct copy of the ’706 patent is attached as Exhibit 1.
`27.
`The ’706 patent is presumed valid under 35 U.S.C. § 282.
`28.
`ParkerVision owns all rights, title, and interest in the ’706 patent.
`
`/ / /
`/ / /
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`COMPLAINT FOR PATENT INFRINGEMENT
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`Case 5:20-cv-01030 Document 1 Filed 05/14/20 Page 9 of 26 Page ID #:9
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`United States Patent No. 6,266,518
`29. 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. A true and
`correct copy of the ’518 patent is attached as Exhibit 2.
`30.
`The ’518 patent is presumed valid under 35 U.S.C. § 282.
`31.
`ParkerVision owns all rights, title, and interest in the ’518 patent.
`United States Patent No. 6,580,902
`32. 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. A true and correct copy of the ’902 patent is attached as
`Exhibit 3.
`33.
`34.
`
`The ’902 patent is presumed valid under 35 U.S.C. § 282.
`ParkerVision owns all rights, title, and interest in the ’902 patent.
`United States Patent No. 7,110,444
`35. 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. A true and correct
`copy of the ’444 patent is attached as Exhibit 4.
`36.
`The ’444 patent is presumed valid under 35 U.S.C. § 282.
`37.
`ParkerVision owns all rights, title, and interest in the ’444 patent.
`United States Patent No. 7,292,835
`38. 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”)
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`entitled “Wireless and Wired Cable Modem Applications of Universal Frequency
`Translation Technology” to inventor David F. Sorrells et al. A true and correct
`copy of the ’835 patent is attached as Exhibit 5.
`39.
`The ’835 patent is presumed valid under 35 U.S.C. § 282.
`40.
`ParkerVision owns all rights, title, and interest in the ’835 patent.
`United States Patent No. 8,588,725
`41. On November 19, 2013, the United States Patent and Trademark
`Office 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. A true and
`correct copy of the ’725 patent is attached as Exhibit 6.
`42.
`The ’725 patent is presumed valid under 35 U.S.C. § 282.
`43.
`ParkerVision owns all rights, title, and interest in the ’725 patent.
`United States Patent No. 8,660,513
`44. 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. A true and correct copy of the ’513 patent is attached as Exhibit 7.
`45.
`The ’513 patent is presumed valid under 35 U.S.C. § 282.
`46.
`ParkerVision owns all rights, title, and interest in the ’513 patent.
`United States Patent No. 9,118,528
`47. 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. A true and correct copy of the ’528 patent is attached as Exhibit 8.
`48.
`The ’528 patent is presumed valid under 35 U.S.C. § 282.
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`49.
`
`ParkerVision owns all rights, title, and interest in the ’528 patent.
`United States Patent No. 9,246,736
`50. 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. A true and correct copy of the ’736 patent is
`attached as Exhibit 9.
`51.
`The ’736 patent is presumed valid under 35 U.S.C. § 282.
`52.
`ParkerVision owns all rights, title, and interest in the ’736 patent.
`United States Patent No. 9,444,673
`53. 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. A true
`and correct copy of the ’673 patent is attached as Exhibit 10.
`54.
`The ’673 patent is presumed valid under 35 U.S.C. § 282.
`55.
`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
`56.
`The allegations set forth above are re-alleged and incorporated by
`reference as if they were set forth fully here.
`57.
`TCL 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.
`TCL products that infringe one or more claims of the ’706 patent
`58.
`include, but are not limited to, the TCL Products and any other TCL audio/visual
`device that is capable of filtering and down-converting a higher-frequency signal to
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`a lower-frequency signal as claimed in the ’706 patent.
`59.
`Each TCL Chip is/includes an apparatus for filtering and down-
`converting (e.g., a higher frequency RF signal to a lower frequency signal). Each
`TCL 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 TCL 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.
`60.
`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.
`ParkerVision has been damaged by the direct infringement of TCL
`61.
`and is suffering and will continue to suffer irreparable harm and damages as a
`result of this infringement.
`COUNT II – Infringement of United States Patent No. 6,266,518
`62.
`The allegations set forth above are re-alleged and incorporated by
`reference as if they were set forth fully here.
`63.
`TCL 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.
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`TCL products that infringe one or more claims of the ‘518 patent
`64.
`include, but are not limited to, the TCL Products and any other TCL audio/visual
`device that is capable of down-converting a higher-frequency signal to a lower-
`frequency signal as claimed in the ‘518 patent.
`65.
`Each TCL 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 TCL Chip has a universal frequency down-converter (UFD),
`including a switch (e.g., transistor), an integrator (e.g., operational amplifier with
`parallel resistor-capacitor feedback) coupled to said switch, a pulse generator (e.g.,
`LO) coupled to said switch; and a reactive structure (e.g., active filter) coupled to
`said UFD.
`The pulse generator (e.g., LO) outputs pulses (e.g., LO signal) to said
`66.
`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.
`67.
`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 transferred from said carrier signal and integrated using said integrator
`(e.g., operational amplifier with parallel resistor-capacitor feedback) during
`apertures of said pulses, and said lower frequency signal (e.g., baseband signal) is
`generated from the transferred energy.
`68.
`The energy is transferred to a load (e.g., resistor) during an off-time
`(e.g., when the switch is open).
`69.
`ParkerVision has been damaged by the direct infringement of TCL,
`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. 6,580,902
`70.
`The allegations set forth above are re-alleged and incorporated by
`reference as if they were set forth fully here.
`
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`10
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`COMPLAINT FOR PATENT INFRINGEMENT
`
`ParkerVision Ex. 2001
`IPR2021-00990
`Page 13 of 26
`
`

`

`Case 5:20-cv-01030 Document 1 Filed 05/14/20 Page 14 of 26 Page ID #:14
`
`TCL directly infringes (literally and/or under the doctrine of
`71.
`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.
`TCL products that infringe one or more claims of the ’902 patent
`72.
`include, but are not limited to, the TCL Products and any other TCL audio/visual
`device that is capable of down-converting a higher-frequency signal to a lower-
`frequency signal as claimed in the ’902 patent.
`73.
`Each TCL Chip is/includes a circuit for down-converting an
`electromagnetic signal (e.g., high frequency RF signal) to a lower frequency signal.
`Each TCL 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 TCL 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.
`74.
`The energy transfer module of each TCL 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.
`75.
`The common control port accepts the energy transfer signal, which
`has a control frequency that is substantially equal to said energy transfer rate.
`76.
`Each of the transistors of the TCL 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.
`
`1 2 3 4 5 6 7 8 9
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`14
`COMPLAINT FOR PATENT INFRINGEMENT
`
`ParkerVision Ex. 2001
`IPR2021-00990
`Page 14 of 26
`
`

`

`Case 5:20-cv-01030 Document 1 Filed 05/14/20 Page 15 of 26 Page ID #:15
`
`ParkerVision has been damaged by the direct infringement of TCL
`77.
`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. 7,110,444
`78.
`The allegations set forth above are re-alleged and incorporated by
`reference as if they were set forth fully here.
`79.
`TCL 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.
`TCL products that infringe one or more claims of the ’444 patent
`80.
`include, but are not limited to, the TCL Products and any other TCL audio/visual
`device that is capable of down-converting a higher-frequency signal to a lower-
`frequency signal as claimed in the ’444 patent.
`81.
`Each TCL 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.
`
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`15
`COMPLAINT FOR PATENT INFRINGEMENT
`
`ParkerVision Ex. 2001
`IPR2021-00990
`Page 15 of 26
`
`

`

`Case 5:20-cv-01030 Document 1 Filed 05/14/20 Page 16 of 26 Page ID #:16
`
`The first frequency down-conversion module under-samples (e.g., at a
`82.
`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.
`83.
`ParkerVision has been damaged by the direct infringement of TCL,
`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
`84.
`The allegations set forth above are re-alleged and incorporated by
`reference as if they were set forth fully here.
`85.
`TCL 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.
`86.
`TCL products that infringe one or more claims of the ’835 patent
`include, but are not limited to, the TCL Products and any other TCL audio/visual
`device that is capable of down-converting a higher-frequency signal to a lower-
`frequency signal as claimed in the ’835 patent.
`87.
`TCL Products enable users to watch live TV and on demand
`programming from their cable service providers over a wireless network.
`https://support.tclusa.com/televisions-setup-configurations/258975-how-to-
`connect-your-tcl-roku-tv-to-the-internet; https://www.tclusa.com/top-tv-apps. TCL
`Chips are configured to function/capable of functioning as wireless cable modems.
`For example, TCL Chips provide a wireless connection to cable services.
`88.
`Each TCL 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
`
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`COMPLAINT FOR PATENT INFRINGEMENT
`
`ParkerVision Ex. 2001
`IPR2021-00990
`Page 16 of 26
`
`

`

`Case 5:20-cv-01030 Document 1 Filed 05/14/20 Page 17 of 26 Page ID #:17
`
`is transmitted by a wireless method to the cable modem.
`89.
`Each TCL 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.
`90.
`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 module samples the electromagnetic signal at a rate (e.g., LO
`with a 25% duty cycle) that is a function of the in-phase oscillating signal, thereby
`creating a first sampled signal.
`91.
`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.
`92.
`ParkerVision has been damaged by the direct infringement of TCL,
`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
`93.
`The allegations set forth above are re-alleged and incorporated by
`reference as if they were set forth fully here.
`
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`17
`COMPLAINT FOR PATENT INFRINGEMENT
`
`ParkerVision Ex. 2001
`IPR2021-00990
`Page 17 of 26
`
`

`

`Case 5:20-cv-01030 Document 1 Filed 05/14/20 Page 18 of 26 Page ID #:18
`
`TCL directly infringes (literally and/or under the doctrine of
`94.
`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.
`TCL products that infringe one or more claims of the ’725 patent
`95.
`include, but are not limited to, the TCL Products and any other TCL audio/visual
`device that is capable of down-converting a higher-frequency signal to a lower-
`frequency signal as claimed in the ’725 patent.
`96.
`Each TCL Chip is/includes an apparatus for down-converting an
`electromagnetic signal (e.g., high frequency RF signal) to a lower frequency signal.
`Each TCL Chip has an aliasing module comprising a switching device (e.g.,
`transistor) 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 cy