Case 6:21-cv-00694-ADA Document 1 Filed 07/01/21 Page 1 of 25
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`UNITED STATES DISTRICT COURT
`FOR THE WESTERN DISTRICT OF TEXAS
`WACO DIVISION
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`XR COMMUNICATIONS, LLC, dba
`VIVATO TECHNOLOGIES,
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`Plaintiff,
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`Case No.
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`JURY TRIAL DEMANDED
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`v.
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`HP INC.,
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`Defendant.
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`COMPLAINT FOR PATENT INFRINGEMENT AGAINST
`HP INC.
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`This is an action for patent infringement arising under the Patent Laws of the United States
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`of America, 35 U.S.C. § 1 et seq., in which Plaintiff XR Communications LLC d/b/a Vivato
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`Technologies (“Plaintiff” or “Vivato”) makes the following allegations against Defendant HP Inc.
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`(“Defendant”):
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`INTRODUCTION
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`1.
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`This complaint arises from Defendant’s unlawful infringement of the following
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`United States patent owned by Vivato, which generally relates to wireless communications
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`technology: United States Patent No. 10,715,235 (the “’235 Patent”) (the “Asserted Patent”).
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`2.
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`Countless electronic devices today connect to the Internet wirelessly. Beyond just
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`connecting our devices together, wireless networks have become an inseparable part of our lives
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`in our homes, our offices, and our neighborhood coffee shops. In even our most crowded spaces,
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`today’s wireless technology allows all of us to communicate with each other, on our own devices,
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`at virtually the same time. Our connected world would be unrecognizable without the ubiquity of
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`sophisticated wireless networking technology.
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`3.
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`Just a few decades ago, wireless technology of this kind could only be found in
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`science fiction. The underlying science behind wireless communications can be traced back to the
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`development of “wireless telegraphy” in the nineteenth century. Guglielmo Marconi is credited
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`with developing the first practical radio, and in 1896, Guglielmo Marconi was awarded British
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`patent 12039, Improvements in transmitting electrical impulses and signals and in apparatus
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`there-for, the first patent to issue for a Herzian wave-based wireless telegraphic system. Marconi
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`would go on to win the Nobel Prize in Physics in 1909 for his contributions to the field.
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`4.
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`One of Marconi’s preeminent contemporaries was Dr. Karl Ferdinand Braun, who
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`shared the 1909 Nobel Prize in Physics with Marconi. In his Nobel lecture dated December 11,
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`1909, Braun explained that he was inspired to work on wireless technology by Marconi’s own
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`experiments. Braun had observed that the signal strength in Marconi’s radio was limited beyond a
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`certain distance, and wondered why increasing the voltage on Marconi’s radio did not result in a
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`stronger transmission at greater distances. Braun thus dedicated himself to developing wireless
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`devices with a stronger, more effective transmission capability.
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`5.
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`In 1905, Braun invented the first phased array antenna. This phased array antenna
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`featured three antennas carefully positioned relative to one another with a specific phase
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`relationship so that the radio waves output from each antenna could add together to increase
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`radiation in a desired direction. This design allowed Braun’s phased array antenna to transmit a
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`directed signal.
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`6.
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`Building on the fundamental breakthrough that radio transmissions can be directed
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`according to a specific radiation pattern through the use of a phased array antenna, directed
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`wireless communication technology has developed many applications over the years. Braun’s
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`invention of the phased array antenna led to the development of radar, smart antennas, and,
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`eventually, to a technology known as “MIMO,” or “multiple-input, multiple-output,” which would
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`ultimately allow a single radio channel to receive and transmit multiple data signals
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`simultaneously. Along the way, engineers have worked tirelessly to overcome limitations and
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`roadblocks directed wireless communication technology.
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`7.
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`At the beginning of the twenty-first century, the vast majority of wireless networks
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`still did not yet take advantage of directed wireless communications. Instead, “omnidirectional”
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`access points were ubiquitous. Omnidirectional access points transmit radio waves uniformly
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`around the access point in every direction and do not steer the signal in particular directions.
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`Omnidirectional antennas access points do typically achieve 360 degrees of coverage around the
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`access point, but with a reduced coverage distance. Omnidirectional access points also lack
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`sophisticated approaches to overcome certain types of interference in the environment. As only
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`one example, the presence of solid obstructions, such as a concrete wall, ceiling, or pillar, can limit
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`signal penetration. As another example, interference arises when radio waves are reflected,
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`refracted, or diffracted based on obstacles present between the transmitter and receiver. The
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`multiple paths that radio waves can travel between the transmitter and receiver often result in signal
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`interference that decreases performance, and omnidirectional access points lack advanced
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`solutions to overcome these “multipath” effects.
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`8.
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`Moving from omnidirectional networks to modern networks has required an
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`additional series of advancements that harness the capabilities of directed wireless technology.
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`These advancements range from conceiving various ways to steer and modify radiation patterns,
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`to enhancing the transmission signal power in a desired direction, to suppressing radiation in
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`undesired directions, to minimizing signal “noise,” and then applying these new approaches into
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`Case 6:21-cv-00694-ADA Document 1 Filed 07/01/21 Page 4 of 25
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`communications networks with multiple, heterogenous transmitters and receivers.
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`9.
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`Harnessing the capabilities of directed wireless technology resulted in a significant
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`leap forward in the signal strength, reliability, concurrent users, and/or data transmission capability
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`of a wireless network. One of the fundamental building blocks of this latest transition was the
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`development of improvements to MIMO and “beamforming,” which are the subject matter of
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`patents in this infringement action. The patents in this action resulted from the investment of tens
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`of millions of dollars and years of tireless effort by a group of engineers who built a technology
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`company slightly ahead of its time. Their patented innovations laid the groundwork for today’s
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`networks, and are infringed by Defendant’s accused products.
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`Case 6:21-cv-00694-ADA Document 1 Filed 07/01/21 Page 5 of 25
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`PARTIES
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`10.
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`Plaintiff XR Communications, LLC, d/b/a Vivato Technologies (“Vivato” or
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`“Plaintiff”) is a limited liability company organized and existing under the laws of the State of
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`Delaware with its principal place of business at 2809 Ocean Front Walk, Venice, California 90291.
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`Vivato is the sole owner by assignment of all right, title, and interest in each Asserted Patent.
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`11.
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`Vivato was founded in 2000 as a $80+ million venture-backed company with
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`several key innovators in the wireless communication field including Siavash Alamouti, Ken Biba,
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`William Crilly, James Brennan, Edward Casas, and Vahid Tarokh, among many others. At that
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`time, and as remains the case today, “Wi-Fi” or “802.11” had become the ubiquitous means of
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`wireless connection to the Internet, integrated into hundreds of millions of mobile devices globally.
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`Vivato was founded to leverage its talent to generate intellectual property and deliver Wi-Fi/802.11
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`wireless connectivity solutions to service the growing demand for bandwidth.
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`12.
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`Vivato has accomplished significant innovations in the field of wireless
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`communications technology. One area of focus at Vivato was the development of advanced
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`wireless systems with sophisticated antenna designs to improve wireless speed, coverage, and
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`reliability. Vivato also focused on designing wireless systems that maximize the efficient use of
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`spectrum and wireless resources for large numbers of connected mobile devices.
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`13.
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`Among many fundamental breakthroughs achieved by Vivato are inventions that
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`allow for intelligent and adaptive beamforming based on up-to-date information about the wireless
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`medium. Through these and many other inventions, Vivato’s engineers pioneered a wireless
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`technology that provides for simultaneous transmission and reception, a significant leap forward
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`over conventional wireless technology.
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`14.
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`Over the years, Vivato has developed proven technology, with over 400
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`deployments globally, including private, public and government, and it has become a recognized
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`provider of extended range Wi-Fi network infrastructure solutions. Vivato's wireless base stations
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`integrate beamforming phased array antenna design with packet steering technology to deliver
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`high-bandwidth extended range connections to serve multiple users and multiple devices.
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`15.
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`Vivato’s patent portfolio includes over 17 issued patents and pending patent
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`applications. The patents at issue in this case are directed to specific aspects of wireless
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`communication, including adaptively steered antenna technology and beam switching technology.
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`16.
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`Defendant HP Inc. is a Delaware corporation with a principal place of business at
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`1501 Page Mill Road, Palo Alto, California 94304.
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`17.
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`Defendant maintains a regular and established place of business at 3800 Quick Hill
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`Road #100, Austin, Texas 78728, and it advertises positions on its website available in Austin.
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`Defendant distributes, markets, and sells electronic devices in the United States. Defendant is
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`authorized to do business in Texas and may be served through its registered agent CT Corporation
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`System, 1999 Bryan Street, Suite 900, Dallas, Texas 75201.
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`18.
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`Defendant offers for sale, sells, designs and manufactures and/or has manufactured
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`on their behalf abroad certain Accused Products that are then sold for importation into the United
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`States, imported into the United States, and/or sold, offered for sale, and/or used within the United
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`States after importation. By registering to conduct business in Texas and by having facilities where
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`it regularly conducts business in this District, Defendant has a permanent and continuous presence
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`in Texas and a regular and established place of business in the Western District of Texas.
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`JURISDICTION AND VENUE
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`19.
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`This action arises under the patent laws of the United States, Title 35 of the United
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`States Code § 1, et seq, including 35 U.S.C. §§ 271, 281, 283, 284, and 285. This Court has original
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`Case 6:21-cv-00694-ADA Document 1 Filed 07/01/21 Page 7 of 25
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`subject matter jurisdiction pursuant to 28 U.S.C. §§ 1331 and 1338(a).
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`20.
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`This Court has personal jurisdiction over Defendant in this action because
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`Defendant has committed acts within this District giving rise to this action, and has established
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`minimum contacts with this forum such that the exercise of jurisdiction over Defendant would not
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`offend traditional notions of fair play and substantial justice. Defendant, directly and/or through
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`subsidiaries or intermediaries, have committed and continue to commit acts of infringement in this
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`District by, among other things, importing, offering to sell, and selling products that infringe the
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`asserted patents, and inducing others to infringe the asserted patents in this District. Defendant is
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`directly and through intermediaries making, using, selling, offering for sale, distributing,
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`advertising, promoting, and otherwise commercializing their infringing products in this District.
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`Defendant regularly conducts and solicits business in, engage in other persistent courses of conduct
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`in, and/or derive substantial revenue from goods and services provided to the residents of this
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`District and the State of Texas. Defendant is subject to jurisdiction pursuant to due process and/or
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`the Texas Long Arm Statute due to its substantial business in this State and District including at
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`least its infringing activities, regularly doing or soliciting business at its Austin facilities, and
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`engaging in persistent conduct and deriving substantial revenues from goods and services provided
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`to residents in the State of Texas including the Western District of Texas.
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`21.
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`Venue is proper in this District pursuant to 28 U.S.C. § 1391(b), (c), (d), and
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`1400(b) because Defendant has a permanent and continuous presence in, have committed acts of
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`infringement in, and maintain regular and established places of business in this district. Defendant
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`has committed acts of direct and indirect infringement in this judicial district including using and
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`purposefully transacting business involving the Accused Products in this judicial district such as
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`by sales to one or more customers in the State of Texas including in the Western District of Texas,
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`Case 6:21-cv-00694-ADA Document 1 Filed 07/01/21 Page 8 of 25
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`and maintaining regular and established places of business in this district. For example, Defendant
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`maintains a regular and established place of business at 3800 Quick Hill Road #100, Austin, Texas
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`78728.
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`COUNT I
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`INFRINGEMENT OF U.S. PATENT NO. 10,715,235
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`22.
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`Vivato realleges and incorporates by reference the foregoing paragraphs as if fully
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`set forth herein.
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`23.
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`On July 14, 2020, United States Patent No. 10,715,235 duly and legally issued for
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`inventions entitled “Directed Wireless Communication.” Vivato owns the ’235 Patent and holds
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`the right to sue and recover damages for infringement thereof. A copy of the ’235 Patent is attached
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`hereto as Exhibit A.
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`24.
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`Defendant has directly infringed and continues to directly infringe numerous claims
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`of the ’235 Patent, including at least claim 8, by manufacturing, using, selling, offering to sell,
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`and/or importing into the United States certain products supporting MIMO and/or MU-MIMO
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`technologies (e.g., Defendant’s Laptop computers, including all variations and configurations
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`thereof, such as: Envy Series, 1 Envy x360 Series, Pavilion Series, Pavilion Gaming Series,
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`Pavilion x360 Convertible Series, Spectre x360 Convertible Series, Omen Series, Chromebook
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`x360 Series, Chromebook 11a Series, Chromebook 14b Series, Chromebook Clamshell Series,
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`Chromebook x360 Series, ProBook Series, Elite DragonFly Series, Elite Folio Series, ZBook
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`Series, Elite x2 Series, and EliteBook Series; Defendant’s Desktop computers, including all
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`variations and configurations thereof, such as: Pavilion Gaming Series, All-in-One Series, Envy
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`Series, Pavilion Series, OMEN Series, ProDesk Series, EliteOne Series, z2 Mini Workstation
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`1 HP Envy 15 Webpage: https://www.hp.com/us-en/laptops/envy/envy-15-laptop.html
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`Case 6:21-cv-00694-ADA Document 1 Filed 07/01/21 Page 9 of 25
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`Series, ProOne Series, EliteDesk Series, Elite Slice Series, Chromebox Series, Z2 Small Form
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`Factor Workstation Series, and Z2 Tower Workstation Series) (collectively, the “’235 Accused
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`Products”). Defendant is liable for infringement of the ’235 Patent pursuant to 35 U.S.C. § 271(a).
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`25.
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`The ’235 Accused Products satisfy all claim limitations of numerous claims of
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`the ’235 Patent, including Claim 8. The following paragraphs compare limitations of Claim 8 to
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`an exemplary Accused Product, the Envy 15 Laptop. See, e.g., HP Envy Laptop Webpage,2 HP
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`Envy Laptop Datasheet.3 Like the Envy 15 Laptop, each Accused Product supports MU-MIMO
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`technology. For example, the Envy 15 Laptop includes “Wi-Fi 6 and Bluetooth 5.0 for super-fast
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`connectivity.” See HP Envy 15 Webpage. The HP Envy 15 supports “Intel® Wi-Fi 6 AX 201
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`(2x2)” connectivity, see HP Envy Laptop Webpage, with “MU-MIMO supported.” See HP Envy
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`Laptop Datasheet.
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`26.
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`Each ’235 Accused Product performs a method for use in a wireless
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`communications system, the method comprising receiving a first signal transmission from a remote
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`station via a first antenna element of an antenna and a second signal transmission from the remote
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`station via a second antenna element of the antenna simultaneously, wherein the first signal
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`transmission and the second signal transmission comprise electromagnetic signals comprising one
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`or more transmission peaks and one or more transmission nulls. For example, as with each ’235
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`2 HP Envy Laptop Webpage, available at: https://www.hp.com/us-en/shop/pdp/hp-envy-laptop-
`15-
`ep0098nr?bvroute=Review%2F234385063&bvstate=pg:2/ct:r&cq_src=google_ads&cq_cmp=12
`690817676&cq_con=123460399194&cq_term=&cq_med=&cq_plac=&cq_net=g&cq_pos=&cq
`_plt=gp&DSA&jumpid=ps_con_nb_ns&utm_medium=ps&utm_source=ga&utm_campaign=HP
`-Store_US_BRA_PS_CPS_OPEX_Google_All_SEM_All_Notebooks-
`DSA&utm_term=&matchtype=b&adid=512564949515&addisttype=g&gclid=CjwKCAjww-
`CGBhALEiwAQzWxOqjxfsR309dR8iCpGVQeiIgUvelkug-
`SAjy99RX2DTwm6UftDCee9xoC0L8QAvD_BwE&gclsrc=aw.ds
`3 HP Envy Laptop Datasheet: https://www8.hp.com/h20195/v2/GetPDF.aspx/c06931364.pdf
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`Accused Product, the Envy 15 Laptop receives a first signal transmission from a remote station,
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`such as a Wi-Fi Access Point, via a first antenna element of an antenna and a second signal
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`transmission from the remote station via a second antenna element of the antenna simultaneously,
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`such as when the Envy 15 Laptop receives first and second signals with its first and second antenna
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`elements that contain training fields of a null data packet used for MU-MIMO sounding and
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`channel estimation procedures. For example, the Envy 15 Laptop includes “Wi-Fi 6 and Bluetooth
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`5.0 for super-fast connectivity.” See HP Envy 15 Webpage. The HP Envy 15 supports “Intel® Wi-
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`Fi 6 AX 201 (2x2)” connectivity, see HP Envy Laptop Webpage, with “MU-MIMO supported.”
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`See HP Envy Laptop Datasheet. See, e.g., IEEE 802.11ax Standard, Section 27.3.1.1 (“The
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`transmission within an RU in a PPDU may be single stream to one user, spatially multiplexed to
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`one user (SU-MIMO), or spatially multiplexed to multiple users (MU-MIMO).”); Section 27.3.2.5
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`(“The number of users in the MU-MIMO group is indicated in the Number Of HE-SIG-B Symbols
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`Or MU-MIMO Users field in HE-SIG-A. The allocated spatial streams for each user and the total
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`number of spatial streams are indicated in the Spatial Configuration field of User field in HE-SIG-
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`B containing the STA-ID of the designated MU-MIMO STA as defined in Table 27-29 (Spatial
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`Configuration subfield encoding)…[i]f there is only one User field (see Table 27-27 (User field
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`format for a non-MU-MIMO allocation)) for an RU in the HE-SIG-B content channel, then the
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`number of spatial streams for the user in the RU is indicated by the NSTS field in the User field.
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`If there is more than one User field (see Table 27-28 (User field for an MU-MIMO allocation)) for
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`an RU in the HE-SIG-B content channel, then the number of allocated spatial streams for each
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`user in the RU is indicated by the Spatial Configuration field of the User field in HE-SIG-B.”);
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`Section 27.3.2.6 (“UL MU transmissions are preceded by a Trigger frame or frame carrying a TRS
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`Control subfield from the AP. The Trigger frame or frame carrying the TRS Control subfield
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`indicates the parameters, such as the duration of the HE TB PPDU, RU allocation, target RSSI and
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`MCS (see 9.3.1.22 (Trigger frame format), 9.2.4.6a.1 (TRS Control) and 26.5.3.3 (Non-AP STA
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`behavior for UL MU operation)), required to transmit an HE TB PPDU”); Section 27.3.10.8 (HE-
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`SIG-B) (“The HE-SIG-B field provides the OFDMA and DL MU-MIMO resource allocation
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`information to allow the STAs to look up the corresponding resources to be used in the data portion
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`of the frame.”); Section 27.3.15 (“SU-MIMO and DL-MU-MIMO beamforming are techniques
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`used by a STA with multiple antennas (the beamformer) to steer signals using knowledge of the
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`channel to improve throughput. With SU-MIMO beamforming all space-time streams in the
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`transmitted signal are intended for reception at a single STA in an RU. With DL MU-MIMO
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`beamforming, disjoint subsets of the space-time streams are intended for reception at different
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`STAs in an RU of size greater than or equal to 106-tones”); Section 27.3.10.8.5 (HE-SIG-B per
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`user content) (“The User Specific field consists of multiple User fields. The User fields follow the
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`Common field of HE-SIG-B. The RU Allocation field in the Common field and the position of the
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`User field in the User Specific field together identify the RU used to transmit a STA’s data…”).
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`See, e.g., IEEE 802.11ac Standard Clause 9.31.5.1 (“Transmit beamforming and DL-MU-MIMO
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`require knowledge of the channel state to compute a steering matrix that is applied to the
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`transmitted signal to optimize reception at one or more receivers. The STA transmitting using the
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`steering matrix is called the VHT beamformer and a STA for which reception is optimized is called
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`a VHT beamformee. An explicit feedback mechanism is used where the VHT beamformee directly
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`measures the channel from the training symbols transmitted by the VHT beamformer and sends
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`back a transformed estimate of the channel state to the VHT beamformer. The VHT beamformer
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`then uses this estimate, perhaps combining estimates from multiple VHT beamformees, to derive
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`the steering matrix.”); See, e.g., 802.11ac Standard Clause 9.31.5.2 (“A VHT beamformer shall
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`initiate a sounding feedback sequence by transmitting a VHT NDP Announcement frame followed
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`by a VHT NDP after a SIFS. The VHT beamformer shall include in the VHT NDP Announcement
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`frame one STA Info field for each VHT beamformee that is expected to prepare VHT Compressed
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`Beamforming feedback and shall identify the VHT beamformee by including the VHT
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`beamformee’s AID in the AID subfield of the STA Info field. The VHT NDP Announcement
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`frame shall include at least one STA Info field.”); id. (“A non-AP VHT beamformee that receives
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`a VHT NDP Announcement frame… shall transmit its VHT Compressed Beamforming feedback
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`a SIFS after receiving a Beamforming Report Poll with RA matching its MAC address and a non-
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`bandwidth signaling TA obtained from the TA field matching the MAC address of the VHT
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`beamformer.”); id. Clause 8.5.23.2 (defining format and subfields within the VHT Compressed
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`Beamforming frame); id. Clause 8.4.1.48 (including Tables 8-53(d)-(h)) (“Each SNR value per
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`tone in stream i (before being averaged) corresponds to the SNR associated with the column i of
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`the beamforming feedback matrix V determined at the beamformee”); id. Clause 8.4.1.49
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`(including Table 8-53i – MU Exclusive Beamforming Report information); id. Clauses 8.4.1.24,
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`9.31.5.1, 9.31.5.2; id. Clauses 22.3.4.6(d), 22.3.4.7(e), 22.3.4.8(l), 22.3.4.9.1(m), 22.3.4.9.2(m),
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`22.3.4.10.4(a) (“Spatial mapping: Apply the Q matrix as described in 22.3.10.11.1.”); id. Clause
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`22.3.10.11.1; IEEE 802.11-2012 Standard Clause 20.3.12.3.6; 802.11ac Standard Clauses
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`8.4.1.24, 9.31.5.1, 9.31.5.2; id. Clause 22.3.11.1:
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`Case 6:21-cv-00694-ADA Document 1 Filed 07/01/21 Page 13 of 25
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`; id. Clause 22.3.11.2:
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`27.
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`Each ’235 Accused Product performs a method for use in a wireless
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`communications system, the method comprising determining first signal information for the first
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`signal transmission and determining second signal information for the second signal transmission,
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`wherein the second signal information is different than the first signal information. For example,
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`as with each ’235 Accused Product, the Envy 15 Laptop determines different signal information
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`for the first signal transmission than it does for the second signal transmission, by using the training
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`fields of a null data packet for MU-MIMO sounding and channel estimation to determine the
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`parameters in the beamforming feedback matrix. For example, the Envy 15 Laptop includes “Wi-
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`Fi 6 and Bluetooth 5.0 for super-fast connectivity.” See HP Envy 15 Webpage. The HP Envy 15
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`supports “Intel® Wi-Fi 6 AX 201 (2x2)” connectivity, see HP Envy Laptop Webpage, with “MU-
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`MIMO supported.” See HP Envy Laptop Datasheet. See, e.g., IEEE 802.11ax Standard, Section
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`26.7 (HE sounding protocol) (“Transmit beamforming and DL MU-MIMO require knowledge of
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`the channel state to compute a steering matrix that is applied to the transmit signal to optimize
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`reception at one or more receivers. HE STAs use the HE sounding protocol to determine the
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`Case 6:21-cv-00694-ADA Document 1 Filed 07/01/21 Page 14 of 25
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`channel state information. The HE sounding protocol provides explicit feedback mechanisms,
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`defined as HE non-trigger-based (non-TB) sounding and HE trigger-based (TB) sounding, where
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`the HE beamformee measures the channel using a training signal (i.e., an HE sounding NDP)
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`transmitted by the HE beamformer and sends back a transformed estimate of the channel state.
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`The HE beamformer uses this estimate to derive the steering matrix. The HE beamformee returns
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`an estimate of the channel state in an HE compressed beamforming/CQI report carried in one or
`
`more HE Compressed Beamforming/CQI frames.”); Section 26.7.3 (“An HE beamformee that
`
`receives an HE NDP Announcement frame from an HE beamformer with which it is associated
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`and that contains the HE beamformee’s MAC address in the RA field and also receives an HE
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`sounding NDP a SIFS after the HE NDP Announcement frame shall transmit its HE compressed
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`beamforming/CQI report a SIFS after the HE sounding NDP. The TXVECTOR parameter
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`CH_BANDWIDTH for the PPDU containing the HE compressed beamforming/CQI report shall
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`be set to indicate a bandwidth not wider than that indicated by the RXVECTOR parameter
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`CH_BANDWIDTH of the HE sounding NDP. An HE beamformee that receives an HE NDP
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`Announcement frame as part of an HE TB sounding sequence with a STA Info field addressed to
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`it soliciting SU or MU feedback shall generate an HE compressed beamforming/CQI report using
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`the feedback type, Ng and codebook size indicated in the STA Info field. If the HE beamformee
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`then receives a BFRP Trigger frame with a User Info field addressed to it, the HE beamformee
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`transmits an HE TB PPDU containing the HE compressed beamforming/CQI report following the
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`rules defined in 26.5.3.3 (Non-AP STA behavior for UL MU operation).”); Section 26.5.3 (UL
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`MU operation) (“UL MU operation allows an AP to solicit simultaneous immediate response
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`frames from one or more non-AP HE STAs”); Section 27.3.10.10 (HE-LTF) (“The HE-LTF field
`
`provides a means for the receiver to estimate the MIMO channel between the set of constellation
`
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`mapper outputs (or, if STBC is applied, the STBC encoder outputs) and the receive chains. In an
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`HE SU PPDU and HE ER SU PPDU, the transmitter provides training for NSTS space-time
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`streams (spatial mapper inputs) used for the transmission of the PSDU. In an HE MU PPDU, the
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`transmitter provides training for NSTS,r,total space-time streams used for the transmission of the
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`PSDU(s) in the r-th RU. In an HE TB PPDU, the transmitter of user u in the r-th RU provides
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`training for NSTS,r,u space-time streams used for the transmission of the PSDU. For each tone in
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`the r-th RU, the MIMO channel that can be estimated is an NRX x NSTS,r,total matrix. An HE
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`transmission has a preamble that contains HE-LTF symbols, where the data tones of each HE-LTF
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`symbol are multiplied by entries belonging to a matrix PHE-LTF, to enable channel estimation at
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`the receiver…. In an HE SU PPDU, HE MU PPDU and HE ER SU PPDU, the combination of
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`HE-LTF type and GI duration is indicated in HE-SIG-A field. In an HE TB PPDU, the combination
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`of HE-LTF type and GI duration is indicated in the Trigger frame that triggers transmission of the
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`PPDU. If an HE PPDU is an HE sounding NDP, the combinations of HE-LTF types and GI
`
`durations are listed in 27.3.18 (Transmit specification). If an HE PPDU is an HE TB feedback
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`NDP, the combination of HE-LTF types and GI durations are listed in 27.3.4 (HE PPDU
`
`formats.”); Section 27.3.15.1 (SU-MIMO and DL-MIMO beamforming) (“The DL MU-MIMO
`
`steering matrix Qk = [Qk,0, Qk,1,…,Qk,Nuser,r-1] can be detected by the beamformer using the
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`beamforming feedback for subcarrier k from beamformee u, where u = 0,1,…Nuser,r -1. The
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`feedback report format is described in 9.4.1.65 (HE Compressed Beamforming Report field) and
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`9.4.1.66 (HE MU Exclusive Beamforming Report field). The steering matrix that is computed (or
`
`updated) using new beamforming feedback from some or all of participating beamformees might
`
`replace the existing steering matrix Qk for the next DL MU-MIMO data transmission. For SU-
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`MIMO beamforming, the steering matrix Qk can be determined from the beamforming feedback
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`matrix Vk that is sent back to the beamformer by the beamformee using the compressed
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`beamforming feedback matrix format as defined in 19.3.12.3.6 (Compressed beamforming
`
`feedback matrix). The feedback report format is described in 9.4.1.65 (HE Compressed
`
`Beamforming Report field.”). See, e.g., IEEE 802.11ac Standard Clause 9.31.5.1 (“Transmit
`
`beamforming and DL-MU-MIMO require knowledge of the channel state to compute a steering
`
`matrix that is applied to the transmitted signal to optimize reception at one or more receivers. The
`
`STA transmitting using the steering matrix is called the VHT beamformer and a STA for which
`
`reception is optimized is called a VHT beamformee. An explicit feedback mechanism is used
`
`where the VHT beamformee directly measures the channel from the training symbols transmitted
`
`by the VHT beamformer and sends back a transformed estimate of the channel state to the VHT
`
`beamformer. The VHT beamformer then uses this estimate, perhaps combining estimates from
`
`multiple VHT beamformees, to derive the steering matrix.”); See, e.g., 802.11ac Standard Clause
`
`9.31.5.2 (“A VHT beamformer shall initiate a sounding feedback sequence by transmitting a VHT
`
`NDP Announcement frame followed by a VHT NDP after a SIFS. The VHT beamformer shall
`
`include in the VHT NDP Announcement frame one STA Info field for each VHT beamformee that
`
`is expected to prepare VHT Compressed Beamforming feedback and shall identify the VHT
`
`beamformee by including the VHT beamformee’s AID in the AID subfield of the STA Info field.
`
`The VHT NDP Announcement frame shall include at least one STA Info field.”); id. (“A non-AP
`
`VHT beamformee that receives a VHT NDP Announcement frame… shall transmit its VHT
`
`Compressed Beamforming feedback a SIFS after receiving a Beamforming Report Poll with RA
`
`matching its MAC address and a non-bandwidth signaling TA obtained from the TA field
`
`matching the MAC address of the VHT beamformer.”); id. Clause 8.5.23.2 (defining format and
`
`subfields within the VHT Compressed Beamforming frame); id. Clause 8.4.1.48 (including Tables
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`8-53(d)-(h)) (“Each SNR value per tone in stream i (before being averaged) corresponds to the
`
`SNR associated with the column i of the beamforming feedback matrix V determined at the
`
`beamformee”); id. Clause 8.4.1.49 (including Table 8-53i – MU Exclusive Beamforming Report
`
`information); id. Clauses 8.4.1.24, 9.31.5.1, 9.31.5.2; id. Clauses 22.3.4.6(d), 22.3.4.7(e),
`
`22.3.4.8(l), 22.3.4.9.1(m), 22.3.4.9.2(m), 22.3.4.10.4(a) (“Spatial mapping: Apply the Q matrix as
`
`described in 22.3.10.11.1.”); id. Clause 22.3.10.11.1; IEEE 802.11-2012 Standard Clause
`
`20.3.12.3.6; 802.11ac Standard Clauses 8.4.1.24, 9.31.5.1, 9.31.5.2; id. Clause 22.3.11.1:
`
`; id. Clause 22.3.11.2:
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`
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`28.
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`Each ’235 Accused Product performs a method for use in a wireless
`
`communications system, the method comprising determining a set of weighting values based on
`
`the first signal information and the second signal information, wherein the set of weighting values
`
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`17
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`C