Infringement Claim Chart for the Infringement of Independent Claim 1 of
`U.S. Patent No. 6,603,343 by Apple
`
`1(a)
`
`Claim
`A phase correction circuit
`for a transistor,
`comprising:
`
`Application to USI 339M00104 used in Exemplary Apple iPhone 12 Pro
`Arigna makes these contentions based on the information reasonably available at this time. Its investigation is
`ongoing. Defendant Apple Inc. has not produced documents concerning its infringement of U.S. Patent
`6,603,343 (the “’343 Patent”). Claim construction proceedings have not commenced. Invalidity contentions
`have not been served. Arigna reserves its right to modify, supplement, and/or amend these contentions as
`additional evidence and information becomes available, including in light of discovery, invalidity contentions,
`prior art, claim construction, or any information provided by Apple or any other party or nonparty to this action.
`
`The Universal Scientific Industrial 339M00104 semiconductor device is a device that enables mobile devices,
`such as smartphones and tablets, to connect to 5G mobile networks. See, e.g.:
`
`The USI 339M00104 includes within it the HG11-PG660-200 RF die.
`
`Defendant Apple makes, uses, sells, offers for sale, and/or imports mobile devices that contain the USI
`339M00104. For example, the exemplary Apple iPhone 12 Pro incorporates the USI 339M00104. See, e.g.:
`
`1
`
`EXHIBIT 1007
`
`
`U.S. Patent No. 6,603,343 by Apple
`
`1(a)
`
`Claim
`A phase correction circuit
`for a transistor,
`comprising:
`
`Application to USI 339M00104 used in Exemplary Apple iPhone 12 Pro
`Arigna makes these contentions based on the information reasonably available at this time. Its investigation is
`ongoing. Defendant Apple Inc. has not produced documents concerning its infringement of U.S. Patent
`6,603,343 (the “’343 Patent”). Claim construction proceedings have not commenced. Invalidity contentions
`have not been served. Arigna reserves its right to modify, supplement, and/or amend these contentions as
`additional evidence and information becomes available, including in light of discovery, invalidity contentions,
`prior art, claim construction, or any information provided by Apple or any other party or nonparty to this action.
`
`The Universal Scientific Industrial 339M00104 semiconductor device is a device that enables mobile devices,
`such as smartphones and tablets, to connect to 5G mobile networks. See, e.g.:
`
`The USI 339M00104 includes within it the HG11-PG660-200 RF die.
`
`Defendant Apple makes, uses, sells, offers for sale, and/or imports mobile devices that contain the USI
`339M00104. For example, the exemplary Apple iPhone 12 Pro incorporates the USI 339M00104. See, e.g.:
`
`1
`
`EXHIBIT 1007
`
`
`
`
`
`Defendant Apple also makes,uses,sells, offers for sale, and/or imports mobile devices that contain the Murata
`
` Exemplary Accused Product: Apple iPhone 12 Pro
`
`1XR-484. For example, the Apple iPhone 12 Pro Maxincorporates the Murata 1XR-484.See,e.g.: The Murata 1XR-484 includes within it the HG11-PG660-200 RF die.
`
`
`
`The Apple iPhone 12 Pro is depicted herein as an exemplary device representative of Apple’s Accused
`Products. On information and belief, Apple’s other Accused Products, as identified in Arigna’s Disclosures
`pursuant to this Court’s November 17, 2021 Standing Order Governing Proceedings – Patent Cases, infringe
`the ’343 Patent in a manner identical or substantially similar to that described below and depicted for the Apple
`iPhone 12 Pro. These other Accused Products, including the iPhone 12, iPhone 12 Mini, iPhone 12 Pro Max,
`iPhone 13, iPhone 13 Pro, iPhone 13 mini, and iPhone 13 Pro Max, contain mmWave antenna modules or
`components including, e.g., the USI 339M00104, Murata 1XR-484, Murata 1V4B, Murata 1V4K, Qualcomm
`SMR525, Qualcomm SMR526, and/or other mmWave antenna modules or components that, on information
`and belief, contain an HG11-PG660-200 RF die or substantially similar RF die. As shown in this claim chart,
`the HG11-PG660-200 RF die infringes claim 1 of the ’343 Patent. See infra. Because antenna modules or
`components of the other Apple Accused Products contain the HG11-PG660-200 RF die just as does the USI
`339M00104 antenna module in the exemplary Apple iPhone 12 Pro charted herein, or an RF die substantially
`similar to the HG11-PG660-200 RF die, on information and belief, there are no material differences between
`the accused instrumentalities that affect Arigna’s infringement theories for the other Apple Accused Products
`not specifically charted herein.
`
`The images and circuit diagrams herein are provided to further explain Arigna’s infringement theory but are
`exemplary and not limiting. The absence or incompleteness of an image or circuit diagram, if any, should not
`be construed as any kind of disclaimer of any infringement by similar or substantially similar functionality.
`
`3
`
`
`
`As shown in this claim chart, the HG11-PG660-200 RF die in the USI 339M00104 infringes claim 1 of the
`’343 Patent. See infra.
`
`To the extent this preamble is considered limiting, the HG11-PG660-200 RF die contains a phase correction
`circuit for a transistor. For example, the following annotated and exemplary circuit diagram of the HG11-
`PG660-200 RF die identifies a power amplifier stage (boxed in gold). See, e.g.:
`
`4
`
`
`
`The power amplifier stage, as identified above, contains a phase correction circuit for a transistor. The
`following annotated and exemplary circuit extraction of the power amplifier stage of the HG11-PG660-200 RF
`die identifies a phase correction circuit (boxed in red) for a transistor (boxed in green).
`
`5
`
`
`
`Arigna asserts that each element of claim 1 is present literally in Apple’s accused devices and methods,
`including but not limited to the exemplary iPhone 12 Pro, as represented by the exemplary information cited
`for each element below; but to the extent that any claim construction or other circumstance results in the
`accused devices and methods falling outside the literal scope of any asserted claim, Arigna asserts in the
`alternative that each element of each asserted claim is met by Apple’s accused devices and methods through
`the doctrine of equivalents because Apple’s accused devices and methods are insubstantially different than the
`patented devices and methods and perform the same functions, in substantially the same ways, to achieve the
`same results as the patented devices and methods.
`
`6
`
`
`
`The phase correction circuit for a transistor in the HG11-PG660-200 RF die comprises a circuit element having
`an output terminal connected to a gate of a transistor to which a control signal line is connected, and an input
`terminal, wherein the circuit element has a reactance component (i.e. capacitance) that changes with potential
`difference between the input terminal and the output terminal.
`
`(b)
`
`a circuit element having
`an output terminal
`connected to a gate of a
`transistor to which a
`control signal line is
`connected, and an input
`terminal, wherein the
`circuit element has a
`reactance that changes
`with potential difference
`between the input
`terminal and the
`output terminal; and
`
`7
`
`
`
`
`
`
`
`9
`
`
`
`
`
`The ’343 Patent specification at 4:46-51 and 5:3-8 identifies the “reactance component” as equivalent to
`“capacitance” (“Cd”). Further, Figures 7 and 8 of the ’343 Patent explain that capacitance Cd of the circuit
`element decreases as the potential difference across its terminals increases (Fig. 7) or as the temperature
`increases (Fig. 8). See, e.g.:
`
`The MOS-C circuit element in the HG11-PG660-200 RF die has a reactance component (i.e. capacitance) that
`changes with potential difference between the input terminal and the output terminal.
`
`10
`
`
`
`
`
`For example, the following exemplary figure showsthat theJy circuit element has a reactance component
`(i.e. capacitance), that changes with potential difference across its input terminal and output terminal. Vab is
`represented by Biasin this figure.
`
`0.4
`
`03
`
`=&
`
`uvo
`§ 0.2
`s; 0:1
`5
`
`0
`
`ge
`
`=9
`
`=f
`
`0
`
`1
`
`2
`
`Bias (V)
`
`--- 1MHz --:- 20GHz
`
`5GHz «-: 55 GHz
`
`See, e.g.: Ming Lietal., Investigation of CMOS Varactors for High-GHz-Range Applications, in JOURNAL OF
`ELECTRICAL AND COMPUTER ENGINEERING,at 2 (2009),
`https://www.hindawi.com/journals/jece/2009/535809/.
`
`11
`
`
`
`The phase correction circuit for a transistor in the HG11-PG660-200 RF die comprises a voltage control circuit
`supplying a voltage to the input terminal of the circuit element so that the reactance component (i.e.
`capacitance) of the circuit element decreases in response to an increase in potential of the gate, wherein a sum
`of the reactance component (i.e. capacitance) of the circuit element and a gate-source reactance component (i.e.
`capacitance) of the transistor remains substantially constant.
`
`1(c)
`
`a voltage control circuit
`supplying a voltage to the
`input terminal of the
`circuit element so that the
`reactance of the circuit
`element decreases in
`response to an increase in
`potential of the gate,
`wherein a sum of the
`reactance of the circuit
`element and a gate-source
`reactance of the transistor
`remains substantially
`constant.
`
`12
`
`
`
`
`
`Ee. As shown in the following annotated and exemplary graph, the capacitance of
`HE decreases as the gate voltage ofdrops,since Bias corresponds to Va, and Va (gate voltage) is
`decreasing.See, e.g.:
`
`
`
`Capacitance(pF) o io
`
`Bias (V)
`
`--- 1MHz ---- 20GHz
`— 5GHz
`-:::: 55 GHz
`
`See, e.g.: Ming Lietal., Investigation of CMOS Varactors for High-GHz-Range Applications, in JOURNAL OF
`ELECTRICAL AND COMPUTER ENGINEERING,at 2 (2009),
`https://www.hindawi.com/journals/jece/2009/535809/.
`
`
`
`As the gate voltage (VG in the figure below) decreases, the gate-source voltage becomes more negative
`(equivalently, the magnitude or absolute value of the
` gate source voltage increases) and, as shown,
`correspondingly the capacitance of the
` transistor increases. Gate-source capacitance of a pMOS
`device versus gate-source voltage (VG) is shown below.
`
`See, e.g.: Philipp Hehenberger, Advanced Characterization of the Bias Temperature Instability § 2.6 (2011),
`https://www.iue.tuwien.ac.at/phd/hehenberger/dissse9.html.
`
`14
`
`
`
`
`
`
`
`
`
`
`
`
`
`T
`
`
`
`
`Fig.9
`7 C02+Cgs}
`
`CdiCgs|_ y~Cd1+Cgso
`
`
`
`Lt te
`0
`Ty
`To
`
`
`
`
`
`
`15
`
`
Accessing this document will incur an additional charge of $.
After purchase, you can access this document again without charge.
Accept $ Charge
Still Working On It
This document is taking longer than usual to download. This can happen if we need to contact the court directly to obtain the document and their servers are running slowly.
Give it another minute or two to complete, and then try the refresh button.
A few More Minutes ... Still Working
It can take up to 5 minutes for us to download a document if the court servers are running slowly.
Thank you for your continued patience.
This document could not be displayed.
We could not find this document within its docket. Please go back to the docket page and check the link. If that does not work, go back to the docket and refresh it to pull the newest information.
Your account does not support viewing this document.
You need a Paid Account to view this document. Click here to change your account type.
Your account does not support viewing this document.
Set your membership
status to view this document.
With a Docket Alarm membership, you'll
get a whole lot more, including:
- Up-to-date information for this case.
- Email alerts whenever there is an update.
- Full text search for other cases.
- Get email alerts whenever a new case matches your search.
One Moment Please
The filing “” is large (MB) and is being downloaded.
Please refresh this page in a few minutes to see if the filing has been downloaded. The filing will also be emailed to you when the download completes.
Your document is on its way!
If you do not receive the document in five minutes, contact support at support@docketalarm.com.
Sealed Document
We are unable to display this document, it may be under a court ordered seal.
If you have proper credentials to access the file, you may proceed directly to the court's system using your government issued username and password.
Access Government Site
