Case 6:21-cv-00626-ADA Document 1 Filed 06/16/21 Page 1 of 37
`
`UNITED STATES DISTRICT COURT
`FOR THE WESTERN DISTRICT OF TEXAS
`WACO DIVISION
`
`XR COMMUNICATIONS, LLC, dba
`VIVATO TECHNOLOGIES,
`
`Plaintiff,
`
`v.
`
`SAMSUNG ELECTRONICS CO., LTD. AND
`SAMSUNG ELECTRONICS AMERICA, INC.,
`
`Defendants.
`
`Case No.
`
`6:21-cv-626
`
`JURY TRIAL DEMANDED
`
`COMPLAINT FOR PATENT INFRINGEMENT AGAINST SAMSUNG
`ELECTRONICS CO., LTD. AND SAMSUNG ELECTRONICS AMERICA, INC.
`
`This is an action for patent infringement arising under the Patent Laws of the United States of
`
`America, 35 U.S.C. § 1 et seq., in which Plaintiff XR Communications LLC d/b/a Vivato
`
`Technologies (“Plaintiff” or “Vivato”) makes the following allegations against Defendants
`
`Samsung Electronics Co., Ltd. and Samsung Electronics America, Inc. (collectively “Samsung”
`
`or “Defendants”):
`
`INTRODUCTION
`
`1.
`
`This complaint arises from Defendants’ unlawful infringement of the following
`
`United States patents owned by Vivato, each of which generally relate to wireless communications
`
`technology: United States Patent Nos. 10,594,376 (the “’376 Patent”) and 10,715,235 (the “’235
`
`Patent”) (collectively, the “Asserted Patents”).
`
`2.
`
`Countless electronic devices today connect to the Internet wirelessly. Beyond just
`
`connecting our devices together, wireless networks have become an inseparable part of our lives
`
`in our homes, our offices, and our neighborhood coffee shops. In even our most crowded spaces,
`
`1
`
`Exhibit 1103
`Page 01 of 37
`
`

`

`Case 6:21-cv-00626-ADA Document 1 Filed 06/16/21 Page 2 of 37
`
`
`
`today’s wireless technology allows all of us to communicate with each other, on our own devices,
`
`at virtually the same time. Our connected world would be unrecognizable without the ubiquity of
`
`sophisticated wireless networking technology.
`
`3.
`
`Just a few decades ago, wireless technology of this kind could only be found in
`
`science fiction. The underlying science behind wireless communications can be traced back to the
`
`development of “wireless telegraphy” in the nineteenth century. Guglielmo Marconi is credited
`
`with developing the first practical radio, and in 1896, Guglielmo Marconi was awarded British
`
`patent 12039, Improvements in transmitting electrical impulses and signals and in apparatus
`
`there-for, the first patent to issue for a Herzian wave-based wireless telegraphic system. Marconi
`
`would go on to win the Nobel Prize in Physics in 1909 for his contributions to the field.
`
`4.
`
`One of Marconi’s preeminent contemporaries was Dr. Karl Ferdinand Braun, who
`
`shared the 1909 Nobel Prize in Physics with Marconi. In his Nobel lecture dated December 11,
`
`1909, Braun explained that he was inspired to work on wireless technology by Marconi’s own
`
`experiments. Braun had observed that the signal strength in Marconi’s radio was limited beyond a
`
`certain distance, and wondered why increasing the voltage on Marconi’s radio did not result in a
`
`stronger transmission at greater distances. Braun thus dedicated himself to developing wireless
`
`devices with a stronger, more effective transmission capability.
`
`5.
`
`In 1905, Braun invented the first phased array antenna. This phased array antenna
`
`featured three antennas carefully positioned relative to one another with a specific phase
`
`relationship so that the radio waves output from each antenna could add together to increase
`
`radiation in a desired direction. This design allowed Braun’s phased array antenna to transmit a
`
`directed signal.
`
`6.
`
`Building on the fundamental breakthrough that radio transmissions can be directed
`
`
`
`2
`
`Exhibit 1103
`Page 02 of 37
`
`

`

`Case 6:21-cv-00626-ADA Document 1 Filed 06/16/21 Page 3 of 37
`
`
`
`according to a specific radiation pattern through the use of a phased array antenna, directed
`
`wireless communication technology has developed many applications over the years. Braun’s
`
`invention of the phased array antenna led to the development of radar, smart antennas, and,
`
`eventually, to a technology known as “MIMO,” or “multiple-input, multiple-output,” which would
`
`ultimately allow a single radio channel to receive and transmit multiple data signals
`
`simultaneously. Along the way, engineers have worked tirelessly to overcome successive
`
`limitations and roadblocks to directed wireless communication technology.
`
`7.
`
`At the beginning of the twenty-first century, the vast majority of wireless networks
`
`still did not yet take advantage of directed wireless communications. Instead, “omnidirectional”
`
`access points were ubiquitous. Omnidirectional access points transmit radio waves uniformly
`
`around the access point in every direction and do not steer the signal in particular directions.
`
`Omnidirectional antennas access points do typically achieve 360 degrees of coverage around the
`
`access point, but with a reduced coverage distance. Omnidirectional access points also lack
`
`sophisticated approaches to overcome certain types of interference in the environment. As only
`
`one example, the presence of solid obstructions, such as a concrete wall, ceiling, or pillar, can limit
`
`signal penetration. As another example, interference arises when radio waves are reflected,
`
`refracted, or diffracted based on obstacles present between the transmitter and receiver. The
`
`multiple paths that radio waves can travel between the transmitter and receiver often result in signal
`
`interference that decreases performance, and omnidirectional access points lack advanced
`
`solutions to overcome these “multipath” effects.
`
`8.
`
`Moving from omnidirectional networks to modern networks has required an
`
`additional series of advancements that harness the capabilities of directed wireless technology.
`
`These advancements range from conceiving various ways to steer and modify radiation patterns,
`
`
`
`3
`
`Exhibit 1103
`Page 03 of 37
`
`

`

`Case 6:21-cv-00626-ADA Document 1 Filed 06/16/21 Page 4 of 37
`
`
`
`to enhancing the transmission signal power in a desired direction, to suppressing radiation in
`
`undesired directions, to minimizing signal “noise,” and then applying these new approaches into
`
`communications networks with multiple, heterogenous transmitters and receivers.
`
`9.
`
`Harnessing the capabilities of directed wireless technology resulted in a significant
`
`leap forward in the signal strength, reliability, concurrent users, and/or data transmission capability
`
`of a wireless network. One of the fundamental building blocks of this latest transition was the
`
`development of improvements to MIMO and “beamforming,” which are the subject matter of
`
`patents in this infringement action. The patents in this action resulted from the investment of tens
`
`of millions of dollars and years of tireless effort by a group of engineers who built a technology
`
`company slightly ahead of its time. Their patented innovations laid the groundwork for today’s
`
`networks, and are infringed by Defendants’ accused products.
`
`
`
`
`
`4
`
`Exhibit 1103
`Page 04 of 37
`
`

`

`Case 6:21-cv-00626-ADA Document 1 Filed 06/16/21 Page 5 of 37
`
`
`
`PARTIES
`
`10.
`
`Plaintiff XR Communications, LLC, d/b/a Vivato Technologies (“Vivato” or
`
`“Plaintiff”) is a limited liability company organized and existing under the laws of the State of
`
`Delaware with its principal place of business at 2809 Ocean Front Walk, Venice, California 90291.
`
`Vivato is the sole owner by assignment of all right, title, and interest in each Asserted Patent.
`
`11.
`
`Vivato was founded in 2000 as a $80+ million venture-backed company with
`
`several key innovators in the wireless communication field including Siavash Alamouti, Ken Biba,
`
`William Crilly, James Brennan, Edward Casas, and Vahid Tarokh, among many others. At that
`
`time, and as remains the case today, “Wi-Fi” or “802.11” had become the ubiquitous means of
`
`wireless connection to the Internet, integrated into hundreds of millions of mobile devices globally.
`
`Vivato was founded to leverage its talent to generate intellectual property and deliver Wi-Fi/802.11
`
`wireless connectivity solutions to service the growing demand for bandwidth.
`
`12.
`
`Vivato has accomplished significant innovations in the field of wireless
`
`communications technology. One area of focus at Vivato was the development of advanced
`
`wireless systems with sophisticated antenna designs to improve wireless speed, coverage, and
`
`reliability. Vivato also focused on designing wireless systems that maximize the efficient use of
`
`spectrum and wireless resources for large numbers of connected mobile devices.
`
`13.
`
`Among many fundamental breakthroughs achieved by Vivato are inventions that
`
`allow for intelligent and adaptive beamforming based on up-to-date information about the wireless
`
`medium. Through these and many other inventions, Vivato’s engineers pioneered a wireless
`
`technology that provides for simultaneous transmission and reception, a significant leap forward
`
`over conventional wireless technology.
`
`14.
`
`Over the years, Vivato has developed proven technology, with over 400
`
`
`
`5
`
`Exhibit 1103
`Page 05 of 37
`
`

`

`Case 6:21-cv-00626-ADA Document 1 Filed 06/16/21 Page 6 of 37
`
`
`
`deployments globally, including private, public and government, and it has become a recognized
`
`provider of extended range Wi-Fi network infrastructure solutions. Vivato's wireless base stations
`
`integrate beamforming phased array antenna design with packet steering technology to deliver
`
`high-bandwidth extended range connections to serve multiple users and multiple devices.
`
`15.
`
`Vivato’s patent portfolio includes over 17 issued patents and pending patent
`
`applications. The patents at issue in this case are directed to specific aspects of wireless
`
`communication, including adaptively steered antenna technology and beam switching technology.
`
`16.
`
`Upon information and belief, Defendant Samsung Electronics Co., Ltd. (“Samsung
`
`Korea”) is a corporation organized under the laws of South Korea, with its principal place of
`
`business at 129 Samsung-Ro, Maetan-3dong, Yeongtong-gu, Suwon-si, Gyeonggi-do, 443-742,
`
`South Korea.
`
`17.
`
`Upon information and belief, Defendant Samsung Electronics America, Inc.
`
`(“Samsung America”) is a wholly-owned subsidiary of Samsung Electronics Co., Ltd. and a
`
`corporation organized under the laws of the State of New York, with its principal place of business
`
`at 85 Challenger Rd., Ridgefield Park, New Jersey 07660.
`
`18.
`
`Samsung has regular and established places of businesses in this District, including
`
`at 12100 Samsung Boulevard, Austin, Texas 78754; 7300 Ranch Road 2222, Austin, Texas 78730;
`
`and 1700 Scenic Loop, Round Rock, Texas 78681. Upon information and belief, Samsung
`
`employs approximately 10,000 employees and contractors in this District serving in a variety of
`
`capacities, including the manufacturing and research and development of components used in the
`
`’376 and ’235 Accused Products.
`
`19.
`
`10. Upon information and belief, Samsung’s presence in the District continues to
`
`grow, as Samsung recently purchased approximately 258 acres of additional land on which it plans
`
`
`
`6
`
`Exhibit 1103
`Page 06 of 37
`
`

`

`Case 6:21-cv-00626-ADA Document 1 Filed 06/16/21 Page 7 of 37
`
`
`
`to expand its existing facilities in the District with a new $17 billion factory that is expected to
`
`bring 1,800 new permanent jobs to the District in the first 10 years. Samsung is seeking
`
`approximately $1 billion in state and local tax incentives in connection with its planned expansion.
`
`See Exhibit B, Austin American-Statesman, Samsung wants $1 billion tax incentive for new Austin
`
`plant
`
`that
`
`would
`
`create
`
`1,800
`
`jobs
`
`(Feb
`
`4,
`
`2021),
`
`available
`
`at
`
`https://www.statesman.com/story/business/2021/02/04/samsung-austin-expansion-chip-plant-
`
`seeks-1-billion-taxpayer-incentives/4309503001/.
`
`20.
`
`Defendants design and manufacture and/or has manufactured on its behalf abroad
`
`the ’376 and ’235 Accused Products that are then sold for importation into the United States,
`
`imported into the United States, and/or sold, offered for sale, and/or used within the United States
`
`after importation. Samsung America is registered to do business in the State of Texas, and has
`
`appointed CT Corporation System, located at 1999 Bryan Street, Suite 900, Dallas, Texas 75201,
`
`as its registered agent. By registering to conduct business in Texas and by having facilities where
`
`it regularly conducts business in this District, Samsung has a permanent and continuous presence
`
`in Texas and a regular and established place of business in the Western District of Texas.
`
`JURISDICTION AND VENUE
`
`21.
`
`This action arises under the patent laws of the United States, Title 35 of the United
`
`States Code § 1, et seq, including 35 U.S.C. §§ 271, 281, 283, 284, and 285. This Court has original
`
`subject matter jurisdiction pursuant to 28 U.S.C. §§ 1331 and 1338(a).
`
`22.
`
`This Court has personal jurisdiction over Defendants in this action because
`
`Defendants have committed acts within this District giving rise to this action, and have established
`
`minimum contacts with this forum such that the exercise of jurisdiction over Defendants would
`
`not offend traditional notions of fair play and substantial justice. Defendants, directly and/or
`
`
`
`7
`
`Exhibit 1103
`Page 07 of 37
`
`

`

`Case 6:21-cv-00626-ADA Document 1 Filed 06/16/21 Page 8 of 37
`
`
`
`through subsidiaries or intermediaries, has committed and continues to commit acts of
`
`infringement in this District by, among other things, importing, offering to sell, and selling
`
`products that infringe the asserted patents, and inducing others to infringe the asserted patents in
`
`this District. Defendants are directly and through intermediaries making, using, selling, offering
`
`for sale, distributing, advertising, promoting, and otherwise commercializing their infringing
`
`products in this District. Defendants regularly conduct and solicit business in, engages in other
`
`persistent courses of conduct in, and/or derives substantial revenue from goods and services
`
`provided to the residents of this District and the State of Texas. Samsung is subject to jurisdiction
`
`pursuant to due process and/or the Texas Long Arm Statute due to its substantial business in this
`
`State and District including at least its infringing activities, regularly doing or soliciting business
`
`at its Austin and Round Rock facilities, and engaging in persistent conduct and deriving substantial
`
`revenues from goods and services provided to residents in the State of Texas including the Western
`
`District of Texas.
`
`23.
`
`Venue is proper in this District pursuant to 28 U.S.C. § 1391(b), (c), (d), and
`
`1400(b) because Samsung has a permanent and continuous presence in, has committed acts of
`
`infringement in, and maintains regular and established places of business in this district. Samsung
`
`has committed acts of direct and indirect infringement in this judicial district including using and
`
`purposefully transacting business involving the ’376 and ’235 Accused Products in this judicial
`
`district such as by sales to one or more customers in the State of Texas including in the Western
`
`District of Texas, and maintaining regular and established places of business in this district.
`
`COUNT I
`
`INFRINGEMENT OF U.S. PATENT NO. 10,594,376
`
`24.
`
`Vivato realleges and incorporates by reference the foregoing paragraphs as if fully
`
`
`
`8
`
`Exhibit 1103
`Page 08 of 37
`
`

`

`Case 6:21-cv-00626-ADA Document 1 Filed 06/16/21 Page 9 of 37
`
`
`
`set forth herein.
`
`25.
`
`On March 17, 2020, United States Patent No. 10,594,376 (“the ’376 Patent”) was
`
`duly and legally issued for inventions entitled “Directed Wireless Communication.” Vivato owns
`
`the ’376 Patent and holds the right to sue and recover damages for infringement thereof. A copy
`
`of the ’376 Patent is attached hereto as Exhibit A.
`
`26.
`
`Defendants have directly infringed and continue to directly infringe numerous
`
`claims of the ’376 Patent, including at least claim 1, by manufacturing, using, selling, offering to
`
`sell, and/or importing into the United States Wi-Fi access points and routers supporting MU-
`
`MIMO, including without limitation access points and routers utilizing the IEEE 802.11ax / “Wi-
`
`Fi 6” standard, and/or the IEEE 802.11ac standard because WiFi 6 is backward compatible (e.g.,
`
`Samsung SmartThings Wifi System) (collectively, the “’376 Accused Products”). Defendants are
`
`liable for infringement of the ’376 Patent pursuant to 35 U.S.C. § 271(a).
`
`27.
`
`The ’376 Accused Products satisfy all claim limitations of numerous claims of
`
`the ’376 Patent, including Claim 1. The following paragraphs compare limitations of Claim 1 to
`
`an exemplary Accused Product, the Samsung SmartThings Wifi. See, e.g., Samsung SmartThings
`
`Wifi Webpage.1 See also the Samsung Newsroom article Smarter Wi-Fi, Smarter Home: Samsung
`
`Announces New SmartThings Mesh Wi-Fi System.2 See also Samsung SmartThings Wifi 3-pack
`
`
`1 Samsung SmartThings Wifi System Webpage is available at Defendants’ website:
`https://www.samsung.com/ca/smartthings/hub/smartthings-wi-fi-et-wv525bwegca/ (last visited
`June 8, 2021).
`2 Samsung Newsroom article Smarter Wi-Fi, Smarter Home: Samsung Announces New
`SmartThings Mesh Wi-Fi System (Aug. 13, 2018) is available at Defendants’ website:
`https://news.samsung.com/us/smarter-wi-fi-smarter-home-samsung-announces-new-smartthings-
`mesh-wi-fi-system/ (last visited June 8, 2021).
`
`
`
`9
`
`Exhibit 1103
`Page 09 of 37
`
`

`

`Case 6:21-cv-00626-ADA Document 1 Filed 06/16/21 Page 10 of 37
`
`
`
`Webpage.3
`
`28.
`
`Each of the ’376 Accused Products comprises a data-communications networking
`
`apparatus. For example, as with each Accused Product, the Samsung SmartThings Wifi System is
`
`an apparatus for communication data on an IEEE 802.11ac data communications network. See,
`
`e.g., Samsung SmartThings Wifi System Webpage, which explains that Samsung SmartThings
`
`Wifi includes a “Quad-core” “716MHz” “Processor,” and “802.11 a/b/g/n/ac, 2.4G+5GHz,
`
`VHT80 2x2 MU MIMO” Wi-Fi functionality. In addition, the Webpage confirms that
`
`“SmartThings Wifi learns from your environment and optimizes to the devices that need it most.”
`
`
`See also the Samsung Newsroom article Smarter Wi-Fi, Smarter Home: Samsung Announces New
`
`SmartThings Mesh Wi-Fi System, indicating the SmartThings Wifi System includes a “Qualcomm
`
`(Quad 710MHz)” processor and supports “2 x 2 MU-MIMO” as well as “802.11 a/b/g/n/ac –
`
`
`3 Samsung SmartThings Wifi 3-pack Webpage is available at Defendants’ website:
`https://www.samsung.com/us/smart-home/smartthings-wifi/multi-packs/samsung-smartthings-
`wifi-3-pack-et-wv525kwegus/ (last visited June 8, 2021).
`
`
`
`10
`
`Exhibit 1103
`Page 10 of 37
`
`

`

`Case 6:21-cv-00626-ADA Document 1 Filed 06/16/21 Page 11 of 37
`
`
`
`Wave2” Wi-Fi Standards. See also Samsung SmartThings Wifi 3-pack Webpage, confirming the
`
`SmartThings Wifi System includes a “Qualcomm (Quad 710MHz)” processor, along with “5GHz:
`
`2EA, 2.4GHz: 2EA” “Antennae,” which support “802.11a/b/g/n/ac - Wave 2, 2x2 MU-MIMO”
`
`Wi-Fi Standards.
`
`29.
`
`Each of the ’376 Accused Products comprises a processor configured to generate a
`
`probing signal for transmission to at least a first client device and a second client device. For
`
`example, as with each Accused Product, the Samsung SmartThings Wifi System has at least one
`
`processor (e.g., one or more central processing units (CPUs), Wi-Fi processors, a baseband
`
`processor in the Wi-Fi radio, as examples) for generating signals for transmission. See, e.g.,
`
`Samsung SmartThings Wifi System Webpage, which explains that Samsung SmartThings Wifi
`
`includes a “Quad-core” “716MHz” “Processor,” and “802.11 a/b/g/n/ac, 2.4G+5GHz, VHT80 2x2
`
`MU MIMO” Wi-Fi functionality. In addition, the Webpage confirms that “SmartThings Wifi
`
`learns from your environment and optimizes to the devices that need it most.” See also the
`
`Samsung Newsroom article Smarter Wi-Fi, Smarter Home: Samsung Announces New
`
`SmartThings Mesh Wi-Fi System, indicating the SmartThings Wifi System includes a “Qualcomm
`
`(Quad 710MHz)” processor and supports “2 x 2 MU-MIMO” as well as “802.11 a/b/g/n/ac –
`
`Wave2” Wi-Fi Standards. See also Samsung SmartThings Wifi 3-pack Webpage, confirming the
`
`SmartThings Wifi System includes a “Qualcomm (Quad 710MHz)” processor, along with “5GHz:
`
`2EA, 2.4GHz: 2EA” “Antennae,” which support “802.11a/b/g/n/ac - Wave 2, 2x2 MU-MIMO”
`
`Wi-Fi Standards. For a further example, as with each Accused Product, the Samsung SmartThings
`
`Wifi System generates a probing signal for transmission (e.g., a probing signal transmission that
`
`triggers or elicits a responsive transmission from each of a first client device and a second client
`
`device, such as NDP Announcement, NDP, beamforming report polling pursuant to Very High
`
`
`
`11
`
`Exhibit 1103
`Page 11 of 37
`
`

`

`Case 6:21-cv-00626-ADA Document 1 Filed 06/16/21 Page 12 of 37
`
`
`
`Throughput VHT channel sounding, including preamble training fields allowing an estimate of the
`
`channel for MU-MIMO) to at least a first client device and a second client device (e.g., a first non-
`
`AP STA / VHT beamformee and a second non-AP STA / VHT beamformee). See, e.g., IEEE
`
`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 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. Clause 22.3.8.3.5;
`
`id. Clause 22.3.11.2.
`
`
`
`12
`
`Exhibit 1103
`Page 12 of 37
`
`

`

`Case 6:21-cv-00626-ADA Document 1 Filed 06/16/21 Page 13 of 37
`
`
`
`
`
`30.
`
`Each of the ’376 Accused Products comprises a processor configured to generate a
`
`first data stream for transmission to the first client device and generate a second data stream for
`
`transmission to the second client device. For example, as with each Accused Product, the Samsung
`
`SmartThings Wifi System has at least one processor and Wi-Fi radio functionality (e.g., the CPU(s)
`
`and/or Wi-Fi processors and/or baseband processor(s) in the Wi-Fi radio) configured to generate
`
`a first data stream for transmission to the first client device (“non-AP STA” or “non-Access Point
`
`Station”) and a second data stream for transmission to a second client device (non-AP STA)
`
`pursuant to MU-MIMO transmissions. See, e.g., Samsung SmartThings Wifi System Webpage,
`
`which explains that Samsung SmartThings Wifi includes a “Quad-core” “716MHz” “Processor,”
`
`and “802.11 a/b/g/n/ac, 2.4G+5GHz, VHT80 2x2 MU MIMO” Wi-Fi functionality. In addition,
`
`the Webpage confirms that “SmartThings Wifi learns from your environment and optimizes to the
`
`devices that need it most.” See also the Samsung Newsroom article Smarter Wi-Fi, Smarter Home:
`
`Samsung Announces New SmartThings Mesh Wi-Fi System, indicating the SmartThings Wifi
`
`System includes a “Qualcomm (Quad 710MHz)” processor and supports “2 x 2 MU-MIMO” as
`
`well as “802.11 a/b/g/n/ac – Wave2” Wi-Fi Standards. See also Samsung SmartThings Wifi 3-
`
`
`
`13
`
`Exhibit 1103
`Page 13 of 37
`
`

`

`Case 6:21-cv-00626-ADA Document 1 Filed 06/16/21 Page 14 of 37
`
`
`
`pack Webpage, confirming the SmartThings Wifi System includes a “Qualcomm (Quad
`
`710MHz)” processor, along with “5GHz: 2EA, 2.4GHz: 2EA” “Antennae,” which support
`
`“802.11a/b/g/n/ac - Wave 2, 2x2 MU-MIMO” Wi-Fi Standards. See, e.g., 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.”); 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, 22.3.11.2.
`
`31.
`
`Each of the ’376 Accused Products comprises a transceiver operatively coupled to
`
`the processor and configured to: transmit the probing signal to at least the first client device and
`
`the second client device via a smart antenna; wherein the smart antenna is operatively coupled to
`
`the transceiver and comprises a first antenna element and a second antenna element. For example,
`
`as with each Accused Product, the Samsung SmartThings Wifi System has a Wi-Fi radio with a
`
`transceiver operatively coupled to the processor (e.g., the Wi-Fi radio generates signals for
`
`transmission and processes received signals with, e.g., the CPU, Wi-Fi processors, and/or
`
`baseband processor in the Wi-Fi radio, and the radio comprises a transceiver that transmits and
`
`
`
`14
`
`Exhibit 1103
`Page 14 of 37
`
`

`

`Case 6:21-cv-00626-ADA Document 1 Filed 06/16/21 Page 15 of 37
`
`
`
`receives signals via a smart antenna); and, as with each Accused Product, the Samsung
`
`SmartThings Wifi System has a Wi-Fi radio transceiver operatively coupled to the processor and
`
`to a smart antenna, wherein the smart antenna is operatively coupled to the Wi-Fi radio and
`
`comprises a first antenna element and a second antenna element. For a further example, as with
`
`each Accused Product, the Samsung SmartThings Wifi System transmits the probing signal (e.g.,
`
`a probing signal transmission that triggers or elicits a responsive transmission from each of a first
`
`client device and a second client device, such as NDP Announcement, NDP, beamforming report
`
`poll frames pursuant to Very High Throughput (VHT) channel sounding, including preamble
`
`training fields allowing an estimate of the channel for MU-MIMO) to at least the first client device
`
`and the second client device (e.g., the first non-AP STA and the second non-AP STA) via the smart
`
`antenna. See, e.g., Samsung SmartThings Wifi System Webpage, which explains that Samsung
`
`SmartThings Wifi includes a “Quad-core” “716MHz” “Processor,” and “802.11 a/b/g/n/ac,
`
`2.4G+5GHz, VHT80 2x2 MU MIMO” Wi-Fi functionality. In addition, the Webpage confirms
`
`that “SmartThings Wifi learns from your environment and optimizes to the devices that need it
`
`most.” See also the Samsung Newsroom article Smarter Wi-Fi, Smarter Home: Samsung
`
`Announces New SmartThings Mesh Wi-Fi System, indicating the SmartThings Wifi System
`
`includes a “Qualcomm (Quad 710MHz)” processor and supports “2 x 2 MU-MIMO” as well as
`
`“802.11 a/b/g/n/ac – Wave2” Wi-Fi Standards. See also Samsung SmartThings Wifi 3-pack
`
`Webpage, confirming the SmartThings Wifi System includes a “Qualcomm (Quad 710MHz)”
`
`processor, along with “5GHz: 2EA, 2.4GHz: 2EA” “Antennae,” which support “802.11a/b/g/n/ac
`
`- Wave 2, 2x2 MU-MIMO” Wi-Fi Standards. 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
`
`
`
`15
`
`Exhibit 1103
`Page 15 of 37
`
`

`

`Case 6:21-cv-00626-ADA Document 1 Filed 06/16/21 Page 16 of 37
`
`
`
`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
`
`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. Clause 22.3.8.3.5; id. Clause 22.3.11.2.
`
`32.
`
`Each of the ’376 Accused Products comprises a data-communications networking
`
`apparatus wherein one or more of the processor, the transceiver, or the smart antenna is further
`
`configured to: receive a first feedback information from the first client device in response to the
`
`transmission of the probing signal; receive a second feedback information from the second client
`
`device in response to transmission of the probing signal. For example, as with each Accused
`
`Product, the Samsung SmartThings Wifi System comprises one or more of the processor, the
`
`transceiver, or the smart antenna further configured to receive channel state information and
`
`estimates of the channel state and MU MIMO-related feedback information from each of the first
`
`non-AP STA and the second non-AP STA pursuant to MU-MIMO sounding procedures. This
`
`feedback information, carried in one or more compressed beamforming frames, is in response to
`
`
`
`16
`
`Exhibit 1103
`Page 16 of 37
`
`

`

`Case 6:21-cv-00626-ADA Document 1 Filed 06/16/21 Page 17 of 37
`
`
`
`the transmission of the probing signal (e.g., a probing signal transmission that triggers or elicits a
`
`responsive transmission from each of a first client device and a second client device, such as NDP
`
`Announcement, NDP, beamforming report polling pursuant to Very High Throughput (VHT)
`
`channel sounding, including preamble training fields allowing an estimate of the channel for MU-
`
`MIMO). See, e.g., Samsung SmartThings Wifi System Webpage, which explains that Samsung
`
`SmartThings Wifi includes a “Quad-core” “716MHz” “Processor,” and “802.11 a/b/g/n/ac,
`
`2.4G+5GHz, VHT80 2x2 MU MIMO” Wi-Fi functionality. In addition, the Webpage confirms
`
`that “SmartThings Wifi learns from your environment and optimizes to the devices that need it
`
`most.” See also the Samsung Newsroom article Smarter Wi-Fi, Smarter Home: Samsung
`
`Announces New SmartThings Mesh Wi-Fi System, indicating the SmartThings Wifi System
`
`includes a “Qualcomm (Quad 710MHz)” processor and supports “2 x 2 MU-MIMO” as well as
`
`“802.11 a/b/g/n/ac – Wave2” Wi-Fi Standards. See also Samsung SmartThings Wifi 3-pack
`
`Webpage, confirming the SmartThings Wifi System includes a “Qualcomm (Quad 710MHz)”
`
`processor, along with “5GHz: 2EA, 2.4GHz: 2EA” “Antennae,” which support “802.11a/b/g/n/ac
`
`- Wave 2, 2x2 MU-MIMO” Wi-Fi Standards. 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 eac