Case 6:22-cv-01163-ADA Document 16 Filed 03/08/23 Page 1 of 23
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`UNITED STATES DISTRICT COURT
`FOR THE WESTERN DISTRICT OF TEXAS
`WACO DIVISION
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`PARKERVISION, INC.,
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`v.
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`MEDIATEK INC. and
`MEDIATEK USA INC.
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`Plaintiff,
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`Defendants.
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`Case No. 6:22-cv-01163-ADA
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`JURY TRIAL DEMANDED
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`AMENDED COMPLAINT FOR PATENT INFRINGEMENT
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`Plaintiff ParkerVision, Inc. (“ParkerVision”), by and through its undersigned counsel,
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`files this Amended Complaint against Defendants MediaTek Inc. and MediaTek USA Inc.
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`(collectively, “MediaTek” or “Defendants”) for patent infringement of United States Patent Nos.
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`6,049,706; 6,266,518; 7,292,835; and 8,660,513 (the “patents-in-suit”) and alleges as follows:
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`NATURE OF THE ACTION
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`1.
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`This is an action for patent infringement arising under the patent laws of the
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`United States, 35 U.S.C. §§ 1 et seq.
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`PARTIES
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`2.
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`Plaintiff ParkerVision is a Florida corporation with its principal place of business
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`at 4446-1A Hendricks Avenue, Suite 354, Jacksonville, Florida 32207.
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`3.
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`On information and belief, MediaTek Inc. (“MediaTek Taiwan”) is a foreign
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`corporation organized and existing under the laws of Taiwan with a principal place of business
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`located at No. 1, Dusing Road 1, Hsinchu Science Park, Hsinchu City 30078, Taiwan.
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`MEDIATEK EX. 1013
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`Case 6:22-cv-01163-ADA Document 16 Filed 03/08/23 Page 2 of 23
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`4.
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`On information and belief, Defendant MediaTek USA Inc. (“MediaTek USA”) is
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`a corporation organized and existing under the laws of the state of Delaware with a place of
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`business in the Western District of Texas, including at 5914 West Courtyard Drive, Suite 400,
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`Austin, TX 78730. https://corp.mediatek.com/about/office-locations/mediatek-usa-offices.
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`5.
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`On information and belief, MediaTek USA is a subsidiary of MediaTek Taiwan
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`and engages in sales, advertising, marketing, and/or research in the United States on behalf of,
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`and under the control of MediaTek Taiwan. See https://www.mediatek.com/who-we-are.
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`6.
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`MediaTek Taiwan and MediaTek USA are companies which together comprise
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`one of the world’s largest manufacturers of integrated circuits, powering more than 2 billion
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`devices a year.1 MediaTek Taiwan designs, develops, manufactures, and ships integrated
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`circuits/wireless chips to be sold in the United States (including to entities in Texas). On
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`information and belief, MediaTek USA sells, advertises, and markets integrated circuits/wireless
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`chips on behalf of, and under the control of MediaTek Taiwan.
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`1 See https://www.mediatek.com/who-we-are.
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`2
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`Case 6:22-cv-01163-ADA Document 16 Filed 03/08/23 Page 3 of 23
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`https://cdn-www.mediatek.com/posts/2021-English-Annual-Report Final.pdf at page 64.
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`7.
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`MediaTek Taiwan and MediaTek USA share the same management, common
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`ownership, advertising platforms, facilities, distribution chains and platforms, and infringing
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`product lines and products involving related technologies. According to MediaTek, the
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`“[b]usiness scope of MediaTek and its affiliates include the investment, R&D, promotion, after-
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`sale service for optical storage products, digital consumer products, wireless communication,
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`digital TV, networking, analog, etc.,” and “MediaTek affiliates support the Company’s core
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`business by acquiring leading technology through investments.”2
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`8.
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`On information and belief, MediaTek Taiwan and MediaTek USA are operated as
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`a single business entity and/or in concert with each other to sell, offer to sell, import, market,
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`advertise, and/or otherwise promote the infringing products (receiver and/or transceiver
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`integrated circuits (e.g., chips for use in wireless devices)) in the United States, including in the
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`State of Texas generally and this judicial district in particular. On information and belief, the
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`Defendants share directors, executives and/or employees. For example, Mr. David Ku is an
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`Executive Vice President and CFO of MediaTek Taiwan and a Director of MediaTek USA. See
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`https://cdn-www.mediatek.com/posts/2021-English-Annual-Report_Final.pdf at page 21:
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`See https://cdn-www.mediatek.com/posts/2021-English-Annual-Report Final.pdf at page 111:
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`2 See https://cdn-www.mediatek.com/posts/2021-English-Annual-Report Final.pdf.
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`Case 6:22-cv-01163-ADA Document 16 Filed 03/08/23 Page 4 of 23
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`9.
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`On information and belief, MediaTek Taiwan controls the business decisions of
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`its affiliates including, but not limited to, MediaTek USA.
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`10.
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`Thus, on information and belief, MediaTek Taiwan and MediaTek USA operate
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`as a unitary business venture and are jointly and severally liable for the acts of patent
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`infringement alleged herein.
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`JURISDICTION AND VENUE
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`11.
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`This Court has jurisdiction over the subject matter of this action pursuant to 28
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`U.S.C. §§ 1331 and 1338(a) because the action arises under the patent laws of the United States,
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`35 U.S.C. §§ 1 et seq.
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`12. MediaTek Taiwan and MediaTek USA are subject to this Court’s personal
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`jurisdiction in accordance with due process and/or the Texas Long-Arm Statute. See Tex. Civ.
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`Prac. & Rem. Code §§ 17.041 et seq.
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`13.
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`This Court has personal jurisdiction over MediaTek Taiwan and MediaTek USA
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`because MediaTek Taiwan and MediaTek USA have sufficient minimum contacts with this
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`forum as a result of business conducted within the State of Texas and this judicial district. In
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`particular, this Court has personal jurisdiction over MediaTek Taiwan and MediaTek USA
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`because, inter alia, MediaTek Taiwan and MediaTek USA, on information and belief, have
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`substantial, continuous, and systematic business contacts in this judicial district, and derive
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`substantial revenue from goods provided to individuals in this judicial district.
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`14. MediaTek Taiwan and MediaTek USA have purposefully availed themselves of
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`the laws of, and of the privileges of, conducting business within this judicial district, have
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`established sufficient minimum contacts with this judicial district such that they should
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`reasonably and fairly anticipate being hauled into court in this judicial district, have purposefully
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`Case 6:22-cv-01163-ADA Document 16 Filed 03/08/23 Page 5 of 23
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`directed activities at residents of this judicial district, and at least a portion of the patent
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`infringement claims alleged in this Complaint arise out of or are related to one or more of the
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`foregoing activities.
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`15. MediaTek Taiwan and MediaTek USA are part of the same corporate structure
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`and distribution chain for the making, importing, offering to sell, selling, and/or using of the
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`infringing products in the United States, including in the State of Texas generally and this
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`judicial district in particular.
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`16.
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`This Court has personal jurisdiction over MediaTek Taiwan and MediaTek USA
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`because MediaTek Taiwan (directly and/or through its subsidiaries, affiliates, or intermediaries)
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`and MediaTek USA have committed and continue to commit acts of infringement in this judicial
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`district in violation of at least 35 U.S.C. § 271(a). In particular, on information and belief,
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`MediaTek Taiwan (including, without limitation, through its subsidiary MediaTek USA) and
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`MediaTek USA (or those acting on its behalf) use, sell, offer for sale, import, advertise, and/or
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`otherwise promote infringing products (receiver and/or transceiver integrated circuits (e.g., chips
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`for use in wireless devices)) in the United States, the State of Texas, and this judicial district. The
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`infringing products include, without limitation, the MediaTek MT7612UN and MT7662TU
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`(“MediaTek Chips”).
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`17.
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`On information and belief, at least the following LG television models
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`sold/offered for sale in the United States contain the MediaTek MT7612UN: (UK620*) -
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`65UK6200PUA, 55UK6200PUA, 49UK6200PUA, 43UK6200PUA; (UK60*) - 65UK6090PUA,
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`60UK6090PUA, 55UK6090PUA, 50UK6090PUA; (UK61*) - 32UK610BPA, 75UK6190PUB,
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`70UK6190PUB. See https://fccid.io/BEJLGSWFAC71/Internal-Photos/internal-photos-
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`4532635.pdf:
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`Case 6:22-cv-01163-ADA Document 16 Filed 03/08/23 Page 6 of 23
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`See also https://fccid.io/BEJLGSWFAC71/Users-Manual/User-Manual-3136306 at page 2.
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`18.
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`On information and belief, at least the following LG television models
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`sold/offered for sale in the United States contain the MediaTek MT7662TU: 65SK9500PUA,
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`
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`55SK9500PUA, 65SK9550PUA, 65SK9000PUA, 55SK9000PUA, 65SK8550PUA,
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`55SK8550PUA, 75SK8070PUA, 75SK8050PUA, 75SK8070AUB, 65SK8000AUB,
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`55SK8000AUB, 65SK8000PUA, 55SK8000PUA, 49SK8000PUA, 65SK8050PUA,
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`55SK8050PUA, 49SK8050PUA, 65UK7700AUB, 65UK7700PUD, 55UK7700AUB,
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`55UK7700PUD, 49UK7700AUB, 49UK7700PUD, 65UK7500PUA, 55UK7500PUA,
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`49UK7500PUA, 86UK6570PUB, 75UK6570PUB, 75UK6570PUA, 86UK6570AUA,
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`Case 6:22-cv-01163-ADA Document 16 Filed 03/08/23 Page 7 of 23
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`75UK6570AUA, 70UK6570PUB, 70UK6550PUA, 70UK6570AUB, 65UK6500AUA,
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`55UK6500AUA, 50UK6500AUA, 43UK6500AUA, 65UK6550PUB ,55UK6550PUB,
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`50UK6550PUB, 43UK6550PUB, 65UK6300PUE, 55UK6300PUE, 50UK6300PUE,
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`49UK6300PUE, 43UK6300PUE, 65UK6300BUB, 65UK6350PUC, 55UK6300BUB,
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`55UK6350PUC, 50UK6300BUB, 49UK6300BUB, 49UK6350PUC, 43UK6300BUB,
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`43UK6350PUC, 50UK6350PUC, 86UK7570PUB, 49LK5750PUA, OLED77C8PUA,
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`OLED65B8PUA, OLED65B8SUC, OLED65C8PUA, OLED65C8AUA, OLED65E8PUA,
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`OLED55B8PUA, OLED55B8SUC, OLED55C8PUA, OLED55C8AUA, OLED55E8PUA. See
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`https://fccid.io/BEJLGSBWAC72/Internal-Photos/Internal-Photos-3078782.pdf:
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`See also https://fccid.io/BEJLGSBWAC72/Users-Manual/User-Manual-3078852 at page 2.
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`Case 6:22-cv-01163-ADA Document 16 Filed 03/08/23 Page 8 of 23
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`19.
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`On information and belief, the Sharp-branded Hisense television model no. LC-
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`55P6000U (below) was sold/offered for sale in the United States and included a MediaTek
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`MT7612UN chip.
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`See https://fccid.io/2AJVQ-ZDGFMT7612U/Internal-Photos/Internal-Photos-3377285:
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`Case 6:22-cv-01163-ADA Document 16 Filed 03/08/23 Page 9 of 23
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`20.
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`On information and belief, MediaTek knew or should have known that its chips
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`would be incorporated into products (such as the televisions identified above) that would be
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`used, sold, offered for sale, and/or imported in the United States, the State of Texas, and this
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`judicial district. MediaTek Taiwan intended that its products be sold in the United States and
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`affirmatively directed its products to the United States market.
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`21.
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`Accordingly, MediaTek Taiwan and MediaTek USA have placed infringing
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`products into the stream of commerce by shipping infringing products into Texas, shipping
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`infringing products knowing that those products would be shipped into Texas, and/or shipping
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`infringing products knowing that these infringing products would be incorporated into other
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`infringing products that would be shipped into Texas.
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`22.
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`On information and belief, MediaTek Taiwan (including, without limitation,
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`through its subsidiary MediaTek USA) and MediaTek USA have a regular and established place
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`of business within the Western District of Texas, including 5914 West Courtyard Drive, Suite
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`400, Austin, TX 78730. On information and belief, MediaTek Taiwan (including, without
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`limitation, through its subsidiary MediaTek USA) and MediaTek USA have physical facilities
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`and employees in this judicial district. On information and belief, MediaTek Taiwan operates the
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`website for MediaTek USA, including job postings for the Austin office. On information and
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`belief, MediaTek Taiwan (including, without limitation, through its subsidiary MediaTek USA)
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`and MediaTek USA maintain additional offices and employees in Texas including at 825
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`Watters Creek Blvd, Suite 265, Allen, TX 75103.
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`23. MediaTek Taiwan and MediaTek USA have purposefully and repeatedly availed
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`themselves of the laws of the United States, this judicial district, and the State of Texas by filing
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`affirmative counterclaims in the following litigations: Ocean Semiconductor LLC v. MediaTek
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`Case 6:22-cv-01163-ADA Document 16 Filed 03/08/23 Page 10 of 23
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`Inc. et al., 6-20-cv-01210 (W.D. Tex.); Nippon Telegraph and Telephone Corporation et al. v.
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`MediaTek Inc. et al., 1-20-cv-00632 (W.D. Tex.); American Patents LLC v. Analog Devices, Inc.
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`et al., 6-18-cv-00356 (W.D. Tex.); Blue Sky Networks, LLC v. MediaTek USA, Inc. et al., 1-17-
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`cv-00656 (W.D. Tex.).
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`24. Moreover, MediaTek Taiwan affirmatively brought suit in federal court in the
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`State of Texas. See MediaTek, Inc. v. Matsushita Electric Industrial Co., Ltd. et al., 2-05-cv-
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`00484 (E.D. Tex.); MediaTek, Inc. v. Sanyo Electric Co. Ltd., et al., 6-05-cv-00323 (E.D. Tex.).
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`25.
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`26.
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`This case is related to at least the following cases before this Court and involves
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`common patents and products: ParkerVision, Inc. v. Hisense Co., Ltd. et al., 6-20-CV-00870
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`(W.D. Tex.) and ParkerVision, Inc. v. LG Electronics, Inc., 6:21-CV-00520 (W.D. Tex.).
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`27.
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`Venue is proper in this judicial district under 28 U.S.C. §§ 1391(b)-(d) and/or
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`1400(b) at least because MediaTek Taiwan is a foreign corporation subject to personal
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`jurisdiction in this judicial district and has committed acts of infringement within this judicial
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`district giving rise to this action.
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`28.
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`Alternatively, the Court has personal jurisdiction over MediaTek Taiwan under
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`Federal Rule of Civil Procedure 4(k)(2). This cause of action arises under federal law, MediaTek
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`Taiwan is not subject to general jurisdiction in any one state, and the exercise of jurisdiction is
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`consistent with the United States Constitution.
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`PARKERVISION
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`29.
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`In 1989, Jeff Parker and David Sorrells started ParkerVision in Jacksonville,
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`Florida. Through the mid-1990s, ParkerVision focused on developing commercial video
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`cameras, e.g., for television broadcasts. The cameras used radio frequency (RF) technology to
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`automatically track the camera’s subject.
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`30. When developing consumer video cameras, however, ParkerVision, encountered
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`a problem – the power and battery requirements for RF communications made a cost effective,
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`consumer-sized product impractical. So, Mr. Sorrels and ParkerVision’s engineering team began
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`researching ways to solve this problem.
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`31.
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`At the time, a decade’s-old RF technology called super-heterodyne dominated the
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`consumer products industry. But this technology was not without its own problems – the circuity
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`was large and required significant power.
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`32.
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`From 1995 through 1998, ParkerVision engineers developed an innovative
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`method of RF direct conversion by a process of sampling a RF carrier signal and transferring
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`energy to create a down-converted baseband signal.
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`33.
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`After creating prototype chips and conducting tests, ParkerVision soon realized
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`that its technology led to improved RF receiver performance, lower power consumption, reduced
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`size and integration benefits. In other words, RF receivers could be built smaller, cheaper and
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`with greater improved performance.
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`34.
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`ParkerVision’s innovations did not stop there. ParkerVision went on to develop
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`additional RF down-conversion technologies, RF up-conversion technologies and other related
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`direct-conversion technologies. ParkerVision also developed complementary wireless
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`communications technologies that involved interactions, processes, and controls between the
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`baseband processor and the transceiver, which improved and enhanced the operation of
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`transceivers that incorporate ParkerVision’s down-converter and up-converter technologies. To
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`Case 6:22-cv-01163-ADA Document 16 Filed 03/08/23 Page 12 of 23
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`date, ParkerVision has been granted over 200 patents related to its innovations, including the
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`patents-in-suit.
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`35.
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`ParkerVision’s technology helped make today’s wireless devices, such as
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`televisions, a reality by enabling RF chips used in these devices to be smaller, cheaper, and more
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`efficient, and with higher performance.
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`36.
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`ParkerVision sold products. To the extent ParkerVision products needed to be
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`marked with a ParkerVision patent number, ParkerVision marked those products in compliance
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`with 35 U.S.C. § 287.
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`PRIOR DISCUSSIONS BETWEEN THE PARTIES
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`37.
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`In April 2010, ParkerVision met with MediaTek USA (including, without
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`limitation, Jim Chapman) and made a presentation regarding ParkerVision’s technology.
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`ParkerVision provided MediaTek USA with a copy of the presentation, which discusses
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`ParkerVision’s D2D technology. Upon information and belief, ParkerVision discussed its D2D
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`technology with MediaTek USA. ParkerVision’s D2D technology is related to the patents-in-
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`suit.
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`38.
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`39.
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`40.
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`THE ASSERTED PATENTS
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`United States Patent No. 6,049,706
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`41.
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`On April 11, 2000, the United States Patent and Trademark Office duly and
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`legally issued United States Patent No. 6,049,706 (“the ’706 patent”) entitled “Integrated
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`Frequency Translation and Selectivity” to inventor Robert W. Cook et al.
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`42.
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`43.
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`44.
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`The ’706 patent is presumed valid under 35 U.S.C. § 282.
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`ParkerVision owns all rights, title, and interest in the ’706 patent.
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`United States Patent No. 6,266,518
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`On July 24, 2001, the United States Patent and Trademark Office duly and legally
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`issued United States Patent No. 6,266,518 (“the ’518 patent”) entitled “Method and System for
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`Down-Converting Electromagnetic Signals by Sampling and Integrating Over Apertures” to
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`inventor David F. Sorrells et al.
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`45.
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`46.
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`47.
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`The ’518 patent is presumed valid under 35 U.S.C. § 282.
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`ParkerVision owns all rights, title, and interest in the ’518 patent.
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`United States Patent No. 7,292,835
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`On November 6, 2007, the United States Patent and Trademark Office duly and
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`legally issued United States Patent No. 7,292,835 (“the ’835 patent”) entitled “Wireless and
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`Wired Cable Modem Applications of Universal Frequency Translation Technology” to inventor
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`David F. Sorrells et al.
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`48.
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`49.
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`50.
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`The ’835 patent is presumed valid under 35 U.S.C. § 282.
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`ParkerVision owns all rights, title, and interest in the ’835 patent.
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`United States Patent No. 8,660,513
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`On February 25, 2014, the United States Patent and Trademark Office duly and
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`legally issued United States Patent No. 8,660,513 (“the ’513 patent”) entitled “Method and
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`Case 6:22-cv-01163-ADA Document 16 Filed 03/08/23 Page 14 of 23
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`System for Down-Converting an Electromagnetic Signal, and Transforms for Same, and
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`Aperture Relationships” to inventor David F. Sorrells et al.
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`51.
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`52.
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`The ’513 patent is presumed valid under 35 U.S.C. § 282.
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`ParkerVision owns all rights, title, and interest in the ’513 patent.
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`CLAIMS FOR RELIEF
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`COUNT I - Infringement of United States Patent No. 6,049,706
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`53.
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`The allegations set forth above are re-alleged and incorporated by reference as if
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`they were set forth fully here.
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`54. MediaTek Taiwan (including, without limitation, through its subsidiary MediaTek
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`USA) and MediaTek USA directly infringe (literally and/or under the doctrine of equivalents)
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`the ’706 patent by using, selling, offering for sale, and/or importing in/into the United States
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`products covered by at least claim 19 of the ’706 patent.
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`55. MediaTek infringes each step of claim 19 because the MediaTek Chips
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`automatically, and without user modification, perform each of the claimed steps.
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`56.
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`On information and belief, MediaTek products that infringe by at least claim 19 of
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`the ’706 patent include, but are not limited to, the MediaTek Chips and any other MediaTek
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`device that is capable of filtering and down-converting an input signal as claimed in the ’706
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`patent. On information and belief, MediaTek uses the MediaTek Chips at least by testing the
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`MediaTek Chips in the United States.
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`57.
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`On information and belief, each MediaTek Chip performs a method of filtering
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`and down-converting an input signal (e.g., a radio frequency (RF) signal at a transmission
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`frequency). The method is performed on the receiver side of each MediaTek Chip.
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`58.
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`On information and belief, each MediaTek Chip filters and down-converts an
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`input signal in an integrated manner using a switch (e.g., one or more transistors), capacitor(s),
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`Case 6:22-cv-01163-ADA Document 16 Filed 03/08/23 Page 15 of 23
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`and low impedance load (e.g., one or more resistors). On information and belief, a down-
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`converted signal (e.g., a baseband signal) is formed from energy from a transistor(s) when the
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`transistor(s) is ON and energy from a capacitor(s) when the transistor(s) is OFF.
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`59.
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`On information and belief, each MediaTek Chip tunes at least one of the filtering
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`operation and down-converting operation (e.g., the MediaTek Chip selects components/adjusts
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`component values).
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`60.
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`On information and belief, a transistor(s) in each MediaTek Chip under-samples
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`(e.g., at a sample rate below the Nyquist rate) the input signal according to a control signal (e.g.,
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`local oscillator (LO) signal). The frequency of the control signal is equal to a frequency of the
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`input signal plus or minus a frequency of a down-converted image, divided by n, where n
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`represents a harmonic or sub-harmonic of the input signal.
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`61.
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`ParkerVision has been damaged by the direct infringement of MediaTek and is
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`suffering and will continue to suffer irreparable harm and damages as a result of this
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`infringement.
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`COUNT II – Infringement of United States Patent No. 6,266,518
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`62.
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`The allegations set forth above are re-alleged and incorporated by reference as if
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`they were set forth fully here.
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`63. MediaTek Taiwan (including, without limitation, through its subsidiary MediaTek
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`USA) and MediaTek USA directly infringe (literally and/or under the doctrine of equivalents)
`
`the ’518 patent by using, selling, offering for sale, and/or importing in/into the United States
`
`products covered by at least claim 27 of the ’518 patent.
`
`64. MediaTek infringes each step of claim 27 because the MediaTek Chips
`
`automatically, and without user modification, perform each of the claimed steps.
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`Case 6:22-cv-01163-ADA Document 16 Filed 03/08/23 Page 16 of 23
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`65.
`
`On information and belief, MediaTek products that infringe at least claim 27 of
`
`the ’518 patent include, but are not limited to, the MediaTek Chips, and any other MediaTek
`
`device that is capable of down-converting a carrier signal to a baseband signal as claimed in the
`
`’518 patent. On information and belief, MediaTek uses the MediaTek Chips at least by testing
`
`the MediaTek Chips in the United States.
`
`66.
`
`On information and belief, each MediaTek Chip performs a method of down-
`
`converting a carrier signal (e.g., an RF signal at a transmission frequency) to a baseband signal.
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`The method is performed on the receiver side of each MediaTek Chip.
`
`67.
`
`On information and belief, each MediaTek Chip receives a carrier signal that
`
`includes at least one of amplitude variations, phase variations, or frequency variations at a
`
`frequency lower than a carrier frequency of the carrier signal (e.g., a modulated carrier signal,
`
`such as a quadrature amplitude modulation (QAM) signal). The carrier signal includes a
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`baseband signal that has been imparted on the carrier signal.
`
`68.
`
`On information and belief, each MediaTek Chip samples the carrier signal by a
`
`transistor(s) turning ON and OFF. The sampling occurs over aperture periods (e.g., periods of
`
`time when the transistor(s) is ON/receives an LO signal) to transfer energy from the carrier
`
`signal at an aliasing rate, which is determined according to a frequency of the carrier signal
`
`divided by N, wherein N indicates a harmonic or sub-harmonic of the carrier signal.
`
`69.
`
`On information and belief, a capacitor(s) in each MediaTek Chip integrates
`
`energy from a transistor(s) over the aperture periods (e.g., when the transistor(s) is ON).
`
`70.
`
`On information and belief, each MediaTek Chip generates a baseband signal
`
`including from the integrated energy that comes from a capacitor(s) when the transistor is OFF.
`
`
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`Case 6:22-cv-01163-ADA Document 16 Filed 03/08/23 Page 17 of 23
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`71.
`
`On information and belief, a capacitor(s) in each MediaTek Chip transfers energy
`
`to a load (e.g., one or more resistors) during an off-time (e.g., when the transistor(s) is OFF).
`
`72.
`
`ParkerVision has been damaged by the direct infringement of MediaTek and is
`
`suffering and will continue to suffer irreparable harm and damages as a result of this
`
`infringement.
`
`COUNT III - Infringement of United States Patent No. 7,292,835
`
`73.
`
`The allegations set forth above are re-alleged and incorporated by reference as if
`
`they were set forth fully here.
`
`74. MediaTek Taiwan (including, without limitation, through its subsidiary MediaTek
`
`USA) and MediaTek USA directly infringe (literally and/or under the doctrine of equivalents)
`
`the ’835 patent by using, selling, offering for sale, and/or importing in/into the United States
`
`products covered by at least claims 3, 4, and 5 of the ’835 patent.
`
`75.
`
`On information and belief, MediaTek products that infringe one or more claims of
`
`the ’835 patent include, but are not limited to, the MediaTek Chips and any other MediaTek
`
`device used e.g., in televisions (“MediaTek TV Chips”) that is capable of down-converting a
`
`higher-frequency signal to a lower-frequency signal as claimed in the ’835 patent. On
`
`information and belief, MediaTek uses the MediaTek TV Chips at least by testing the MediaTek
`
`TV Chips in the United States.
`
`76.
`
`The MediaTek TV Chips used in televisions enable users to watch live TV and on
`
`demand programming from their cable service providers over a wireless network. For example,
`
`some of the MediaTek TV Chips provide wireless connectivity for televisions, such as Hisense
`
`
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`Case 6:22-cv-01163-ADA Document 16 Filed 03/08/23 Page 18 of 23
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`and LG televisions.3 The MediaTek TV Chips are configured to function/capable of functioning
`
`as wireless cable modems. For example, the MediaTek TV Chips provide a wireless connection
`
`to cable services.
`
`77.
`
`On information and belief, each MediaTek TV Chip is/includes a cable modem
`
`(e.g., wireless modem for communicating with a cable television network) for down-converting
`
`an electromagnetic signal (e.g., a high frequency RF signal), having complex modulations (e.g.,
`
`QAM), to a lower frequency signal. The electromagnetic signal is transmitted by a wireless
`
`method to the cable modem.
`
`78.
`
`Each MediaTek TV Chip has (a) an oscillator (e.g., LO) to generate an in-phase
`
`oscillating signal (e.g., in-phase LO signal), (b) a phase shifter (e.g., a flip-flop) to receive the in-
`
`phase oscillating signal and to create a quadrature-phase oscillating signal (e.g., quadrature-phase
`
`LO signal), (c) a first frequency down-conversion module (e.g., a first module that includes at
`
`least one switch/transistor and at least one capacitor) to receive the electromagnetic signal and
`
`the in-phase oscillating signal and (d) a second frequency down-conversion module (e.g., a
`
`second module that includes at least one switch/transistor and at least one capacitor) to receive
`
`the electromagnetic signal and the quadrature-phase oscillating signal.
`
`79.
`
`On information and belief, the first frequency down-conversion module includes a
`
`first frequency translation module (e.g., a module having one or more switches/transistors) and a
`
`first storage module (e.g., a module having one or more capacitors). The first frequency
`
`
`3 See, e.g., https://fccid.io/BEJLGSWFAC71/Users-Manual/User-Manual-3136306;
`https://fccid.io/BEJLGSWFAC71/Internal-Photos/Internal-Photos-3136304.pdf;
`https://fccid.io/W9HLCDF0098; https://fccid.io/W9HLCDF0098/Internal-
`Photos/TempConfidential-W9HLCDF0098-Internal-Photos-3264487.pdf.
`
`
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`
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`translation module samples the electromagnetic signal at a rate (e.g., LO rate with a 25% duty
`
`cycle) that is a function of the in-phase oscillating signal, thereby creating a first sampled signal.
`
`80.
`
`The second frequency down-conversion module includes a second frequency
`
`translation module (e.g., a module having one or more switches/transistors) and a second storage
`
`module (e.g., a module having one or more capacitors). The second frequency translation module
`
`samples the electromagnetic signal at a rate (e.g., LO rate with a 25% duty cycle) that is a
`
`function of the quadrature-phase oscillating signal, thereby creating a second sampled signal.
`
`81.
`
`The first storage module/device has a first port (e.g., first connection point) and a
`
`second port (e.g., second connection point). The first port is connected to the first sampled signal
`
`(e.g., output from at least one switch/transistor) and the second port is connected to a first
`
`reference potential (e.g., ground).
`
`82.
`
`The second storage module/device has a first port (e.g., first connection point) and
`
`a second port (e.g., second connection point). The first port is connected to the second sampled
`
`signal (e.g., output from at least one switch/transistor) and the second port is connected to a
`
`second reference potential (e.g., ground).
`
`83.
`
`ParkerVision has been damaged by the direct infringement of MediaTek and is
`
`suffering and will continue to suffer irreparable harm and damages as a result of this
`
`infringement.
`
`COUNT IV - Infringement of United States Patent No. 8,660,513
`
`84.
`
`The allegations set forth above are re-alleged and incorporated by reference as if
`
`they were set forth fully here.
`
`85. MediaTek Taiwan (including, without limitation, through its subsidiary MediaTek
`
`USA) and MediaTek USA directly infringe (literally and/or under the doctrine of equivalents)
`
`
`
`19
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`Case 6:22-cv-01163-ADA Document 16 Filed 03/08/23 Page 20 of 23
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`
`
`the ’513 patent by using, selling, offering for sale, and/or importing in/into the United States
`
`products covered by at least claim 19 of the ’513 patent.
`
`86.
`
`On information and belief, MediaTek products that infringe one or more claims of
`
`the ’513 patent include, but are not limited to, the MediaTek Chips, and any other MediaTek
`
`device that is capable of down-converting a higher-frequency signal to a lower-frequency signal
`
`as claimed in the ’513 patent. On information and belief, MediaTek uses the MediaTek Chips at
`
`least by testing the MediaTek Chips in the United States.
`
`87.
`
`On information and belief, each MediaTek Chip is/includes a system for
`
`frequency down-converting a modulated carrier signal (e.g., high frequency RF signal) to a lower
`
`frequency signal. Each MediaTek Chip has (a) a first switch (e.g., one or more transistors), (b) a
`
`first control signal (e.g., LO signal) which comprises a sampling aperture (e.g., 25% duty cycle)
`
`with a specified frequency, and (c) a first energy storage element (e.g., one or more capacitors)
`
`that down-converts the modulated carrier signal according to the first control signal and outputs a
`
`down-converted in-phase signal portion of the modulated carrier signal.
`
`88.
`
`On information and belief, each MediaTek Chip has (a) a second switch (e.g., one
`
`or more transistors), (b) a second control signal (e.g., LO signal) which comprises a sampling
`
`aperture (e.g., 25% duty cycle) with a specified frequency, and (c) a second energy storage
`
`element (e.g., one or more capacitors) that down-converts the modulated carrier signal (e.g., high
`
`frequency RF signal) according to the second control signal and outputs a down-converted
`
`inverted in-phase signal portion of the modulated carrier signal.
`
`89.
`
`On information and belief, each MediaTek Chip has a first differential amplifier
`
`circuit that combines the down-converted in-phase signal portion with the inverted in-phase
`
`signal portion and outputs a first channel down-converted differential in-phase signal.
`
`
`
`20