Case 6:21-cv-00520-ADA Document 1 Filed 05/22/21 Page 1 of 32
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`UNITED STATES DISTRICT COURT
`WESTERN DISTRICT OF TEXAS
`WACO DIVISION
`
` Plaintiff,
`
`
`
`PARKERVISION, INC.,
`
`
`
` v.
`
`LG ELECTRONICS, INC.
`
` Defendant.
`
`
` Case No. 6:21-cv-00520
`
` JURY TRIAL DEMANDED
`
`COMPLAINT FOR PATENT INFRINGEMENT
`
`Plaintiff ParkerVision, Inc. (“ParkerVision”), by and through its undersigned
`
`
`
`
`
`
`
`counsel, files this Complaint against Defendant LG Electronics, Inc. (collectively, “LG”
`
`or “Defendant”) for patent infringement of United States Patent Nos. 6,049,706;
`
`6,266,518; 6,580,902; 7,110,444; 7,292,835; 8,588,725; 8,660,513; 9,118,528; 9,246,736 and
`
`9,444,673 (the “patents-in-suit”) and alleges as follows:
`
`NATURE OF THE ACTION
`
`1.
`
`This is an action for patent infringement arising under the patent laws of
`
`the United States, 35 U.S.C. §§ 1 et seq.
`
`PARTIES
`
`2.
`
`Plaintiff ParkerVision is a Florida corporation with its principal place of
`
`business at 4446-1A Hendricks Avenue, Suite 354, Jacksonville, Florida 32207.
`
`
`
`UNITED STATES DISTRICT COURT
`WESTERN DISTRICT OF TEXAS
`WACO DIVISION
`
` Plaintiff,
`
`
`
`PARKERVISION, INC.,
`
`
`
` v.
`
`LG ELECTRONICS, INC.
`
` Defendant.
`
`
` Case No. 6:21-cv-00520
`
` JURY TRIAL DEMANDED
`
`COMPLAINT FOR PATENT INFRINGEMENT
`
`Plaintiff ParkerVision, Inc. (“ParkerVision”), by and through its undersigned
`
`
`
`
`
`
`
`counsel, files this Complaint against Defendant LG Electronics, Inc. (collectively, “LG”
`
`or “Defendant”) for patent infringement of United States Patent Nos. 6,049,706;
`
`6,266,518; 6,580,902; 7,110,444; 7,292,835; 8,588,725; 8,660,513; 9,118,528; 9,246,736 and
`
`9,444,673 (the “patents-in-suit”) and alleges as follows:
`
`NATURE OF THE ACTION
`
`1.
`
`This is an action for patent infringement arising under the patent laws of
`
`the United States, 35 U.S.C. §§ 1 et seq.
`
`PARTIES
`
`2.
`
`Plaintiff ParkerVision is a Florida corporation with its principal place of
`
`business at 4446-1A Hendricks Avenue, Suite 354, Jacksonville, Florida 32207.
`
`
`
`Case 6:21-cv-00520-ADA Document 1 Filed 05/22/21 Page 2 of 32
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`3.
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`Defendant LG Electronics, Inc. is a foreign corporation duly organized
`
`and existing under the laws of the Republic of South Korea, with a principal place of
`
`business at LG Twin Tower 128, Yeouido-dong, Yeongdeungpo District, Seoul, South
`
`Korea.
`
`4.
`
`On information and belief, Defendant acts in concert to design,
`
`manufacture, sell, offer for sale, import, distribute, advertise, and/or otherwise promote
`
`the accused infringing products in the United States, the State of Texas, and this judicial
`
`district.
`
`JURISDICTION AND VENUE
`
`5.
`
`This Court has jurisdiction over the subject matter of this action pursuant
`
`to 28 U.S.C. §§ 1331 and 1338(a) because the action arises under the patent laws of the
`
`United States, 35 U.S.C. §§ 1 et seq.
`
`6.
`
`LG is subject to this Court’s personal jurisdiction in accordance with due
`
`process and/or the Texas Long-Arm Statute. See Tex. Civ. Prac. & Rem. Code §§ 17.041
`
`et seq.
`
`7.
`
`This Court has personal jurisdiction over LG because LG has sufficient
`
`minimum contacts with this forum as a result of business conducted within the State of
`
`Texas and this judicial district. In particular, this Court has personal jurisdiction over
`
`LG because, inter alia, LG, on information and belief, has substantial, continuous, and
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`systematic business contacts in this judicial district, and derives substantial revenue
`
`from goods provided to individuals in this judicial district.
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`
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`2
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`Case 6:21-cv-00520-ADA Document 1 Filed 05/22/21 Page 3 of 32
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`8.
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`LG has purposefully availed itself of the privileges of conducting business
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`within this judicial district, has established sufficient minimum contacts with this
`
`judicial district such that it should reasonably and fairly anticipate being hauled into
`
`court in this judicial district, has purposefully directed activities at residents of this
`
`judicial district, and at least a portion of the patent infringement claims alleged in this
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`Complaint arise out of or are related to one or more of the foregoing activities.
`
`9.
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`This Court has personal jurisdiction over LG because LG (directly and/or
`
`through its subsidiaries, affiliates, or intermediaries) has committed and continues to
`
`commit acts of infringement in this judicial district in violation of at least 35 U.S.C. §
`
`271(a). In particular, on information and belief, LG uses, sells, offers for sale, imports,
`
`advertises, and/or otherwise promotes infringing products in the United States, the
`
`State of Texas, and this judicial district.
`
`10.
`
`Venue is proper in this judicial district under 28 U.S.C. §§ 1391(b) and (c)
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`because LG is not resident in the United States and may be sued in any judicial district
`
`including this district.
`
`BACKGROUND
`
`11.
`
`In 1989, Jeff Parker and David Sorrells started ParkerVision in
`
`Jacksonville, Florida. Through the mid-1990s, ParkerVision focused on developing
`
`commercial video cameras, e.g., for television broadcasts. The cameras used radio
`
`frequency (RF) technology to automatically track the camera’s subject.
`
`12. When developing consumer video cameras, however, ParkerVision,
`
`encountered a problem – the power and battery requirements for RF communications
`
`
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`3
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`Case 6:21-cv-00520-ADA Document 1 Filed 05/22/21 Page 4 of 32
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`made a cost effective, consumer-sized product impractical. So, Mr. Sorrels and
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`ParkerVision’s engineering team began researching ways to solve this problem.
`
`13. At the time, a decade’s-old RF technology called super-heterodyne
`
`dominated the consumer products industry. But this technology was not without its
`
`own problems – the circuity was large and required significant power.
`
`14.
`
`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 energy to create a down-converted baseband signal.
`
`15. After creating prototype chips and conducting tests, ParkerVision soon
`
`realized that its technology led to improved RF receiver performance, lower power
`
`consumption, reduced size and integration benefits. In other words, RF receivers could
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`be built smaller, cheaper and with greater improved performance.
`
`16.
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`ParkerVision’s innovations did not stop there. ParkerVision went on to
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`develop additional RF down-conversion technologies, RF up-conversion technologies
`
`and other related direct-conversion technologies. ParkerVision also developed
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`complementary wireless communications technologies that involved interactions,
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`processes, and controls between the baseband processor and the transceiver, which
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`improved and enhanced the operation of transceivers that incorporate ParkerVision’s
`
`down-converter and up-converter technologies. To date, ParkerVision has been granted
`
`over 200 patents related to its innovations including, the patents-in-suit.
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`
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`4
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`Case 6:21-cv-00520-ADA Document 1 Filed 05/22/21 Page 5 of 32
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`17.
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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 efficient, and with higher performance.
`
`LG
`
`18.
`
`LG Electronics, Inc., Ltd. is a South Korean multinational electronics
`
`company headquartered in Seoul, Korea.
`
`19. On information and belief, since 1999, LG (or those acting on its behalf)
`
`has made, used, sold, offered for sale and/or imported televisions (“LG Products”)
`
`in/into the United States under the LG brand.
`
`20. On information and belief, LG Products can be purchased through
`
`retailers throughout the United States including, without limitation, Amazon, Best Buy,
`
`Target, Walmart, Costco, BJ Wholesale, B&H and Crutchfield.
`
`21.
`
`From 2008-2019, LG shipped a range of 10-13.6% of the total TVs sold in
`
`the world by units. See https://www.statista.com/statistics/267095/global-market-
`
`share-of-lcd-tv-manufacturers/.
`
`22.
`
`In 2019, LG held a 19% share of the North American market. See
`
`http://www.businesskorea.co.kr/news/articleView.html?idxno=38301.
`
`23.
`
`LG Products include modules containing Wi-Fi chips including, without
`
`limitation, MediaTek MT7612UN, MediaTek MT7662TU, and Realtek RTL8812BU (each
`
`a “LG Chip”; collectively, the “LG Chips”). LG Chips provide wireless connectivity for
`
`LG Products.
`
`
`
`5
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`Case 6:21-cv-00520-ADA Document 1 Filed 05/22/21 Page 6 of 32
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`24. On information and belief, the LG LGSWFAC71 wireless module, which is
`
`identified by the Federal Communications Commission (FCC) Identification (ID)
`
`number, BEJLGSWFAC71, includes a MediaTek MT7612U(N) chip. See the image from
`
`page 2 of the user manual (https://fccid.io/BEJLGSWFAC71/Users-Manual/User-
`
`Manual-3136306) that was submitted to the FCC by LG Innotek:
`
`
`
`
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`6
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`Case 6:21-cv-00520-ADA Document 1 Filed 05/22/21 Page 7 of 32
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`See also the internal photographs that were submitted to the FCC in
`
`https://fccid.io/BEJLGSWFAC71/Internal-Photos/internal-photos-4532635.pdf:
`
`
`
`
`
`25. On information and belief, the LG model LGSBWAC72 wireless module,
`
`which is identified by the FCC ID number BEJLGSBWAC72, includes a MediaTek
`
`MT7662T(U) chip that is substantially similar to the MT7612U(N) with respect to
`
`infringement. See the image from page 2 of the user manual
`
`(https://fccid.io/BEJLGSBWAC72/Users-Manual/User-Manual-3078852) that was
`
`
`
`7
`
`
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`Case 6:21-cv-00520-ADA Document 1 Filed 05/22/21 Page 8 of 32
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`submitted to the FCC by LG Innotek:
`
`See also the internal photographs that were submitted to the FCC in
`
`https://fccid.io/BEJLGSWFAC71/Internal-Photos/internal-photos-4532635.pdf:
`
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`
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`
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`8
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`Case 6:21-cv-00520-ADA Document 1 Filed 05/22/21 Page 9 of 32
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`26. On information and belief, the LG model LGSWFAC81 wireless module,
`
`which is identified by the FCC ID number BEJLGSWFAC81, includes a Realtek
`
`RTL8812BU chip. See the image from page 1 of the user manual
`
`(https://fccid.io/BEJLGSWFAC81/Users-Manual/Users-Manual-3587629) that was
`
`submitted to the FCC by Arcadyan Technology:
`
`See also the internal photographs that were submitted to the FCC in
`
`https://fccid.io/BEJLGSWFAC81/Internal-Photos/Internal-Photos-3585492.pdf:
`
`
`
`
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`
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`9
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`Case 6:21-cv-00520-ADA Document 1 Filed 05/22/21 Page 10 of 32
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`27. On information and belief, the following LG Product models contain the
`
`LGSWFAC71 module and the MediaTek MT7612UN chip: (UK620*) - 65UK6200PUA,
`
`55UK6200PUA, 49UK6200PUA, 43UK6200PUA; (UK60*) - 65UK6090PUA,
`
`60UK6090PUA, 55UK6090PUA, 50UK6090PUA; (UK61*) - 32UK610BPA,
`
`75UK6190PUB, 70UK6190PUB.
`
`28. On information and belief, the following LG Product models contain the
`
`LGSWFAC81 module and the RT8812: (LK570*) - 49LK5700PUA, 49LK5700BUA,
`
`43LK5700PUA, 43LK5700BUA; (LK61*) - 32LK610PUA.
`
`29. On information and belief, at least the following LG Product models
`
`contain the LGSBWAC72 module and the MediaTek MT7662TU chip: 65SK9500PUA,
`
`55SK9500PUA, 65SK9550PUA, 65SK9000PUA, 55SK9000PUA, 65SK8550PUA,
`
`55SK8550PUA, 75SK8070PUA, 75SK8050PUA, 75SK8070AUB, 65SK8000AUB,
`
`55SK8000AUB, 65SK8000PUA, 55SK8000PUA, 49SK8000PUA, 65SK8050PUA,
`
`55SK8050PUA, 49SK8050PUA, 65UK7700AUB, 65UK7700PUD, 55UK7700AUB,
`
`55UK7700PUD, 49UK7700AUB, 49UK7700PUD, 65UK7500PUA, 55UK7500PUA,
`
`49UK7500PUA, 86UK6570PUB, 75UK6570PUB, 75UK6570PUA, 86UK6570AUA,
`
`75UK6570AUA, 70UK6570PUB, 70UK6550PUA, 70UK6570AUB, 65UK6500AUA,
`
`55UK6500AUA, 50UK6500AUA, 43UK6500AUA, 65UK6550PUB ,55UK6550PUB,
`
`50UK6550PUB, 43UK6550PUB, 65UK6300PUE, 55UK6300PUE, 50UK6300PUE,
`
`49UK6300PUE, 43UK6300PUE, 65UK6300BUB, 65UK6350PUC, 55UK6300BUB,
`
`55UK6350PUC, 50UK6300BUB, 49UK6300BUB, 49UK6350PUC, 43UK6300BUB,
`
`43UK6350PUC, 50UK6350PUC, 86UK7570PUB, 49LK5750PUA, OLED77C8PUA,
`
`
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`10
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`Case 6:21-cv-00520-ADA Document 1 Filed 05/22/21 Page 11 of 32
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`OLED65B8PUA, OLED65B8SUC, OLED65C8PUA, OLED65C8AUA, OLED65E8PUA,
`
`OLED55B8PUA, OLED55B8SUC, OLED55C8PUA, OLED55C8AUA, OLED55E8PUA.
`
`THE ASSERTED PATENTS
`
`United States Patent No. 6,049,706
`
`30. On April 11, 2000, the United States Patent and Trademark Office duly
`
`and legally issued United States Patent No. 6,049,706 (“the ‘706 patent”) entitled
`
`“Integrated Frequency Translation and Selectivity” to inventor Robert W. Cook et al.
`
`31.
`
`The ‘706 patent is presumed valid under 35 U.S.C. § 282.
`
`32.
`
`ParkerVision owns all rights, title, and interest in the ‘706 patent.
`
`United States Patent No. 6,266,518
`
`33. On July 24, 2001, the United States Patent and Trademark Office duly and
`
`legally issued United States Patent No. 6,266,518 (“the ‘518 patent”) entitled “Method
`
`and System for Down-Converting Electromagnetic Signals by Sampling and Integrating
`
`Over Apertures” to inventor David F. Sorrells et al.
`
`34.
`
`The ‘518 patent is presumed valid under 35 U.S.C. § 282.
`
`35.
`
`ParkerVision owns all rights, title, and interest in the ‘518 patent.
`
`United States Patent No. 6,580,902
`
`36. On June 17, 2003, the United States Patent and Trademark Office duly and
`
`legally issued United States Patent No. 6,580,902 (“the ‘902 patent”) entitled “Frequency
`
`Translation Using Optimized Switch Structures” to inventor David F. Sorrells et al.
`
`37.
`
`The ‘902 patent is presumed valid under 35 U.S.C. § 282.
`
`38.
`
`ParkerVision owns all rights, title, and interest in the ‘902 patent.
`
`
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`11
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`Case 6:21-cv-00520-ADA Document 1 Filed 05/22/21 Page 12 of 32
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`United States Patent No. 7,110,444
`
`39. On September 19, 2006, the United States Patent and Trademark Office
`
`duly and legally issued United States Patent No. 7,110,444 (“the ‘444 patent”) entitled
`
`“Wireless Local Area Network (WLAN) Using Universal Frequency Translation
`
`Technology Including Multi-Phase Embodiments and Circuit Implementations” to
`
`inventor David F. Sorrells et al.
`
`40.
`
`The ‘444 patent is presumed valid under 35 U.S.C. § 282.
`
`41.
`
`ParkerVision owns all rights, title, and interest in the ‘444 patent.
`
`United States Patent No. 7,292,835
`
`42. On November 6, 2007, the United States Patent and Trademark Office
`
`duly and legally issued United States Patent No. 7,292,835 (“the ‘835 patent”) entitled
`
`“Wireless and Wired Cable Modem Applications of Universal Frequency Translation
`
`Technology” to inventor David F. Sorrells et al.
`
`43.
`
`The ‘835 patent is presumed valid under 35 U.S.C. § 282.
`
`44.
`
`ParkerVision owns all rights, title, and interest in the ‘835 patent.
`
`United States Patent No. 8,588,725
`
`45. On November 19, 2013, the United States Patent and Trademark Office
`
`duly and legally issued United States Patent No. 8,588,725 (“the ‘725 patent”) entitled
`
`“Apparatus, System, and Method For Down Converting and Up-Converting
`
`Electromagnetic Signals” to inventor David F. Sorrells et al.
`
`46.
`
`The ‘725 patent is presumed valid under 35 U.S.C. § 282.
`
`47.
`
`ParkerVision owns all rights, title, and interest in the ‘725 patent.
`
`
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`12
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`Case 6:21-cv-00520-ADA Document 1 Filed 05/22/21 Page 13 of 32
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`United States Patent No. 8,660,513
`
`48. On February 25, 2014, the United States Patent and Trademark Office duly
`
`and legally issued United States Patent No. 8,660,513 (“the ‘513 patent”) entitled
`
`“Method and System for Down-Converting an Electromagnetic Signal, and Transforms
`
`for Same, and Aperture Relationships” to inventor David F. Sorrells et al.
`
`49.
`
`The ‘513 patent is presumed valid under 35 U.S.C. § 282.
`
`50.
`
`ParkerVision owns all rights, title, and interest in the ‘513 patent.
`
`United States Patent No. 9,118,528
`
`51. On August 25, 2015, the United States Patent and Trademark Office duly
`
`and legally issued United States Patent No. 9,118,528 (“the ‘528 patent”) entitled
`
`“Method and System for Down-Converting an Electromagnetic Signal, and Transforms
`
`for Same, and Aperture Relationships” to inventor David F. Sorrells et al.
`
`52.
`
`The ‘528 patent is presumed valid under 35 U.S.C. § 282.
`
`53.
`
`ParkerVision owns all rights, title, and interest in the ‘528 patent.
`
`United States Patent No. 9,246,736
`
`54. On January 26, 2016, the United States Patent and Trademark Office duly
`
`and legally issued United States Patent No. 9,246,736 (“the ‘736 patent”) entitled
`
`“Method and System for Down-Converting an Electromagnetic Signal” to inventor
`
`David F. Sorrells et al.
`
`55.
`
`The ‘736 patent is presumed valid under 35 U.S.C. § 282.
`
`56.
`
`ParkerVision owns all rights, title, and interest in the ‘736 patent.
`
`
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`13
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`Case 6:21-cv-00520-ADA Document 1 Filed 05/22/21 Page 14 of 32
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`United States Patent No. 9,444,673
`
`57. On September 13, 2016, the United States Patent and Trademark Office
`
`duly and legally issued United States Patent No. 9,444,673 (“the ‘673 patent”) entitled
`
`“Methods and Systems for Down-Converting a Signal Using a Complementary
`
`Transistor Structure” to inventor David F. Sorrells et al.
`
`58.
`
`The ‘673 patent is presumed valid under 35 U.S.C. § 282.
`
`59.
`
`ParkerVision owns all rights, title, and interest in the ‘673 patent.
`
`CLAIMS FOR RELIEF
`
`COUNT I - Infringement of United States Patent No. 6,049,706
`
`60.
`
`The allegations set forth above are re-alleged and incorporated by
`
`reference as if they were set forth fully here.
`
`61.
`
`LG directly infringes (literally and/or under the doctrine of equivalents)
`
`the ’706 patent by making, using, selling, offering for sale, and/or importing in/into the
`
`United States products covered by at least claim 1 of the ’706 patent.
`
`62.
`
`LG products that infringe one or more claims of the ’706 patent include,
`
`but are not limited to, the LG Products and any other LG device that is capable of
`
`filtering and down-converting a higher-frequency signal to a lower-frequency signal as
`
`claimed in the ’706 patent.
`
`63.
`
`Each LG Chip is/includes an apparatus for filtering and down-converting
`
`(e.g., a higher frequency RF signal to a lower frequency signal). Each LG Chip includes
`
`a frequency translator, comprising a down-convert and delay module to under-sample
`
`an input signal (e.g., high frequency RF signal) to produce an input sample of a down-
`
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`14
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`Case 6:21-cv-00520-ADA Document 1 Filed 05/22/21 Page 15 of 32
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`converted image of said input signal, and to delay said input sample. Each LG Chip
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`also includes a filter, comprising at least a portion of said down-convert and delay
`
`module, at least one delay module to delay instances of an output signal, and an adder
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`(e.g., operational amplifier with parallel resistor-capacitor feedback) to combine at least
`
`said delayed input sample with at least one of said delayed instances of said output
`
`signal to generate an instance of said output signal.
`
`64.
`
`The down-convert and delay module under-samples (e.g., at a sample rate
`
`below the Nyquist rate) said input signal according to a control signal (e.g., local
`
`oscillator (LO) signal), wherein a frequency of said control signal is equal to a frequency
`
`of said input signal plus or minus a frequency of said down-converted image, divided
`
`by n, where n represents a harmonic or sub-harmonic of said input signal.
`
`65.
`
`ParkerVision has been damaged by the direct infringement of LG and is
`
`suffering and will continue to suffer irreparable harm and damages as a result of this
`
`infringement.
`
`COUNT II – Infringement of United States Patent No. 6,266,518
`
`66.
`
`The allegations set forth above are re-alleged and incorporated by
`
`reference as if they were set forth fully here.
`
`67.
`
`LG directly infringes (literally and/or under the doctrine of equivalents)
`
`the ‘518 patent by making, using, selling, offering for sale, and/or importing in/into the
`
`United States products covered by at least claim 67 of the ‘518 patent.
`
`68.
`
`LG products that infringe one or more claims of the ‘518 patent include,
`
`but are not limited to, the LG Products and any other LG device that is capable of
`
`
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`15
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`Case 6:21-cv-00520-ADA Document 1 Filed 05/22/21 Page 16 of 32
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`down-converting a higher-frequency signal to a lower-frequency signal as claimed in
`
`the ‘518 patent.
`
`69.
`
`Each LG Chip is/includes an apparatus for down-converting a carrier
`
`signal (e.g., high frequency RF signal) to a lower frequency signal (e.g., baseband
`
`signal). Each LG Chip has a universal frequency down-converter (UFD), including a
`
`switch (e.g., transistor), an integrator (e.g., capacitor) coupled to said switch, a pulse
`
`generator (e.g., LO and/or LO circuitry) coupled to said switch; and a reactive structure
`
`(e.g., filter(s)) coupled to said UFD.
`
`70.
`
`The pulse generator (e.g., LO and/or LO circuitry) outputs pulses (e.g.,
`
`LO signal) to said switch at an aliasing rate that is determined according to a frequency
`
`of the carrier signal +/− a frequency of the lower frequency signal) divided by N.
`
`71.
`
`The pulses have apertures (e.g., 25% duty cycle) and cause said switch to
`
`close and sample said carrier signal (e.g., high frequency RF signal). Energy is
`
`transferred from said carrier signal and integrated using said integrator (e.g., capacitor)
`
`during apertures of said pulses, and said lower frequency signal (e.g., baseband signal)
`
`is generated from the transferred energy.
`
`72.
`
`The energy is transferred to a load (e.g., resistor) during an off-time (e.g.,
`
`when the switch is open).
`
`73.
`
`ParkerVision has been damaged by the direct infringement of LG, and is
`
`suffering and will continue to suffer irreparable harm and damages as a result of this
`
`infringement.
`
`
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`16
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`Case 6:21-cv-00520-ADA Document 1 Filed 05/22/21 Page 17 of 32
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`COUNT III – Infringement of United States Patent No. 6,580,902
`
`74.
`
`The allegations set forth above are re-alleged and incorporated by
`
`reference as if they were set forth fully here.
`
`75.
`
`LG directly infringes (literally and/or under the doctrine of equivalents)
`
`the ’902 patent by making, using, selling, offering for sale, and/or importing in/into the
`
`United States products covered by at least claim 1 of the ’902 patent.
`
`76.
`
`LG products that infringe one or more claims of the ’902 patent include,
`
`but are not limited to, the LG Products and any other LG device that is capable of
`
`down-converting a higher-frequency signal to a lower-frequency signal as claimed in
`
`the ’902 patent.
`
`77.
`
`Each LG Chip is/includes a circuit for down-converting an
`
`electromagnetic signal (e.g., high frequency RF signal) to a lower frequency signal. Each
`
`LG Chip includes an energy transfer module having a switch module (e.g., module with
`
`one or more transistors) and an energy storage module (e.g., module with one or more
`
`capacitors). The energy transfer module of the LG Chip samples the electromagnetic
`
`signal at an energy transfer rate (e.g., LO rate with a 25% duty cycle), according to an
`
`energy transfer signal (e.g., LO signal), to obtain sampled energy. The sampled energy
`
`is stored by said energy storage module (e.g., module with one or more capacitors). A
`
`down-converted signal (e.g., baseband signal) is generated from the sampled energy.
`
`78.
`
`The energy transfer module of each LG Chip has transistors coupled
`
`together. The transistors have a common first port, a common second port, and a
`
`
`
`17
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`Case 6:21-cv-00520-ADA Document 1 Filed 05/22/21 Page 18 of 32
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`common control port. The electromagnetic signal is accepted at the common first port
`
`and the sampled energy is present at the common second port.
`
`79.
`
`The common control port accepts the energy transfer signal, which has a
`
`control frequency that is substantially equal to said energy transfer rate.
`
`80.
`
`Each of the transistors of the LG Chip has a drain, a source, and a gate.
`
`The common first port couples together drains of the transistors, the common second
`
`port couples together sources of the transistors, and the common control port couples
`
`together gates of the transistors.
`
`81.
`
`ParkerVision has been damaged by the direct infringement of LG and is
`
`suffering and will continue to suffer irreparable harm and damages as a result of this
`
`infringement.
`
`COUNT IV - Infringement of United States Patent No. 7,110,444
`
`82.
`
`The allegations set forth above are re-alleged and incorporated by
`
`reference as if they were set forth fully here.
`
`83.
`
`LG directly infringes (literally and/or under the doctrine of equivalents)
`
`the ’444 patent by making, using, selling, offering for sale, and/or importing in/into the
`
`United States products covered by at least claim 2 of the ‘444 patent.
`
`84.
`
`LG products that infringe one or more claims of the ’444 patent include,
`
`but are not limited to, the LG Products and any other LG device that is capable of
`
`down-converting a higher-frequency signal to a lower-frequency signal as claimed in
`
`the ’444 patent.
`
`
`
`18
`
`
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`Case 6:21-cv-00520-ADA Document 1 Filed 05/22/21 Page 19 of 32
`
`85.
`
`Each LG Chip is/includes a wireless modem apparatus (e.g., a
`
`modulation/demodulation device providing bi-directional, over-the-air data
`
`transmission) having a receiver for frequency down-converting an input signal (e.g.,
`
`high frequency RF signal). The receiver for frequency down-converting an input signal
`
`includes a first frequency down-conversion module to down-convert the input signal,
`
`wherein said first frequency down-conversion module down-converts said input signal
`
`according to a first control signal (e.g., LO signal) and outputs a first down-converted
`
`signal (e.g., baseband signal); a second frequency down-conversion module to down-
`
`convert said input signal, wherein said second frequency down-conversion module
`
`down-converts said input signal according to a second control signal (e.g., LO signal)
`
`and outputs a second down-converted signal (e.g., baseband signal); and a subtractor
`
`module (e.g., module with differential amplifier) that subtracts said second down-
`
`converted signal from said first down-converted signal and outputs a down-converted
`
`signal.
`
`86.
`
`The first frequency down-conversion module under-samples (e.g., at a
`
`sample rate below the Nyquist rate) the input signal according to the first control signal,
`
`and the second frequency down-conversion module under-samples samples (e.g., at a
`
`sample rate below the Nyquist rate) the input signal according to said second control
`
`signal.
`
`87.
`
`ParkerVision has been damaged by the direct infringement of LG, and is
`
`suffering and will continue to suffer irreparable harm and damages as a result of this
`
`infringement.
`
`
`
`19
`
`
`
`Case 6:21-cv-00520-ADA Document 1 Filed 05/22/21 Page 20 of 32
`
`COUNT V - Infringement of United States Patent No. 7,292,835
`
`88.
`
`The allegations set forth above are re-alleged and incorporated by
`
`reference as if they were set forth fully here.
`
`89.
`
`LG directly infringes the ’835 patent by making, using, selling, offering for
`
`sale, and/or importing in/into the United States products covered by at least claims 1
`
`and 17 of the ’835 patent.
`
`90.
`
`LG products that infringe one or more claims of the ’835 patent include,
`
`but are not limited to, the LG Products and any other LG device that is capable of
`
`down-converting a higher-frequency signal to a lower-frequency signal as claimed in
`
`the ’835 patent.
`
`91.
`
`LG Products enable users to watch live TV and on demand programming
`
`from their cable service providers, such as Spectrum, over a wireless network.
`
`https://www.spectrum.net/support/internet/lg-smart-tv-wifi-setup/. LG Chips are
`
`configured to function/capable of functioning as wireless cable modems. For example,
`
`LG Chips provide a wireless connection to cable services.
`
`92.
`
`Each LG 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.
`
`93.
`
`Each LG 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
`
`
`
`20
`
`
`
`Case 6:21-cv-00520-ADA Document 1 Filed 05/22/21 Page 21 of 32
`
`the in-phase oscillating signal and to create a quadrature-phase oscillating signal (e.g.,
`
`quadrature-phase LO signal), (c) a first frequency down-conversion module (e.g., a first
`
`module that includes at least one switch and at least one capacitor) to receive the
`
`electromagnetic signal and the in-phase oscillating signal and (d) a second frequency
`
`down-conversion module (e.g., a second module that includes at least one switch and at
`
`least one capacitor) to receive the electromagnetic signal and the quadrature-phase
`
`oscillating signal.
`
`94.
`
`The first frequency down-conversion module includes a first frequency
`
`translation module (e.g., a module having one or more switches) and a first storage
`
`module (e.g., a module having one or more capacitors). The first frequency translation
`
`module samples the electromagnetic signal at a rate (e.g., LO rate with a 25% duty
`
`cycle) that is a function of the in-phase oscillating signal, thereby creating a first
`
`sampled signal.
`
`95.
`
`The second frequency down-conversion module includes a second
`
`frequency translation module (e.g., a module having one or more switches) and a
`
`second storage module (e.g., a module having one or more capacitors). The second
`
`frequency translation module samples the electromagnetic signal at a rate (e.g., LO rate
`
`with a 25% duty cycle) that is a function of the quadrature-phase oscillating signal,
`
`thereby creating a second sampled signal.
`
`96.
`
`ParkerVision has been damaged by the direct infringement of LG, and is
`
`suffering and will continue to suffer irreparable harm and damages as a result of this
`
`infringement.
`
`
`
`21
`
`
`
`Case 6:21-cv-00520-ADA Document 1 Filed 05/22/21 Page 22 of 32
`
`COUNT VI - Infringement of United States Patent No. 8,588,725
`
`97.
`
`The allegations set forth above are re-alleged and incorporated by
`
`reference as if they were set forth fully here.
`
`98.
`
`LG directly infringes (literally and/or under the doctrine of equivalents)
`
`the ’725 patent by making, using, selling, offering for sale, and/or importing in/into the
`
`United States products covered by at least claim 1 of the ’725 patent.
`
`99.
`
`LG products that infringe one or more claims of the ’725 patent include,
`
`but are not limited to, the LG Products and any other LG device that is capable of
`
`down-converting a higher-frequency signal to a lower-frequency signal as claimed in
`
`the ’725 patent.
`
`100. Each LG Chip is/includes an apparatus for down-converting an
`
`electromagnetic signal (e.g., high frequency RF signal) to a lower frequency signal. Each
`
`LG Chip has an aliasing module comprising a switching device (e.g., one or more
`
`transistors) and a storage module (e.g., one or more capacitors). The aliasing module
`
`receives as an input an RF information signal and provides as an output a down-
`
`converted signal. The switching device of the aliasing module receives as an input a
`
`control signal (e.g., LO signal) that controls a charging and discharging cycle of the
`
`storage module by controlling the switching device so that a portion of energy is
`
`transferred from the RF information signal to the storage module during a charging
`
`part of the cycle and a portion of the transferred energy is discharged during a
`
`discharging part of the cycle.
`
`
`
`22
`
`
`
`Case 6:21-cv-00520-ADA Document 1 Filed 05/22/21 Page 23 of 32
`
`101. The control signal operates at an aliasing rate (e.g., LO rate with a 25%
`
`duty cycle) selected so that energy of the RF information signal is sampled and applied
`
`to the storage module at a frequency that is equal to or less than twice the frequency of
`
`the RF information signal. The storage module generates the down-converted signal
`
`from the alternate charging and discharging applied to the storage module using the
`
`control signal.
`
`102. ParkerVision has been damaged by the direct infringement of LG, and is
`
`suffering and will continue to suffer irreparable harm and damages as a result of this
`
`infringement.
`
`COUNT VII - Infringement of United States Patent No. 8,660,513
`
`103. The allegations set forth above are re-alleged and incorporated by
`
`reference as if they were set forth fully here.
`
`104. LG directly infringes (literally and/or under the doctrine of equivalents)
`
`the ‘513 patent by making, using, selling, offering for sale, and/or importing in/into the
`
`United States products covered by at least claim 19 of the ’513 patent.
`
`105. LG products that infringe one or more claims of the ‘513 patent include,
`
`but are not limited to, the LG Products and any other LG device that is capable of
`
`down-converting a higher-frequency signal to a lower-frequency signal as claimed in
`
`the ’513 patent.
`
`106. Each LG Chip is/includes a system for frequency down-converting a
`
`modulated carrier signal (e.g., a high frequency RF signal) to a lower frequency signal.
`
`Each LG Chip has (a) a first switch (e.g., transistor), (b) a first control signal (e.g., LO
`
`
`
`23
`
`
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`Case 6:21-cv-00520-ADA Document 1 Filed 05/22/21 Page 24 of 32
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`signal) which comprises a sampl
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