Case 6:21-cv-00520-ADA Document 32-13 Filed 02/23/22 Page 1 of 17
`Case 6:21-cv-00520-ADA Document 32-13 Filed 02/23/22 Page 1 of 17
`
`EXHIBIT 14
`EXHIBIT 14
`
`
`
`

`

`
`
`Case 6:20-cv-00870-ADA Document 51 Filed 10/29/21 Page 1 of 16Case 6:21-cv-00520-ADA Document 32-13 Filed 02/23/22 Page 2 of 17
`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE WESTERN DISTRICT OF TEXAS
`WACO DIVISION
`
`
`
`6-20-CV-00870
`
`
`
`
`6-20-CV-00945
`
`
`PARKERVISION, INC.,
` Plaintiff
`
`-v-
`
`HISENSE CO., LTD., HISENSE
`VISUAL TECHNOLOGY CO., LTD.
` Defendants
`
`
`PARKERVISION, INC.,
` Plaintiff
`
`-v-
`
`TCL INDUSTRIES HOLDINGS CO.,
`LTD., TCL ELECTRONICS
`HOLDINGS LTD., SHENZHEN TCL
`NEW TECHNOLOGY CO., LTD., TCL
`KING ELECTRICAL APPLIANCES
`(HUIZHOU) CO., LTD., TCL MOKA
`INT'L LTD., TCL MOKA
`MANUFACTURING S.A. DE C.V.
` Defendants
`
`
`§
`§
`§
`§
`§
`§
`§
`§
`§
`§
`§
`§
`§
`§
`§
`§
`§
`§
`§
`§
`§
`§
`§
`§
`§
`
`
`
`
`
`
`SPECIAL MASTER’S RECOMMENDED CLAIM CONSTRUCTIONS
`
`The undersigned held a Markman hearing on October 27, 2021, during which, the
`
`undersigned provided the constructions he planned to recommend to the court. The undersigned
`
`now formally enters those recommended claim constructions (“Recommendations”). The
`
`undersigned will, as soon as is practicable, enter a full Report and Recommendation explaining
`
`the basis for these Recommendations. The deadlines for the parties’ objections to the
`
`Recommendations are based on the entry of the full Report and Recommendation, and not these
`
`Recommendations.
`
`
`
`

`

`
`
`Case 6:20-cv-00870-ADA Document 51 Filed 10/29/21 Page 2 of 16Case 6:21-cv-00520-ADA Document 32-13 Filed 02/23/22 Page 3 of 17
`
`SIGNED this 29th day of October, 2021.
`
`
`
`
`
`JOSHUA J. YI, Ph.D.
`
`

`

`
`
`Case 6:20-cv-00870-ADA Document 51 Filed 10/29/21 Page 3 of 16Case 6:21-cv-00520-ADA Document 32-13 Filed 02/23/22 Page 4 of 17
`
`I.
`
`Level of ordinary skill in the art
`
`Plaintiff’s Proposal
`(i) a Bachelor of Science degree in
`electrical or computer engineering (or a
`related academic field), and at least two 2
`additional years of experience in the
`design and development of radio
`frequency circuits and/or systems or (at
`least five 5 years of experience and
`training in the design and development of
`radio frequency circuits and/or systems
`
`
`
`
`II.
`
`Disputed constructions
`
`Defendants’ Proposal
`At least an undergraduate degree in
`electrical engineering or a related subject
`and two or more years of experience in
`the fields of communication systems,
`signal processing and/or RF circuit design
`Less work experience may be
`compensated by a higher level of
`education, such as a master’s degree
`
`
`Special Master’s Recommendation
`A Bachelor of Science degree in electrical
`engineering (or an equivalent degree) and
`at least two additional years of experience
`in the design and development of radio
`frequency circuits and/or systems. Less
`experience may be compensated by a
`higher level of education, such as a
`master’s degree.
`
`
`Note: The Court previously construed the shaded terms in ParkerVision v. Intel (6-20-cv-00108 and 6-20-cv-00562).
`
`Plaintiff’s Proposed
`Construction
`Plain and ordinary meaning
`
`
`Defendants’ Proposed
`Construction
`Indefinite
`
`Special Master’s
`Recommended Construction
`Not indefinite. Plain and
`ordinary meaning.
`
`
`Term
`
`#1: “low impedance load”
`
`U.S. Patent No. 9,246,736,
`Claims 26, 27; 9,444,673,
`Claim 5
`
`Proposed by TCL
`
`
`

`

`
`
`Case 6:20-cv-00870-ADA Document 51 Filed 10/29/21 Page 4 of 16Case 6:21-cv-00520-ADA Document 32-13 Filed 02/23/22 Page 5 of 17
`
`Plaintiff’s Proposed
`Construction
`Plain and ordinary meaning
`
`
`Defendants’ Proposed
`Construction
`Indefinite
`
`
`Special Master’s
`Recommended Construction
`Not indefinite. Plain and
`ordinary meaning.
`
`
`Term
`
`#2: “said energy discharged
`from said capacitor provides
`sufficient power to drive the
`low impedance load”
`
`U.S. Patent No. 9,444,673,
`Claim 5
`
`Proposed by TCL
`
`
`

`

`
`
`Case 6:20-cv-00870-ADA Document 51 Filed 10/29/21 Page 5 of 16Case 6:21-cv-00520-ADA Document 32-13 Filed 02/23/22 Page 6 of 17
`
`Term
`
`#3: “Storage” terms
`
`U.S. Patent No. 6,049,706,
`Claims 105, 114, 115, 164,
`166, 168, 175, 179, 186, 190;
`U.S. Patent No. 6,580,902,
`Claim 1; U.S. Patent No.
`7,110,444, Claim 3; U.S.
`Patent No. 7,292,835, Claims
`1, 18, 20; U.S. Patent No.
`8,588,725, Claims 1, 6, 17, 18,
`19; U.S. Patent No. 8,660,513,
`Claim 19; U.S. Patent No.
`9,118,528, Claims 1, 9; U.S.
`Patent No. 9,246,736, Claims
`1, 11, 21, 26, 27; U.S. Patent
`No. 9,444,673, Claims 13, 17,
`18
`
`Proposed by ParkerVision
`
`
`Plaintiff’s Proposed
`Construction
`Energy storage element /
`storage element: “an element
`of an energy transfer system
`that stores nonnegligible
`amounts of energy from an
`input electromagnetic signal
`for driving a low impedance
`load.”
`
`Energy storage module /
`storage module: “a module of
`an energy transfer system that
`stores nonnegligible amounts
`of energy from an input
`electromagnetic signal for
`driving a low impedance load.
`
`Energy storage device: “a
`device of an energy transfer
`system that stores
`nonnegligible amounts of
`energy from an input
`electromagnetic signal for
`driving a low impedance load.”
`
`
`Defendants’ Proposed
`Construction
`“an apparatus that stores non-
`negligible amounts of energy
`from the carrier signal.”
`
`(all terms are indefinite under
`ParkerVision’s proposed
`constructions)
`
`
`Special Master’s
`Recommended Construction
`Energy storage element /
`storage element: “an element
`of an energy transfer system
`that stores nonnegligible
`amounts of energy from an
`input electromagnetic signal.”
`
`Energy storage module /
`storage module: “a module of
`an energy transfer system that
`stores nonnegligible amounts
`of energy from an input
`electromagnetic signal.
`
`Energy storage device: “a
`device of an energy transfer
`system that stores
`nonnegligible amounts of
`energy from an input
`electromagnetic signal.”
`
`
`

`

`
`
`Case 6:20-cv-00870-ADA Document 51 Filed 10/29/21 Page 6 of 16Case 6:21-cv-00520-ADA Document 32-13 Filed 02/23/22 Page 7 of 17
`
`Term
`
`#4: “voltage of the input
`modulated carrier signal is not
`reproduced or approximated at
`the capacitor during the
`apertures or outside of the
`apertures”
`
`U.S. Patent No. 9,444,673,
`Claim 2
`
`Proposed by TCL
`
`#5: “a down-convert and delay
`module to under-sample an
`input signal to produce an
`input sample of a down-
`converted image of said input
`signal, and to delay said input
`sample”
`
`U.S. Patent No. 6,049,706,
`Claims 1, 7
`
`Proposed by TCL
`
`
`Plaintiff’s Proposed
`Construction
`Plain and ordinary meaning
`
`Defendants’ Proposed
`Construction
`Indefinite
`
`
`Special Master’s
`Recommended Construction
`Not indefinite. Plain-and-
`ordinary meaning.
`
`
`Not subject to 35 U.S.C. § 112,
`¶ 6.
`
`Plain and ordinary meaning
`
`
`Not subject to 35 U.S.C. § 112,
`¶ 6
`
`Plain and ordinary meaning
`
`
`Subject to 35 U.S.C. § 112, ¶
`6.
`
`Function: “under-sample an
`input signal according to a
`control signal to produce an
`input sample of a down-
`converted image of said input
`signal, and to delay said input
`sample”
`
`Structure: “the down convert
`and delay module 2624 in Fig.
`26 and described at 26:1-27:21
`and 28:2041, that includes the
`switches 2650 and 2654, and
`the capacitors 2652 and 2656;
`and equivalents thereof”
`
`
`

`

`
`
`Case 6:20-cv-00870-ADA Document 51 Filed 10/29/21 Page 7 of 16Case 6:21-cv-00520-ADA Document 32-13 Filed 02/23/22 Page 8 of 17
`
`Term
`
`#6: “delay module” terms
`
`U.S. Patent No. 6,049,706,
`Claims 1, 7, 34, 140
`
`Proposed by TCL
`
`
`Plaintiff’s Proposed
`Construction
`Not subject to 35 U.S.C. § 112,
`¶ 6.
`
`Plain and ordinary meaning
`
`
`Special Master’s
`Recommended Construction
`Not subject to 35 U.S.C. § 112,
`¶ 6.
`
`Plain and ordinary meaning
`
`
`Defendants’ Proposed
`Construction
`Subject to 35 U.S.C. § 112, ¶
`6.
`
`Function: “delay instances
`of an output signal / further
`delay one or more of said
`delayed and down-converted
`input samples”
`
`Structure: “structure
`including “first delay
`module 2628,” “second
`delay module 2630” shown
`in Fig 26, “delay module
`3204” shown in Fig. 32 and
`described at 35:118; the
`sample and hold circuit
`4501 and 4503 in Fig. 45
`and described at 32:44-
`33:19; or an analog delay
`line having a combination of
`capacitors, inductors and/or
`resistors described at 35:19-
`27; or equivalents thereof”
`
`
`

`

`
`
`Case 6:20-cv-00870-ADA Document 51 Filed 10/29/21 Page 8 of 16Case 6:21-cv-00520-ADA Document 32-13 Filed 02/23/22 Page 9 of 17
`
`Term
`
`#7: “said control signal
`comprises a train of pulses
`having pulse widths that are
`established to improve energy
`transfer from said input signal
`to said down-converted
`image”
`
`U.S. Patent No. 6,049,706,
`Claim 2
`
`Proposed by TCL
`
`#8: “means for under-sampling
`an input signal to produce an
`input sample of a down-
`converted image of said input
`signal”
`
`U.S. Patent No. 6,049,706,
`Claim 6
`
`Proposed by TCL
`
`
`Plaintiff’s Proposed
`Construction
`Plain and ordinary meaning
`
`
`Defendants’ Proposed
`Construction
`Indefinite
`
`
`Special Master’s
`Recommended Construction
`Not indefinite. Plain-and-
`ordinary meaning.
`
`
`Subject to § 112, ¶ 6.
`
`Function: under-sampling an
`input signal to produce an
`input sample of a down-
`converted image of the input
`signal and under-sampling the
`input signal according to a
`control signal
`
`Structure: switch 2650 in
`Fig. 26; switch 5308 in Figs.
`53A/53A-1; and equivalents
`thereof
`
`
`Subject to § 112, ¶ 6.
`
`Function: “under-sampling an
`input signal to produce an
`input sample of a down-
`converted image of said input
`signal and under-sampling the
`input signal according to a
`control signal”
`
`Structure: “the switch 2650
`and the capacitor 2652 in Fig.
`26; the switch 5308 and
`capacitor 5310 in Figs.
`53A/53A-1, and equivalents
`thereof”
`
`
`Subject to § 112, ¶ 6.
`
`Function: under-sampling an
`input signal to produce an
`input sample of a down-
`converted image of said input
`signal and under-sampling the
`input signal according to a
`control signal
`
`Structure: the switch 2650
`and the capacitor 2652 in Fig.
`26 the switch 5308 and
`capacitor 5310 in Figs.
`53A/53A-1, and equivalents
`thereof.
`
`
`

`

`
`
`Case 6:20-cv-00870-ADA Document 51 Filed 10/29/21 Page 9 of 16Case 6:21-cv-00520-ADA Document 32-13 Filed 02/23/22 Page 10 of 17
`
`Plaintiff’s Proposed
`Construction
`Subject to § 112, ¶ 6.
`
`Function: delaying the input
`sample of a down-converted
`image of said input signal
`
`Structure: capacitor 2656 in
`Fig. 26 or capacitor 5310 in
`Figs. 53A/53A1; and
`equivalents thereof
`
`Not subject to 35 U.S.C. § 112,
`¶ 6.
`
`Plain and ordinary meaning
`
`
`Term
`
`#9: “first delaying means for
`delaying said input sample”
`
`U.S. Patent No. 6,049,706,
`Claim 6
`
`Proposed by TCL
`
`
`#10: “a frequency translator to
`produce a sample of a down-
`converted image of an input
`signal, and to delay said
`sample”
`
`U.S. Patent No. 6,049,706,
`Claim 34
`
`Proposed by TCL
`
`
`Defendants’ Proposed
`Construction
`Subject to § 112, ¶ 6.
`
`Function: “delaying said input
`sample”
`
`Structure: “switch 2654 and
`capacitor 2656 shown in Fig.
`26”
`
`
`Special Master’s
`Recommended Construction
`Subject to § 112, ¶ 6.
`
`Function: delaying said input
`sample
`
`Structure: switch 2654 and
`capacitor 2656 shown in Fig.
`26.
`
`
`Not subject to § 112, ¶ 6.
`Plain-and-ordinary meaning.
`
`
`Subject to 35 U.S.C. § 112, ¶
`6.
`
`Function:
`“produce a sample of a down-
`converted image of an input
`signal according to a control
`signal, and delay said sample”
`
`Structure: “the down-convert
`and delay module 2624 in Fig.
`26 and described at 26:1-27:21
`and 28:20-41, that includes the
`switches 2650 and 2654, and
`the capacitors 2652 and 2656;
`and equivalents thereof”
`
`
`

`

`
`
`Case 6:20-cv-00870-ADA Document 51 Filed 10/29/21 Page 10 of 16Case 6:21-cv-00520-ADA Document 32-13 Filed 02/23/22 Page 11 of 17
`
`Plaintiff’s Proposed
`Construction
`Plain and ordinary meaning
`
`
`Defendants’ Proposed
`Construction
`Indefinite
`
`
`Special Master’s
`Recommended Construction
`Not indefinite. Plain-and-
`ordinary meaning.
`
`
`Term
`
`#11: “wherein said energy
`transfer signal generator in
`widening said apertures of said
`pulses by a nonnegligible
`amount that tends away from
`zero time in duration to extend
`the time that said switch is
`closed for the purpose of
`increasing energy transferred
`from said input signal does so
`at the expense of reproducing
`said input signal, such that said
`increased energy transferred
`from said input signal when
`said switch is closed in
`response to said energy
`transfer signal prevents
`substantial voltage
`reproduction of said input
`signal”
`
`U.S. Patent No. 6,049,706,
`Claim 111
`
`Proposed by TCL
`
`
`

`

`
`
`Case 6:20-cv-00870-ADA Document 51 Filed 10/29/21 Page 11 of 16Case 6:21-cv-00520-ADA Document 32-13 Filed 02/23/22 Page 12 of 17
`
`Plaintiff’s Proposed
`Construction
`Plain and ordinary meaning
`
`Defendants’ Proposed
`Construction
`Indefinite
`
`Special Master’s
`Recommended Construction
`Not indefinite. Plain-and-
`ordinary meaning.
`
`
`Term
`
`#12: “establishing apertures”
`terms
`
`U.S. Patent No. 6,049,706,
`Claims 165, 107, 176, 187
`
`Proposed by TCL
`
`#13: “frequency down-
`conversion module”
`
`U.S. Patent No. 7,110,444,
`Claims 2, 3
`
`Proposed by TCL
`
`
`Plain and ordinary meaning
`
`
`Subject to § 112, ¶ 6.
`
`Function: “to down-convert
`the input signal ... according to
`a [] control signal and output[]
`a [] down-converted signal.”
`
`Structure: an
`“aliasing module 2000” (blue)
`comprising at least one switch
`and one capacitor (Figures
`20A and 20A-1).
`
`“sampling at less than or equal
`to twice the frequency of the
`input signal”
`
`
`Not subject to § 112, ¶ 6.
`Plain-and-ordinary meaning.
`
`
`“sampling at an aliasing rate”
`or “sampling at less than or
`equal to twice the frequency of
`the input signal”
`
`
`#14: “Under-Sample” /
`“Under-Samples” / “Under-
`Sampling”
`
`
`“sampling at an aliasing
`rate” or “sampling at
`less than or equal to
`twice the frequency of
`the input signal”
`
`
`

`

`
`
`Case 6:20-cv-00870-ADA Document 51 Filed 10/29/21 Page 12 of 16Case 6:21-cv-00520-ADA Document 32-13 Filed 02/23/22 Page 13 of 17
`
`Term
`
`#15: “harmonic” / “harmonics”
`
`U.S. Patent No. 6,049,706,
`Claims 1, 6-7, 28, 34; U.S.
`Patent No. 6,266,518, Claim 1
`
`Proposed by ParkerVision
`
`
`#16: “integral filter/frequency
`translator to filter and down-
`convert an input signal”
`
`U.S. Patent No. 6,049,706,
`Claim 28
`
`Proposed by ParkerVision
`
`
`Defendants’ Proposed
`Construction
`Harmonic: “A sinusoidal
`component of a periodic wave
`that has a frequency that is an
`integer multiple of the
`fundamental frequency of the
`periodic wave”
`
`Harmonics: “Sinusoidal
`components of a periodic
`wave each of which have a
`frequency that is an integer
`multiple of the fundamental
`frequency of the periodic
`wave”
`
`
`Plain and ordinary meaning
`
`
`Plaintiff’s Proposed
`Construction
`Harmonic: “A sinusoidal
`component of a periodic wave
`that has a frequency that is an
`integer multiple of the
`fundamental frequency of the
`periodic waveform and
`including the fundamental
`frequency as the first
`harmonic”
`
`
`Harmonics: “A frequency or
`tone that, when compared to its
`fundamental or reference
`frequency or tone, is an integer
`multiple of it and including the
`fundamental frequency as the
`first harmonic”
`
`
`Plain-and-ordinary meaning
`wherein the plain-and-ordinary
`meaning is “a circuit having a
`unified input filter and
`frequency translator.”
`
`
`Special Master’s
`Recommended Construction
`Plain-and-ordinary meanings:
` Harmonic: “A sinusoidal
`component of a periodic
`wave that has a frequency
`that is an integer multiple
`of the fundamental
`frequency of the periodic
`waveform and including
`the fundamental frequency
`as the first harmonic”
` Harmonics: “A frequency
`or tone that, when
`compared to its
`fundamental or reference
`frequency or tone, is an
`integer multiple of it and
`including the fundamental
`frequency as the first
`harmonic”
`
`
`Plain-and-ordinary meaning
`wherein the plain-and-ordinary
`meaning is “a circuit having a
`unified input filter and
`frequency translator.”
`
`
`

`

`
`
`Case 6:20-cv-00870-ADA Document 51 Filed 10/29/21 Page 13 of 16Case 6:21-cv-00520-ADA Document 32-13 Filed 02/23/22 Page 14 of 17
`
`Term
`
`#17: “modulated signal” /
`“modulated carrier signal”
`
`U.S. Patent No. 6,049,706,
`Claim 127; U.S. Patent No.
`8,660,513, Claim 19; U.S.
`Patent No. 9,118,528, Claims
`1, 5; U.S. Patent No.
`9,246,736, Claims 1, 11, 15;
`U.S. Patent No. 9,444,673,
`Claims 1, 2, 7, 13, 19
`
`Proposed by ParkerVision
`
`#18: “universal frequency
`downconverter (UFD)”
`
`U.S. Patent No. 6,266,518,
`Claim 50
`
`Proposed by ParkerVision
`
`
`Defendants’ Proposed
`Construction
`Plain and ordinary meaning
`
`
`Plaintiff’s Proposed
`Construction
`“an electromagnetic signal at a
`transmission frequency having
`at least one characteristic that
`has been modulated by a
`baseband signal”
`
`
`Special Master’s
`Recommended Construction
`Plain-and-ordinary meaning
`wherein the plain-and-ordinary
`meaning is “an
`electromagnetic signal at a
`transmission frequency having
`at least one characteristic that
`has been modulated by a
`baseband signal”
`
`
`Plain and ordinary meaning
`
`
`“circuitry that generates a
`down converted output signal
`from an input signal from a
`wide range of electromagnetic
`frequencies”
`
`
`“circuitry that generates a
`down converted output signal
`from an input signal from a
`wide range of electromagnetic
`frequencies”
`
`
`

`

`
`
`Case 6:20-cv-00870-ADA Document 51 Filed 10/29/21 Page 14 of 16Case 6:21-cv-00520-ADA Document 32-13 Filed 02/23/22 Page 15 of 17
`
`Plaintiff’s Proposed
`Construction
`Plain and ordinary meaning
`wherein the “a capacitor” in
`each of the storage elements
`reduces a DC offset voltage in
`the corresponding
`downconverted signal
`
`
`Defendants’ Proposed
`Construction
`[wherein said storage elements
`comprises] “a capacitor that
`reduces a DC offset voltage in
`both said first down-converted
`signal and said second down-
`converted signal
`
`
`Special Master’s
`Recommended Construction
`Plain-and-ordinary meaning
`wherein the “a capacitor” in
`each of the storage elements
`reduces a DC offset voltage in
`the corresponding down-
`converted signal.”
`
`
`Plain-and-ordinary meaning
`wherein the plain-and ordinary
`meaning is “the difference
`between the DC voltage of a
`signal and a reference voltage,
`e.g., ground”
`
`“a period of time during which
`the switch is in its closed (i.e.,
`on) state”
`
`Plain and ordinary meaning
`
`
`“a period of time during which
`the switch is in its closed (i.e.,
`on) state as part of the process
`of reducing a continuous-time
`signal to a discrete-time
`signal”
`
`
`Plain-and-ordinary meaning
`wherein the plain-and-ordinary
`meaning is “the difference
`between the DC voltage of a
`signal and a reference voltage,
`e.g., ground”
`
`“a period of time during which
`the switch is in its closed (i.e.,
`on) state”
`
`
`Term
`
`#19: [wherein said storage
`elements comprises] “a
`capacitor that reduces a DC
`offset voltage in said first-
`down converted signal and
`said second down converted
`signal”
`
`U.S. Patent No. 7,110,444,
`Claim 4
`
`Proposed by ParkerVision
`
`#20: “DC offset voltage”
`
`U.S. Patent No. 7,110,444,
`Claim 4
`
`Proposed by ParkerVision
`
`#21: “sampling aperture”
`
`U.S. Patent No. 8,660,513,
`Claim 19; U.S. Patent No.
`9,118,528, Claim 1; U.S.
`Patent No. 9,246,736, claims
`1, 11; U.S. Patent No.
`9,444,673, Claims 13, 17, 19
`
`Proposed by ParkerVision
`
`
`

`

`
`
`Case 6:20-cv-00870-ADA Document 51 Filed 10/29/21 Page 15 of 16Case 6:21-cv-00520-ADA Document 32-13 Filed 02/23/22 Page 16 of 17
`
`Defendants’ Proposed
`Construction
`Plain and ordinary meaning
`
`
`Plaintiff’s Proposed
`Construction
`Plain-and-ordinary meaning
`wherein the plain-and-
`ordinary meaning is “an
`electronic device for opening
`and closing a circuit as
`dictated by an independent
`control input”
`
`
`Special Master’s
`Recommended Construction
`Plain-and-ordinary meaning
`wherein the plain-and-
`ordinary meaning is “an
`electronic device for opening
`and closing a circuit as
`dictated by an independent
`control input”
`
`
`Term
`
`#22: “switch” / “switching
`device” / “switching module” /
`“switch module”
`
`U.S. Patent No. 6,049,706,
`Claims 105, 107, 109, 111,
`114, 115, 164, 165, 166, 168,
`175, 176, 179, 186, 187, 190;
`U.S. Patent No. 6,266,518,
`Claim 50; U.S. Patent No.
`6,580,902, Claim 1; U.S.
`Patent No. 7,110,444, Claim 3;
`U.S. Patent No. 7,292,835,
`Claims 18, 19, 20; U.S. Patent
`No. 8,588,725, Claim 1; U.S.
`Patent No. 8,660,513, Claim
`19; U.S. Patent No. 9,118,528,
`Claims 1, 5, 8, 17; U.S. Patent
`No. 9,246,736,, claims 1, 11,
`15, 21, 26, 27; U.S. Patent No.
`9,444,673, Claims 1, 6, 7, 13,
`17, 18
`
`Proposed by ParkerVision
`
`
`

`

`
`
`Case 6:20-cv-00870-ADA Document 51 Filed 10/29/21 Page 16 of 16Case 6:21-cv-00520-ADA Document 32-13 Filed 02/23/22 Page 17 of 17
`
`Term
`
`#23: “a down-converted signal
`being generated from said
`sampled energy”
`
`U.S. Patent No. 6,580,902,
`Claim 1
`
`Proposed by ParkerVision
`
`
`Plaintiff’s Proposed
`Construction
`“a lower frequency signal
`formed from sampled energy
`transferred from the
`electromagnetic signal when
`the switch module is closed
`and from sampled energy
`discharged from the storage
`module when the switch
`module is open”
`
`
`
`
`Defendants’ Proposed
`Construction
`“a down-converted signal
`being created from sampled
`energy stored in the energy
`storage module”
`
`
`Special Master’s
`Recommended Construction
`“a lower frequency signal
`formed from sampled energy
`transferred from the
`electromagnetic signal when
`the switch module is closed
`and from sampled energy
`discharged from the storage
`module when the switch
`module is open”
`
`
`