Case 6:21-cv-01045 Document 1 Filed 10/06/21 Page 1 of 20
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`
`
`UNITED STATES DISTRICT COURT
`WESTERN DISTRICT OF TEXAS
`WACO DIVISION
`
`
`
`Case No. 6:21-cv-1045
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`
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`JURY TRIAL DEMANDED
`
`
`
`ARIGNA TECHNOLOGY LIMITED,
`
`
`
`Plaintiff,
`
`vs.
`
`GOOGLE LLC,
`
`
`
`Defendant.
`
`
`
`
`COMPLAINT FOR PATENT INFRINGEMENT
`
`
`
`This is an action for patent infringement in which Arigna Technology Limited makes the
`
`following allegations against Defendant Google LLC (“Google”), who without authority imports,
`
`makes, offers for sale and/or sells in the United States mobile devices that infringe the Patents
`
`asserted in this matter.
`
`PARTIES
`
`1.
`
`Plaintiff Arigna Technology Limited (“Plaintiff” or “Arigna”) is an Irish company
`
`conducting business at The Hyde Building, Carrickmines, Suite 23, Dublin 18, Ireland. Arigna
`
`owns a portfolio of patents that cover radio frequency amplifiers and circuits with applications in
`
`a wide variety of consumer electronics products, including smartphones and laptops, as well as
`
`power semiconductors for applications in the communications, automotive, industrial automation,
`
`and energy industries. Arigna is the owner of all rights, title, and interest in and to United States
`
`Patent No. 6,603,343 (the “’343 Patent”) and United States Patent No. 8,947,164 (the “’164
`
`Patent”).
`
`2.
`
`Google is a corporation organized under the laws of the State of California with its
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`1
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`Case 6:21-cv-01045 Document 1 Filed 10/06/21 Page 2 of 20
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`headquarters at 1600 Amphitheatre Parkway, Mountain View, California 94043.
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`3.
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`Google does business in this District and across the State of Texas. It has over 1,700
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`full-time employees in Texas. On information and belief, they are located predominantly in this
`
`District. Google “has proudly called Texas home for more than a decade with offices in Austin
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`and Dallas, and a data center in Midlothian—a $600M investment.”1 Google maintains regular and
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`established places of business in this District, including offices at 500 West 2nd Street, Suite 2900,
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`Austin, Texas 78701 and 110 East Houston Street #300, San Antonio, Texas 78205, among other
`
`locations.2
`
`4.
`
`According to Google, “Teams at Google Austin focus on Android, Google Cloud,
`
`Google Play, people operations, finance, legal, and engineering.”3 Google’s website lists job
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`openings in Google’s Austin and San Antonio offices.4 Multiple job openings for engineering roles
`
`in Google’s Devices and Services group, including at senior levels, indicate that the employee can
`
`choose to work in Austin.5 Such openings for a “CPU Silicon Engineer, Design Verification,
`
`Devices and Services” and a “CPU Emulation Engineer, Devices and Services” seek candidates
`
`
`1 Google, Google is proud to call Texas home (accessed Oct. 5, 2021), available at:
`https://kstatic.googleusercontent.com/files/b008bec49e466217468bdb3fbb0a9e6146435f1a75c7e
`ba13f30fb30c9a5871deb617df65cb75f4ca7b4fdb940d1f9c4c8b75088f4de2277c76940696d07a0
`8c#:~:text=Google%20has%20proudly%20called%20Texas,Midlothian%E2%80%94a%20%24
`600M%20investment.&text=Texans%20are%20employed%20full%2Dtime%20at%20Google.
`2
`Google,
`offices
`(accessed
`Oct.
`5,
`2021),
`available
`at
`Our
`https://about.google/intl/ALL_us/locations/?region=north-america
`3 Google Economic
`Impact, Texas
`(accessed Oct.
`5,
`2021),
`available
`at:
`https://economicimpact.google.com/state/tx/.
`4
`Google
`Careers,
`Jobs
`(accessed
`Oct.
`5,
`2021),
`available
`at
`https://careers.google.com/jobs/results/?company=Google&company=YouTube&hl=en&jlo=en-
`US&location=Austin,%20TX,%20USA&location=San%20Antonio,%20TX,%20USA
`5 Google Careers, Senior Engineering Manager, Compilers, Devices and Services (accessed Oct.
`5, 2021), available at: https://careers.google.com/jobs/results/104794466419647174-senior-
`engineering-manager-compilers-devices-and-
`services/?company=Google&company=YouTube&hl=en&jlo=en-
`US&location=Austin,%20TX,%20USA&location=San%20Antonio,%20TX,%20USA&skills=h
`ardware%20engineering.
`
`2
`
`

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`Case 6:21-cv-01045 Document 1 Filed 10/06/21 Page 3 of 20
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`with electrical engineering credentials to “research, design, and develop new technologies and
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`hardware to make computing faster, seamless, and more powerful.”6 Given that Google gives
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`hardware engineers the choice to work in Austin, on information and belief, documents and
`
`witnesses relevant to this action are located in this District.
`
`5.
`
`Google also advertises job openings for engineers to work on “CPU Front End
`
`Design,” specifying Austin as one of the work locations.7 Google’s job postings indicate that
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`candidates for such roles will “[d]evelop CPU frontend designs, emphasizing on microarchitecture
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`and RTL design for the next generation CPU” and “[p]ropose performance enhancing
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`microarchitecture features with efficiency in mind, and work with architects and performance
`
`teams for trade-off studies.”8 Given that Google is hiring such engineers and giving them the option
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`to work in this District, witnesses with knowledge relevant to this action are likely to be located in
`
`this District.
`
`6.
`
`On information and belief, Google’s in-house legal department also has a
`
`substantial presence in Austin, Texas. Google’s Careers website includes job postings for both
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`“Litigation Counsel, Patent Litigation” and “Litigation Paralegal” roles with the option to work in
`
`Austin.9 Given the location of Google legal personnel in Austin, on information and belief,
`
`
`6 Google Careers, CPU Silicon Engineer, Design Verification, Devices and Services (accessed Oct.
`5, 2021), available at: https://careers.google.com/jobs/results/126548485169128134-cpu-silicon-
`engineer-design-verification-devices-and-
`services/?company=Google&company=YouTube&hl=en&jlo=en-xan
`gersonUS&location=Austin,%20TX,%20USA&location=San%20Antonio,%20TX,%20USA&s
`kills=hardware%20engineering.
`7 Google Careers, Senior Engineer, CPU Front End Design (accessed Oct. 3, 2021), available at:
`https://careers.google.com/jobs/results/143377253611250374-senior-engineer-cpu-front-end-
`design/?location=Texas,%20USA&q=engineer.
`8 Id.
`9 See, e.g., Google Careers, Litigation Counsel, Patent Litigation (accessed Oct. 3, 2021), available
`at:
`https://careers.google.com/jobs/results/129929351756948166-litigation-counsel-patent-
`litigation/?category=LEGAL&company=Google&company=YouTube&hl=en&jlo=en-
`US&location=Austin,%20TX,%20USA.
`
`3
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`Case 6:21-cv-01045 Document 1 Filed 10/06/21 Page 4 of 20
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`documents, materials, and potential witnesses relevant to this action are located in this District.
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`7.
`
`Google has placed or contributed to placing infringing products, such as the Google
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`Pixel 5, into the stream of commerce via established distribution channels knowing or
`
`understanding that such products would be sold and used in the United States, including in the
`
`Western District of Texas. Google also has derived substantial revenue from infringing acts in the
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`Western District of Texas, including from the sale and use of infringing products such as the
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`Google Pixel 5.
`
`8.
`
`On information and belief, Google designs, manufactures, distributes, imports,
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`offers for sale, and/or sells in the State of Texas and the Western District of Texas mobile devices
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`that infringe the Patents asserted in this matter.
`
`JURISDICTION AND VENUE
`
`9.
`
`This is an action for patent infringement arising under the patent laws of the United
`
`States. This Court has subject matter jurisdiction pursuant to 28 U.S.C. §§ 1331 and 1338(a).
`
`10.
`
`This Court has personal jurisdiction over Google because it conducts business in
`
`and has committed acts of patent infringement in this District, the State of Texas, and elsewhere
`
`in the United States and has established minimum contacts with this forum state such that the
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`exercise of jurisdiction over it would not offend the traditional notions of fair play and substantial
`
`justice. Upon information and belief, Google transacts substantial business with entities and
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`individuals in the State of Texas and the Western District of Texas by, among other things,
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`importing, offering to sell, distributing, and selling products that infringe the Asserted Patents,
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`including the infringing mobile devices that Google purposefully directs into the State of Texas
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`and this District as alleged herein, as well as by providing service and support to customers in this
`
`District, and/or inducing others to commit acts of patent infringement in Texas. Google places the
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`Case 6:21-cv-01045 Document 1 Filed 10/06/21 Page 5 of 20
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`accused mobile devices into the stream of commerce via authorized and established distribution
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`channels with the knowledge and expectation that they will be sold in the United States, including
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`in the State of Texas and this District, and does not otherwise permit the sale of the accused
`
`products in the State of Texas, or in this District, outside of these established, authorized, and
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`ratified distribution channels.
`
`11.
`
`Venue is proper in this District pursuant to 28 U.S.C. §§ 1391(b)-(c) and 1400(b)
`
`because Google has committed acts of infringement in this District and has regular and established
`
`places of business in this District, including at 500 West 2nd Street, Suite 2900, Austin, Texas
`
`78701 and 110 East Houston Street #300, San Antonio, Texas 78205. See In re Cray Inc., 871 F.3d
`
`1355, 1362-63 (Fed. Cir. 2017).
`
`THE ASSERTED PATENTS
`
`12.
`
`This complaint asserts causes of action for infringement of United States Patent No.
`
`6,603,343 and United States Patent No. 8,947,164 (together, the “Asserted Patents”). The Asserted
`
`Patents are valid and enforceable United States Patents, the entire right, title, and interest to which
`
`Arigna owns by assignment.
`
`13.
`
`The Asserted Patents relate to power semiconductor devices using high-frequency
`
`RF signals for use in mobile devices, including smartphones, tablets, and computers.
`
`14.
`
`On August 5, 2003, the U.S. Patent and Trademark Office duly and legally issued
`
`the ’343 Patent, which is entitled “Phase Correction Circuit for Transistor Using High-Frequency
`
`Signal.” Plaintiff holds all rights and title to the Patent, including the sole and exclusive right to
`
`bring a claim for its infringement. A true and correct copy of the ’343 Patent is attached as Exhibit
`
`A.
`
`15.
`
`The ’343 Patent generally claims a phase correction circuit for a transistor using a
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`5
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`Case 6:21-cv-01045 Document 1 Filed 10/06/21 Page 6 of 20
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`high-frequency signal. The claimed phase correction circuit stabilizes a phase of an output signal
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`of a transistor even if the transistor’s gate potential is increased by a temperature increase or other
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`factors.
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`16.
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`To the extent applicable, Plaintiff has complied with 35 U.S.C. § 287(a) with
`
`respect to the ’343 Patent.
`
`17.
`
`On February 3, 2015, the U.S. Patent and Trademark Office duly and legally issued
`
`the ’164 Patent, which is entitled “Integrated Technique for Enhanced Power Amplifier Forward
`
`Power Detection.” Plaintiff holds all rights and title to the Patent, including the sole and exclusive
`
`right to bring a claim for its infringement. A true and correct copy of the ’164 Patent is attached
`
`as Exhibit B.
`
`18.
`
`The ’164 Patent generally claims a method for accurate power detection in power
`
`amplifiers at a low cost, and in which the power detector’s design does not affect the design of the
`
`power amplifier.
`
`19.
`
`To the extent applicable, Plaintiff has complied with 35 U.S.C. § 287(a) with
`
`respect to the ’164 Patent.
`
`20.
`
`Plaintiff owns all rights, title, and interest in and to the Asserted Patents and
`
`possesses all rights of recovery.
`
`FACTUAL ALLEGATIONS
`
`21.
`
`As referred to in this Complaint, and consistent with 35 U.S.C. § 100(c), the
`
`“United States” means “the United States of America, its territories and possessions.”
`
`22.
`
`Google has no right to practice the intellectual property protected by the Asserted
`
`Patents.
`
`23.
`
`Google makes, uses, offers to sell, sells, and/or imports into the United States,
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`6
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`products made in accordance with the ’343 Patent, including but not limited to the Google Pixel
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`5, in addition to other mobile devices including smartphones, tablets, and computers.
`
`24.
`
`Google also makes, uses, offers to sell, sells, and/or imports into the United States,
`
`products made in accordance with the ’164 Patent, including but not limited to the Google Pixel
`
`5, in addition to other mobile devices including smartphones, tablets, and computers.
`
`COUNT ONE
`INFRINGEMENT OF U.S. PATENT NO. 6,603,343
`
`25.
`
`Plaintiff repeats and incorporates by reference each preceding paragraph as if fully
`
`set forth herein and further states:
`
`26.
`
`Google has infringed and continues to infringe at least claim 1 of the ’343 Patent in
`
`violation of 35 U.S.C. § 271, either literally or through the doctrine of equivalents, by making,
`
`using, selling, or offering for sale in the United States, and/or importing into the United States,
`
`without authorization, products that practice at least claim 1 of the ’343 Patent. Google is liable
`
`for its infringement of the ’343 Patent pursuant to 35 U.S.C. § 271(a), (b), and (c).
`
`27. More specifically, Google designs, manufactures, assembles, imports, offers for
`
`sale, and/or sells mobile devices that incorporate the HG11-PG660-200 RF die semiconductor
`
`device and infringe at least independent claim 1 of the ’343 Patent.
`
`28.
`
`The HG11-PG660-200 RF die is found inside the Qualcomm QTM525 mmWave
`
`antenna module. The QTM525 mmWave antenna module that includes the HG11-PG660-200 RF
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`die is designed to be included in smartphones.
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`7
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`Case 6:21-cv-01045 Document 1 Filed 10/06/21 Page 8 of 20
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`FIGURE 1
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`
`
`
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`Source: Qualcomm, Snapdragon X55 and 5G RF briefing slides (Feb. 2019), available at:
`https://www.t-mobile.com/content/dam/tfb/pdf/tfb-iot/Qualcomm_SDX55_datasheet.pdf.
`
`The QTM525 comes pre-installed in certain Google devices, including the Google
`
`29.
`
`Pixel 5. Figure 2 identifies these antenna modules in the Pixel 5.
`
`FIGURE 2
`
`Source: Ars Technica, Pixel 5 teardown shows off the guts of Google’s latest flagship
`
`
`
`8
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`

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`Case 6:21-cv-01045 Document 1 Filed 10/06/21 Page 9 of 20
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`
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`(Nov. 2, 2020), available at: https://arstechnica.com/gadgets/2020/11/pixel-5-teardown-
`shows-off-the-guts-of-googles-latest-flagship/
`
`30.
`
`Claim 1 is illustrative of the ’343 Patent. It recites “[a] phase correction circuit for
`
`a transistor, comprising: a circuit element having an output terminal connected to a gate of a
`
`transistor to which a control signal line is connected, and an input terminal, wherein the circuit
`
`element has a reactance that changes with potential difference between the input terminal and the
`
`output terminal; and a voltage control circuit supplying a voltage to the input terminal of the circuit
`
`element so that the reactance of the circuit element decreases in response to an increase in potential
`
`of the gate, wherein a sum of the reactance of the circuit element and a gate-source reactance of
`
`the transistor remains substantially constant.”
`
`31.
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`Devices with transceivers, antenna modules, front-end modules (FEMs), and/or
`
`other components which incorporate the HG11-PG660-200 RF die meet every element of this
`
`claim.10 The HG11-PG660-200 RF die contains a phase correction circuit for a transistor. For
`
`example, the transmitter portion of the HG11-PG660-200 RF die contains transistors with a phase
`
`correction circuit. For instance, a circuit element in the HG11-PG660-200 RF die (hereafter called
`
`“MOS-C”) forms part of a phase correction circuitry for a transistor in the HG11-PG660-200 RF
`
`die (hereafter called “MOS7”).
`
`32.
`
`This phase correction circuit contains a circuit element having an output terminal
`
`connected to a gate of a transistor to which a control signal line is connected. For example, in the
`
`HG11-PG660-200 RF die, the circuit element MOS-C has an output terminal connected to a gate
`
`of the MOS7 transistor. It also has an input terminal.
`
`33.
`
`A control signal line is also connected to the gate of the transistor. For example, a
`
`
`10 This description of infringement is illustrative and not intended to be an exhaustive or limiting
`explanation of every manner in which Google’s products infringe the ’343 Patent.
`
`9
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`Case 6:21-cv-01045 Document 1 Filed 10/06/21 Page 10 of 20
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`control signal line is connected to the gate of the MOS7 transistor through a passive bias network.
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`34.
`
`The circuit element has a reactance that changes with potential difference between
`
`the input terminal and the output terminal. For example, the identified MOS-C circuit element is
`
`an NMOS Field Effect Transistor whose source and drain are connected. MOS-C acts as a varactor
`
`whose capacitance (and thus reactance) changes according to the potential difference between the
`
`input terminal (drain and source node) and the output terminal (gate node).
`
`35.
`
`This phase correction circuit in the HG11-PG660-200 RF die also contains a
`
`voltage control circuit supplying a voltage to the input terminal of the circuit element so that the
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`reactance of the circuit element decreases in response to an increase in the potential of the gate.
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`For example, another transistor in the HG11-PG660-200 RF die forms part of the voltage control
`
`circuit supplying a voltage to the input terminal of the circuit element MOS-C.
`
`36.
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`The reactance of the circuit element decreases in response to an increase in potential
`
`of the gate, wherein a sum of the reactance of the circuit element and a gate-source reactance of
`
`the transistor remains substantially constant. For example, when the magnitude of the gate-source
`
`potential at MOS7 increases, it leads to a reduction in the capacitance of the circuit element (MOS-
`
`C). As the gate potential of the MOS7 gets more negative (i.e., the magnitude of gate-source
`
`potential increases), the gate-source capacitance of transistor MOS7 increases. This increase is
`
`offset, however, by the decrease in the capacitance of the circuit element (MOS-C) that occurs due
`
`to the increase in the magnitude of the gate potential of MOS7 such that the sum of capacitance
`
`(i.e. reactance) of the circuit element (MOS-C) and transistor (MOS7) remains substantially
`
`constant.
`
`37.
`
`Google makes, uses, imports, offers for sale, and/or sells mobile devices such as
`
`smartphones that incorporate the HG11-PG660-200 RF die in their antenna modules, including
`
`10
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`but not limited to the Pixel 5.
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`38.
`
`Google has imported and sold, and continues to sell and offer for sale, these mobile
`
`devices in the United States, including through Google websites (store.google.com) and Google
`
`authorized retailers in the Western District of Texas.
`
`39.
`
`Google committed and is committing the foregoing infringing activities without
`
`license from Arigna. Google’s acts of infringement have damaged Arigna, as owner and assignee
`
`of the ’343 Patent. Arigna is entitled to recover from Google the damages it has sustained as a
`
`result of Google’s wrongful acts in an amount subject to proof at trial. Google’s infringement of
`
`Arigna’s rights under the ’343 Patent is ongoing and will continue to damage Arigna.
`
`40.
`
`Beginning no later than the filing of this Complaint, Google has had actual
`
`knowledge of the ’343 Patent. Google’s continued infringement following the filing of this
`
`Complaint, despite its knowledge of the ’343 Patent and Arigna’s infringement allegations, is
`
`intentional and deliberate and willful.
`
`41.
`
`In addition, Google indirectly infringed, and continues to indirectly infringe, the
`
`’343 Patent by actively inducing its infringement in violation 35 U.S.C. § 271(b).
`
`42.
`
`Google’s authorized retailers, such as Best Buy, and wireless carriers, such as
`
`Verizon, directly infringe the ’343 Patent by selling the accused Google devices to consumers.
`
`Consumers directly infringe the ’343 Patent by using the accused Google devices.
`
`43.
`
`Google knowingly induced and induces these acts of infringement with the specific
`
`intent to encourage them by taking active steps to encourage and facilitate direct infringement by
`
`these third parties, in this District and elsewhere in the United States, through its manufacture and
`
`sale of the infringing products, and through its creation and dissemination of promotional and
`
`marketing materials, supporting materials, instructions, product manuals, and/or technical
`
`11
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`Case 6:21-cv-01045 Document 1 Filed 10/06/21 Page 12 of 20
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`information relating to the products with knowledge and the specific intent that its efforts will
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`result in the direct infringement of the ’343 Patent by these third parties.
`
`44.
`
`Such active steps include, for example, advertising and marketing the infringing
`
`products to resellers, wireless carriers, and consumers, obtaining FCC approval for such devices
`
`to be utilized in the United States, and distributing and selling such devices to consumers and
`
`resellers knowing that they would be marketed, offered for sale, and used in the United States.
`
`Google touts that Pixel 5 “phones work with 5G networks” and, specifically, with both “mmWave
`
`& Sub-6” 5G networks.11 Further, Google’s website informs consumers that “A 5G icon in your
`
`status bar shows when your phone is within an area where 5G service is available.”12
`
`45.
`
`Google user guides for the accused products likewise facilitate infringement,
`
`instructing consumers about, among other things, how to “[c]onnect to mobile networks on a Pixel
`
`phone.”13 By instructing third parties to turn on and use the accused products for infringing
`
`purposes, such as to make and receive calls using the products’ antenna modules, Google
`
`knowingly induces these third parties to commit infringing acts.
`
`46.
`
`In addition, Google has indirectly infringed and continues to indirectly infringe the
`
`’343 Patent as a contributory infringer in violation of 35 U.S.C. § 271(c) by selling or offering to
`
`sell in the United States, or importing into the United States, infringing products with knowledge
`
`that they are especially designed or adapted to operate in a manner that infringes the ’343 Patent
`
`and despite the fact that the infringing technology is not a staple article of commerce suitable for
`
`substantial non-infringing use. Google knowingly incorporates antenna modules with the
`
`
`11 Pixel Phone Help, Understand 5G network compatibility & roaming on Pixel phones (accessed
`Oct. 5, 2021), available at: https://support.google.com/pixelphone/answer/10082009?hl=en.
`12 Id.
`13 Pixel Phone Help, Connect to mobile networks on a Pixel phone (accessed Oct. 5, 2021),
`available at: https://support.google.com/pixelphone/answer/2926415?hl=en.
`
`12
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`Case 6:21-cv-01045 Document 1 Filed 10/06/21 Page 13 of 20
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`
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`infringing HG11-PG660-200 RF die into the accused Google products such that they operate in an
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`infringing manner. By incorporating such antenna modules into its products, Google contributes
`
`to infringing use as consumers make and receive calls using the antennas of the accused products,
`
`which lack substantially non-infringing uses because the accused products are designed and
`
`manufactured to operate as phones in a manner that infringes the ’343 Patent.
`
`COUNT TWO
`INFRINGEMENT OF U.S. PATENT NO. 8,947,164
`
`47.
`
`Plaintiff repeats and incorporates by reference each preceding paragraph as if fully
`
`set forth herein and further states:
`
`48.
`
`Google has infringed and continues to infringe at least claim 1 of the ’164 Patent in
`
`violation of 35 U.S.C. § 271, either literally or through the doctrine of equivalents, by making,
`
`using, selling, or offering for sale in the United States, and/or importing into the United States,
`
`without authorization, products that practice at least claim 1 of the ’164 Patent. Google is liable
`
`for its infringement of the ’164 Patent pursuant to 35 U.S.C. § 271(a), (b), and (c).
`
`49. More specifically, Google designs, manufactures, assembles, imports, offers for
`
`sale, and/or sells mobile devices that incorporate the Qualcomm SDR865 transceiver and
`
`QPM5670 front-end module, and/or other components, which infringe at least independent claim
`
`1 of the ’164 Patent.
`
`50.
`
`For example, the SDR865 transceiver and QPM5670 front-end module come
`
`preinstalled in certain Google mobile devices, including the Pixel 5. Figure 3 identifies these
`
`components in the Pixel 5.
`
`13
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`Case 6:21-cv-01045 Document 1 Filed 10/06/21 Page 14 of 20
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`FIGURE 3
`
`QPM5670 
`
`SDR865 
`
`
`
`
`
`Source: Tech Insights.
`
`51.
`
`Claim 1 is illustrative of the ’164 Patent. It recites “[a] power amplifier with power
`
`detection, comprising: a radio frequency (RF) power amplifier having a gain stage that includes a
`
`gain stage input, a gain stage output, and a feedback loop coupled between an input and an output
`
`of the power amplifier; a detection circuit having a first detection circuit input electrically coupled
`
`to the gain stage input an d having a detection circuit output; an amplitude control circuit and a
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`phase control circuit electrically coupled together in series between the gain stage output and a
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`second detection circuit input; wherein the amplitude control circuit and the phase control circuit
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`produce a signal received by the second detection circuit input so that the detection circuit detects
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`a signal at the output of the detection circuit that has a power proportional to a forward power
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`output of the power amplifier.”
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`52.
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`The SDR865 transceiver and QPM5670 front-end module, as installed by Google
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`14
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`Case 6:21-cv-01045 Document 1 Filed 10/06/21 Page 15 of 20
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`in at least the Pixel 5, meet every element of this claim.14
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`53.
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`A power amplifier is present in the QPM5670 with power detection provided by
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`the SDR865. For example, the RX19 RF AFE identified below is part of a feedback receiver in
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`the SDR865 that carries out a power detection function.
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`FIGURE 4
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`
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`54.
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`The QPM5670 front-end module contains a radio frequency (RF) power amplifier
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`having a gain stage that includes a gain stage input and a gain stage output. A feedback loop is
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`coupled between an input and an output of the power amplifier.
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`14 This description of infringement is illustrative and not intended to be an exhaustive or limiting
`explanation of every manner in which Google’s products infringe the ’164 Patent.
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`15
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`Case 6:21-cv-01045 Document 1 Filed 10/06/21 Page 16 of 20
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`55.
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`The SDR865 contains a detection circuit having a first detection circuit input
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`electrically coupled to the gain stage input and having a detection circuit output. For example, the
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`gain stage input of the power amplifier in the QPM5670 is electrically coupled to a first detection
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`circuit input in the SDR865.
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`56.
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`The SDR865 and QPM5670 also contain an amplitude control circuit and a phase
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`control circuit electrically coupled together in series between the gain stage output and a second
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`detection circuit input. The phase control circuit consists of an inductor and a capacitor in series
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`with a low noise amplifier acting as an amplitude control circuit.
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`57.
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`The amplitude control circuit and the phase control circuit produce a signal received
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`by the second detection circuit input so that the detection circuit detects a signal at the output of
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`the detection circuit that has a power proportional to a forward power output of the power
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`amplifier. For example, the amplitude and phase control circuit produce a signal that is received
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`into the mixer of the detection circuit (second input). The mixer also receives a LO signal (first
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`input) and the result is used to estimate the forward power output of the power amplifier in the
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`front-end module.
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`58.
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`Google makes, uses, imports, offers for sale, and/or sells mobile devices that
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`incorporate the infringing combination of SDR865 and QPM5670 components, and/or others that
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`perform in substantially equivalent manners, including the Pixel 5.
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`59.
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`Google has imported and sold, and continues to sell and offer for sale, these mobile
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`devices in the United States, including through Google websites (store.google.com) and Google
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`authorized retailers in the Western District of Texas.
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`60.
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`Google committed and is committing the foregoing infringing activities without
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`license from Arigna. Google’s acts of infringement have damaged Arigna, as owner and assignee
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`16
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`Case 6:21-cv-01045 Document 1 Filed 10/06/21 Page 17 of 20
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`of the ’164 Patent. Arigna is entitled to recover from Google the damages it has sustained as a
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`result of Google’s wrongful acts in an amount subject to proof at trial. Google’s infringement of
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`Arigna’s rights under the ’164 Patent will continue to damage Arigna.
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`61.
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`Beginning no later than the filing of this Complaint, Google has had actual
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`knowledge of the ’164 Patent. Google’s continued infringement following the filing of this
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`Complaint, despite its knowledge of the ’164 Patent and Arigna’s infringement allegations, is
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`intentional and deliberate and willful.
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`62.
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`In addition, Google indirectly infringed, and continues to indirectly infringe, the
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`’164 Patent by actively inducing its infringement in violation 35 U.S.C. § 271(b).
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`63.
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`Google’s authorized retailers, such as Best Buy, and wireless carriers, such as
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`Verizon, directly infringe the ’164 Patent by selling the accused Google devices to consumers.
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`Consumers directly infringe the ’164 Patent by using the accused Google devices.
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`64.
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`Google knowingly induced and induces these acts of infringement with the specific
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`intent to encourage them by taking active steps to encourage and facilitate direct infringement by
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`these third parties, in this District and elsewhere in the United States, through its manufacture and
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`sale of the infringing products, and through its creation and dissemination of promotional and
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`marketing materials, supporting materials, instructions, product manuals, and/or technical
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`information relating to the products with knowledge and the specific intent that its efforts will
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`result in the direct infringement of the ’164 Patent by these third parties.
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`65.
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`Such active steps include, for example, advertising and marketing the infringing
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`products to resellers, wireless carriers, and consumers, obtaining FCC approval for such devices
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`to be utilized in the United States, and distributing and selling such devices to consumers and
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`resellers knowing that they would be marketed, offered for sale, and used in the United States.
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`17
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`Case 6:21-cv-01045 Document 1 Filed 10/06/21 Page 18 of 20
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`Google user guides for the accused products facilitate infringement, instructing consumers about,
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`among other things, “turn your phone on and off with the top button on the right side.”15 By
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`instructing third parties to turn on and use the accused products, Google knowingly induces these
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`third parties to commit infringing acts as the power detection functions of the infringing products
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`operate.
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`66.
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`In addition, Google has indirectly infringed and continues to indirectly infringe the
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`’164 Patent as a contributory infringer in violation of 35 U.S.C. § 271(c) by selling or offering to
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`sell in the United States, or importing into the United States, infringing products with knowledge
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`that they are especially designed or adapted to operate in a manner that infringes the ’164 Patent
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`and despite the fact that the infringing technology is not a staple article of commerce suitable for
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`substantial non-infringing use. Google knowingly incorporates specific transceivers and front-end
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`modules into the accused products such that they operate in an infringing manner. By incorporating
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`such devices into its products, Google contributes to infringing use as consumers turn on and use
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`the accused products, which lack substantially non-infringing uses because the accused products
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`are designed and manufactured to operate as smart