Case 6:22-cv-01162-ADA Document 51 Filed 05/25/23 Page 1 of 24
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`UNITED STATES DISTRICT COURT
`WESTERN DISTRICT OF TEXAS
`WACO DIVISION
`
`
`
` Plaintiff,
`
`PARKERVISION, INC.,
`
`
`
` v.
`
`REALTEK SEMICONDUCTOR CORP.,
`
`
`Defendant.
`
` Case No. 6:22-cv-01162-ADA
`
` JURY TRIAL DEMANDED
`
`AMENDED COMPLAINT FOR PATENT INFRINGEMENT
`
`Plaintiff ParkerVision, Inc. (“ParkerVision”), by and through its undersigned counsel,
`
`files this Amended Complaint against Defendant Realtek Semiconductor Corp. (“Realtek” or
`
`“Defendant”) for patent infringement of United States Patent Nos. 6,049,706; 6,266,518;
`
`7,292,835; and 8,660,513 (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.
`
`3.
`
`On information and belief, Realtek is a foreign corporation organized and existing
`
`under the laws of Taiwan with a place of business located at No. 2, Innovation Road II, Hsinchu
`
`Science Park, Hsinchu 300, Taiwan.
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`

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`Case 6:22-cv-01162-ADA Document 51 Filed 05/25/23 Page 2 of 24
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`4.
`
`According to Realtek, “Realtek Semiconductor Corporation is a world-leading IC
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`provider that designs and develops a wide range of IC products for connected media,
`
`communications network, computer peripheral, and multimedia applications.”
`
`https://www.realtek.com/en/press-room/news-releases/item/realtek-to-announce-full-range-of-
`
`communications-network-multimedia-and-consumer-electronics-solutions-at-2022-ces.
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`https://www.realtek.com/images/ar/-2021__20220518.pdf at page 69.
`
`5.
`
`Moreover, according to Realtek, “Realtek Semiconductor Corporation . . . was
`
`incorporated on October 21, 1987, and debuted on the Taiwan Stock Exchange in October 1998.
`
`It is headquartered in Taiwan and it has sales or R&D teams in China, Singapore, the United
`
`States, Japan, and South Korea.” https://www.realtek.com/images/ar/-2021__20220518.pdf at
`
`page 4.
`
`6.
`
`In Realtek’s 2021 Annual Report, Realtek lists wholly-owned affiliates that are
`
`registered in the United States, specifically, Cortina Access, Inc. and Ubilinx Technology Inc.
`
`2
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`

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`Case 6:22-cv-01162-ADA Document 51 Filed 05/25/23 Page 3 of 24
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`https://www.realtek.com/images/ar/-2021__20220518.pdf at pages 107-108.
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`7.
`
`On information and belief, Realtek has designed, manufactured, and/or sold
`
`Realtek Wi-Fi/802.11/Bluetooth chips (“Wi-Fi chips”) in the United States and that are found in
`
`products sold in the United States. https://www.realtek.com/images/ar/-2021__20220518.pdf at
`
`pages 70, 84; https://www.realtek.com/images/ar/-__.pdf at pages 67, 70, 79-80.
`
`8.
`
`On information and belief, Realtek sells Wi-Fi chips to its customers knowing
`
`those chips will be incorporated into products imported and/or sold in the United States.
`
`9.
`
`For example, on information and belief, Realtek provides its customers with Wi-
`
`Fi chips for televisions to be sold in the United States.
`
`3
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`

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`Case 6:22-cv-01162-ADA Document 51 Filed 05/25/23 Page 4 of 24
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`https://www.realtek.com/images/ar/-2021__20220518.pdf at page 78.
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`10.
`
`Realtek Wi-Fi chips are found in televisions sold in the United States including by
`
`TCL and LG.
`
`11.
`
`For example, the Realtek RTL8812BU is found in TCL television model no.
`
`43S425.
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`4
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`

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`Case 6:22-cv-01162-ADA Document 51 Filed 05/25/23 Page 5 of 24
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`12.
`
`On information and belief, Realtek’s RTL8812BU chip is found in other TCL
`
`televisions sold in the United States including, without limitation, the television models shown
`
`below.
`
`TV Model No.
`65S427
`43S423
`55S426
`75Q825
`65R625
`55S427
`55R625
`43S525
`65S525
`55S525
`55S423
`43S421
`50S525
`50S423
`65S423
`75S425
`75R615
`32S301
`55S421
`32S325
`
`FCC ID
`W8U65S427
`W8U43S423
`W8U55S426
`W8U75Q825
`W8U65R625
`W8U55S427
`W8U55R625
`W8U43S525
`W8U65S525
`W8U55S525
`W8U55S423
`W8U43S421
`W8U50S525
`W8U50S423
`W8U65S423
`W8U75S425
`W8U75R615
`W8U32S301
`W8U55S421
`W8U32S325
`
`5
`
`

`

`Case 6:22-cv-01162-ADA Document 51 Filed 05/25/23 Page 6 of 24
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`49S325
`43S325
`40S325
`32S327
`32S425
`50S425
`49S425
`32S321
`65S425
`55S425
`49S403
`65S401
`43S403
`55S401
`65S517
`55S517
`65R613
`55R613
`49S517
`43S517
`75C807
`49S303
`43S303
`40S303
`28S303
`32S303
`55C807
`65C807
`
`W8U49S325
`W8U43S325
`W8U40S325
`W8U32S327
`W8U43S425
`W8U50S425
`W8U49S425
`W8U32S321
`W8U65S425
`W8U55S425
`W8U49S403
`W8U65S401
`W8U43S403
`W8U55S401
`W8U65S517
`W8U55S517
`W8U65R613
`W8U55R613
`W8U49S517
`W8U43S517
`W8U75C807
`W8U49S303
`W8U43S303
`W8U40S303
`W8U28S303
`W8U32S303
`W8U55C807
`W8U65C807
`
`13.
`
`On information and belief, the LG model LGSWFAC81 wireless module, which
`
`is identified by the FCC ID number BEJLGSWFAC81, includes Realtek’s RTL8812BU chip.
`
`6
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`

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`Case 6:22-cv-01162-ADA Document 51 Filed 05/25/23 Page 7 of 24
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`https://fccid.io/BEJLGSWFAC81/Users-Manual/Users-Manual-3587629.
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`https://fccid.io/BEJLGSWFAC81/Internal-Photos/Internal-Photos-3585492.
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`14.
`
`On information and belief, the following LG television models contain the
`
`LGSWFAC81 module and Realtek’s RTL8812BU chip: 43UM6900PUA, 49UM6900PUA,
`
`55UM6900PUA, 65UM6900PUA, 43UM6950DUB, 49UM6950DUB, 55UM6950DUB,
`
`7
`
`

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`Case 6:22-cv-01162-ADA Document 51 Filed 05/25/23 Page 8 of 24
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`60UM6900PUA, 60UM6950DUB, 65UM6950DUB, 55UM6910PUC, 49LK5700PUA,
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`49LK5700BUA, 43LK5700PUA, 43LK5700BUA, 32LK610PUA.
`
`15.
`
`On information and belief, at CES 2020 and 2022 in Las Vegas, Nevada, Realtek
`
`exhibited, demonstrated, and used a number of products containing Realtek Wi-Fi chips.
`
`https://www.realtek.com/en/press-room/news-releases/item/realtek-to-demonstrate-full-range-of-
`
`connectivity-multimedia-and-consumer-electronics-solutions-at-2020-ces;
`
`https://www.realtek.com/en/press-room/news-releases/item/realtek-to-announce-full-range-of-
`
`communications-network-multimedia-and-consumer-electronics-solutions-at-2022-ces. On
`
`information and belief, Realtek (or those acting on its behalf) sold, offered for sale and imported
`
`these products into the United States.
`
`16.
`
`On information and belief, Realtek sells and/or offers to sell Wi-Fi chips to
`
`United States customers (e.g., HP Inc.) for incorporating into devices e.g. laptop computers. See,
`
`e.g., https://fccid.io/B94RTL; https://support.hp.com/us-en/document/c06624389.
`
`17.
`
`On information and belief, Realtek provides technical support for United States
`
`customers to incorporate Realtek Wi-Fi chips into devices.
`
`18.
`
`On information and belief, Realtek sells, offers to sell, provides, exports and/or
`
`transfers in and to the United States Realtek Wi-Fi chips to its wholly-owned affiliates Cortina
`
`Access, Inc. and Ubilinx Technology Inc.
`
`JURISDICTION AND VENUE
`
`19.
`
`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.
`
`8
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`

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`Case 6:22-cv-01162-ADA Document 51 Filed 05/25/23 Page 9 of 24
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`20.
`
`Realtek 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.
`
`21.
`
`This Court has personal jurisdiction over Realtek because Realtek 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 Realtek because,
`
`inter alia, Realtek, on information and belief, has substantial, continuous, and systematic
`
`business contacts in this judicial district, and derives substantial revenue from goods provided to
`
`individuals in this judicial district.
`
`22.
`
`Realtek has purposefully availed itself of the privileges of conducting business
`
`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 Complaint arise out of or are related to one or more
`
`of the foregoing activities.
`
`23.
`
`This Court has personal jurisdiction over Realtek because Realtek (directly and/or
`
`through its subsidiaries, affiliates, intermediaries, or customers) 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, Realtek (directly and/or through its subsidiaries, affiliates,
`
`intermediaries, or customers) uses, sells, offers for sale, imports, advertises, and/or otherwise
`
`promotes infringing products (receiver, transmitter, and/or transceiver integrated circuits (e.g.,
`
`chips for use in wireless devices)) in the United States, the State of Texas, and this judicial
`
`district. The infringing products include, without limitation, the Realtek RTL8812BU (“Realtek
`
`Chips”).
`
`9
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`

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`Case 6:22-cv-01162-ADA Document 51 Filed 05/25/23 Page 10 of 24
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`24.
`
`Customers can purchase TCL televisions containing Realtek Chips at brick-and-
`
`mortar stores located in this judicial district. For example, and as illustrated below, customers
`
`can order TCL televisions, including the TCL TV Model No. 40S325 (which includes the
`
`RTL8812BU) (indicated by the yellow box (below)), for in-store pickup at the Best Buy in
`
`Waco, Texas (indicated by the red box (below)).
`
`https://www.bestbuy.com/site/tcl-40-class-3-series-led-full-hd-smart-roku-
`
`tv/6302321.p?skuId=6302321.
`
`10
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`

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`https://www.bestbuy.com/site/searchpage.jsp?_dyncharset=UTF-
`
`8&browsedCategory=pcmcat1526935930973&cp=2&id=pcat17071&iht=n&ks=960&list=y&sc
`
`=Global&st=pcmcat1526935930973_categoryid%24abcat0101001&type=page&usc=All%20Cat
`
`egories.
`
`25.
`
`On information and belief, Realtek has known of and has had notice of the
`
`patents-in-suit and ParkerVision’s accused infringement of Realtek Chips since at least as early
`
`as October 12, 2020 when ParkerVision filed suit against TCL in ParkerVision v. TCL
`
`Industries Holdings Co., Ltd., et al., 6:20-cv-00945 (ADA).
`
`26.
`
`On information and belief, Realtek knew or should have known that its chips
`
`would be incorporated into products (such as the televisions identified above) that would be
`
`11
`
`

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`Case 6:22-cv-01162-ADA Document 51 Filed 05/25/23 Page 12 of 24
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`used, sold, offered for sale, and/or imported in the United States, the State of Texas, and this
`
`judicial district. Realtek intended that its products be sold in the United States and affirmatively
`
`directed its products to the United States market including, without limitation, through its
`
`customers and distributors. See, e.g., https://www.realtek.com/en/contact-us-en/cu-3-en-
`
`2/category/42-12-en-3.
`
`27.
`
`On information and belief, Realtek targets the United States market and has
`
`purposefully availed itself of doing business in the United States. On information and belief,
`
`Realtek conducts business with U.S. companies for the purpose of incorporating its products into
`
`products sold in the United States, has sought authorization from the FCC to sell its products in
`
`the United States (including, without limitation, the Realtek Chips – see https://fccid.io/TX2),
`
`and has presented products for sale and distribution in the United States at the Consumer
`
`Electronics Show in Nevada.
`
`28.
`
`This case is related to at least the following cases before this Court and involves
`
`common patents and products: ParkerVision, Inc. v. TCL Industries Holdings Co., Ltd., et al.,
`
`6:20-CV-00945, and ParkerVision, Inc. v. LG Electronics, Inc. 6:21-CV-00520 (W.D. Tex).
`
`29.
`
`Realtek has been involved in a number of litigations in this judicial district
`
`including against Bandspeed, LLC; Rock Creek Networks, LLC; and Future Link Systems, LLC.
`
`30.
`
`Venue is proper in this judicial district under 28 U.S.C. §§ 1391(b)-(d) and/or
`
`1400(b) at least because Realtek is a foreign corporation subject to personal jurisdiction in this
`
`judicial district and has committed acts of infringement within this judicial district giving rise to
`
`this action.
`
`PARKERVISION
`
`12
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`Case 6:22-cv-01162-ADA Document 51 Filed 05/25/23 Page 13 of 24
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`31.
`
`In 1989, Jeff Parker and David Sorrells started ParkerVision in Jacksonville,
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`Florida. Through the mid-1990s, ParkerVision focused on developing commercial video
`
`cameras, e.g., for television broadcasts. The cameras used radio frequency (RF) technology to
`
`automatically track the camera’s subject.
`
`32. When developing consumer video cameras, however, ParkerVision, encountered
`
`a problem – the power and battery requirements for RF communications made a cost effective,
`
`consumer-sized product impractical. So, Mr. Sorrells and ParkerVision’s engineering team began
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`researching ways to solve this problem.
`
`33.
`
`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.
`
`34.
`
`From 1995 through 1998, ParkerVision engineers developed an innovative
`
`method of RF direct conversion by a process of sampling a RF carrier signal and transferring
`
`energy to create a down-converted baseband signal.
`
`35.
`
`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 be built smaller, cheaper and
`
`with greater improved performance.
`
`36.
`
`ParkerVision’s innovations did not stop there. ParkerVision went on to develop
`
`additional RF down-conversion technologies, RF up-conversion technologies and other related
`
`direct-conversion technologies. ParkerVision also developed complementary wireless
`
`communications technologies that involved interactions, processes, and controls between the
`
`baseband processor and the transceiver, which improved and enhanced the operation of
`
`13
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`Case 6:22-cv-01162-ADA Document 51 Filed 05/25/23 Page 14 of 24
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`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.
`
`37.
`
`ParkerVision’s technology helped make today’s wireless devices, such as
`
`televisions, a reality by enabling RF chips used in these devices to be smaller, cheaper, and more
`
`efficient, and with higher performance.
`
`38.
`
`ParkerVision sold products. To the extent ParkerVision products needed to be
`
`marked with a ParkerVision patent number, ParkerVision marked those products in compliance
`
`with 35 U.S.C. § 287.
`
`THE ASSERTED PATENTS
`
`United States Patent No. 6,049,706
`
`39.
`
`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.
`
`40.
`
`41.
`
`42.
`
`The ’706 patent is presumed valid under 35 U.S.C. § 282.
`
`ParkerVision owns all rights, title, and interest in the ’706 patent.
`
`United States Patent No. 6,266,518
`
`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.
`
`43.
`
`44.
`
`The ’518 patent is presumed valid under 35 U.S.C. § 282.
`
`ParkerVision owns all rights, title, and interest in the ’518 patent.
`
`14
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`Case 6:22-cv-01162-ADA Document 51 Filed 05/25/23 Page 15 of 24
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`United States Patent No. 7,292,835
`
`45.
`
`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.
`
`46.
`
`47.
`
`48.
`
`The ’835 patent is presumed valid under 35 U.S.C. § 282.
`
`ParkerVision owns all rights, title, and interest in the ’835 patent.
`
`United States Patent No. 8,660,513
`
`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.
`
`50.
`
`The ’513 patent is presumed valid under 35 U.S.C. § 282.
`
`ParkerVision owns all rights, title, and interest in the ’513 patent.
`
`CLAIMS FOR RELIEF
`
`COUNT I - Infringement of United States Patent No. 6,049,706
`
`51.
`
`The allegations set forth above are re-alleged and incorporated by reference as if
`
`they were set forth fully here.
`
`52.
`
`Realtek directly infringes (literally and/or under the doctrine of equivalents) the
`
`’706 patent by using, selling, offering for sale, and/or importing in/into the United States
`
`products covered by at least claim 19 of the ’706 patent. Realtek infringes each step of claim 19
`
`because the Realtek Chips automatically, and without user modification, perform each of the
`
`claimed steps.
`
`15
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`53.
`
`On information and belief, Realtek products that infringe by at least claim 19 of
`
`the ’706 patent include, but are not limited to, the Realtek Chips and any other Realtek device
`
`that is capable of filtering and down-converting an input signal as claimed in the ’706 patent. On
`
`information and belief, Realtek uses the Realtek Chips at least by demonstrating and testing (or
`
`having others on its behalf demonstrate and test, including without limitation HP Inc. and other
`
`U.S. customers, as well as Cortina Access, Inc. and Ubilinx Technology Inc.) the Realtek Chips
`
`in the United States.
`
`54.
`
`On information and belief, each Realtek Chip performs a method of filtering and
`
`down-converting an input signal (e.g., a radio frequency (RF) signal at a transmission
`
`frequency). The method is performed on the receiver side of each Realtek Chip.
`
`55.
`
`On information and belief, each Realtek Chips filters and down-converts an input
`
`signal in an integrated manner using a switch (e.g., one or more transistor(s)), capacitor(s), and
`
`low impedance load (e.g., one or more resistors). On information and belief, a down-converted
`
`signal (e.g., a baseband signal) is formed from energy from a transistor(s) when the transistor(s)
`
`is ON and energy from a capacitor(s) when the transistor(s) is OFF.
`
`56.
`
`On information and belief, each Realtek Chip tunes at least one of the filtering
`
`operation and down-converting operation (e.g., the Realtek Chip selects components/adjusts
`
`component values).
`
`57.
`
`On information and belief, a transistor(s) in each Realtek Chip under-samples
`
`(e.g., at a sample rate below the Nyquist rate) the input signal according to a control signal (e.g.,
`
`local oscillator (LO) signal). The frequency of the control signal is equal to a frequency of the
`
`input signal plus or minus a frequency of a down-converted image, divided by n, where n
`
`represents a harmonic or sub-harmonic of the input signal.
`
`16
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`Case 6:22-cv-01162-ADA Document 51 Filed 05/25/23 Page 17 of 24
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`58.
`
`ParkerVision has been damaged by the direct infringement of Realtek 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
`
`59.
`
`The allegations set forth above are re-alleged and incorporated by reference as if
`
`they were set forth fully here.
`
`60.
`
`Realtek directly infringes (literally and/or under the doctrine of equivalents) the
`
`’518 patent by using, selling, offering for sale, and/or importing in/into the United States
`
`products covered by at least claim 27 of the ’518 patent. Realtek infringes each step of claim 27
`
`because the Realtek Chips automatically, and without user modification, performed each of the
`
`claimed steps.
`
`61.
`
`On information and belief, Realtek products that infringe at least claim 27 of the
`
`’518 patent include, but are not limited to, the Realtek Chips, and any other Realtek device that is
`
`capable of down-converting a carrier signal to a baseband signal as claimed in the ’518 patent.
`
`On information and belief, Realtek uses the Realtek Chips at least by demonstrating and testing
`
`(or having others on its behalf demonstrate and test, including without limitation HP Inc. and
`
`other U.S. customers, as well as Cortina Access, Inc. and Ubilinx Technology Inc.) the Realtek
`
`Chips in the United States.
`
`62.
`
`On information and belief, the Realtek Chips perform a method of down-
`
`converting a carrier signal (e.g., an RF signal at a transmission frequency) to a baseband signal.
`
`The method is performed on the receiver side of each Realtek Chip.
`
`63.
`
`On information and belief, each Realtek Chip receives a carrier signal that
`
`includes at least one of amplitude variations, phase variations, or frequency variations at a
`
`17
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`Case 6:22-cv-01162-ADA Document 51 Filed 05/25/23 Page 18 of 24
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`frequency lower than a carrier frequency of the carrier signal (e.g., a modulated carrier signal,
`
`such as a quadrature amplitude modulation (QAM) signal). The carrier signal includes a
`
`baseband signal that has been imparted on the carrier signal.
`
`64.
`
`On information and belief, each Realtek Chip samples the carrier signal by a
`
`transistor(s) turning ON and OFF. The sampling occurs over aperture periods (e.g., periods of
`
`time when the transistor(s) is ON/receives an LO signal) to transfer energy from the carrier
`
`signal at an aliasing rate, which is determined according to a frequency of the carrier signal
`
`divided by N, wherein N indicates a harmonic or sub-harmonic of the carrier signal.
`
`65.
`
`On information and belief, a capacitor(s) in each Realtek Chip integrates energy
`
`from a transistor(s) over the aperture periods (e.g., when the transistor(s) is ON).
`
`66.
`
`On information and belief, each Realtek Chip generates a baseband signal
`
`including from the integrated energy that comes from a capacitor(s) when the transistor(s) is
`
`OFF.
`
`67.
`
`On information and belief, a capacitor(s) in each Realtek Chip transfers energy to
`
`a load (e.g., one or more resistors) during an off-time (e.g., when the transistor(s) is OFF).
`
`68.
`
`ParkerVision has been damaged by the direct infringement of Realtek and is
`
`suffering and will continue to suffer irreparable harm and damages as a result of this
`
`infringement.
`
`COUNT III - Infringement of United States Patent No. 7,292,835
`
`69.
`
`The allegations set forth above are re-alleged and incorporated by reference as if
`
`they were set forth fully here.
`
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`Case 6:22-cv-01162-ADA Document 51 Filed 05/25/23 Page 19 of 24
`
`70.
`
`Realtek directly infringes (literally and/or under the doctrine of equivalents) the
`
`’835 patent by using, selling, offering for sale, and/or importing in/into the United States
`
`products covered by at least claims 1 and 17 of the ’835 patent.
`
`71.
`
`On information and belief, Realtek products that infringe one or more claims of
`
`the ’835 patent include the Realtek Chips and any other Realtek device used e.g., in televisions
`
`(“Realtek TV Chips”) that is capable of down-converting a higher-frequency signal to a lower-
`
`frequency signal as claimed in the ’835 patent. On information and belief, Realtek uses the
`
`Realtek Chips at least by demonstrating and testing (or having others on its behalf demonstrate
`
`and test, including without limitation HP Inc. and other U.S. customers, as well as Cortina
`
`Access, Inc. and Ubilinx Technology Inc.) the Realtek Chips in the United States.
`
`72.
`
`The Realtek TV Chips used in televisions enable users to watch live TV and on
`
`demand programming from their cable service providers over a wireless network. For example,
`
`some of the Realtek TV Chips provide wireless connectivity for televisions, such as TCL and LG
`
`televisions. The Realtek TV Chips are configured to function/capable of functioning as wireless
`
`cable modems. For example, the Realtek TV Chips provide a wireless connection to cable
`
`services.
`
`73.
`
`On information and belief, each Realtek TV Chip is/includes a cable modem (e.g.,
`
`wireless modem for communicating with a cable television network) for down-converting an
`
`electromagnetic signal (e.g., a high frequency RF signal), having complex modulations (e.g.,
`
`QAM), to a lower frequency signal. The electromagnetic signal is transmitted by a wireless
`
`method to the cable modem.
`
`74.
`
`Each Realtek TV Chip has (a) an oscillator (e.g., LO) to generate an in-phase
`
`oscillating signal (e.g., in-phase LO signal), (b) a phase shifter (e.g., a flip-flop) to receive the in-
`
`19
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`Case 6:22-cv-01162-ADA Document 51 Filed 05/25/23 Page 20 of 24
`
`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.
`
`75.
`
`On information and belief, the first frequency down-conversion module includes a
`
`first frequency translation module (e.g., a module having one or more switches) 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.
`
`76.
`
`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.
`
`77.
`
`ParkerVision has been damaged by the direct infringement of Realtek and is
`
`suffering and will continue to suffer irreparable harm and damages as a result of this
`
`infringement.
`
`COUNT IV - Infringement of United States Patent No. 8,660,513
`
`78.
`
`The allegations set forth above are re-alleged and incorporated by reference as if
`
`they were set forth fully here.
`
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`Case 6:22-cv-01162-ADA Document 51 Filed 05/25/23 Page 21 of 24
`
`79.
`
`Realtek directly infringes (literally and/or under the doctrine of equivalents) the
`
`’513 patent by using, selling, offering for sale, and/or importing in/into the United States
`
`products covered by at least claim 19 of the ’513 patent.
`
`80.
`
`On information and belief, Realtek products that infringe one or more claims of
`
`the ’513 patent include, but are not limited to, the Realtek Chips, and any other Realtek device
`
`that is capable of down-converting a higher-frequency signal to a lower-frequency signal as
`
`claimed in the ’513 patent. On information and belief, Realtek uses the Realtek Chips at least by
`
`demonstrating and testing (or having others on its behalf demonstrate and test, including without
`
`limitation HP Inc. and other U.S. customers, as well as Cortina Access, Inc. and Ubilinx
`
`Technology Inc.) the Realtek Chips in the United States.
`
`81.
`
`On information and belief, each Realtek Chip is/includes a system for frequency
`
`down-converting a modulated carrier signal (e.g., high frequency RF signal) to a lower frequency
`
`signal. Each Realtek Chip has (a) a first switch (e.g., one or more transistors), (b) a first control
`
`signal (e.g., LO signal) which comprises a sampling aperture (e.g., 25% duty cycle) with a
`
`specified frequency, and (c) a first energy storage element (e.g., one or more capacitors) that
`
`down-converts the modulated carrier signal according to the first control signal and outputs a
`
`down-converted in-phase signal portion of the modulated carrier signal.
`
`82.
`
`On information and belief, each Realtek Chip has (a) a second switch (e.g., one or
`
`more transistors), (b) a second control signal (e.g., LO signal) which comprises a sampling
`
`aperture (e.g., 25% duty cycle) with a specified frequency, and (c) a second energy storage
`
`element (e.g., one or more capacitors) that down-converts the modulated carrier signal (e.g., high
`
`frequency RF signal) according to the second control signal and outputs a down-converted
`
`inverted in-phase signal portion of the modulated carrier signal.
`
`21
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`Case 6:22-cv-01162-ADA Document 51 Filed 05/25/23 Page 22 of 24
`
`83.
`
`On information and belief, each Realtek Chip has a first differential amplifier
`
`circuit that combines the down-converted in-phase signal portion with the inverted in-phase
`
`signal portion and outputs a first channel down-converted differential in-phase signal.
`
`84.
`
`On information and belief, each Realtek Chip has (a) a third switch (e.g., one or
`
`more transistors), (b) a third control signal (e.g., LO signal) which comprises a sampling aperture
`
`(e.g., 25% duty cycle) with a specified frequency, and (c) a third energy storage element (e.g.,
`
`one or more capacitors) that down-converts the modulated carrier signal (e.g., high frequency RF
`
`signal) according to the third control signal and outputs a down-converted quadrature-phase
`
`signal portion of the modulated carrier signal.
`
`85.
`
`On information and belief, each Realtek Chip has (a) a fourth switch (e.g., one or
`
`more transistors), (b) a fourth aperture signal (e.g., LO signal), and (c) a fourth energy storage
`
`element (e.g., one or more capacitors) that down-converts the modulated carrier signal (e.g., high
`
`frequency RF signal) according to the fourth control signal and outputs a down-converted
`
`inverted quadrature-phase signal portion of the modulated carrier signal.
`
`86.
`
`On information and belief, each Realtek Chip has a second differential amplifier
`
`circuit that combines the down-converted quadrature-phase signal portion with the inverted
`
`quadrature-phase signal portion and outputs a second channel down-converted differential
`
`quadrature-phase signal.
`
`87.
`
`ParkerVision has been damaged by the direct infringement of Realtek and is
`
`suffering and will continue to suffer irreparable harm and damages as a result of this
`
`infringement.
`
`22
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`Case 6:22-cv-01162-ADA Document 51 Filed 05/25/23 Page 23 of 24
`
`JURY DEMANDED
`
`Pursuant to Rule 38(b) of the Federal Rules of Civil Procedure, ParkerVision hereby
`
`requests a trial by jury on all issues so triable.
`
`PRAYER FOR RELIEF
`
`WHEREFORE, ParkerVision respectfully requests that the Court enter judgment in its
`
`favor and against Realtek as follows:
`
`a.
`
`finding that Realtek directly infringes one or more claims of each of the patents-
`
`in-suit;
`
`b.
`
`awarding ParkerVision damages under 35 U.S.C. § 284, or otherwise permitted
`
`by law, including supplemental damages for any continued post-verdict
`
`infringement;
`
`c.
`
`awarding ParkerVision pre-judgment and post-judgment interest on the damages
`
`award and costs;
`
`d.
`
`awarding cost of this action (including all disbursements) and attorney fees
`
`pursuant to 35 U.S.C. § 285, or as otherwise permitted by the law; and
`
`e.
`
`awarding such other costs and further relief that the Court determines to be just
`
`and equitable.
`
`
`
`23
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`Case 6:22-cv-01162-ADA Document 51 Filed 05/25/23 Page 24 of 24
`
`THE MORT LAW FIRM, PLLC
`
`/s/Raymond W. Mort, III
`Raymond W. Mort, III
`Texas State Bar No. 00791308
`raymort@austinlaw.com
`501 Congress Avenue, Suite 150
`Austin, Texas 78701
`Tel/Fax: 512-865-7950
`
`
`Attorneys for Plaintiff ParkerVis