Case 4:23-cv-00789-ALM Document 1 Filed 09/01/23 Page 1 of 82 PageID #: 1
`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE EASTERN DISTRICT OF TEXAS
`SHERMAN DIVISION
`
`BELL NORTHERN RESEARCH, LLC,
`
`Plaintiff,
`
`Civil Action No. 4:23-cv-789
`
`v.
`
`AT&T INC., AT&T CORP., AT&T
`MOBILITY, LLC, AT&T SERVICES,
`INC., CRICKET WIRELESS LLC, and
`EMBLEM SOLUTIONS LLC
`
`Defendants.
`
`JURY TRIAL DEMANDED
`
`COMPLAINT FOR PATENT INFRINGEMENT
`
`Plaintiff Bell Northern Research, LLC (“BNR” or “Plaintiff”), for its Complaint against
`
`Defendant AT&T Inc., (“AT&T Inc.” or “Defendant”), Defendant AT&T Corp., (“AT&T Corp.”
`
`or “Defendant”), Defendant AT&T Mobility, LLC, (“AT&T Mobility” or “Defendant”), Defendant
`
`AT&T Services Inc., (“AT&T Services” or “Defendant”), Cricket Wireless LLC (“Cricket” or
`
`“Defendant”), and Emblem Solutions (“Emblem” or “Defendant”) (individually each a
`
`“Defendant” and collectively “Defendants”) for infringement of U.S. Patent Nos. 8,204,554,
`
`7,319,889, RE 48,629, 8,416,862, 7,564,914, 7,957,450, 6,941,156, 6,696,941, 7,039,435,
`
`6,963,129, 6,858,930, 8,396,072, and 8,792,432 (the “Asserted Patents”) alleges the following:
`
`NATURE OF THE ACTION
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`1. This is an action for patent infringement arising under the Patent Laws of the United
`
`States, 35 U.S.C. § 1 et seq.
`
`THE PARTIES
`
`2. Plaintiff BNR is a limited liability company organized under the laws of the State of
`
`Delaware with a place of business at 401 N. Michigan Ave., Suite 1630, Chicago, IL 60611.
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`

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`3. On information and belief, Defendant AT&T Inc. is a Delaware corporation with its
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`principal place of business at 208 S. Akard Street, Dallas, Texas, 75202. AT&T Inc.’s registered
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`agent for service is CT Corporation System, 1999 Bryan Street, Suite 900, Dallas, Texas 75201.
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`Upon information and belief, AT&T Inc. sells and offers to sell products and services throughout
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`the United States, including in this judicial district, and introduces products and services that into
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`the stream of commerce and that incorporate infringing technology knowing that they would be
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`sold in this judicial district and elsewhere in the United States.
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`4. On information and belief, Defendant AT&T Corp. is a New York corporation with a
`
`principal place of business at One AT&T Way, Bedminster, New Jersey 07921-0752. AT&T
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`Corp.’s registered agent for service is CT Corporation System, 28 Liberty Street, New York, New
`
`York, 10005. Upon information and belief, AT&T Corp. sells and offers to sell products and
`
`services throughout the United States, including in this judicial district, and introduces products and
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`services that into the stream of commerce and that incorporate infringing technology knowing that
`
`they would be sold in this judicial district and elsewhere in the United States.
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`5. On information and belief, Defendant AT&T Mobility is a Delaware limited liability
`
`company with its principal place of business at 5565 Glenridge Connector, Atlanta, Georgia 30349.
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`AT&T Mobility LLC’s registered agent for service is The Corporation Trust Company, located at
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`Corporation Trust Center, 1209 Orange Street, Wilmington, Delaware 19801. Upon information
`
`and belief, AT&T Mobility sells and offers to sell products and services throughout the United
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`States, including in this judicial district, and introduces products and services that into the stream of
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`commerce and that incorporate infringing technology knowing that they would be sold in this
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`judicial district and elsewhere in the United States.
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`6. On information and belief, Defendant AT&T Services is a corporation organized and
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`existing under the laws of the State of Delaware, with a principal place of business at 208 South
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`Akard Street, Dallas, Texas 75202. AT&T Services, Inc.’s registered agent for service is CT
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`Corporation System, located at 1999 Bryan Street, Suite 900, Dallas, Texas 75201. Upon
`
`information and belief, AT&T Services sells and offers to sell products and services throughout the
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`United States, including in this judicial district, and introduces products and services that into the
`
`stream of commerce and that incorporate infringing technology knowing that they would be sold in
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`this judicial district and elsewhere in the United States.
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`7. Upon information and belief, Cricket is a limited liability company organized and
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`existing under the laws of Delaware that maintains its principal place of business at 575 Morosgo
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`Dr NE, Atlanta, GA 30324. Cricket has as its registered agent for service: The Corporation Trust
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`Company, located at Corporation Trust Center, 1209 Orange Street, Wilmington, Delaware 19801.
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`Upon information and belief, Cricket sells and offers to sell products and services throughout the
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`United States, including in this judicial district, and introduces products and services that into the
`
`stream of commerce and that incorporate infringing technology knowing that they would be sold in
`
`this judicial district and elsewhere in the United States.
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`8. Upon information and belief, Emblem Solutions LLC is a limited liability company
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`organized and existing under the laws of Delaware that maintains its principal place of business at
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`2200 Century Parkway NE, Ste 250, Atlanta, GA 30345. Emblem has as its registered agent for
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`service: The Corporation Trust Company, located at Corporation Trust Center, 1209 Orange Street,
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`Wilmington, Delaware 19801. Upon information and belief, Emblem sells and offers to sell
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`products and services throughout the United States, including in this judicial district, and introduces
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`products and services that into the stream of commerce and that incorporate infringing technology
`
`knowing that they would be sold in this judicial district and elsewhere in the United States.
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`

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`Case 4:23-cv-00789-ALM Document 1 Filed 09/01/23 Page 4 of 82 PageID #: 4
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`JURISDICTION AND VENUE
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`9.
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`This is an action for patent infringement arising under the Patent Laws of the United
`
`States, Title 35 of the United States Code.
`
`10.
`
`11.
`
`12.
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`This Court has subject matter jurisdiction under 28 U.S.C. §§ 1331 and 1338(a).
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`Venue is proper in this judicial district under 28 U.S.C. §1400(b).
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`On information and belief, AT&T Inc. has committed acts of infringement in this
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`District and has a regular and established places of business within this District at 208 S. Akard
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`Street, Dallas, Texas, 75202, as well as at multitude of retail stores. See e.g.,
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`https://www.att.com/stores/texas/plano (showing 5 AT&T stores located in Plano, Texas).
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`13.
`
`On information and belief, AT&T Corp. has committed acts of infringement in this
`
`District.
`
`14.
`
`On information and belief, AT&T Mobility has committed acts of infringement in
`
`this District.
`
`15.
`
`On information and belief, AT&T Services has committed acts of infringement in
`
`this District.
`
`16.
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`On information and belief, Cricket has committed acts of infringement in this
`
`District and has regular and established places of business within this District at 1405 Jupiter Road,
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`Plano, TX 75074, and at 2400 K Ave, Ste F, Plano, TX 75074.
`
`17.
`
`On information and belief, Emblem has committed acts of infringement in this
`
`District.
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`18.
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`On information and belief, each Defendant is subject to this Court’s general and
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`specific personal jurisdiction because each Defendant has sufficient minimum contacts within the
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`State of Texas and this District, pursuant to due process and/or the Texas Long Arm Statute
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`because each Defendant purposefully availed itself of the privileges of conducting business in the
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`

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`State of Texas and in this District, because each Defendant regularly conducts and solicits business
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`within the State of Texas and within this District, and because Plaintiff’s causes of action arise
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`directly from each of Defendant’s business contacts and other activities in the State of Texas and
`
`this District.
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`19. This Court has personal jurisdiction over AT&T Inc. in this action because AT&T Inc. has
`
`committed acts of infringement within this District giving rise to this action, has a regular and
`
`established place of business in this District, and has established minimum contacts with this forum
`
`such that the exercise of jurisdiction over AT&T Inc. would not offend traditional notions of fair play
`
`and substantial justice. AT&T Inc., directly and/or through subsidiaries or intermediaries, conducts its
`
`business extensively throughout Texas, by shipping, distributing, offering for sale, selling, and
`
`advertising its products and/or services in the State of Texas and the Eastern District of Texas,
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`regularly does business or solicits business, engages in other persistent courses of conduct, and/or
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`derives substantial revenue from products and/or services provided to individuals in the State of
`
`Texas, and commits acts of infringement of Plaintiff’s patents in this District by, among other things,
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`making, using, importing, offering to sell, and selling products and/or services that infringe the
`
`asserted patents, including without limitation the tablets and phones accused of infringement in this
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`case and cellular services offered by AT&T Inc. on its network.
`
`20. AT&T Inc., directly and/or through subsidiaries or intermediaries, has purposefully and
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`voluntarily placed one or more products and/or services in the stream of commerce that practice the
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`Asserted Patents with the intention and expectation that they will be purchased and used by
`
`consumers in the Eastern District of Texas. These products and/or services have been and continue to
`
`be
`
`purchased
`
`and
`
`used
`
`in
`
`the Eastern District
`
`of Texas.
`
`
`
`See
`
`e.g.,
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`https://www.att.com/stores/texas/plano (showing 5 AT&T stores located in Plano, Texas).
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`

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`21. This Court has personal jurisdiction over AT&T Corp. in this action because AT&T Corp.
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`has committed acts of infringement within this District giving rise to this action, and has established
`
`minimum contacts with this forum such that the exercise of jurisdiction over AT&T Corp. would not
`
`offend traditional notions of fair play and substantial justice. AT&T Corp., directly and/or through
`
`subsidiaries or intermediaries, conducts its business extensively throughout Texas, by shipping,
`
`distributing, offering for sale, selling, and advertising its products and/or services in the State of Texas
`
`and the Eastern District of Texas, regularly does business or solicits business, engages in other
`
`persistent courses of conduct, and/or derives substantial revenue from products and/or services
`
`provided to individuals in the State of Texas, and commits acts of infringement of Plaintiff’s patents
`
`in this District by, among other things, making, using, importing, offering to sell, and selling products
`
`and/or services that infringe the asserted patents, including without limitation the tablets and phones
`
`accused of infringement in this case and cellular services offered by AT&T Corp. on its network.
`
`22. AT&T Corp., directly and/or through subsidiaries or intermediaries, has purposefully and
`
`voluntarily placed one or more products and/or services in the stream of commerce that practice the
`
`Asserted Patents with the intention and expectation that they will be purchased and used by
`
`consumers in the Eastern District of Texas. These products and/or services have been and continue to
`
`be purchased and used in the Eastern District of Texas.
`
`23. This Court has personal jurisdiction over AT&T Mobility in this action because AT&T
`
`Mobility has committed acts of infringement within this District giving rise to this action and has
`
`established minimum contacts with this forum such that the exercise of jurisdiction over AT&T
`
`Mobility would not offend traditional notions of fair play and substantial justice. AT&T Mobility,
`
`directly and/or through subsidiaries or intermediaries, conducts its business extensively throughout
`
`Texas, by shipping, distributing, offering for sale, selling, and advertising its products and/or services
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`in the State of Texas and the Eastern District of Texas, regularly does business or solicits business,
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`engages in other persistent courses of conduct, and/or derives substantial revenue from products
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`and/or services provided to individuals in the State of Texas, and commits acts of infringement of
`
`Plaintiff’s patents in this District by, among other things, making, using, importing, offering to sell,
`
`and selling products and/or services that infringe the asserted patents, including without limitation
`
`the tablets and phones accused of infringement in this case and cellular services offered by AT&T
`
`Mobility on its network.
`
`24. AT&T Mobility, directly and/or through subsidiaries or intermediaries, has purposefully
`
`and voluntarily placed one or more products and/or services in the stream of commerce that practice
`
`the Asserted Patents with the intention and expectation that they will be purchased and used by
`
`consumers in the Eastern District of Texas. These products and/or services have been and continue
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`to be purchased and used in the Eastern District of Texas.
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`25. This Court has personal jurisdiction over AT&T Services in this action because AT&T
`
`Services has committed acts of infringement within this District giving rise to this action, and has
`
`established minimum contacts with this forum such that the exercise of jurisdiction over AT&T
`
`Services would not offend traditional notions of fair play and substantial justice. AT&T Services,
`
`directly and/or through subsidiaries or intermediaries, conducts its business extensively throughout
`
`Texas, by shipping, distributing, offering for sale, selling, and advertising its products and/or services
`
`in the State of Texas and the Eastern District of Texas, regularly does business or solicits business,
`
`engages in other persistent courses of conduct, and/or derives substantial revenue from products
`
`and/or services provided to individuals in the State of Texas, and commits acts of infringement of
`
`Plaintiff’s patents in this District by, among other things, making, using, importing, offering to sell,
`
`and selling products and/or services that infringe the asserted patents, including without limitation
`
`the tablets and phones accused of infringement in this case and cellular services offered by AT&T
`
`Services on its network.
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`

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`26. AT&T Services, directly and/or through subsidiaries or intermediaries, has purposefully
`
`and voluntarily placed one or more products and/or services in the stream of commerce that practice
`
`the Asserted Patents with the intention and expectation that they will be purchased and used by
`
`consumers in the Eastern District of Texas. These products and/or services have been and continue to
`
`be purchased and used in the Eastern District of Texas.
`
`27. Cricket, directly and/or through subsidiaries or intermediaries, has purposefully and
`
`voluntarily placed one or more products and/or services in the stream of commerce that practice the
`
`Asserted Patents with the intention and expectation that they will be purchased and used by
`
`consumers in the Eastern District of Texas. These products and/or services have been and continue to
`
`be
`
`purchased
`
`and
`
`used
`
`in
`
`the
`
`Eastern District
`
`of
`
`Texas.
`
`See
`
`e.g.,
`
`https://www.cricketwireless.com/stores/site-map/US/TX/Plano.
`
`28. Emblem, directly and/or through subsidiaries or intermediaries, has purposefully and
`
`voluntarily placed one or more products and/or services in the stream of commerce that practice the
`
`Asserted Patents with the intention and expectation that they will be purchased and used by
`
`consumers in the Eastern District of Texas. These products and/or services have been and continue
`
`to
`
`be
`
`purchased
`
`and
`
`used
`
`in
`
`the
`
`Eastern District
`
`of
`
`Texas.
`
`See
`
`https://www.linkedin.com/company/emblem-solutions/about/ (explaining the Emblem “connects
`
`innovative mobile technologies to the marketing power of major brands providing ready-to-run sales
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`channels.”); see also https://emblemsolutions.com/products/ (“Through our partnerships, we bring a
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`new generation of nationally-branded phones to major markets.”)
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`
`
`BACKGROUND
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`29.
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`The Asserted Patents come from a rich pedigree dating back to the late 19th
`
`century. This is when Bell Labs sprang to life from the combined efforts of AT&T and Western
`
`Electric. Bell Labs is one of America’s greatest technology incubators, and paved the way for
`
`many technological advances we know and use today, including the transistor, several kinds of
`
`lasers, the UNIX operating system, and computer languages such as C++. In total, Bell Labs
`
`received nine Nobel Prizes for its work over the years.
`
`30.
`
`Eventually the Bell system broke up and spawned several new companies. They
`
`included telecommunications powerhouses Lucent and Agere Systems. Lucent was absorbed by
`
`Nokia, while Agere Systems was acquired by LSI, then Avago, and ultimately renamed
`
`Broadcom. The Bell system also spun off Northern Electric which led to the creation of a
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`research lab known as BNR. This lab grew to host thousands of engineers in offices around the
`
`globe. One of those was an 800,000-square-foot campus in Richardson, Texas.
`
`31.
`
`Collectively, these companies spurred a digital revolution in telecommunications,
`
`starting with the first digital telephone switch in 1975. They continued to push the industry to
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`new heights in the late-80s, when BNR announced the desire to create a global fiber optic
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`network (called “FiberWorld”). Its goal was to give users easy, reliable, and fast access to a
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`variety of multimedia services. To realize this vision, Bell Labs and subsequent innovators made
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`numerous breakthroughs in laser, integrated circuit, photodetector, amplifier, and waveguide
`
`designs. These advancements led to the modern fiber optic systems we use today.
`
`32.
`
`This work naturally evolved to include cellular telecommunications as well. On
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`May 6, 1992, BNR VP George Brody—along with executives from Bell Cellular and Northern
`
`Electric—made the first Canada-US digital cellular call. It stretched from Toronto, Ontario to
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`Fort Worth, Texas.
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`
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`33.
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`Eventually, Nortel Networks absorbed BNR. Although Nortel was ultimately
`
`unsuccessful in its bid to supply digital telecommunications and networking solutions to the
`
`market, some Bell Labs and Nortel alumni decided to reenergize BNR in 2017. Today it is the
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`successor in interest to many of the key telecommunications technologies.
`
`34.
`
`The BNR Patent portfolio reflects important developments in telecommunications
`
`that were invented and refined by leading technology research companies, including Agere, LSI,
`
`and Broadcom. These include U.S. Patent Nos. 8,204,554, 7,319,889, RE 48,629, 8,416,862,
`
`7,564,914, 7,957,450, 6,941,156, 6,696,941, 7,039,435, 6,963,129, 6,858,930, 8,396,072, and
`
`8,792,432. (collectively, these patents comprise the “Asserted Patents”).
`
`35.
`
`Portions of the BNR portfolio are presently licensed and/or were previously
`
`licensed to leading technology companies.
`
`36.
`
`BNR brings this action to put a stop to Defendants’ unauthorized and unlicensed
`
`use of the Asserted Patents.
`
`U.S. Patent No. 8,204,554
`
`37.
`
`Norman Goris and Wolfgang Scheit are the inventors of U.S. Patent No.
`
`8,204,554 (“the ’554 patent”). A true and correct copy of the ’554 patent is attached as Exhibit
`
`A.
`
`38.
`
`The ’554 patent resulted from the pioneering efforts of Messrs. Goris and Scheit
`
`(hereinafter “the Inventors”) in the area of mobile devices. These efforts resulted in the
`
`development of a system of power reducer controls to control the power consumption of a
`
`mobile station display use with a mobile device and a method of operation thereof in the early
`
`2000s. At the time of these pioneering efforts, the most widely implemented technology used to
`
`increase stand-by time as well as the talk-time of a mobile device was to increase the capacity of
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`
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`the battery. The drawback of increasing the capacity of the battery is that as the capacity of the
`
`battery increases, so too does its size, weight, and cost. The Inventors conceived of the invention
`
`claimed in the ’554 patent as a way of prolonging the use of a mobile device without increasing
`
`the capacity of the battery.
`
`39.
`
`For example, the Inventors developed a mobile station, comprising: a display; a
`
`proximity sensor adapted to generate a signal indicative of the existence of a first condition, the
`
`first condition being that an external object is proximate; and a microprocessor adapted to:
`
`(a)determine, without using the proximity sensor, the existence of a second condition
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`independent and different from the first condition, the second condition being that a user of the
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`mobile station has performed an action to initiate an outgoing call or to answer an incoming call;
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`(b) in response to a determination in step (a) that the second condition exists, activate the
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`proximity sensor; (c) receive the signal from the activated proximity sensor; and (d) reduce
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`power to the display if the signal from the activated proximity sensor indicates that the first
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`condition exists.
`
`40.
`
`One advantage of the claimed ’554 invention over the prior art is to reduce the
`
`power consumption of a cell phone display when the display is not needed. (See ’554 patent at
`
`1:40-52.) This increases available battery power that results in increased stand-by and/or talk
`
`time. (See ’554 patent at 1:50-55.)
`
`U.S. Patent No. 7,319,889
`
`41.
`
`Norman Goris and Wolfgang Scheit are the inventors of U.S. Patent No.
`
`7,319,889 (“the ’889 patent”). A true and correct copy of the ’889 patent is attached as Exhibit
`
`B.
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`
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`
`
`42.
`
`The ’889 patent resulted from the pioneering efforts of Messrs. Goris and Scheit
`
`(hereinafter “the Inventors”) in the area of mobile devices. These efforts resulted in the
`
`development of a system of power reducer controls to control the power consumption of a
`
`mobile station display use with a mobile device and a method of operation thereof in the early
`
`2000s. At the time of these pioneering efforts, the most widely implemented technology used to
`
`increase stand-by time as well as the talk-time of a mobile device was to increase the capacity of
`
`the battery. The drawback of increasing the capacity of the battery is that as the capacity of the
`
`battery increases, so too does its size, weight, and cost. The Inventors conceived of the invention
`
`claimed in the ’889 patent as a way of prolonging the use of a mobile device without increasing
`
`the capacity of the battery.
`
`43.
`
`For example, the Inventors developed a mobile station, comprising: a display; a
`
`proximity sensor adapted to generate a signal indicative of proximity of an external object; and a
`
`microprocessor adapted to: (a) determine whether a telephone call is active; (b) receive the signal
`
`from the proximity sensor; and (c) reduce power to the display if (i) the microprocessor
`
`determines that a telephone call is active and (ii) the signal indicates the proximity of the external
`
`object; wherein: the telephone call is a wireless telephone call; the microprocessor reduces power
`
`to the display while the signal indicates the proximity of the external object only if the
`
`microprocessor determines that the wireless telephone call is active; and the proximity sensor
`
`begins detecting whether an external object is proximate substantially concurrently with the
`
`mobile station initiating an outgoing wireless telephone call or receiving an incoming wireless
`
`telephone call.
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`
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`44.
`
`One advantage of the claimed ʼ889 invention over the prior art is to reduce the
`
`power consumption of the display of a cell phone when the display is not needed. (See ’889
`
`patent at 1:40-52.)
`
`U.S. Patent No. RE 48,629
`
`45.
`
`Jason Alexander Trachewsky and Rajendra T. Moorti are the inventors of U.S.
`
`Patent No. RE 48,629 (the ’629 patent). A true and correct copy of the ’629 patent is attached as
`
`Exhibit C.
`
`46.
`
`The ’629 patent resulted from the pioneering efforts of Messrs. Trachewsky and
`
`Moorti (hereinafter “the Inventors”) in the general area of wireless communication systems and
`
`more particularly to long training sequences of minimum peak-to-average power ratio which
`
`may be used in legacy systems. At the time of these pioneering efforts, conventionally
`
`implemented technology did not sufficiently address the problem of different wireless devices
`
`compliant with different standards or different versions of the same standard while enabling
`
`backward compatibility with legacy devices that avoids collisions. For example, in the 802.11a
`
`and 802.11g standards, each data packet starts with a preamble which includes a short training
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`sequence followed by a long training sequence. The short and long training sequences are used
`
`for synchronization between the sender and the receiver. The long training sequence of 802.11a
`
`and 802.11g is defined such that each of sub-carriers -26 to +26, except for the subcarrier 0
`
`which is set to 0, has one binary phase shift keying constellation point, either +1 or -1.
`
`47.
`
`There existed a need to create a long training sequence of minimum peak-to-
`
`average ratio that uses more sub-carriers without interfering with adjacent channels.
`
`48.
`
`For example, the Inventors developed a wireless communications device,
`
`comprising: a signal generator that generates an extended long training sequence; and an Inverse
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`Fourier Transformer operatively coupled to the signal generator, wherein the Inverse Fourier
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`Transformer processes the extended long training sequence from the signal generator and
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`provides an optimal extended long training sequence with a minimal peak-to-average ratio, and
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`wherein at least the optimal extended long training sequence is carried by a greater number of
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`subcarriers than a standard wireless networking configuration for an Orthogonal Frequency
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`Division Multiplexing scheme, wherein the optimal extended long training sequence is carried
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`by exactly 56 active sub-carriers, and wherein the optimal extended long training sequence is
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`represented by encodings for indexed sub-carriers -28 to +28, excluding indexed sub-carrier 0
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`which is set to zero, as follows:
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`
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`49.
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`One advantage of the patented invention is that it provides an expanded long
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`training sequence of minimum peak-to-average power ratio thereby decreasing power back-off.
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`(See ’629 patent at 4:15-17.)
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`50.
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`Another advantage of the invention is that expanded long training sequence may
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`be used by 802.11a and 802.11g devices for estimating the channel impulse response and by a
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`receiver for estimating the carrier frequency offset between the transmitter clock and receiver
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`clock. (See ’629 patent at 4:17-21.)
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`Case 4:23-cv-00789-ALM Document 1 Filed 09/01/23 Page 15 of 82 PageID #: 15
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`U.S. Patent No. 8,416,862
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`51.
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`Carlos Aldana and Joonsuk Kim are the inventors of U.S. Patent No 8,416,862
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`(“the ’862 patent”). A true and correct copy of the ’862 patent is attached as Exhibit D.
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`52.
`
`The ’862 patent resulted from the pioneering efforts of Messrs. Aldana and Kim
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`(hereinafter “the Inventors”) in the area of wireless communications systems using beamforming.
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`These efforts resulted in the development of a method and system for the efficient feedback of
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`channel information in a closed loop beamforming wireless communication system.
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`53.
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`At the time of these pioneering efforts, the most widely implemented technology
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`used to address reduced beam forming feedback information for wireless communications was to
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`reduce the size of the feedback. For instance, in a 2x2 MIMO wireless communication, the
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`feedback needs four elements that are all complex Cartesian coordinate values V11 V12;V21
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`V22. In general, Vik=aik+j*bik, where aik and bik are values between -1, 1. Thus, with 1 bit
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`express per each element for each of the real and imaginary components, aik and bik can be
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`either -1/2 or +1/2, which requires 4x2x1=8 bits per tone. With 4 bit expressions per each
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`element of V(f) in an orthogonal frequency division multiplexing (OFDM) 2x2 MIMO wireless
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`communication, the number of bits required is 1728 per tone (e.g., 42*54*4=1728, 4 elements
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`per tone, 2 bits for real and imaginary components per tone, 54 data tones per frame, and 4 bits
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`per element), which requires overhead for a packet exchange that is too large for practical
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`applications.
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`54.
`
`The Inventors conceived of the invention claimed in the ’862 patent as a way to
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`reduce beam forming feedback information for wireless communications.
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`55.
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`For example, the Inventors developed a method for feeding back transmitter
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`beamforming information from a receiving wireless communication device to a transmitting
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`
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`wireless communication device, the method comprising: the receiving wireless communication
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`device receiving a preamble sequence from the transmitting wireless device; the receiving
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`wireless device estimating a channel response based upon the preamble sequence; the receiving
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`wireless device determining an estimated transmitter beamforming unitary matrix (V) based
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`upon the channel response and a receiver beamforming unitary matrix (U); the receiving wireless
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`device decomposing the estimated transmitter beamforming unitary matrix (V) to produce the
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`transmitter beamforming information; and the receiving wireless device wirelessly sending the
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`transmitter beamforming information to the transmitting wireless device.
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`56.
`
`One advantage of the patented invention is a reduction of beamforming feedback
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`information for wireless communications. (See ’862 patent at 3:49-51.)
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`U.S. Patent No. 7,564,914
`
`57.
`
`Christopher J. Hansen, Carlos H. Aldana, and Joonsuk Kim are the inventors of
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`U.S. Patent No. 7,564,914 (“the ’914 patent”). A true and correct copy of the ’914 patent is
`
`attached as Exhibit E.
`
`58.
`
`The ’914 patent resulted from the pioneering efforts of Messrs. Hansen, Aldana,
`
`and Kim (hereinafter “the Inventors”) in the general area of wireless networking.
`
`59.
`
`For example, the Inventors developed a method for communicating information in
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`a communication system, the method comprising: transmitting data via a plurality of radio
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`frequency (RF) channels utilizing a plurality of transmitting antennas; receiving feedback
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`information via at least one of said plurality of RF channels; modifying a transmission mode
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`based on said feedback information; receiving said feedback information comprising channel
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`estimates based on transmission characteristics of said transmitted data via at least one of said
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`plurality of transmitting antennas; and deriving said feedback information from mathematical
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`matrix decomposition of said channel estimates.
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`60.
`
`One advantage of the ’914 patent is the more precise estimation of channel
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`characteristics. (See ’914 patent at 18:12-15.)
`
`61.
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`Another advantage of the patented invention is that it minimizes the quantity of
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`feedback information and in turn reduces overhead. (See ’914 patent at 1