DCT

1:20-cv-01710

Koninklijke Philips NV v. Quectel Wireless Solutions Co Ltd

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I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 1:20-cv-01710, D. Del., 10/03/2025
  • Venue Allegations: Plaintiff alleges venue is proper for Quectel as a foreign corporation and for the other defendants because they are incorporated in Delaware and conduct substantial business in the district.
  • Core Dispute: Plaintiff alleges that Defendants’ cellular communication modules and the Internet of Things (IoT) products containing them infringe four patents related to fundamental technologies for managing data transmission and power control in 3G and 4G wireless networks.
  • Technical Context: The patents concern methods for prioritizing data packets for uplink transmission, allocating control channels for downlink transmission, and managing device power limits, all of which are foundational to modern cellular communication standards.
  • Key Procedural History: The complaint notes that the asserted patents were previously part of an International Trade Commission (ITC) investigation against the same defendants that concluded in July 2022. It also references related district court litigation against other cellular module makers (Thales, Telit) that resulted in settlements and FRAND licenses, as well as a separate case against Defendant Quectel involving different patents that have been subject to inter partes review (IPR) proceedings.

Case Timeline

Date Event
2002-02-08 Priority Date for U.S. Patent Nos. 7,554,943 and 8,199,711
2003-08-11 Priority Date for U.S. Patent No. 7,831,271
2005-11-04 Priority Date for U.S. Patent No. 7,944,935
2009-06-30 U.S. Patent No. 7,554,943 Issued
2010-11-09 U.S. Patent No. 7,831,271 Issued
2011-05-17 U.S. Patent No. 7,944,935 Issued
2012-06-12 U.S. Patent No. 8,199,711 Issued
2015-12-29 Alleged notice of infringement of Asserted Patents to Quectel
2020-10-19 Alleged notice of infringement of Asserted Patents to CalAmp and Xirgo
2020-11-12 Alleged notice of infringement of Asserted Patents to Laird
2020-12-17 Original Complaint Filed
2022-07-01 ITC Investigation 337-TA-1240 involving Asserted Patents concluded (approx.)
2025-10-03 Second Amended Complaint Filed

II. Technology and Patent(s)-in-Suit Analysis

U.S. Patent No. 7,944,935 - Method for Priority Based Queuing and Assembling of Packets

The Invention Explained

  • Problem Addressed: The patent’s background section describes an issue in wireless communication systems like UMTS where strictly prioritizing the transmission of high-priority data packets can lead to lower-priority packets being indefinitely delayed or "starved," which is an inflexible and inefficient way to manage network resources and meet Quality of Service (QoS) requirements (Compl. ¶56; ’935 Patent, col. 1:27-47).
  • The Patented Solution: The invention proposes a method to assemble a group of data packets for transmission by dividing the group into at least two portions. Each portion is filled using a different rule. For example, a first portion can be populated with high-priority packets according to a strict priority rule, while a second portion is populated using a different rule that might select lower-priority packets that have experienced a long delay, thus preventing starvation (Compl. ¶57; ’935 Patent, col. 1:50-59).
  • Technical Importance: This approach provides greater flexibility for handling data with different priorities, managing guaranteed bit-rates, and mitigating starvation scenarios in cellular uplink transmissions (Compl. ¶57; ’935 Patent, col. 1:60-66).

Key Claims at a Glance

  • The complaint asserts independent claims 1 (a method) and 9 (an apparatus) (Compl. ¶96, ¶105).
  • Independent Claim 1 recites a method of multiplexing data packets with different priorities, comprising the essential elements of:
    • receiving data packets;
    • operating a queue for each different priority;
    • assembling a group of data packets where a "first portion" is populated according to a "first rule" and a "second portion" is populated according to a "second rule"; and
    • transmitting the group, wherein the size of the first and second portions is adapted according to the delay experienced by data in each queue.
  • Independent Claim 9 recites a multiplexing apparatus with means for performing the steps of claim 1.
  • The complaint asserts dependent claims 2-4, 10-12, and 17 and reserves the right to assert others (Compl. ¶96).

U.S. Patent No. 7,554,943 - Radio Communication System

The Invention Explained

  • Problem Addressed: In high-speed downlink systems (like HSDPA), a mobile station needs to know which control channel to monitor for incoming data packets. The patent’s background explains that using a separate "indicator signal" to point to the correct control channel adds system complexity and requires significant power, while statically assigning a channel to a device restricts scheduling flexibility when multiple devices share that channel (Compl. ¶65; ’943 Patent, col. 1:42-60).
  • The Patented Solution: The invention proposes changing, or "shuffling," the control channel allocated to a mobile station over time according to a defined sequence that is known to both the network (primary station) and the device (secondary station). By knowing the sequence, the device can determine which channel to monitor at any given time without needing a separate indicator signal, thereby improving system performance under worst-case conditions (Compl. ¶66; ’943 Patent, col. 2:6-16).
  • Technical Importance: This technique improves scheduling flexibility and system efficiency by avoiding the complexity and power consumption associated with indicator signals used in prior art systems (Compl. ¶66; ’943 Patent, col. 2:13-16).

Key Claims at a Glance

  • The complaint asserts independent claims 12 (a secondary station) and 15 (a method) (Compl. ¶131).
  • Independent Claim 12 recites a secondary station comprising:
    • means for determining which of a plurality of control channels is allocated to it, where the allocated channel is changed according to a defined sequence known to both the primary and secondary stations;
    • means for monitoring the currently allocated channel to get information about packet transmissions;
    • wherein the sequence is configured to reduce the probability of an "allocation collision" to 1/N, where N is the total number of control channels.
  • Independent Claim 15 recites a method of operating a radio communication system with the essential steps of allocating, changing, and monitoring a control channel according to a defined sequence.
  • The complaint does not explicitly identify asserted dependent claims but reserves the right to do so.

U.S. Patent No. 8,199,711 - Radio Communication System

Technology Synopsis

This patent is a continuation of the ’943 Patent and shares a common specification (Compl. ¶72). It addresses the same technical problem of efficiently allocating control channels without an indicator signal. The claims focus on a system where control channels are allocated to a plurality of secondary stations according to a plurality of respective, different defined sequences (Compl. ¶155, ¶159).

Asserted Claims

Independent claims 9 (a secondary station) and 12 (a method) (Compl. ¶151).

Accused Features

The accused products are alleged to infringe by implementing LTE standards that require them to monitor changing sets of control channel candidates according to device-specific sequences (Compl. ¶160-161, ¶164).

U.S. Patent No. 7,831,271 - Communication System and Method of Operating the Communicating System

Technology Synopsis

The patent addresses how a mobile terminal can transmit an additional signal (e.g., an ACK/NACK) when its ongoing transmissions are already near the maximum power limit (Compl. ¶83). The patented solution is to scale down the power of the ongoing signal in advance, using an amount that accounts for the greatest possible power requirement of any potential additional signal, thereby ensuring compliance with the power limit without needing to know which specific signal will ultimately be sent (Compl. ¶85; ’271 Patent, col. 1:49-54).

Asserted Claims

Independent claims 1 (a method) and 5 (a communication station) (Compl. ¶170).

Accused Features

The accused products are alleged to infringe by implementing 3G UMTS standards for managing uplink power control, where the power of existing channels is scaled to accommodate the transmission of HARQ-ACK signals without exceeding the device's maximum transmit power (Compl. ¶185, ¶189-190).

III. The Accused Instrumentality

Product Identification

Plaintiff accuses a range of cellular communication modules manufactured by Defendant Quectel (e.g., EG25-G, EG91, BG96) and downstream Internet of Things (IoT) products manufactured by the other Defendants that incorporate these modules (Compl. ¶46). The complaint includes a photo of a CalAmp LMU-3640MB circuit board, which visibly incorporates an accused Quectel BG96 module (Compl. ¶50).

Functionality and Market Context

The accused products are hardware modules that provide 3G (UMTS) and 4G (LTE) cellular connectivity, enabling IoT devices to communicate over wireless networks (Compl. ¶27, ¶45). Their core functionality is to implement the communication protocols set by the 3GPP standards bodies (Compl. ¶114, ¶141). Plaintiff alleges these modules are marketed and sold in the United States and have been certified for use on major U.S. carrier networks (Compl. ¶45, ¶53).

IV. Analysis of Infringement Allegations

7,944,935 Infringement Allegations

Claim Element (from Independent Claim 1) Alleged Infringing Functionality Complaint Citation Patent Citation
a method of multiplexing data packets having different assigned priorities The accused products implement the 3GPP Logical Channel Prioritization procedure when a new transmission is performed. ¶97, ¶115 col. 1:1-3
receiving data packets Packets are received from higher layers of the protocol stack. ¶98, ¶116 col. 4:50-55
operating a queue for each different priority of data packet The products maintain a variable "Bj" for each logical channel, which is controlled by RRC signaling of "priority", "prioritisedBitRate" (PBR), and "bucketSizeDuration" (BSD) to create priority-based queues. ¶99, ¶117 col. 4:55-60
assembling a group of the data packets wherein a first portion ... is populated ... according to a first rule and a second portion ... is populated ... according to a second rule The 3GPP procedure involves two steps alleged to be two rules: Step 1 allocates resources to channels where Bj > 0 (the second rule), and Step 3 allocates any remaining resources in strict priority order (the first rule). ¶100, ¶118 col. 5:1-12
transmitting the group, wherein the size of the first and second portions is adapted according to the delay experienced by data in each queue relative to a delay criterion for the respective queue The size of the portions is determined by the amount of data served under the two rules, which is controlled by the PBR and BSD parameters that govern the "Bj" variable, thereby adapting the allocation based on delay criteria. ¶101, ¶120 col. 2:23-30
  • Identified Points of Contention:
    • Scope Questions: A primary question is whether the sequential steps of the 3GPP Logical Channel Prioritization procedure can be construed as populating two distinct "portions" of a data group, as required by the claim. The defense may argue the standard describes a single, sequentially-filled buffer, not two pre-defined or logically separate portions.
    • Technical Questions: Does the token-bucket-like mechanism (using PBR and BSD to manage the "Bj" variable) in the 3GPP standard constitute "adapting the size" of portions "according to the delay experienced," or is it a more general QoS mechanism that does not directly measure and respond to delay in the manner contemplated by the patent?

7,554,943 Infringement Allegations

Claim Element (from Independent Claim 12) Alleged Infringing Functionality Complaint Citation Patent Citation
A secondary station for use in a radio communication system... The accused products are secondary stations (user equipment) that operate in LTE radio communication systems. ¶132, ¶142 col. 2:35-37
means for determining which of the control channels is allocated to the secondary station, the allocated control channel being changed according to a defined sequence... The products determine a "UE-specific search space" of control channel candidates to monitor. This search space is changed according to a sequence "Yk" that is a function of the slot number and a device-specific identifier (RNTI). ¶134, ¶145, ¶147 col. 2:45-53
and for monitoring the currently allocated control channel to determine information about packet transmissions The products monitor the set of PDCCH candidates within the determined search space in every non-DRX subframe to find control information. ¶134, ¶145 col. 2:50-53
wherein the defined sequence is configured to reduce probability of an allocation collision to 1/N... The use of a device-specific sequence based on a prime modulus multiplicative linear congruential generator inherently de-correlates the search spaces of different devices, reducing the probability of collision. ¶135, ¶145 col. 4:5-12
  • Identified Points of Contention:
    • Scope Questions: Does changing the "search space" of potential control channel candidates that a device must monitor equate to "changing the allocated control channel" itself? The defense may argue that the network makes the final allocation within that space, and the claim requires changing the actual, singular allocated channel, not the list of candidates.
    • Technical Questions: The infringement theory relies on the "Yk" sequence from the 3GPP LTE standard being equivalent to the "defined sequence" of the patent. The degree of technical overlap between the standard's implementation and the patent's disclosure will be a central factual dispute.

V. Key Claim Terms for Construction

  • Patent: '935 Patent

    • The Term: "a first portion ... and a second portion"
    • Context and Importance: This term is the structural foundation of the independent claims. The infringement allegation maps the multi-step 3GPP prioritization procedure onto this two-portion framework. If the procedure is found to create a single logical data group rather than two distinct portions, the infringement theory may not hold.
    • Intrinsic Evidence for Interpretation:
      • Evidence for a Broader Interpretation: The specification emphasizes the functional benefit of "enabling different multiplexing rules to be used for the different portions" (’935 Patent, col. 1:63-65). This may support a construction where the "portions" are defined by the application of different rules, not necessarily by being physically separate or pre-sized.
      • Evidence for a Narrower Interpretation: The claim language recites "adapting the size of the first and second portions" (’935 Patent, col. 8:16-17). This phrasing may support a more structural interpretation where the portions are distinct segments whose sizes are determined before they are populated with data.

  • Patent: '943 Patent

    • The Term: "changing the allocated control channel"
    • Context and Importance: Plaintiff’s infringement theory equates the LTE standard's method of changing a device's "search space" with "changing the allocated control channel." The viability of this theory depends on whether a list of potential channels is legally equivalent to the single channel that is ultimately allocated.
    • Intrinsic Evidence for Interpretation:
      • Evidence for a Broader Interpretation: The patent's stated object is to provide an improved arrangement that does not require an "indicator signal" (’943 Patent, col. 1:65-67). The LTE "search space" mechanism achieves this objective by telling the device where to look for a potential allocation. This functional similarity may support a broader reading of "allocated."
      • Evidence for a Narrower Interpretation: The patent repeatedly refers to allocating "one of the control channels" and changing "the allocated control channel" (singular) (’943 Patent, col. 2:8-10). This language may support a narrower construction requiring a change to a single, specific channel assignment, not a change to a list of candidates from which an assignment is later made.

VI. Other Allegations

  • Indirect Infringement: The complaint alleges both induced and contributory infringement for all four asserted patents. Inducement is based on allegations that Defendants provide instructions, user manuals, and marketing materials that direct end-users to operate the accused products in an infringing manner (Compl. ¶94, ¶129, ¶149, ¶168). Contributory infringement is based on allegations that the accused modules are a material part of the inventions, are not staple articles of commerce, and have no substantial non-infringing use (Compl. ¶95, ¶130, ¶150, ¶169).
  • Willful Infringement: Willfulness is alleged based on pre-suit knowledge. The complaint asserts that each defendant received notice of the asserted patents via letters from Philips on specific dates, with the earliest notice to Quectel dated December 29, 2015 (Compl. ¶40-44). The allegations state that Defendants' infringement continued after receiving notice (Compl. ¶201).

VII. Analyst’s Conclusion: Key Questions for the Case

  • A core issue will be one of technical mapping: Can the specific, multi-step algorithms defined in the 3GPP standards for LTE channel prioritization and search space calculation be persuasively mapped onto the broader, more conceptual language of the patent claims? This will likely be a central battleground for expert testimony.
  • A key question of definitional scope for the ’935 Patent will be: Does the term "portions," as used in the claims, refer to functionally distinct sets of data selected by different rules, or does it require structurally distinct and pre-sized segments within a data transmission?
  • The case for the ’943 and ’711 Patents may turn on a question of functional interpretation: Does altering a "search space" of potential control channels in the LTE standard perform the same function as "changing the allocated control channel" as recited in the claims, or is the distinction between a candidate list and a final, single allocation a dispositive technical and legal difference?