DCT

1:22-cv-03441

Theta IP LLC v. Motorola Mobility LLC

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I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 1:22-cv-03441, N.D. Ill., 06/30/2022
  • Venue Allegations: Plaintiff alleges venue is proper in the Northern District of Illinois because Defendants Motorola Mobility and Lenovo (United States) Inc. have regular and established places of business in the district. Venue over Lenovo Group Ltd. is asserted based on its status as a foreign corporation.
  • Core Dispute: Plaintiff alleges that Defendant’s cellular smartphones and tablets infringe patents related to dynamically adjusting radio receiver components to reduce power consumption and improve battery life.
  • Technical Context: The technology at issue involves adaptive power management in radio frequency (RF) transceivers, a critical area for extending battery life in power-constrained mobile devices.
  • Key Procedural History: The complaint alleges that in 2007, Plaintiff’s predecessor contacted Motorola regarding a potential license, and discussions between the parties occurred in 2008. This allegation of pre-suit notice may be relevant to claims of willful infringement regarding at least one of the asserted patents.

Case Timeline

Date Event
2003-03-01 Priority Date for Asserted Patents
2006-03-07 U.S. Patent No. 7,010,330 Issues
2007-01-01 Plaintiff allegedly contacts Motorola regarding licensing
2010-01-01 Lenovo enters smartphone market (approximate date)
2014-01-01 Lenovo acquires Motorola Mobility
2018-11-13 U.S. Patent No. 10,129,825 Issues
2019-12-31 U.S. Patent No. 10,524,202 Issues
2020-01-01 Lenovo's Accused Product "Razr (2020)" becomes available
2021-01-01 Lenovo's Accused Product "Moto G Power (2021)" becomes available
2022-06-30 Complaint Filed

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

U.S. Patent No. 7,010,330 - “Power Dissipation Reduction in Wireless Transceivers”

  • Patent Identification: U.S. Patent No. 7010330, “Power Dissipation Reduction in Wireless Transceivers,” issued March 7, 2006 (the “’330 Patent”).

The Invention Explained

  • Problem Addressed: The patent’s background section states that electronic circuits in wireless transceivers are typically designed to function under "worst-case" operating conditions, where a desired signal is weak and interfering signals are strong. This approach results in excessive power consumption and drains battery life when signal conditions are more favorable (Compl. ¶36; ’330 Patent, col. 1:33-40).
  • The Patented Solution: The invention proposes to reduce power dissipation by dynamically adjusting the operational characteristics of components in the receiver’s signal path—such as their bias current, impedance, or gain—based on the actual, measured strengths of the desired signal and any interfering signals (’330 Patent, Abstract; ’330 Patent, col. 2:49-62). This allows the circuit to adapt to better-than-worst-case conditions and consume less power.
  • Technical Importance: This adaptive power management technique was aimed at improving battery life, a critical competitive differentiator for portable electronic devices (Compl. ¶37).

Key Claims at a Glance

  • The complaint asserts at least independent claim 23 (Compl. ¶73).
  • The essential elements of claim 23 are:
    • A wireless transceiver including a receiver signal path with an amplifier, a mixer, and a filter.
    • Circuitry for determining a signal strength of a desired signal.
    • Circuitry for determining a signal strength of an interferer signal.
    • Wherein one or more of the circuits in the signal path has an impedance that is dynamically adjusted based on the determined signal strengths.
  • The complaint does not explicitly reserve the right to assert dependent claims but states infringement of "one or more claims" (Compl. ¶90).

U.S. Patent No. 10,129,825 - “Power Dissipation Reduction in Wireless Transceivers”

  • Patent Identification: U.S. Patent No. 10129825, “Power Dissipation Reduction in Wireless Transceivers,” issued November 13, 2018 (the “’825 Patent”).

The Invention Explained

  • Problem Addressed: Similar to the ’330 Patent, this patent addresses the problem of high power drain in wireless transceivers that are designed to operate continuously under worst-case signal conditions, which are not always present (Compl. ¶36; ’825 Patent, col. 1:32-39).
  • The Patented Solution: The invention describes methods for reducing power dissipation by dynamically varying the bias current or impedance of receiver components in response to specific combinations of desired and interferer signal strengths (’825 Patent, Abstract). The specification describes that operating parameters are changed to reduce power dissipation in response to better-than-worst-case conditions (’825 Patent, col. 2:58-62).
  • Technical Importance: The technology provides a method to extend battery life in mobile devices by adapting power use to real-world signal environments (Compl. ¶37).

Key Claims at a Glance

  • The complaint asserts at least independent claim 3 (Compl. ¶100).
  • The essential elements of claim 3 are:
    • A method for power dissipation reduction in a receiver of a battery powered portable wireless device.
    • The method involves receiving a wireless signal having a desired signal and an interferer signal.
    • A worst-case power dissipation condition is defined as when the desired signal is low and the interferer signal is high.
    • Power dissipation is reduced by varying a bias current when the interferer is high and the desired signal is low, but the desired signal has a strength that is "larger than in the worst-case power dissipation conditions."
    • This variation causes the bias current to be decreased compared to the worst-case condition.
  • The complaint does not explicitly reserve the right to assert dependent claims but states infringement of "one or more claims" of the patent family (Compl. ¶71).

U.S. Patent No. 10,524,202 - “Power Dissipation Reduction in Wireless Transceivers”

  • Multi-Patent Capsule:
    • Patent Identification: U.S. Patent No. 10524202, “Power Dissipation Reduction in Wireless Transceivers,” issued December 31, 2019 (the “’202 Patent”).
    • Technology Synopsis: The patent describes methods for reducing power consumption in wireless transceivers by moving away from a static, worst-case design paradigm (Compl. ¶48). The patented solution involves determining the signal strengths of desired and interferer signals and, in response to a comparison, dynamically adjusting the gain, impedance, or bias current of receiver components to reduce power consumption from the battery (’202 Patent, Abstract; Compl. ¶48).
    • Asserted Claims: At least independent claim 7 (Compl. ¶126).
    • Accused Features: The complaint accuses power-saving techniques in the Accused Products' transceiver, modem, and RF Front End components, which allegedly adjust gain, bias, and/or impedance in response to signal strengths (Compl. ¶127).

III. The Accused Instrumentality

Product Identification

  • The complaint identifies a broad range of cellular-enabled smartphones and tablets sold under the Motorola and Lenovo brands, including the Moto G, Motorola Edge, RAZR, and Tab Series product families (Compl. ¶56).

Functionality and Market Context

  • The accused functionality resides within the radio frequency (RF) circuitry of these devices, specifically in components such as Qualcomm Snapdragon mobile platforms, Qualcomm transceivers (e.g., SDR660, WTR3925), and Skyworks RF Front End modules (Compl. ¶62, ¶65, ¶109). The complaint alleges these components employ the patented dynamic power dissipation technology to manage power consumption based on cellular signal conditions (Compl. ¶61). Plaintiff links this technical functionality to Defendant's marketing, which promotes extended battery life and includes disclaimers that performance varies based on factors including signal strength (Compl. ¶55, ¶59). A Qualcomm diagram of a representative 5G mobile platform RF signal path shows key components like the RF Transceiver, Low noise amplifier, and Filters (Compl. ¶77, p. 26).

IV. Analysis of Infringement Allegations

’330 Patent Infringement Allegations

Claim Element (from Independent Claim 23) Alleged Infringing Functionality Complaint Citation Patent Citation
a wireless transceiver including a receiver signal path, the receiver signal path comprising a plurality of circuits, wherein the plurality of circuits comprises an amplifier, a mixer, and a filter Each Accused Product includes wireless transceiver circuitry with a receiver signal path containing a low-noise amplifier, a mixer, and a filter, often within Qualcomm mobile RF components. ¶75, ¶77 col. 4:19-25
circuitry coupled to the signal path for determining a signal strength of a desired signal The Accused Products include circuitry to determine and display the Received Signal Strength Indicator (RSSI) for the desired cellular signal. ¶79 col. 4:21-23
circuitry coupled to the signal path for determining a signal strength of an interferer signal Qualcomm components used in the Accused Products allegedly include "jammer detection circuitry" that determines the signal strength levels of interferer signals. ¶80 col. 4:33-47
wherein one or more of the plurality of circuits in the receiver signal path has an impedance that is dynamically adjusted based upon the determined desired signal strength and the determined interferer signal strength The Accused Products allegedly use transceiver components with programmable "gain states" that effect variable impedances in response to measured changes in desired and interferer signal strength. ¶82, ¶87 col. 2:15-18

Identified Points of Contention

  • Scope Questions: A central question may be whether the alleged "jammer detection circuitry" in the accused Qualcomm components performs the function of "determining a signal strength of an interferer signal" as required by the claim. The defense may question whether a general "jammer" indicator is equivalent to determining a specific "signal strength."
  • Technical Questions: The complaint provides evidence of adjusting "gain states" and "bias currents" (Compl. ¶83, ¶86). A point of contention could be the evidentiary link between these adjustments and the specific claim requirement of dynamically adjusting "impedance."

’825 Patent Infringement Allegations

Claim Element (from Independent Claim 3) Alleged Infringing Functionality Complaint Citation Patent Citation
A method for power dissipation reduction... comprising: receiving a wireless signal having a desired signal and an interferer signal... The Accused Products are wireless devices that receive cellular signals, which include both desired signals and interferer signals. ¶102, ¶103 col. 13:42-45
wherein a worst-case power dissipation condition... results when the signal strength of the desired signal is low and the signal strength of the interferer signal is high The complaint alleges that this worst-case condition occurs in the Accused Products and necessitates high bias currents to maintain linearity and dynamic range. ¶107 col. 13:54-57
wherein the power dissipation reduction... is achieved by causing a bias current to vary... when the signal strength of the interferer signal is high and the signal strength of the desired signal is low, and the desired signal has a signal strength that is larger than in the worst-case power dissipation conditions... The Accused Products allegedly use programmable "gain states" in their RF components to effect variable bias currents. The complaint alleges that when conditions match the claim's scenario, a gain state is changed, which in turn decreases the bias current compared to the worst-case condition, thereby saving power. ¶108, ¶113 col. 13:60-67

Identified Points of Contention

  • Technical Questions: Claim 3 recites a highly specific operational scenario: interferer is high, desired signal is low, but the desired signal is simultaneously "larger than in a worst-case power dissipation condition." The complaint does not detail how the accused system differentiates this specific state from a true worst-case state. The defense may argue that the accused systems do not implement this precise conditional logic. A slide from a Qualcomm "IntelliCeiver" presentation shows that when jammers are below a threshold, current is reduced in the LNA and mixer (Compl. ¶85, p. 30).
  • Evidentiary Questions: What evidence demonstrates that a change in the accused devices' "gain state" directly corresponds to the "bias current... decreased compared to the worst-case power dissipation condition" as required by the claim's specific logic? The complaint provides a datasheet for a WTR3925 transceiver showing multiple programmable gain modes (Compl. ¶83, p. 29).

V. Key Claim Terms for Construction

  • The Term: "dynamically adjusted" / "dynamically changing"

    • Context and Importance: This term is at the core of the asserted patents, defining the adaptive nature of the invention. Its construction will determine whether the adjustments made by the accused devices—which may be stepped, programmatic changes between discrete "gain states"—fall within the claim scope, or whether a more continuous or real-time adjustment is required.
    • Intrinsic Evidence for Interpretation:
      • Evidence for a Broader Interpretation: The specification suggests a flexible process, stating that currents "may start at a point in between and vary up or down" ('825 Patent, col. 2:2-3). This language may support a construction that is not limited to a specific type of adjustment.
      • Evidence for a Narrower Interpretation: Figures in a patent cited by the complaint to explain the accused technology depict gain changing in discrete steps at specific "Switch Points" (Compl. ¶86, p. 31, Fig. 4). This could support an argument that "dynamic" refers to switching between predefined states rather than a continuous variation.

  • The Term: "interferer signal"

    • Context and Importance: The complaint alleges infringement by citing to "jammer detection circuitry" in the accused products (Compl. ¶80, ¶106). The case may depend on whether the term "interferer signal" is construed broadly to encompass any signal that a "jammer detector" would identify, or more narrowly to exclude certain types of unwanted signals.
    • Intrinsic Evidence for Interpretation:
      • Evidence for a Broader Interpretation: The specification provides a broad definition, stating interferers "may be generated by similar transceivers, or other electrical equipment, circuits, or systems" ('330 Patent, col. 5:29-31). This could support reading the term on a wide range of unwanted signals.
      • Evidence for a Narrower Interpretation: The patent figures consistently depict interferers as distinct, strong signals at specific frequencies separate from the desired signal (e.g., ’330 Patent, Fig. 2B). This could be used to argue the term does not cover diffuse background noise or minor adjacent-channel interference.

VI. Other Allegations

  • Indirect Infringement: The complaint alleges inducement by making and selling the Accused Products with knowledge of the patents and with the intent that customers' normal use will "necessarily result in infringement" (Compl. ¶92, ¶118). Knowledge of the ’330 Patent is alleged based on licensing discussions with Motorola in 2007-2008 (Compl. ¶52).
  • Willful Infringement: Willfulness allegations for the ’330 Patent are based on alleged pre-suit knowledge from the 2007-2008 discussions (Compl. ¶97). For all asserted patents, willfulness is also alleged based on knowledge acquired no later than the filing of the complaint (Compl. ¶97, ¶123, ¶148).

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

  • A core issue will be one of evidentiary mapping: can Plaintiff produce technical evidence that definitively maps the high-level marketing claims and component datasheets to the specific, multi-part conditional logic recited in the asserted claims (particularly claim 3 of the ’825 Patent), or will there be a disconnect between the general capability for dynamic adjustment and the precise method claimed?
  • The case may also turn on a question of functional equivalency: does the accused "jammer detection circuitry," which may provide a binary or coarse-grained indication of interference, perform the function of "determining a signal strength of an interferer signal" as understood in the context of the patent, or is there a fundamental mismatch in the granularity of the information generated and used?