DCT

2:15-cv-00579

Cellular Communications Equipment LLC v. Sprint Corp

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I. Executive Summary and Procedural Information

Case Timeline

Date Event
2007-06-20 ’676 Patent Priority Date
2008-03-26 ’957 Patent Priority Date
2008-09-22 ’022 Patent Priority Date
2010-03-25 ’472 and ’262 Patents Priority Date
2010-06-21 ’590 Patent Priority Date
2010-08-01 Alleged earliest notice of ’957 Patent disclosure to 3GPP
2012-12-01 Alleged earliest notice of ’022 and '676 Patent disclosures to 3GPP
2013-03-01 Alleged earliest notice of ’472 Patent disclosure to 3GPP
2013-06-04 ’022 Patent Issue Date
2013-06-04 ’676 Patent Issue Date
2013-10-29 ’957 Patent Issue Date
2014-10-21 ’472 Patent Issue Date
2015-05-05 ’590 Patent Issue Date
2015-07-07 ’262 Patent Issue Date
2015-11-12 Complaint Filing Date

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

U.S. Patent No. 8,457,022 - “Method and Apparatus for Providing Signaling of Redundancy Versions”

The Invention Explained

  • Problem Addressed: In wireless systems like LTE, system information is broadcast repeatedly to ensure devices can receive it. When a transmission fails, a different "redundancy version" (RV) of the data can be sent. The patent’s background section notes that for certain critical broadcasts, there is no efficient, standardized way to implicitly signal which RV is being used, which can waste network resources. (Compl. ¶ 31; ’022 Patent, col. 1:29-35, col. 5:19-24).
  • The Patented Solution: The invention proposes a method where the network equipment and user devices follow a predetermined, synchronized scheme. By detecting the start of a specific "system information message transmission window," both sides can implicitly know which RV to use based on the timing within that window, eliminating the need for explicit signaling bits. (’022 Patent, Abstract, col. 2:40-44). The process involves assigning an RV sequence at the start of the window. (’022 Patent, Fig. 2).
  • Technical Importance: This approach reduces control channel overhead, which improves the overall spectral efficiency for broadcasting essential system information in an LTE network. (Compl. ¶ 2).

Key Claims at a Glance

  • The complaint asserts one or more claims; independent claim 1 is representative. (Compl. ¶ 33).
  • Claim 1 of the ’022 Patent recites a method with the essential elements of:
    • detecting start of a system information message transmission window;
    • assigning a redundancy version sequence at the start of the transmission window;
    • wherein the assignment includes excluding one or more predetermined subframes in even-numbered radio frames if they fall within the window; and
    • wherein the assignment also includes excluding uplink and multi-cast subframes.
  • The complaint does not explicitly reserve the right to assert dependent claims but makes a general allegation of infringement of "one or more claims." (Compl. ¶ 33).

U.S. Patent No. 8,570,957 - “Extension of Power Headroom Reporting and Trigger Conditions”

The Invention Explained

  • Problem Addressed: A user device's "power headroom" is the difference between its maximum transmission power and its current transmission power. Standard reporting methods only convey positive headroom (i.e., available power). The patent notes that when a device is power-limited (has zero headroom), the base station does not know by how much the device is underpowered, hindering efficient resource management. (’957 Patent, col. 4:10-18).
  • The Patented Solution: The invention extends the concept of power headroom reporting to include negative values. A negative value explicitly quantifies the "missing power in dB to fulfill transmission requirements." (’957 Patent, Abstract). This gives the base station precise information to make better scheduling decisions, such as reducing the device's allocated bandwidth or assigning a less power-intensive modulation scheme. (’957 Patent, col. 5:25-34).
  • Technical Importance: This method enables more precise and efficient radio resource management, particularly for devices at the cell edge or in other power-constrained situations, thereby improving overall network performance. (Compl. ¶ 2).

Key Claims at a Glance

  • The complaint asserts one or more claims; independent apparatus claim 1 is representative. (Compl. ¶ 48).
  • Claim 1 of the ’957 Patent recites an apparatus with the essential elements of:
    • A processor configured to determine a power headroom report.
    • A transmitter configured to transmit the report.
    • Wherein the processor determines the report with both positive and negative values of power headroom.
    • Wherein negative values indicate the missing power in dB to fulfill transmission requirements.
  • The complaint makes a general allegation of infringement of "one or more claims." (Compl. ¶ 48).

U.S. Patent No. 8,867,472 - “Signalling of Channel Information”

Technology Synopsis

This patent addresses aperiodic channel state information (CSI) reporting in networks using carrier aggregation (combining multiple frequency bands). The technical problem is how a base station can efficiently request a detailed quality report for one specific carrier out of many without forcing the user device to send voluminous reports for all carriers. The solution provides methods for a base station to generate and send a request that triggers an aperiodic CSI report for a selected downlink component carrier. (Compl. ¶¶ 61, 70-71).

Asserted Claims

One or more claims, including independent claims 1, 15, 28, and 44. (Compl. ¶ 63).

Accused Features

The accused functionality involves base stations generating and sending requests for aperiodic channel information for a selected carrier, and user equipment receiving such requests and transmitting the corresponding channel information. (Compl. ¶¶ 70, 71).

U.S. Patent No. 8,457,676 - “Power Headroom Reporting Method”

Technology Synopsis

This patent addresses the conditions that trigger a user device to send a power headroom report. The technical challenge is balancing the base station's need for timely power information against the need to conserve uplink bandwidth and device battery life. The invention provides a method where the device sends a report only after a set of adjustable triggering criteria is met, such as a change in path loss exceeding a threshold or a certain amount of time passing since the last report. (Compl. ¶¶ 76, 85; ’676 Patent, Abstract).

Asserted Claims

One or more claims, including independent claims 1, 11, 19, and 33. (Compl. ¶ 78).

Accused Features

The accused functionality involves user equipment determining that at least one triggering criterion is met and, in response, providing a power control headroom report to the base station. (Compl. ¶ 85).

U.S. Patent No. 9,025,590 - “Carrier Aggregation with Power Headroom Report”

Technology Synopsis

This patent addresses how to format a power headroom report in a carrier aggregation context. The problem is that sending separate reports for each aggregated carrier is inefficient. The solution is a method where a single power headroom report control element contains a bitmap, where each bit corresponds to a specific carrier and indicates whether a power headroom report for that carrier is included in the message payload. (Compl. ¶¶ 91, 100; ’590 Patent, Abstract).

Asserted Claims

One or more claims, including independent claims 1 and 9. (Compl. ¶ 93).

Accused Features

The accused functionality involves base stations that are programmed to configure, receive, and process a power headroom report control element that includes a bitmap indicating which reports are being transmitted. (Compl. ¶ 100).

U.S. Patent No. 9,078,262 - “Signalling of Channel Information”

Technology Synopsis

This patent is from the same family as the ’472 patent and similarly addresses aperiodic channel information reporting with carrier aggregation. It provides methods for a base station to request, and a user device to provide, channel quality information for a specific, selected downlink component carrier from a plurality of available carriers, thereby managing uplink signaling overhead. (Compl. ¶¶ 104, 113).

Asserted Claims

One or more claims, including independent claims 1, 16, and 31. (Compl. ¶ 106).

Accused Features

The accused functionality involves base stations generating and sending a request for providing aperiodic channel information for a selected component carrier. (Compl. ¶ 113).

III. The Accused Instrumentality

Product Identification

  • The complaint identifies two broad categories of accused instrumentalities: “Sprint LTE User Equipment” and “Sprint Base Stations,” collectively referred to as “Sprint LTE User Equipment and Network Equipment.” (Compl. ¶ 33). The complaint provides extensive, non-exhaustive lists of accused products, including numerous smartphone and tablet models from Apple, HTC, LG, Samsung, and ZTE, as well as base station and network infrastructure equipment from Alcatel-Lucent, Ericsson, and Samsung. (Compl. ¶¶ 33, 48, 63).

Functionality and Market Context

  • The complaint alleges these products are designed to be compatible with and operate on Sprint’s LTE wireless network. (Compl. ¶¶ 33, 48). Their accused functionality is their implementation of various features of the LTE wireless standards, which allegedly practice the methods claimed in the patents-in-suit. (Compl. ¶ 2). For example, the user equipment is alleged to contain baseband processors and software specifically configured to perform functions such as assigning redundancy version sequences and determining power headroom reports with negative values, as described in Sections II and IV. (Compl. ¶¶ 40, 55). The base stations are alleged to be configured to perform corresponding network-side functions. (Compl. ¶¶ 41, 56). The complaint frames these features as critical to Sprint’s ability to offer competitive 4G LTE service. (Compl. ¶ 2).

IV. Analysis of Infringement Allegations

’022 Patent Infringement Allegations

Claim Element (from Independent Claim 1) Alleged Infringing Functionality Complaint Citation Patent Citation
detecting start of a system information message transmission window The Sprint User Equipment and Base Stations contain a baseband processor and software specifically programmed and/or configured to detect the start of a system information message transmission window. ¶¶40, 41 col. 2:40-42
and assigning a redundancy version sequence at the start of the transmission window... The Sprint User Equipment and Base Stations are programmed and/or configured to assign a redundancy version sequence at the start of the transmission window as claimed in the patent. ¶¶40, 41 col. 2:42-44
wherein the assignment includes excluding one or more of the predetermined subframes in even-numbered radio frames... The complaint alleges that the accused products practice the claimed method, which includes assigning the redundancy version sequence in a manner that excludes these specific subframes. ¶¶34, 40, 41 col. 16:1-11
and wherein the assignment includes excluding uplink subframes and multi-cast subframes... The complaint alleges that the accused products practice the claimed method, which includes assigning the redundancy version sequence in a manner that excludes uplink and multi-cast subframes. ¶¶34, 40, 41 col. 16:1-11

’957 Patent Infringement Allegations

Claim Element (from Independent Claim 1) Alleged Infringing Functionality Complaint Citation Patent Citation
a processor configured to determine a power headroom report Each of the Sprint User Equipment contains at least a baseband processor and software configured to determine a power headroom report. ¶55 col. 7:1-3
and a transmitter configured to transmit the headroom report... Each of the Sprint User Equipment contains at least a transceiver configured to transmit the determined power headroom report. ¶55 col. 7:3-4
wherein the processor is configured to determine the power headroom report with both positive and negative values... The baseband processor is specifically programmed to determine a power headroom report that includes both positive and negative values of power headroom as claimed in the patent. ¶55 col. 7:5-8
in which negative values indicate the missing power in dB to fulfill transmission requirements... The functionality is programmed such that the negative values correspond to the "missing power" required by the claim. ¶55 col. 7:7-9

Identified Points of Contention

  • Scope Questions: For the ’957 Patent, a potential point of contention is the definition of "negative values of power headroom." The analysis may question whether the accused devices' reporting of low power levels constitutes the specific "missing power in dB" calculation required by the patent’s claims and specification.
  • Technical Questions: For the ’022 Patent, a key evidentiary question will concern the specific assignment logic. The complaint alleges the devices perform the method, but the analysis will depend on evidence showing that the accused products’ software actually implements the specific exclusion rules recited in claim 1 (e.g., excluding subframes in even-numbered radio frames and excluding uplink/multi-cast subframes).

No probative visual evidence provided in complaint.

V. Key Claim Terms for Construction

For the ’022 Patent

  • The Term: "system information message transmission window"
  • Context and Importance: This term defines the temporal scope within which the claimed method operates. Its construction is critical because it determines when the obligation to assign an RV sequence begins and what subframes are subject to the claimed exclusion rules. Practitioners may focus on this term because the infringement analysis depends entirely on identifying this specific "window" in the accused LTE system's operation.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The term itself is not explicitly defined in the specification, which may suggest it should be given its plain and ordinary meaning in the context of LTE systems.
    • Evidence for a Narrower Interpretation: The specification repeatedly refers to exemplary window lengths, such as 15 ms, and depicts specific window structures in its figures. (e.g., ’022 Patent, Figs. 6A-8B). This may support an argument that the term is limited to the specific types of window structures disclosed in the preferred embodiments.

For the ’957 Patent

  • The Term: "negative values of power headroom"
  • Context and Importance: This term is the central inventive concept of the ’957 patent. The entire infringement case rests on whether the accused devices determine and transmit "negative values" as contemplated by the patent. Practitioners may focus on this term because it is not a standard industry term and its meaning is supplied by the patent itself.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: A party might argue that any reported power value below a predefined zero-point reference could be considered a "negative value."
    • Evidence for a Narrower Interpretation: The patent provides an explicit definition, stating that "negative values indicate the missing power in dB to fulfill transmission requirements." (’957 Patent, col. 7:7-9). The specification further explains this concept as reporting "negative headroom if the required transmit power according to the allocation scheme...requires higher power than the nominal maximum transmit power." (’957 Patent, col. 5:16-24). This intrinsic evidence provides strong support for a narrower construction tied to a specific calculation of a power deficit.

VI. Other Allegations

Indirect Infringement

  • The complaint alleges both induced and contributory infringement for all asserted patents. Inducement allegations are based on Defendants providing instructional materials, user manuals, and online support resources that allegedly "specifically teach" customers and end users to operate the accused equipment in a manner that infringes the patents. (Compl. ¶¶ 38, 53, 68, 83). Contributory infringement is alleged on the basis that the accused devices contain "proprietary hardware components and software instructions" that perform the claimed functions, are a "material part of the inventions," and are "not staple articles of commerce suitable for substantial non-infringing use." (Compl. ¶¶ 39, 54, 69, 84).

Willful Infringement

  • Willfulness is alleged for the ’022, ’957, ’472, and ’676 patents. (Compl. ¶ 39(d)). The allegations are based on alleged pre-suit knowledge. The complaint asserts that each Defendant, as a member of the 3GPP standards body, received actual notice of the patents (or their applications) when they were disclosed to ETSI as standard essential patents. These alleged notice dates range from August 2010 to March 2013, all preceding the 2015 filing date. (Compl. ¶¶ 35, 50, 65, 80). The complaint alleges that despite this knowledge, Defendants continued their infringing conduct, disregarding an objectively high likelihood of infringement. (Compl. ¶¶ 42, 57, 72, 87).

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

  • A central issue will be the patents' alleged standard-essential status. The Plaintiff’s assertion that the patents are essential to the LTE standard, and that Defendants had notice through standards bodies, will be critical for both willfulness and damages calculations, potentially implicating Fair, Reasonable, and Non-Discriminatory (FRAND) licensing obligations.
  • A key technical question will be one of claim scope versus standard compliance. The case will likely require a detailed analysis of whether practicing the mandatory sections of the 3GPP LTE standard necessarily results in infringement of the asserted claims, or if the claims cover optional features or include limitations that diverge from the standard's requirements.
  • A primary evidentiary question will be one of operational proof. Given the complaint's high-level allegations that the accused products are "programmed and/or configured" to perform the claimed steps, the case will likely turn on the technical evidence, such as source code analysis and device testing, that Plaintiff can present to demonstrate a direct mapping between the accused products' real-world operation and the specific technical limitations recited in the patent claims.