DCT

2:17-cv-00101

Red Rock Analytics LLC v. Samsung Electronics Co Ltd

Log In

I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 2:17-cv-00101, E.D. Tex., 02/01/2017
  • Venue Allegations: Plaintiff alleges venue is proper in the Eastern District of Texas because Defendants conduct business in the district, have regular and established places of business, and have committed the alleged acts of infringement within the district.
  • Core Dispute: Plaintiff alleges that Defendants’ products containing high-data-rate transceivers, such as those compliant with 802.11n and LTE standards, infringe a patent related to the calibration of signal imbalances in radio transceivers.
  • Technical Context: The technology concerns methods for correcting gain imbalances between the in-phase (I) and quadrature (Q) channels in wireless transceivers, a critical function for ensuring signal fidelity in modern high-speed communication systems.
  • Key Procedural History: The complaint notes that two certificates of correction were issued for the patent-in-suit, on November 1, 2016, and January 31, 2017, just prior to the complaint's filing. No other procedural events are mentioned.

Case Timeline

Date Event
2002-03-04 Patent Priority Date (via Provisional App. 60/361,630)
2008-03-18 U.S. Patent No. 7,346,313 Issues
2016-11-01 First Certificate of Correction for '313 Patent Issues
2017-01-31 Second Certificate of Correction for '313 Patent Issues
2017-02-01 Complaint Filed

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

U.S. Patent No. 7,346,313 - “Calibration of I-Q Balance in Transceivers”

  • Patent Identification: U.S. Patent No. 7,346,313, “Calibration of I-Q Balance in Transceivers,” issued March 18, 2008. (Compl. ¶10; ’313 Patent, p.1).

The Invention Explained

  • Problem Addressed: The patent addresses the technical challenge of maintaining precise gain balance between the in-phase (I) and quadrature (Q) signal channels in wireless transceivers, particularly in low-cost, direct-conversion architectures. Such imbalances can distort the signal, degrading performance for bandwidth-efficient modulations and becoming more severe at the lower supply voltages used in modern integrated circuits. (’313 Patent, col. 1:40-61).
  • The Patented Solution: The invention describes a system that performs a comprehensive, closed-loop calibration. It generates a known calibration signal within the transceiver's transmit chain, injects that signal into its own receive chain, and then observes the resulting signal at the baseband output. By analyzing the difference between the transmitted and received calibration signal, the system can identify and correct for I-Q gain imbalances across the entire transmit and receive signal paths, including the RF conversion stages. (’313 Patent, Abstract; col. 2:13-27, Fig. 4).
  • Technical Importance: This approach provides a method for comprehensive on-chip calibration, which is designed to be more accurate than prior art techniques that might only calibrate the baseband sections or fail to account for the entire signal path. (’313 Patent, col. 1:62-col. 2:10).

Key Claims at a Glance

  • The complaint asserts independent claims 1 and 7. (Compl. ¶12). The phrasing "including at least" suggests the right to assert additional claims may be reserved.
  • Independent Claim 1 (System) recites:
    • A transceiver system with a transmit chain and a receive chain.
    • A calibration subsystem with a signal path to inject a calibration RF signal from the transmit chain into the receive chain.
    • The purpose is to "independently calibrate the I-Q gain balance of the both transmit and receive chains in their entirety."
    • This is achieved via a "calibration cycle" that first determines transmitter I-Q gain settings while holding receiver settings constant, and then in turn determines receiver settings while holding transmitter settings constant.
  • Independent Claim 7 (System) recites a more detailed system with similar functionality, specifying:
    • A transmit chain with a signal generator, a baseband I-Q amplification subsystem, and a direct-conversion subsystem.
    • A receive chain with corresponding direct-conversion and baseband I-Q amplification subsystems.
    • A calibration subsystem with a signal path from the RF transmit port to the RF receive port, a processor to form an "observable indicator of I-Q imbalance," and a "channel gain adjuster."

III. The Accused Instrumentality

Product Identification

  • The complaint accuses a broad category of Samsung products that "include high data rate transceivers (e.g., 802.11n transceivers, LTE transceivers)." (Compl. ¶12). Specific examples cited include the 4G LTE Mobile Hotspot (SCH-LC11), cellular phones such as the Galaxy S4 and Galaxy S6, the Galaxy Tab S2 9.1 tablet, and several notebook computers. (Compl. ¶13).

Functionality and Market Context

  • The complaint alleges that the accused products contain transceivers that implement the patented calibration systems and methods to ensure signal quality for standards like 802.11n and LTE. (Compl. ¶12). It asserts these products are part of Samsung's substantial business in communications devices in the U.S. but does not provide specific details on the technical operation of the accused calibration functions. (Compl. ¶¶ 6, 8, 12).

IV. Analysis of Infringement Allegations

The complaint does not contain a claim chart or detailed, element-by-element infringement allegations. The following summary is based on the narrative allegations.

No probative visual evidence provided in complaint.

'313 Patent Infringement Allegations

Claim Element (from Independent Claim 1) Alleged Infringing Functionality Complaint Citation Patent Citation
A transceiver system for transmitting and receiving data using both I and Q channels, comprising: a transmit chain; a receive chain; and The accused products are alleged to contain high data rate transceivers (e.g., 802.11n, LTE) that necessarily include transmit and receive chains for wireless communication. ¶12 col. 5:26-45
a calibration subsystem comprising a signal path for injecting a calibration RF signal, generated in response to and as a function of a signal generated through the transmit chain, into the receive chain...in order to independently calibrate the I-Q gain balance of the both transmit and receive chains in their entirety; The transceivers in the accused products are alleged to implement calibration systems that use a signal path to loop a calibration signal from the transmit side to the receive side to correct for I-Q imbalance. ¶12 col. 2:13-23
wherein the calibration RF signal includes a calibration cycle, and the calibration cycle determines transmitter I-Q gain settings...while holding receive I-Q gain settings constant, and which in turn determines receiver I-Q gain settings...while holding the transmit I-Q gain settings constant. The transceivers in the accused products are alleged to implement calibration methods that perform an iterative calibration cycle, adjusting the transmitter and receiver independently as described in the claim. ¶12 col. 11:63-12:5
  • Identified Points of Contention:
    • Technical Questions: A central factual question for discovery will be whether the accused Samsung transceivers physically or logically implement a "signal path for injecting" a calibration signal from the transmit output to the receive input. The complaint provides no specific evidence on how Samsung's chips are architected.
    • Scope Questions: The infringement analysis will likely turn on whether the accused devices' calibration algorithms perform the specific iterative process required by the claims—namely, adjusting one chain's gain "while holding" the other's "constant." A key question is whether Samsung's method, if different, still falls within the claim's functional scope.

V. Key Claim Terms for Construction

  • The Term: "independently calibrate"

  • Context and Importance: This term defines the core functional step of the invention. The dispute will likely focus on the degree of separation required between the calibration of the transmit and receive chains. Practitioners may focus on this term because whether the accused calibration algorithm meets this "independent" standard, as further defined by the "while holding...constant" language, will be a critical infringement issue.

  • Intrinsic Evidence for Interpretation:

    • Evidence for a Broader Interpretation: The specification suggests the process is iterative and can be repeated, stating "the process could alternate several times if required," which may support a view that strict, sequential independence is not the only covered embodiment. (’313 Patent, col. 6:8-9).
    • Evidence for a Narrower Interpretation: The claim language itself provides a specific definition: "determines transmitter I-Q gain settings... while holding receive I-Q gain settings constant, and which in turn determines receiver I-Q gain settings... while holding the transmit I-Q gain settings constant." (’313 Patent, col. 12:1-5). This supports a more structured, sequential definition of "independently."

  • The Term: "in their entirety"

  • Context and Importance: This term addresses the comprehensiveness of the calibration. A key issue will be whether the accused system must calibrate every single gain stage in the transmit and receive paths to meet this limitation. Practitioners may scrutinize this term to argue whether an accused system that, for instance, calibrates baseband and RF stages via separate mechanisms infringes.

  • Intrinsic Evidence for Interpretation:

    • Evidence for a Broader Interpretation: The term can be argued to distinguish the invention from prior art that was piecemeal, without necessarily requiring a single calibration process to touch every single circuit component from digital-to-analog converter to antenna. (’313 Patent, col. 1:62-col. 2:2).
    • Evidence for a Narrower Interpretation: The detailed description states the goal is for the calibration signal to include "all gains relevant to normal operation in the transmit chain," which could be used to argue for a very high standard of comprehensiveness. (’313 Patent, col. 5:40-44).

VI. Other Allegations

  • Indirect Infringement: The complaint alleges both active inducement (§ 271(b)) and contributory infringement (§ 271(c)). For inducement, it alleges Samsung provides instructions and technical support that encourage infringing use. (Compl. ¶14). For contributory infringement, it alleges the transceiver components are a material part of the invention and are not staple articles of commerce suitable for substantial non-infringing use. (Compl. ¶15).
  • Willful Infringement: The complaint does not use the word "willful" but alleges that "at least as of the filing of this complaint, Defendants have knowledge of the '313 Patent." (Compl. ¶¶ 14-15). This allegation of post-suit knowledge could be used to support a later claim for enhanced damages under 35 U.S.C. § 284, which is requested in the prayer for relief. (Compl. ¶19).

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

  • A core issue will be one of evidentiary proof: what evidence will discovery yield about the actual architecture and operation of Samsung’s accused transceivers? The viability of the infringement case rests on whether Plaintiff can demonstrate that the accused chips contain the "signal path" and execute the specific iterative calibration algorithm recited in the claims.
  • The case will also turn on a question of definitional scope: can the claim term "independently calibrate," defined by the "while holding... constant" language, be construed to read on the specific calibration algorithm implemented by Samsung, or is there a fundamental mismatch in their operational sequence?
  • Finally, a key question for damages and any indirect infringement claim will be one of knowledge and intent: given that the complaint only alleges knowledge of the patent as of the filing date, what evidence, if any, can Plaintiff find to establish pre-suit knowledge or the specific intent required to prove inducement?