DCT

1:25-cv-01945

Active Wireless Tech LLC v. Qualcomm Inc

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Key Events
Complaint

I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 1:25-cv-01945, W.D. Tex., 11/26/2025
  • Venue Allegations: Plaintiff alleges venue is proper in the Western District of Texas because Defendants maintain at least two regular and established places of business in Austin, Texas.
  • Core Dispute: Plaintiff alleges that Defendant’s 3GPP-compliant mobile platforms and modem-RF systems infringe six patents related to 4G LTE and 5G New Radio (NR) wireless communication technologies.
  • Technical Context: The patents relate to fundamental aspects of modern wireless communication, including power control, channel state reporting, and control channel design, which are critical for the performance and efficiency of devices operating on 4G and 5G networks.
  • Key Procedural History: The complaint alleges that Defendant had actual notice of the patents-in-suit as of an April 11, 2025 letter, which forms the basis for the willfulness allegations.

Case Timeline

Date Event
2016-08-09 U.S. Patent No. 10,805,955 Priority Date
2016-08-11 U.S. Patent No. 10,785,764 Priority Date
2017-06-15 U.S. Patent No. 10,531,443 Priority Date
2017-08-10 U.S. Patent No. 10,601,566 Priority Date
2018-01-11 U.S. Patent No. 10,855,432 Priority Date
2018-05-10 U.S. Patent No. 11,019,557 Priority Date
2020-01-07 U.S. Patent No. 10,531,443 Issued
2020-03-24 U.S. Patent No. 10,601,566 Issued
2020-09-22 U.S. Patent No. 10,785,764 Issued
2020-10-13 U.S. Patent No. 10,805,955 Issued
2020-12-01 U.S. Patent No. 10,855,432 Issued
2021-05-25 U.S. Patent No. 11,019,557 Issued
2025-04-11 Plaintiff allegedly provided Defendant with actual notice of infringement
2025-11-26 Complaint Filed

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

U.S. Patent No. 10,805,955 - "Terminal Apparatus, Base Station Apparatus, Communication Method, and Integrated Circuit," Issued October 13, 2020 (’955 Patent)

The Invention Explained

  • Problem Addressed: The patent addresses the need for a terminal apparatus (e.g., a mobile phone) to correctly determine its transmission power for the Physical Uplink Shared Channel (PUSCH), particularly in systems like Licensed Assisted Access (LAA) where transmissions may not always start at the beginning of a transmission slot due to "Listen-Before-Talk" requirements (’955 Patent, col. 1:15-41; Compl. ¶¶ 41-42).
  • The Patented Solution: The invention provides a method for determining transmit power based on the number of Single Carrier-Frequency Division Multiple Access (SC-FDMA) symbols used for the transmission (’955 Patent, col. 2:1-12). This calculation is adjusted by a specific parameter ("NLBT") which accounts for cases where the initial symbol of a transmission is generated based on the content of a subsequent symbol, a scenario that occurs when a transmission does not start at the beginning of a slot (’955 Patent, Abstract; Compl. ¶37).
  • Technical Importance: This approach allows for more accurate and efficient power control in dynamic spectrum environments like LAA, ensuring reliable communication without using excessive power (’955 Patent, col. 1:42-51).

Key Claims at a Glance

  • The complaint asserts at least independent claim 1 (Compl. ¶37).
  • Claim 1 requires a terminal apparatus with:
    • Transmission circuitry to transmit a transport block on a PUSCH.
    • Physical layer processing circuitry to determine transmit power for the PUSCH based on a number of SC-FDMA symbols.
    • Wherein the number of SC-FDMA symbols is given based on a parameter "NLBT" and the number of symbols in an uplink slot.
    • And wherein "NLBT" is 1 in a case that a signal of a SC-FDMA symbol with index l is generated based on a content for resource elements corresponding to a SC-FDMA symbol with index l+1.
  • The complaint does not explicitly reserve the right to assert dependent claims.

U.S. Patent No. 10,855,432 - "User Equipments, Base Stations and Methods," Issued December 1, 2020 (’432 Patent)

The Invention Explained

  • Problem Addressed: In advanced wireless systems like 5G NR, a user equipment (UE) can operate on different segments of bandwidth called downlink bandwidth parts (DL BWPs). Managing channel state reporting resources, such as Channel State Information-Reference Signals (CSI-RS), across multiple BWPs can be inefficient if the UE continues to process configurations for BWPs that are not currently active (’432 Patent, col. 1:55-2:15).
  • The Patented Solution: The invention teaches a user equipment that, upon deactivation of a specific DL BWP, considers the semi-persistent CSI-RS and Channel State Information-Interference Measurement (CSI-IM) resource configurations associated with that BWP to be "suspended" (’432 Patent, Abstract). The UE receives explicit activation and deactivation commands for these resource configurations, which are linked to a specific DL BWP, thereby preventing unnecessary processing when the BWP is inactive (’432 Patent, col. 15:1-20; Compl. ¶50).
  • Technical Importance: This method improves UE power efficiency and reduces processing load by ensuring that channel state measurement and reporting activities are only performed for currently active bandwidth parts (’432 Patent, col. 2:8-15).

Key Claims at a Glance

  • The complaint asserts at least independent claim 1 (Compl. ¶50).
  • Claim 1 requires a user equipment that communicates with a base station on one or more DL BWPs, comprising:
    • Receiving circuitry configured to receive an activation command for a semi-persistent CSI-RS and/or CSI-IM resource configuration, with the configuration being associated with a DL BWP.
    • The receiving circuitry is also configured to receive a deactivation command for that resource configuration.
    • Processing circuitry configured to consider that the semi-persistent CSI-RS and/or CSI-IM resource configuration is suspended in a case that the associated DL BWP is deactivated.
  • The complaint does not explicitly reserve the right to assert dependent claims.

U.S. Patent No. 10,531,443 - "Physical Uplink Control Channel (PUCCH) Format Adaptation for 5th Generation (5G) New Radio (NR)," Issued January 7, 2020 (’443 Patent)

  • Technology Synopsis: The patent relates to adapting the format of the Physical Uplink Control Channel (PUCCH) for reporting Hybrid Automatic Repeat Request Acknowledgement (HARQ-ACK) feedback. The invention provides a method for a user equipment to report either a single HARQ-ACK bit for an entire data block or multiple bits for individual code block groups (CBGs), depending on whether the data was scheduled in a common search space (CSS) or a user-equipment-specific search space (USS). (Compl. ¶¶ 27, 62; ’443 Patent, col. 21:39-65).
  • Asserted Claims: At least independent claim 1 (Compl. ¶62).
  • Accused Features: The accused products allegedly implement this adaptive HARQ-ACK reporting scheme, reporting one bit for PDSCH scheduled in a CSS and all CBG bits for PDSCH scheduled in a USS, in compliance with 3GPP standards (Compl. ¶¶ 64-65).

U.S. Patent No. 11,019,557 - "Apparatus and Method for Acquisition of Periodically Broadcasted System Information in Wireless Communication," Issued May 25, 2021 (’557 Patent)

  • Technology Synopsis: This patent addresses the process for a UE to acquire system information (SI). The invention describes a method where a UE receives a first type of system information block (SIB1) that schedules periodically broadcasted SI messages. If the UE fails to acquire an SI message, it initiates a re-acquisition process to re-acquire the SIB1. (Compl. ¶¶ 28, 73; ’557 Patent, Abstract).
  • Asserted Claims: At least independent claim 1 (Compl. ¶73).
  • Accused Features: The accused products are alleged to perform the claimed SI acquisition and re-acquisition process, where they initiate an SI acquisition process based on scheduling information in SIB1 and, upon failure, re-acquire SIB1 to restart the process (Compl. ¶¶ 74-78).

U.S. Patent No. 10,785,764 - "Information Change Transmission Method and Device for Single-Cell Multicast Service," Issued September 22, 2020 (’764 Patent)

  • Technology Synopsis: The patent relates to information change notifications for Single-Cell Multicast Control Channel (SC-MCCH) information. A UE receives control information (DCI) on a narrowband control channel (NPDCCH). If a second DCI format indicates an SC-MCCH change, the UE then acquires the new SC-MCCH information based on a first DCI format. (Compl. ¶¶ 29, 86; ’764 Patent, Abstract).
  • Asserted Claims: At least independent claim 1 (Compl. ¶86).
  • Accused Features: The accused products are alleged to receive different DCI formats on an NPDCCH and, upon receiving a DCI format that indicates an SC-MCCH change notification, acquire the new SC-MCCH information based on another DCI format that indicates the resource for its transmission (Compl. ¶¶ 87-90).

U.S. Patent No. 10,601,566 - "Multiple Slot Long Physical Uplink Control Channel (PUCCH) Design for 5th Generation (5G) New Radio (NR)," Issued March 24, 2020 (’566 Patent)

  • Technology Synopsis: The patent describes a design for a Physical Uplink Control Channel (PUCCH) that spans multiple slots. The invention includes determining the multi-slot PUCCH based on signaling from a base station, determining a frequency hopping method, and transmitting uplink control information (UCI) such that the number and location of PUCCH symbols are the same in each slot. (Compl. ¶¶ 30, 98; ’566 Patent, Abstract).
  • Asserted Claims: At least independent claim 1 (Compl. ¶98).
  • Accused Features: The accused products allegedly determine that a PUCCH spans multiple slots based on base station signaling and transmit UCI with frequency hopping, where the PUCCH transmission in each slot has the same number of symbols and the same starting symbol (Compl. ¶¶ 99-101).

III. The Accused Instrumentality

Product Identification

  • The accused products are a wide range of Qualcomm's mobile platforms and modem-RF systems, including numerous generations of the Snapdragon 8, 7, 6, and 4 series, as well as Snapdragon X50 and X55 5G Modem-RF Systems (Compl. ¶31).

Functionality and Market Context

  • The complaint alleges these products are integrated circuits (chips) that provide the core processing and wireless communication functionalities for mobile devices such as smartphones (Compl. ¶31). The allegations center on the products' compliance with 3GPP standards for 4G LTE and 5G NR, which allegedly causes them to practice the claimed inventions (Compl. ¶¶ 31, 37, 50). Qualcomm is identified as a premier manufacturer of such integrated circuits for the global wireless device industry (Compl. ¶5).

IV. Analysis of Infringement Allegations

’955 Patent Infringement Allegations

Claim Element (from Independent Claim 1) Alleged Infringing Functionality Complaint Citation Patent Citation
a terminal apparatus comprising: transmission circuitry, configured to... transmit a transport block on a Physical Uplink Channel (PUSCH) The accused products are used in terminal apparatuses that transmit transport blocks on the PUSCH, as specified by 3GPP standards. The complaint provides an excerpt from a standard showing the mapping of the UL-SCH transport channel to the PUSCH physical channel. (Table 4.1-1, Compl. p. 11). ¶38 col. 10:1-10
and physical layer processing circuitry configured to... determine transmit power for the PUSCH at least based on a number of Single Carrier (SC)-Frequency Division Multiple Access (FDMA) symbols... The accused products determine PUSCH transmit power based on formulas defined in 3GPP standards, which include a term for the number of SC-FDMA symbols for the initial PUSCH transmission. ¶39 col. 10:11-20
wherein: the number of the SC-FDMA symbols... is given based on NLBT and a number of SC-FDMA symbols included in a uplink slot NULsymb The number of SC-FDMA symbols for the transmission is calculated using a formula from the 3GPP standard that includes terms functionally equivalent to "NUL_symb" and parameters that represent "NLBT". ¶40 col. 10:21-30
and the NLBT is 1 in a case that a signal of a SC-FDMA symbol with index l is generated, based on a content for resource elements, corresponding to a SC-FDMA symbol with index l+1. In Licensed Assisted Access (LAA) mode, when a transmission start is delayed due to Listen-Before-Talk (LBT), the PUSCH starting position is not symbol 0. The complaint cites a 3GPP table where starting positions '01' and '10' correspond to non-zero start times, which allegedly makes the equivalent of "NLBT" equal to 1. This table showing PUSCH starting positions provides key visual evidence for this allegation. (Table 5.3.3.1.1A-1, Compl. p. 16). ¶41, ¶42 col. 10:31-40

Identified Points of Contention

  • Scope Questions: A central question may be whether the parameters defined in the 3GPP standards (e.g., "NPUSCH-initial_start") are coextensive with the claimed term "NLBT". The analysis will likely focus on mapping the standard's implementation of LAA transmissions to the specific functional requirements of claim 1.
  • Technical Questions: The dispute may turn on whether the accused products' signal generation process, when starting a PUSCH transmission after the beginning of a slot, technically performs the function of generating a signal for one symbol "based on a content for resource elements, corresponding to a... symbol with index l+1," as required by the claim.

’432 Patent Infringement Allegations

Claim Element (from Independent Claim 1) Alleged Infringing Functionality Complaint Citation Patent Citation
a user equipment that communicates with a base station apparatus on one or more downlink bandwidth parts (DL BWPs) The accused products are used in UEs that operate on one or more DL BWPs in a serving cell, as defined by 3GPP standards. The complaint provides an excerpt describing BWP operation. (Compl. p. 20). ¶51 col. 15:1-5
comprising: receiving circuitry, configured to receive an activation command for at least one of a semi-persistent channel state information-reference signal (CSI-RS) and a channel state information-interference measurement (CSI-IM) resource configuration... The accused products receive activation commands for semi-persistent CSI-RS/CSI-IM resource sets via a MAC Control Element (MAC CE), as specified in the standards. The complaint includes a screenshot detailing the fields of the "SP CSI-RS/CSI-IM Resource Set Activation/Deactivation MAC CE." (Compl. p. 22). ¶52 col. 15:6-12
the semi-persistent CSI-RS and CSI-IM resource configuration being associated with a DL BWP of the on one or more DL BWPs The 3GPP standards allegedly specify that each CSI Resource Setting is located in a DL BWP, linking the resource configuration to a specific BWP. ¶52 col. 15:13-16
the receiving circuitry, configured to receive a deactivation command for the at least one of semi-persistent CSI-RS, and CSI-IM resource configuration The accused products receive deactivation commands for the same resources via the same MAC CE mechanism used for activation. The "A/D" field in the MAC CE indicates activation or deactivation. ¶53 col. 15:17-20
and processing circuitry, configured to consider that the at least one of the semi-persistent CSI-RS and CSI-IM resource configuration is suspended, in a case that the associated DL BWP is deactivated. The complaint alleges that according to the 3GPP standard, if a UE has an active semi-persistent CSI-RS/CSI-IM configuration, it is "considered to be active when the corresponding DL BWP is active, otherwise they are considered suspended." ¶54 col. 15:21-26

Identified Points of Contention

  • Scope Questions: The primary point of contention will likely be the construction of the term "suspended." The defense may argue that the standard's language "considered suspended" is a legal or logical fiction for standards-compliance purposes and does not describe the specific technical state of being "suspended" as taught and claimed in the patent.
  • Technical Questions: The analysis will question what evidence demonstrates that the accused products' processing circuitry performs the affirmative step of considering the configuration "suspended." Plaintiff's theory appears to rely on the argument that compliance with the standard necessitates performing this claimed function.

V. Key Claim Terms for Construction

’955 Patent: "a signal of a SC-FDMA symbol with index l is generated, based on a content for resource elements, corresponding to a SC-FDMA symbol with index l+1"

  • The Term: "...generated, based on a content for resource elements, corresponding to a SC-FDMA symbol with index l+1"
  • Context and Importance: This functional language is the core of the novelty described in claim 1, defining the specific condition under which "NLBT" is 1. Its construction will determine whether the signal processing that occurs in an LAA transmission with a delayed start meets the claim's requirements. Practitioners may focus on this term because it links the abstract parameter "NLBT" to a concrete physical layer action.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The specification may describe the generation of SC-FDMA signals in general terms, potentially allowing for any process where the signal for one symbol period is influenced by data intended for the next symbol period to meet the limitation (’955 Patent, col. 5:1-20).
    • Evidence for a Narrower Interpretation: The detailed description likely provides specific embodiments or mathematical formulas illustrating this "generation" process. These examples could be used to argue that the claim requires a specific type of signal processing (e.g., a particular windowing or filtering operation) that is directly dependent on the data of the subsequent symbol, rather than just a timing shift (’955 Patent, col. 9:1-10:40).

’432 Patent: "suspended"

  • The Term: "suspended"
  • Context and Importance: This term is critical to the infringement analysis. The complaint's theory hinges on the allegation that when a DL BWP is deactivated, the associated CSI-RS/CSI-IM configuration enters a "suspended" state. The definition of this term will determine whether the operational state of the accused products meets this limitation.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The patent specification may use "suspended" interchangeably with terms like "inactive" or "not in use," suggesting a general state where the UE is not required to act on the configuration. This would align well with the complaint's reliance on the standard's phrase "considered suspended." (’432 Patent, col. 8:30-45).
    • Evidence for a Narrower Interpretation: The abstract and detailed description may describe "suspended" as a specific technical state, such as temporarily disabling a software module, clearing a memory buffer, or flagging a resource as unavailable for processing. This could require Plaintiff to provide evidence of the internal software or hardware state of the accused products, beyond merely showing compliance with the standard's logical model (’432 Patent, col. 15:21-26).

VI. Other Allegations

Indirect Infringement

  • For all six patents, the complaint alleges both induced and contributory infringement. The inducement theory is based on allegations that Defendant provides the accused chipsets to its customers (e.g., device manufacturers) along with technical support, product manuals, and other documentation that instruct them on how to implement these products in 3GPP-compliant devices, which allegedly directly infringe the patents (Compl. ¶¶ 43, 55). The contributory infringement theory alleges the accused components are material to the inventions, are not staple articles of commerce, and are known by Defendant to be especially made for use in an infringing manner (Compl. ¶¶ 44, 56).

Willful Infringement

  • The complaint alleges that Defendant’s infringement has been willful for all six patents, based on alleged pre-suit knowledge stemming from a notice letter sent by Plaintiff on April 11, 2025 (Compl. ¶¶ 45, 57).

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

  • Standard Essentiality and Claim Mapping: A dispositive issue for the entire case will be whether the functionality described in the cited 3GPP standards, which the accused products are alleged to implement, falls within the scope of the patent claims. The litigation will likely focus on a meticulous mapping of the standards' technical specifications to the specific language of the asserted claims, raising underlying questions about whether these patents are, in effect, being asserted as Standard Essential Patents.
  • Functional vs. Logical States: A key evidentiary question, particularly for patents like the ’432 Patent, will be one of functional operation versus logical description. Does the standard's statement that a resource is "considered suspended" upon BWP deactivation merely describe a logical state for rules-based compliance, or does it necessarily require the accused product's circuitry to enter the specific technical state of being "suspended" as claimed in the patent?
  • Technical Equivalence: The infringement analysis for patents like the ’955 Patent will likely turn on a question of technical equivalence. Does the combination of parameters used in the 3GPP standards to calculate PUSCH transmission power in LAA mode perform the same function, in substantially the same way, to achieve the same result as the method defined by the claim's "NLBT" parameter, or is there a fundamental mismatch in their technical operation?