DCT

6:21-cv-00346

Red Rock Analytics LLC v. Apple Inc

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Key Events
Complaint

I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 6:21-cv-00346, W.D. Tex., 04/08/2021
  • Venue Allegations: Plaintiff alleges venue is proper in the Western District of Texas because both Apple and Qualcomm maintain regular and established places of business in the district, including corporate offices and, for Apple, retail stores.
  • Core Dispute: Plaintiff alleges that Defendants' 5G and Wi-Fi 6 wireless transceivers, and the Apple products incorporating them, infringe a patent related to the calibration of in-phase (I) and quadrature (Q) signal balance in such devices.
  • Technical Context: The patent addresses methods for correcting signal imbalances in RF transceivers, a fundamental technical challenge for achieving high-performance, bandwidth-efficient digital communications in integrated circuits.
  • Key Procedural History: The complaint alleges that Apple had notice of the patent-in-suit as of April 18, 2019, due to a prior lawsuit filed by Red Rock in the Eastern District of Texas. The complaint also alleges that Qualcomm had notice of the patent as early as November 7, 2008, from patent prosecution activities, and later through a subpoena in a separate 2017 civil action.

Case Timeline

Date Event
2002-03-04 ’313 Patent Priority Date (Provisional App. 60/361,630)
2008-03-18 ’313 Patent Issue Date
2008-11-07 Qualcomm allegedly received International Search Report citing '313 Patent
2009-10-16 Qualcomm allegedly received Notice of References Cited citing '313 Patent
2011-03-16 Qualcomm allegedly submitted IDS citing '313 Patent
2017-08-01 Red Rock allegedly served Qualcomm with subpoena referencing '313 Patent
2019-04-18 Apple allegedly served with prior complaint asserting '313 Patent
2021-04-08 Complaint Filing Date

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

U.S. Patent No. 7,346,313 - "Calibration of I-Q Balance in Transceivers," issued March 18, 2008

The Invention Explained

  • Problem Addressed: The patent’s background section describes the difficulty of maintaining "adequate gain balance between the I and Q channels" in modern transceivers, particularly "direct-conversion" types that are popular for low-cost integrated circuits (’313 Patent, col. 1:42-47). This imbalance, exacerbated by the trend toward lower supply voltages, can distort complex signals and increase error rates (’313 Patent, col. 1:47-56).
  • The Patented Solution: The invention proposes a comprehensive calibration system where a known calibration signal is generated in the transceiver's transmit chain, looped back and injected into its receive chain, and then observed at the receiver's output (’313 Patent, Abstract). By analyzing how this signal is altered as it passes through both the transmit and receive paths, the system can "independently calibrate the I-Q gain balance of the both transmit and receive chains in their entirety" (’313 Patent, col. 2:18-22).
  • Technical Importance: This approach allows for the correction of imbalances not only in the baseband sections but also in the RF up-conversion and down-conversion stages, which is critical for enabling low-cost, integrated transceivers to support high-order, bandwidth-efficient modulations (’313 Patent, col. 1:61-65; col. 2:2-6).

Key Claims at a Glance

  • The complaint asserts infringement of numerous claims, including independent claims 7 and 16 (Compl. ¶18, ¶25).
  • Independent Claim 7 recites a transceiver system comprising:
    • A transmit chain with a signal generator, an I-Q amplification subsystem, and a direct-conversion subsystem.
    • A receive chain with an RF receive port, a direct-conversion subsystem, and an I-Q amplification subsystem.
    • A "calibration subsystem" which includes a "signal path for injecting the calibration RF signal from the RF transmit signal port to the RF receive signal port," a processor for forming an "observable indicator of I-Q imbalance," and a channel gain adjuster.
  • Independent Claim 16 is similarly structured to claim 7, reciting a transceiver system with a transmit chain, a receive chain, and a calibration subsystem that includes a signal path for injecting a calibration signal.
  • The complaint reserves the right to assert additional claims, including numerous dependent claims (Compl. ¶18, ¶25).

III. The Accused Instrumentality

Product Identification

The accused instrumentalities are 5G and Wi-Fi 6 wireless transceivers manufactured by Qualcomm, including at least the SDR865, SDX55M, and SMR526 models, and Apple products that incorporate them, including the iPhone 12, iPhone 12 mini, iPhone 12 Pro, and iPhone 12 Pro Max (Compl. ¶15, ¶18, ¶25).

Functionality and Market Context

The complaint alleges these transceivers provide wireless communication capabilities for Apple's products by complying with standards such as "3GPP release 15" for 5G and "IEEE 802.11ax" for Wi-Fi 6 (Compl. ¶18, ¶25). The integration of these advanced transceivers is central to the functionality and market positioning of Apple's flagship smartphones (Compl. ¶15, ¶18).

IV. Analysis of Infringement Allegations

The complaint does not contain a claim chart but incorporates by reference an "Exhibit B" which was not provided with the complaint document (Compl. ¶19, ¶26). The complaint's narrative infringement theory is that the accused Qualcomm transceivers, which are integrated into Apple's iPhones, are "5G wireless transceivers" and "Wi-Fi 6 wireless transceivers" that necessarily "infringe the systems and methods claimed by the '313 Patent" (Compl. ¶18, ¶25). The allegations are made on "information and belief" and are supported by reference to the accused products' compliance with public wireless standards, such as 3GPP and IEEE 802.11 (Compl. ¶18, ¶25). The core of the allegation is that to meet the performance requirements of these standards, the accused transceivers must implement a form of I-Q balance calibration that falls within the scope of the asserted claims.

No probative visual evidence provided in complaint.

V. Key Claim Terms for Construction

"calibration subsystem" (Claim 7)

  • Context and Importance: This term defines the core of the inventive concept. Its construction will determine what structural and functional components are required to meet the limitation. Practitioners may focus on this term because the infringement analysis will depend on whether the integrated calibration circuits in modern SoCs meet the patent's description.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The patent summary describes the invention broadly as a system where "A calibration RF signal, generated in response to and as a function of a signal generated through the transmit chain, is injected into the receive chain" (’313 Patent, col. 2:16-19). This could support a reading that covers any on-chip loopback calibration method.
    • Evidence for a Narrower Interpretation: Claim 7 explicitly requires the subsystem to include "a signal path for injecting the calibration RF signal from the RF transmit signal port to the RF receive signal port" (’313 Patent, col. 12:41-44). A defendant may argue this language requires a distinct physical path between structures that function as "ports," potentially limiting the claim's applicability to highly integrated systems where such discrete ports may not exist.

"independently calibrate" (Claim 1)

  • Context and Importance: This term is central to how the calibration process is performed. Whether the accused devices perform calibration "independently" for the transmit and receive chains will be a key factual question.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The term itself might be argued to mean simply that the transmit chain can be adjusted without necessarily altering the receive chain's settings, and vice versa, allowing for separate optimization.
    • Evidence for a Narrower Interpretation: The detailed description provides a specific sequence: "minimizing the imbalance observable with respect to gain adjustments in the transmit chain while holding the gains in the receive chain fixed, then minimizing the imbalance... in the receive chain while holding the gains in the transmit chain fixed" (’313 Patent, col. 6:1-8). This language suggests a specific, sequential process that a court could read into the term "independently," potentially narrowing its scope.

VI. Other Allegations

Indirect Infringement

The complaint alleges inducement against Apple, based on acts such as "selling Infringing Products to its customers," "marketing," and providing "instructions, technical support, and other support and encouragement" for their use (Compl. ¶21). It alleges contributory infringement against Apple by providing hardware and software components that "are a material part of the inventions" and "not staple articles of commerce" (Compl. ¶22). Similar allegations are made against Qualcomm (Compl. ¶31-32).

Willful Infringement

The complaint alleges willful infringement by both defendants based on pre-suit knowledge of the ’313 Patent. For Apple, knowledge is alleged from at least April 18, 2019, via a prior lawsuit (Compl. ¶20, ¶24). For Qualcomm, knowledge is alleged from multiple events, including a 2008 International Search Report, a 2011 Information Disclosure Statement, and a 2017 subpoena (Compl. ¶27-30, ¶34).

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

  1. A central issue will be one of claim scope and technical implementation: Can the patent's description of a "calibration subsystem" with a "signal path" between transmit and receive "ports"—language rooted in a 2002-era understanding of transceiver design—be construed to read on the highly integrated, on-chip calibration loops used in modern 5G and Wi-Fi 6 Systems-on-a-Chip?
  2. A second key question will be evidentiary sufficiency: Does the complaint’s assertion, based on "information and belief" and compliance with general industry standards, provide sufficient factual plausibility to demonstrate that the accused products practice the specific calibration method claimed, or will it be vulnerable to an early-stage dismissal challenge?
  3. Finally, a critical question for assessing risk and potential damages will be the viability of the willfulness claim: The complaint presents specific, dated allegations of pre-suit knowledge against both defendants. The extent to which this alleged knowledge can be proven and whether Defendants' subsequent conduct is found to be egregious will likely be a primary focus of the litigation.