DCT
6:23-cv-00375
ParkerVision Inc v. MediaTek Inc
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: ParkerVision, Inc. (Florida)
- Defendant: MediaTek Inc. (Taiwan) and MediaTek USA Inc. (Delaware)
- Plaintiff’s Counsel: The Mort Law Firm, PLLC; Daignault Iyer LLP
- Case Identification: 6:23-cv-00375, W.D. Tex., 05/17/2023
- Venue Allegations: Plaintiff alleges venue is proper in the Western District of Texas because Defendants maintain a regular and established place of business in the district, have committed acts of infringement there, and have purposefully availed themselves of the laws of Texas and the United States.
- Core Dispute: Plaintiff alleges that Defendant’s wireless integrated circuits infringe patents related to radio frequency (RF) signal down-conversion and multi-protocol communication technologies.
- Technical Context: The technology concerns fundamental methods for processing RF signals in transceivers, a core component in billions of modern wireless devices.
- Key Procedural History: The complaint alleges that the parties met in April 2010 to discuss Plaintiff's direct-conversion technology, which is related to the patents-in-suit. The complaint also references other litigation involving Plaintiff and Defendants, as well as Plaintiff against other technology companies, suggesting an ongoing enforcement campaign for this patent portfolio.
Case Timeline
| Date | Event |
|---|---|
| 1998-10-21 | Priority Date for ’177 and ’528 Patents |
| 1999-03-03 | Priority Date for ’686 Patent |
| 2009-01-27 | U.S. Patent No. 7,483,686 Issued |
| 2010-04-01 | Alleged meeting between ParkerVision and MediaTek USA |
| 2011-01-04 | U.S. Patent No. 7,865,177 Issued |
| 2015-08-25 | U.S. Patent No. 9,118,528 Issued |
| 2023-05-17 | Complaint Filed |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 7,483,686 - "Universal Platform Module and Methods and Apparatuses Relating Thereto Enabled by Universal Frequency Translation Technology"
- Issued: January 27, 2009
The Invention Explained
- Problem Addressed: The patent’s background section identifies the technical challenge of designing communication devices that can operate across multiple, disparate wireless protocols (e.g., WLAN, Bluetooth, cellular) without requiring numerous, complex, and power-hungry hardware components for each protocol (’686 Patent, col. 6:10-30).
- The Patented Solution: The invention proposes a "universal platform module" (UPM) architecture built around a core "universal frequency translation" (UFT) module. This UFT module is described as a flexible component capable of efficiently up-converting or down-converting signals for various communication standards, allowing a single hardware platform to be configured to handle multiple protocols, potentially at the same time (’686 Patent, Abstract; col. 7:55-67). The UFT module itself operates by using a switch to transfer energy from an incoming signal to a storage element, thereby creating a frequency-translated output signal (’686 Patent, col. 50:55-51:3).
- Technical Importance: This unified architecture was designed to reduce the size, cost, and power consumption of multi-mode wireless transceivers by replacing multiple dedicated RF circuits with a single, configurable system (Compl. ¶33, ¶35).
Key Claims at a Glance
- The complaint asserts independent method claim 11 (Compl. ¶51).
- Claim 11 requires a method for performing simultaneous multi-platform operations by:
- Controlling a multi-platform module that includes a plurality of transceivers, each having a frequency translation module.
- The frequency translation module must comprise a switch (to sub-sample and transfer energy from a first signal) and a storage module (to store the energy).
- A second signal, of a different frequency, is generated from the stored energy.
- Simultaneously operating a first transceiver according to a first communication protocol (e.g., Wi-Fi).
- Simultaneously operating a second transceiver according to a second communication protocol (e.g., Bluetooth).
- The complaint does not explicitly reserve the right to assert other claims.
U.S. Patent No. 7,865,177 - "Method and System for Down-Converting An Electromagnetic Signal, And Transforms For Same, And Aperture Relationships"
- Issued: January 4, 2011
The Invention Explained
- Problem Addressed: The patent describes conventional RF receivers as being complex, expensive, and power-inefficient due to their reliance on multiple intermediate frequency (IF) stages, mixers, and filters, which are difficult to integrate onto a single chip (’177 Patent, col. 31:31-50; col. 32:5-20).
- The Patented Solution: The invention discloses a more direct method for down-converting an RF signal by using an "aliasing signal" to under-sample the incoming modulated carrier. This process involves performing a "matched filtering/correlating operation" that repeatedly samples the incoming signal, accumulates the energy from these samples (e.g., in a capacitor), and thereby produces a down-converted signal directly, without the need for traditional IF stages (’177 Patent, Abstract; col. 3:20-29). Figure 148 of the patent illustrates this high-level process of performing a matched filtering operation, accumulating the result, and outputting the down-converted signal (’177 Patent, Fig. 148).
- Technical Importance: This direct-conversion approach aimed to drastically simplify receiver design, enabling smaller, cheaper, and more power-efficient integrated circuits for wireless communications (Compl. ¶32-33).
Key Claims at a Glance
- The complaint asserts independent method claim 14 (Compl. ¶64).
- Claim 14 requires a method for down-converting an electromagnetic signal by:
- Receiving an input signal at a first matched filtering/correlating module.
- Down-converting the input signal at the first module using a first control signal to create a first down-converted signal.
- Receiving the same input signal at a second matched filtering/correlating module.
- Down-converting the input signal at the second module using a second control signal to create a second down-converted signal.
- Combining the first and second down-converted signals to output a channel down-converted signal.
- The complaint does not explicitly reserve the right to assert other claims.
U.S. Patent No. 9,118,528 - "Method and System for Down-Converting an Electromagnetic Signal, and Transforms for Same, and Aperture Relationships"
- Issued: August 25, 2015 (Compl. ¶47)
Technology Synopsis
As a continuation of the same family as the ’177 patent, the ’528 patent also addresses direct RF down-conversion. It claims a system with switches controlled by signals with specific sampling apertures to transfer energy from a modulated carrier signal to energy storage elements, thereby generating down-converted in-phase and inverted in-phase baseband signals that are subsequently combined by a differential amplifier (’528 Patent, Abstract; Compl. ¶75-80).
Asserted Claims & Accused Features
- Asserted Claims: Independent system claim 1 (Compl. ¶73).
- Accused Features: The frequency down-converting systems within the accused MediaTek Chips, which allegedly include switches and energy storage elements that perform the claimed functions (Compl. ¶75).
III. The Accused Instrumentality
Product Identification
The accused instrumentalities are integrated circuits identified as the MediaTek MT7612UN and MT7662TU wireless chips ("MediaTek Chips") (Compl. ¶16).
Functionality and Market Context
The complaint alleges these are "Multi-platform MediaTek Chip[s]" capable of handling multiple communication protocols, such as Wi-Fi and Bluetooth, simultaneously (Compl. ¶53). The complaint provides photographic evidence identifying the accused chips on RF module circuit boards intended for consumer electronics. One photograph shows the MediaTek MT7612UN chip on a board labeled for use in an LG device (Compl. p. 6). The chips are alleged to be incorporated into numerous television models from manufacturers including LG and Sharp that are sold in the United States (Compl. ¶17-19).
IV. Analysis of Infringement Allegations
’686 Patent Infringement Allegations
| Claim Element (from Independent Claim 11) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| controlling at least one multi-platform module to communicate...wherein the at least one multi-platform module includes a plurality of transceivers... | Each MediaTek Chip allegedly controls a module having multiple receiver and transmitter paths for different protocols (e.g., Wi-Fi, Bluetooth). | ¶55, ¶56 | col. 50:50-53 |
| wherein each of the plurality of transceivers has at least one frequency translation module, wherein said at least on frequency translation module comprises: a switch...and a storage module... | The transceivers allegedly contain a frequency translation module for down-conversion that uses transistors as the switch and capacitors as the storage module. | ¶56, ¶57, ¶58 | col. 50:53-51:1 |
| wherein a second EM signal is generated from said stored energy, said second EM signal having a frequency different from said first EM signal | A lower-frequency baseband signal is allegedly generated when the capacitors discharge the energy transferred from the higher-frequency RF signal. | ¶59 | col. 51:1-3 |
| simultaneously operating a first transceiver in conformance with a first protocol/standard combination using a first standard/protocol sub-module | The MediaTek Chip is alleged to operate a transceiver in conformance with a Wi-Fi protocol/standard. | ¶60 | col. 51:13-17 |
| and simultaneously operating a second transceiver in conformance with a second protocol/standard combination using a second standard/protocol sub-module. | The MediaTek Chip is alleged to operate a second transceiver in conformance with a Bluetooth protocol/standard. | ¶61 | col. 51:18-22 |
Identified Points of Contention
- Scope Questions: A primary question may be whether a single, highly integrated chip, as depicted in the complaint's photographs (Compl. p. 6-8), constitutes a "multi-platform module" that includes a "plurality of transceivers" as contemplated by the patent. The defense could argue that the accused product is a single, integrated transceiver system, not a module controlling distinct transceiver units, potentially creating a mismatch with the claim's structural limitations.
- Technical Questions: The interpretation of "simultaneously operating" will be critical. The complaint alleges simultaneous Wi-Fi and Bluetooth operations (Compl. ¶53), but the analysis will question whether this is truly concurrent operation or a form of rapid time-division multiplexing that appears simultaneous to the end-user. The evidence presented regarding the chip's actual operational mode will be central to this dispute.
’177 Patent Infringement Allegations
| Claim Element (from Independent Claim 14) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| receiving an input signal at a first matched filtering/correlating module; | The MediaTek Chip allegedly receives a high-frequency RF signal at circuitry that samples the signal at an aliasing rate. | ¶67 | col. 194:54-56 |
| down-converting said input signal at said first matched filtering/correlating module according to a first control signal and outputting a first down-converted signal; | The chip allegedly down-converts the input signal according to a first local oscillator (LO) signal and outputs a first baseband signal. | ¶68 | col. 194:56-58 |
| receiving said input signal at a second matched filtering/correlating module; | The chip allegedly receives the same input signal at a second instance of circuitry that samples the signal at an aliasing rate. | ¶67 | col. 194:59-61 |
| down-converting said input signal at said second matched filtering/correlating module according to a second control signal and outputting a second down-converted signal; | The chip allegedly down-converts the input signal according to a second LO signal and outputs a second baseband signal. | ¶69 | col. 194:61-63 |
| and combining said second down-converted signal and said first down-converted signal to output a first channel down-converted signal. | A differential amplifier circuit allegedly combines the two down-converted signals to produce the final output. | ¶70 | col. 194:64-67 |
Identified Points of Contention
- Scope Questions: The dispute may center on whether the architecture of the accused chips maps onto the claim's structure of two distinct "matched filtering/correlating modules." The defense may argue that the accused products utilize a unified differential receiver architecture that does not contain the two separate modules required by the claim language.
- Technical Questions: The definition of "matched filtering/correlating module" will be a key issue for claim construction. The complaint alleges this corresponds to "linear time-variant circuitry that samples a modulated RF carrier signal at an aliasing rate" (Compl. ¶67). The technical evidence will need to establish whether the accused circuits actually perform this specific function, as opposed to a different form of down-conversion.
V. Key Claim Terms for Construction
For the ’686 Patent (Claim 11)
- The Term: "simultaneously operating"
- Context and Importance: This term is central because modern wireless chips often manage multiple protocols through high-speed switching rather than truly parallel, independent operation. The viability of the infringement allegation depends on whether the term's scope can encompass such time-multiplexed operations.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The specification mentions "virtual simultaneous operation" and the ability for a module to "switch between networks" and "communicate on both networks," which may suggest that operations do not need to be strictly concurrent in time to be considered "simultaneous" within the patent's context (’686 Patent, col. 8:26-30).
- Evidence for a Narrower Interpretation: The patent depicts physically separate modules for different protocols (e.g., a "CDMA Platform Module" 2508 and a "Bluetooth Platform Module" 2506 in FIG. 25A), which could support an argument that "simultaneously operating" requires distinct hardware paths to be active at the same time.
For the ’177 Patent (Claim 14)
- The Term: "matched filtering/correlating module"
- Context and Importance: The infringement theory requires the presence of two such modules. The definition of this term will determine whether the claim can read on modern differential receiver architectures or is limited to the specific embodiments shown in the patent.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The specification provides a high-level functional description, stating the invention involves "performing a matched filtering/correlating operation" and "accumulating the result" (’177 Patent, Fig. 148). This functional language may support a broader construction that is not tied to a single circuit layout.
- Evidence for a Narrower Interpretation: The patent provides detailed mathematical descriptions and embodiments based on sampling "approximate half cycles of the carrier signal" and accumulating energy over those cycles (’177 Patent, col. 130:25-44). This detailed disclosure could be used to argue for a narrower construction limited to circuits that operate according to this specific principle.
VI. Other Allegations
Indirect Infringement
While no formal count for indirect infringement is included, the complaint alleges facts that may support such a claim. It asserts that MediaTek knew its chips would be incorporated into infringing end-products like televisions and intended for those products to be sold in the U.S. market (Compl. ¶20).
Willful Infringement
The complaint does not explicitly allege "willful" infringement. However, it alleges that ParkerVision met with MediaTek USA in April 2010 and gave a presentation on its "direct-conversion technology," which is related to the patents-in-suit (Compl. ¶37). These facts could form the basis for a later argument of pre-suit knowledge of the technology, which is a predicate for a willfulness finding.
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of architectural mapping: Do the highly integrated, multi-standard circuits in the accused MediaTek chips meet the structural requirements of the patent claims, which describe systems of distinct "modules" and "transceivers" (’686 patent) or a pair of separate "matched filtering/correlating modules" (’177 patent)? The case may hinge on whether these claim limitations can be read functionally to cover a single, unified chip design.
- The dispute will likely involve a significant battle over definitional scope: For the '686 patent, what degree of concurrency is required by the term "simultaneously operating" in the context of managing multiple wireless protocols? For the '177 patent, what is the precise technical meaning of a "matched filtering/correlating module," and is it broad enough to encompass modern differential receiver designs?
- A key factual question with potential implications for enhanced damages is the impact of alleged pre-suit knowledge: What specific information was conveyed during the alleged April 2010 meeting between the parties, and does it establish that MediaTek had knowledge of the patented technology, or the patents themselves, before the lawsuit was filed?