DCT
6:23-cv-00732
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-00732, W.D. Tex., 10/30/2023
- Venue Allegations: Plaintiff alleges venue is proper because Defendant MediaTek Taiwan is a foreign corporation subject to personal jurisdiction, and both defendants have a regular and established place of business in the district, have committed acts of infringement in the district, and derive substantial revenue from the district.
- Core Dispute: Plaintiff alleges that Defendant’s wireless transceiver integrated circuits and power management modules infringe three patents related to radio frequency (RF) signal up-conversion and power supply control.
- Technical Context: The technology concerns the fundamental architecture of RF transmitters and power supplies used in modern wireless communication devices, a market where efficiency, size, and cost are critical competitive factors.
- Key Procedural History: The complaint alleges that in April 2010, ParkerVision, Inc met with MediaTek Inc USA and presented its direct-conversion technology. It also identifies two other pending cases between the same parties in the same court involving common technology.
Case Timeline
| Date | Event |
|---|---|
| 1998-04-21 | U.S. Patent No. 7,050,508 Priority Date |
| 1999-04-16 | U.S. Patent No. 7,929,638 Priority Date |
| 2006-05-23 | U.S. Patent No. 7,050,508 Issued |
| 2006-11-09 | U.S. Patent No. 8,498,593 Priority Date |
| 2010-04-DD | ParkerVision alleges meeting with MediaTek USA |
| 2011-04-19 | U.S. Patent No. 7,929,638 Issued |
| 2013-07-30 | U.S. Patent No. 8,498,593 Issued |
| 2014-01-DD | MediaTek allegedly demonstrated infringing products at CES |
| 2023-10-30 | Complaint Filed |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 7,050,508 - "Method and System for Frequency Up-Conversion with a Variety of Transmitter Configurations"
- Issued: May 23, 2006
The Invention Explained
- Problem Addressed: Conventional RF transmitters often required expensive, power-intensive, and difficult-to-integrate high-frequency components, such as oscillators and filters, to up-convert a baseband signal to a higher transmission frequency. (’508 Patent, col. 15:25-42).
- The Patented Solution: The invention proposes a more efficient method for up-conversion. Instead of directly generating a high-frequency carrier, it starts with a stable, low-frequency oscillating signal. This signal is used to control a switch that "gates" a bias signal, creating a harmonically rich periodic waveform (like a square wave). This new waveform contains the original frequency plus numerous integer multiples (harmonics). A filter can then easily select the desired high-frequency harmonic for transmission, avoiding the need for a dedicated high-frequency oscillator. (’508 Patent, Abstract; col. 16:9-18).
- Technical Importance: This approach allows for the use of simpler, lower-frequency, and more stable components to generate high-frequency signals, which can reduce the cost, size, and power consumption of RF transmitters. (Compl. ¶42, ¶44).
Key Claims at a Glance
- The complaint asserts independent method claim 11. (Compl. ¶60).
- The essential elements of claim 11 include:
- shaping a string of pulses from a reference signal;
- generating a string of multiple pulses from said string of pulses;
- gating a bias signal under the control of said string of multiple pulses to generate a periodic signal having a plurality of harmonics;
- wherein at least one of said harmonics is at a desired frequency.
U.S. Patent No. 7,929,638 - "Wireless Local Area Network (WLAN) Using Universal Frequency Translation Technology Including Multi-Phase Embodiments"
- Issued: April 19, 2011
The Invention Explained
- Problem Addressed: Conventional wireless communication circuits were often complex, costly, and consumed significant power, which limited battery life and increased the size of wireless devices. (’638 Patent, col. 2:13-20).
- The Patented Solution: The patent describes a balanced transmitter architecture to improve performance. It receives a baseband signal, creates an inverted copy of that signal, and then uses two separate switches controlled by harmonically-rich control signals to sample the original and inverted signals. The outputs are then combined. This differential approach is designed to reduce unwanted signal artifacts, such as DC offset and carrier leakage, which can degrade transmission quality. (’638 Patent, Abstract; col. 46:25-52).
- Technical Importance: By minimizing unwanted carrier insertion and DC offsets at the circuit level, this technology aims to create cleaner, more efficient RF transmissions, which is particularly valuable for complex modulation schemes used in WLANs. (Compl. ¶42, ¶44).
Key Claims at a Glance
- The complaint asserts independent method claim 16. (Compl. ¶73).
- The essential elements of claim 16 include:
- receiving an input baseband signal in an inverter;
- inverting said baseband signal to generate an inverted baseband signal;
- sampling said baseband signal according to a first control signal to generate a first harmonically rich signal;
- sampling said inverted baseband signal according to a second control signal to generate a second harmonically rich signal;
- combining said first harmonically rich signal and said second harmonically rich signal to generate a third harmonically rich signal.
U.S. Patent No. 8,498,593 - "Switching Power Supply"
- Issued: July 30, 2013
Technology Synopsis
The patent describes a switching power supply with an intelligent bypass mode. The circuitry monitors its own power efficiency. If the efficiency exceeds a predetermined threshold (e.g., during high power output where the switching components become less efficient), the control module deactivates the switching device and passes the input voltage directly to the output, improving overall system efficiency. (’593 Patent, Abstract).
Asserted Claims
The complaint asserts independent method claim 9. (Compl. ¶87).
Accused Features
The complaint accuses MediaTek’s Envelope Tracking Modules (ETMs), such as the MT6300 and MT6303P, which are designed to control power supplies for RF power amplifiers. (Compl. ¶23, ¶88). Figure 27.6.1 of a 2018 ISSCC paper, referenced in the complaint, shows the architecture of an accused envelope-tracking modulator, including a "Maximum Power Selection Circuit" that appears to select between different power paths. (Compl. ¶94).
III. The Accused Instrumentality
Product Identification
A wide range of MediaTek integrated circuits, collectively referred to as “MediaTek Chips,” and power management circuits called “MediaTek ETMs” (Envelope Tracking Modules). (Compl. ¶23). The complaint specifically identifies dozens of MT-series chips, including the MT8768T found in the Samsung Galaxy Tab A7 Lite. (Compl. ¶23, ¶26).
Functionality and Market Context
The accused products are core components for wireless communication in consumer electronics, performing functions like RF signal transmission, reception, and power management for 4G/5G/LTE standards. (Compl. ¶11, ¶13). They are sold to device manufacturers like Samsung, Motorola, and OnePlus for inclusion in smartphones, tablets, and other wireless devices. (Compl. ¶14, ¶16, ¶26). The complaint alleges MediaTek is one of the world's largest manufacturers of integrated circuits, "powering more than 2 billion devices a year." (Compl. ¶6). The complaint provides a screenshot from Best Buy's website showing a Samsung tablet containing an accused MediaTek chip available for in-store pickup in the judicial district. (Compl. ¶26, p. 10).
IV. Analysis of Infringement Allegations
U.S. Patent No. 7,050,508 Infringement Allegations
| Claim Element (from Independent Claim 11) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| A method for frequency up conversion comprising: shaping a string of pulses from a reference signal... | Each MediaTek Chip allegedly shapes a string of pulses from a local oscillator (LO) reference signal. (Compl. ¶63). Figure 10.6.3 from a 2020 ISSCC paper shows an exemplary "LO delay control loop and phase generation" block diagram. (Compl. ¶69). | ¶63, ¶69 | col. 46:60-64 |
| ...and generating a string of multiple pulses from said string of pulses; | The chips allegedly generate multiple pulses from the initial string of pulses using logic devices and a digital phase locked loop. (Compl. ¶63). | ¶63 | col. 47:1-6 |
| gating a bias signal under the control of said string of multiple pulses to generate a periodic signal having a plurality of harmonics... | A switch (e.g., one or more transistors) allegedly gates a bias signal under the control of the multiple pulses (e.g., 25% duty-cycle LO signals) to generate a periodic signal. (Compl. ¶64, ¶68). Figure 10.6.2 from a 2020 ISSCC paper shows a transmitter path with switches driven by LO signals. (Compl. ¶68). | ¶64, ¶68 | col. 37:16-23 |
| ...at least one of which is at a desired frequency. | The generated periodic signal allegedly has multiple harmonics, one of which is at the desired transmission frequency. (Compl. ¶64). | ¶64 | col. 20:29-33 |
- Identified Points of Contention:
- Scope Questions: A central question may be whether the accused circuitry, as depicted in the IEEE papers, performs two distinct claimed steps of "shaping" and "generating" pulses, or if it performs a single, integrated function of generating phased LO signals. The defense may argue that the complex "LO delay control loop and phase generation" circuitry (Compl. ¶69) does not map onto the claim's sequential language.
- Technical Questions: The complaint relies on academic papers to describe the accused functionality. A key evidentiary question will be whether ParkerVision can prove that the specific architectures described in these papers are actually implemented in the dozens of accused MediaTek chip models listed in the complaint.
U.S. Patent No. 7,929,638 Infringement Allegations
| Claim Element (from Independent Claim 16) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| A method for up-converting a baseband signal, comprising: receiving an input baseband signal in an inverter; and inverting said baseband signal to generate an inverted baseband signal; | The accused MediaTek Chip allegedly receives a baseband signal at an inverter and generates an inverted version of it. (Compl. ¶76). | ¶76 | col. 41:52-59 |
| sampling said baseband signal according to a first control signal to generate a first harmonically rich signal; | A first switch (e.g., transistor) allegedly samples the baseband signal using a first control signal (e.g., an LO signal) to generate a first harmonically rich signal. (Compl. ¶77). | ¶77 | col. 41:40-44 |
| sampling said inverted baseband signal according to a second control signal to generate a second harmonically rich signal; | A second switch allegedly samples the inverted baseband signal using a second control signal to generate a second harmonically rich signal. (Compl. ¶78). | ¶78 | col. 41:45-48 |
| and combining said first harmonically rich signal and said second harmonically rich signal to generate a third harmonically rich signal. | The two harmonically rich signals are allegedly combined at an output node. (Compl. ¶79). Figure 10.6.2 from the 2020 ISSCC paper is used to illustrate the first and second switches and a combining node. (Compl. ¶83). | ¶79, ¶83 | col. 41:49-52 |
- Identified Points of Contention:
- Scope Questions: A likely point of dispute will be the interpretation of "sampling." MediaTek may argue that its circuits perform a continuous-time "mixing" function rather than discrete "sampling" as described in the patent. The outcome may depend on whether the court construes "sampling" to require a sample-and-hold operation or if it can read on the switching action of a passive mixer.
- Technical Questions: What evidence does the complaint provide that the accused chips' architecture, specifically the "Harmonic-rejected complementary Mixer" (Compl. p. 23), functions by generating two separate harmonically rich signals that are subsequently combined, as opposed to a different method of balanced modulation?
V. Key Claim Terms for Construction
The Term: "shaping a string of pulses from a reference signal" ('508 Patent, claim 11)
- Context and Importance: This term is the first step of the asserted method claim. Its scope is critical because the defense may argue that the accused LO generation circuitry does not perform a "shaping" function separate from the subsequent "generating" step. The definition will determine whether the accused functionality meets this limitation or performs a single, indivisible function.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The specification describes a "pulse shaping circuit" that receives a continuous waveform and outputs "a string of pulses," suggesting a broad transformation from one signal type to another. (’508 Patent, col. 46:60-64).
- Evidence for a Narrower Interpretation: The detailed description of the "pulse shaping circuit" focuses on specific digital logic implementations, such as using an AND gate or XNOR gates to create pulses from a square wave. (’508 Patent, col. 47:1-48:60). The defense may argue the term should be limited to these digital logic embodiments.
The Term: "sampling" ('638 Patent, claim 16)
- Context and Importance: This term defines the core action performed by the switches on the baseband signals. Practitioners may focus on this term because its construction will determine whether the claim reads on conventional RF mixers. If "sampling" is construed broadly to mean any switching action, the claim may cover a wider range of technologies; if construed narrowly to require a specific type of signal capture (e.g., aliasing), the infringement case may be more difficult to prove.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The patent uses the term in the context of a "universal frequency translation" (UFT) module, which is broadly described as a switch controlled by a signal, suggesting the term could encompass the general action of a switch in a modulator. (’638 Patent, col. 7:32-49).
- Evidence for a Narrower Interpretation: The detailed description of down-conversion, incorporated by reference for context, describes "sampling" in the context of aliasing, where the sampling rate is chosen to directly down-convert the signal to baseband, a specific technical operation. (’638 Patent, col. 9:44-55).
VI. Other Allegations
- Indirect Infringement: The complaint does not contain a separate count for indirect infringement. However, it alleges facts that may support such a claim, stating that MediaTek sells its chips to customers "knowing those chips will be incorporated into products imported and/or sold in the United States" and provides "technical support for United States customers to incorporate" the chips. (Compl. ¶12, ¶16, ¶24).
- Willful Infringement: The complaint does not explicitly plead willfulness. However, it alleges that ParkerVision met with MediaTek in April 2010 and gave a presentation on its "direct-conversion technology." (Compl. ¶46). These allegations may be used to argue that MediaTek had pre-suit knowledge of ParkerVision's technology and patents, which could form the basis for a later claim of willfulness.
VII. Analyst’s Conclusion: Key Questions for the Case
This case will likely hinge on two fundamental issues of claim interpretation and proof, which will require expert technical testimony.
- A core issue will be one of definitional scope: can the method steps recited in the claims, such as "shaping... and generating" pulses ('508 patent) or "sampling" a signal ('638 patent), be construed to cover the integrated, complex operations of the modern RF mixer and local oscillator architectures described in the technical papers relied upon by the Plaintiff?
- A key evidentiary question will be one of technical identity: can ParkerVision successfully demonstrate that the exemplary circuits depicted in academic papers from 2013-2020 accurately represent the functionality of the dozens of different MediaTek chips—some of which predate the papers—that are accused of infringement?