Cobblestone WIRELESS, LLC v. Apple INC.

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Cobblestone Wireless, LLC (Texas)
  • Defendant: Apple Inc. (California)
  • Plaintiff’s Counsel: Russ August & Kabat
• Case Identification: 7:24-cv-00232, W.D. Tex., 09/20/2024
• Venue Allegations: Plaintiff alleges venue is proper because Apple has a regular and established place of business in the district, has committed acts of infringement in the district, and has purposefully placed its products into the stream of commerce with the expectation they will be used there. The complaint identifies specific Apple facilities in Austin, Texas.
• Core Dispute: Plaintiff alleges that Defendant’s iPhone and iPad products, which support 5G NR beamforming and carrier aggregation, infringe patents related to a "user-focusing" pre-distortion technique and simultaneous multi-frequency wireless transmission.
• Technical Context: The technologies at issue concern advanced methods for improving the efficiency, reliability, and speed of wireless communications, which are foundational to modern cellular standards like 5G.
• Key Procedural History: The complaint does not mention any prior litigation, Inter Partes Review (IPR) proceedings, or licensing history related to the patents-in-suit.

Case Timeline

Date	Event
2008-01-23	U.S. Patent No. 7,924,802 Priority Date
2011-04-12	U.S. Patent No. 7,924,802 Issued
2011-07-28	U.S. Patent No. 8,891,347 Priority Date
2014-11-18	U.S. Patent No. 8,891,347 Issued
2024-09-20	Complaint Filed

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

U.S. Patent No. 8,891,347 - "User-Focusing Technique for Wireless Communication Systems," issued November 18, 2014

The Invention Explained

• Problem Addressed: The patent describes the challenge of signal distortion and interference in wireless systems caused by signals traveling along multiple propagation paths between a transmitter and receiver. It notes that conventional equalization techniques place a significant computational burden on the receiver. ( ’347 Patent, col. 1:7-41).
• The Patented Solution: The invention proposes a method where the transmitter "pre-distorts" a signal before transmission. This pre-distortion is calculated based on channel parameter information (e.g., delay, direction, Doppler frequency) fed back from the receiver. The pre-distortion is specifically designed to be canceled out by the channel itself, causing the signals from various paths to arrive at the receiver with their phases aligned, thereby adding together constructively and effectively moving the equalization burden from the receiver to the transmitter. ('347 Patent, Abstract; col. 2:1-9; col. 9:5-15).
• Technical Importance: This "user-focusing" approach aims to reduce receiver complexity, decrease power consumption, and improve service quality, particularly in environments with high user density or for users in high-speed motion. ('347 Patent, col. 8:20-25).

Key Claims at a Glance

• The complaint asserts independent claim 1 (Compl. ¶10).
• Claim 1 is a method claim with the following essential elements:
  • Transmitting a first signal from a transmitter to a receiver via a propagation path.
  • Receiving the first signal at the receiver.
  • Performing a channel estimation on the first signal to obtain path parameter information.
  • Sending the channel estimation from the receiver back to the transmitter.
  • Predistorting a second signal at the transmitter "in a time domain, a frequency domain, and a spatial domain" based on the channel estimation.
  • Transmitting the predistorted second signal to the receiver.
  • Receiving the predistorted second signal at the receiver.
• The complaint alleges infringement of "at least Claim 1," reserving the right to assert other claims (Compl. ¶10).

U.S. Patent No. 7,924,802 - "Wireless Communication Systems and Methods," issued April 12, 2011

The Invention Explained

• Problem Addressed: The patent identifies limitations in conventional wireless transmitters, which typically up-convert signals to a single center frequency. This approach constrains the amount of data that can be transmitted and is subject to regulatory power limits within a given frequency band. ( ’802 Patent, col. 1:21-38).
• The Patented Solution: The invention describes a method and system for simultaneously transmitting information across two or more different frequency ranges using a single wireless transmitter, notably sharing a single power amplifier and antenna. The system takes multiple digital signals, converts them to analog, up-converts each to a distinct RF center frequency, combines the up-converted signals, and then amplifies and transmits the combined signal. This allows for increased throughput or improved reliability by sending the same data over different frequencies. ('802 Patent, Abstract; Fig. 2; col. 6:56-63).
• Technical Importance: This technique is a form of carrier aggregation, a technology that is fundamental to achieving the high data rates promised by modern wireless standards like LTE and 5G by allowing a device to use spectrum from multiple frequency bands at once. ('802 Patent, col. 1:50-57).

Key Claims at a Glance

• The complaint asserts independent claim 1 (Compl. ¶18).
• Claim 1 is a method claim with the following essential elements:
  • Transmitting first information across a first frequency range using a wireless transmitter.
  • Simultaneously transmitting second information across a second frequency range "using the same wireless transmitter."
  • The second frequency range has a center frequency greater than the first.
• The complaint alleges infringement of "at least Claim 1," reserving the right to assert other claims (Compl. ¶18).

III. The Accused Instrumentality

Product Identification

• The complaint identifies a wide range of Apple's cellular-enabled products as the "Accused Instrumentalities," including the iPhone 12, 13, 14, 15, and 16 series, the iPhone SE (3rd Gen.), and various models of the iPad, iPad Air, iPad Mini, and iPad Pro (Compl. ¶¶10, 18).

Functionality and Market Context

• The complaint alleges that these products infringe the ’347 Patent because they support "3GPP 5G NR beamforming" (Compl. ¶10).
• It alleges the same products infringe the ’802 Patent because they support "3GPP carrier aggregation" (Compl. ¶18).
• These features are central to the performance of modern 5G devices. The complaint does not detail the specific technical operation of Apple's implementation but rather ties infringement to the products' compliance with these industry standards. The accused products represent Apple's core, high-volume mobile and tablet product lines.

IV. Analysis of Infringement Allegations

The complaint references, but does not include, claim chart exhibits detailing its infringement theories (Compl. ¶¶13, 21). The narrative allegations are summarized below. No probative visual evidence provided in complaint.

• ’347 Patent Infringement Allegations: The complaint's theory is that the accused Apple products, by implementing "3GPP 5G NR beamforming," necessarily perform the steps of the asserted claims (Compl. ¶10). This implies that in the course of normal operation, the devices transmit signals, receive channel state information from a connected user device, and then use that information to pre-distort subsequent transmissions to focus signal energy toward the user, thereby practicing the patented method.
• ’802 Patent Infringement Allegations: The complaint alleges that the accused products' implementation of "3GPP carrier aggregation" infringes the asserted claims (Compl. ¶18). This theory suggests that the devices are capable of, and do in operation, simultaneously transmit information over at least two different frequency bands using the same transmitter hardware, as recited in the patent's claims.
• Identified Points of Contention:
  • Technical Questions: A primary question will be whether the standardized "beamforming" and "carrier aggregation" functionalities, as implemented by Apple, operate in a manner that maps to the specific limitations of the asserted claims. For the ’347 Patent, does Apple's beamforming constitute "predistorting... in a time domain, a frequency domain, and a spatial domain" for the purpose of aligning phases from multiple propagation paths, or does it perform a different function? For the ’802 Patent, what evidence shows that the devices "simultaneously" transmit distinct "first" and "second" information across different bands during normal use?
  • Scope Questions: The infringement analysis for the ’802 Patent may turn on the construction of "the same wireless transmitter." A court will need to determine if Apple's radio frequency architecture, likely containing multiple parallel processing chains, falls within the scope of this term as it is used and defined in the patent.

V. Key Claim Terms for Construction

’347 Patent, Claim 1: "predistorting a second signal at the transmitter in a time domain, a frequency domain, and a spatial domain"

• Context and Importance: This phrase captures the core of the invention. The outcome of the case will likely depend on whether Apple's accused "beamforming" technology is found to perform this specific, multi-faceted pre-distortion.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The patent states the goal is to make signals from different paths "aligned' in phases and can be added constructively" ('347 Patent, col. 2:28-30). Plaintiff may argue that any technique that achieves this alignment via transmitter-side adjustments based on channel feedback falls within the scope of "predistorting."
  • Evidence for a Narrower Interpretation: The specification provides a specific mathematical formula for creating the pre-distorted signal replica, involving the "complex conjugate of the transmitter antenna array... response" and the "complex conjugate of the receiver antenna array... response" ('347 Patent, col. 9:35-42). Defendant may argue that the claim term should be limited to this specific mathematical approach or one that is structurally equivalent.

’802 Patent, Claim 1: "using the same wireless transmitter"

• Context and Importance: This term is critical for defining the required hardware architecture for infringement. Whether Apple's products infringe will depend on whether their internal radio-frequency components are considered to be "the same wireless transmitter."
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The patent specification discloses an embodiment where two up-converted signals are "simply added together at the input of" a single power amplifier (PA) which then feeds a single antenna ('802 Patent, col. 6:58-63; Fig. 2). Plaintiff may argue that the "transmitter" refers to this shared final amplification and radiation stage.
  • Evidence for a Narrower Interpretation: The figures show two distinct signal paths (including DACs, filters, and up-converters) before combination at the power amplifier ('802 Patent, Fig. 2). Defendant may argue that modern, highly integrated RF front-ends in its products do not map to this specific architecture and therefore do not use "the same wireless transmitter" for the entire process leading up to amplification.

VI. Other Allegations

• Indirect Infringement: The complaint alleges induced infringement for both patents. The factual basis asserted is that Apple provides "user manuals and online instruction materials on its website" that encourage and instruct customers to use the accused products in their normal, infringing manner (e.g., by using 5G cellular services) (Compl. ¶¶11, 19).
• Willful Infringement: The complaint alleges knowledge of the patents and infringement "[t]hrough at least the filing and service of this Complaint" (Compl. ¶¶11, 19). This forms a basis for potential post-suit willfulness but does not allege any pre-suit knowledge.

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

This dispute will likely focus on the technical overlap between the broad functionality of industry standards (5G beamforming, carrier aggregation) and the specific methods defined in the patents-in-suit. The central questions for the court appear to be:

1. A key issue will be one of technical equivalence: Does the "beamforming" implemented in Apple's products perform the specific multi-domain "pre-distortion" claimed in the ’347 Patent, which is aimed at aligning phases from different physical propagation paths, or is it a fundamentally different signal processing technique?

2. A second core issue will be one of definitional scope: Can the term "the same wireless transmitter" from the ’802 Patent be construed to read on the highly integrated, multi-chain radio frequency architecture of the accused Apple devices, or is the claim limited to the more discrete component layout depicted in the patent?

3. Finally, an evidentiary question will be what proof Plaintiff can marshal to demonstrate that the accused products actually perform the specific steps of the asserted method claims during normal operation, beyond merely showing that the products are compliant with general industry standards.