UNITED STATES DISTRICT COURT 

WESTERN DISTRICT OF TEXAS 

WACO DIVISION 

PARKERVISION, INC., 

 

 Plaintiff, 

 v. 

INTEL CORPORATION, 

 Defendant. 

Case No. 6:20-cv-00108-ADA 

JURY TRIAL DEMANDED

FIRST AMENDED COMPLAINT FOR PATENT INFRINGEMENT 

 Plaintiff ParkerVision, Inc. (“ParkerVision”), by and through its undersigned 

counsel, files this Complaint against Defendant Intel Corporation (“Intel”) for patent 

infringement of United States Patent Nos. 6,049,706; 6,266,518; 6,580,902; 7,110,444; 

7,539,474; 8,588,725; 8,660,513; 9,118,528; 9,246,736 and 9,444,673 (the “patents-in-suit”) 

(Exhibits 1-10) and alleges as follows: 

NATURE OF THE ACTION 

1. This is an action for patent infringement arising under the patent laws of 

the United States, 35 U.S.C. §§ 1 et seq. 

PARTIES 

2. Plaintiff ParkerVision is a Florida corporation with its principal place of 

business at 9446 Philips Highway, Jacksonville, Florida 32256. 

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3. On information and belief, Defendant Intel is a Delaware corporation with 

a place of business at 2200 Mission College Boulevard, Santa Clara, California 95054. 

4. On information and belief, Intel has places of business in this judicial 

district: 1300 S Mopac Expressway, Austin, Texas 78746; 6500 River Place Blvd, Bldg 

7, Austin, Texas 78730 and 5113 Southwest Parkway, Austin, Texas 78735 (collectively, 

“Austin Offices”). https://www.intel.com/content/www/us/en/location/usa.html. 

5. Intel can be served with process through its registered agent for service in 

Texas: CT Corporation System, 1999 Bryan Street, Suite 900, Dallas, Texas 75201. 

6. On information and belief, since April 1989, Intel has been registered to do 

business in the State of Texas under Texas Taxpayer Number 19416727436. 

JURISDICTION AND VENUE 

7. This Court has jurisdiction over the subject matter of this action pursuant 

to 28 U.S.C. §§ 1331 and 1338(a) because the action arises under the patent laws of the 

United States, 35 U.S.C. §§ 1 et seq. 

8. Venue is proper in this judicial district pursuant to 28 U.S.C. §§ 1391(b), (c), 

(d) and/or 1400(b). 

9. Intel is subject to this Court’s personal jurisdiction, in accordance with due 

process and/or the Texas Long Arm Statute because Intel “[r]ecruits Texas residents, 

directly or through an intermediary located in this state, for employment inside or 

outside this state.” See Tex. Civ. Prac. & Rem. Code § 17.042. 

10. This Court has personal jurisdiction over Intel because Intel has sufficient 

minimum contacts with this forum as a result of business conducted within the State of 

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Texas and this judicial district. In particular, this Court has personal jurisdiction over 

Intel because, inter alia, Intel, on information and belief: (1) has substantial, continuous, 

and systematic business contacts in this judicial district; (2) owns, manages and operates 

facilities in this judicial district; (3) enjoys substantial income from its operations in this 

judicial district, and (4) employs Texas residents in this judicial district. 

11. Intel has purposefully availed itself of the privileges of conducting business 

within this judicial district; has established sufficient minimum contacts with this judicial 

district such that it should reasonably and fairly anticipate being hauled into court in this 

judicial district; has purposefully directed activities at residents of this judicial district; 

and at least a portion of the patent infringement claims alleged in this Complaint arise 

out of or are related to one or more of the foregoing activities. 

12. This Court also has personal jurisdiction over Intel because Intel, directly 

and/or through its subsidiaries, affiliates, or intermediaries, makes, uses, offers for sale, 

sells, imports, advertises, makes available and/or markets infringing products in the 

United States, the State of Texas and/or this judicial district, as described more 

particularly below. 

13. On information and belief, Intel maintains a significant physical presence 

in this judicial district. 

14. On information and belief, Intel uses its Austin Office as a regular and 

established place of business. On information and belief, Intel has employed over 1700 

employees in the Austin area. https://www.linkedin.com/company/intelcorporation/people/?facetGeoRegion=us%3A64. 

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15. Intel describes its operations in Austin on its website: “Located in the 

capitol city of Texas, Intel Austin is an important research and development center for 

the Intel technology that is changing the way we live, work, and play. Among the 

innovations developed in Austin are core technologies for next-generation 

microprocessors, platforms and base software; groundbreaking silicon solutions for 

computing and communications devices, which include handheld computing and 

cellular communications; and cutting-edge network storage products.” 

https://www.intel.com/content/www/us/en/jobs/locations/unitedstates/sites/austin.html. 

16. On information and belief, Intel has hundreds of H-1B labor condition 

applications for people employed in Austin, Texas. https://h1bsalary.online/search?% 

20searchtext=INTEL+CORPORATION&year=&minsalary=&state=&worksite_city=AU

STIN&job_title=. Employees holding an H-1B visa are employed in a specialty 

occupation that requires “theoretical and practical application of a body of highly 

specialized knowledge . . . and attainment of a bachelor’s or higher degree in the specific 

specialty.” See generally 8 U.S.C. § 1184. As such, Intel employees in Austin, Texas are 

highly specialized and important to the operation of Intel. 

17. Intel lists job openings on its website for positions in Austin, Texas. 

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https://jobs.intel.com/ListJobs/All/Search/state/tx/ (visited on 1/7/2020). 

18. On information and belief, Intel has litigated/is litigating cases before this 

Court in which it admitted that venue was proper, did not contest personal jurisdiction, 

and/or filed counterclaims. See, e.g., Flash-Control, LLC v. Intel Corp., Case No. 1:19-cv01107 (W.D. Tex.); VLSI Tech. LLC v. Intel Corp., Case No. 1:19-cv-00977 (W.D. Tex.). 

BACKGROUND 

19. In 1989, Jeff Parker and David Sorrells started ParkerVision in Jacksonville, 

Florida. Through the mid-1990s, ParkerVision focused on developing commercial video 

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cameras, e.g., for television broadcasts. The cameras used radio frequency (RF) 

technology to automatically track the camera’s subject. 

20. When developing consumer video cameras, however, ParkerVision, 

encountered a problem – the power and battery requirements for RF communications 

made a cost effective, consumer-sized product impractical. So, Mr. Sorrels and 

ParkerVision’s engineering team began researching ways to solve this problem. 

21. At the time, a decade’s-old RF technology called super-heterodyne 

dominated the consumer products industry. But this technology was not without its own 

problems – the circuity was large and required significant power. 

22. From 1995 through 1998, ParkerVision engineers developed an innovative 

method of RF direct conversion by a process of sampling a RF carrier signal and 

transferring energy to create a down-converted baseband signal. 

23. After creating prototype chips and conducting tests, ParkerVision soon 

realized that its technology led to improved RF receiver performance, lower power 

consumption, reduced size and integration benefits. In other words, RF receivers could 

be built smaller, cheaper and with greater improved performance. 

24. ParkerVision’s innovations did not stop there. ParkerVision went on to 

develop additional RF down-conversion technologies, RF up-conversion technologies 

and other related direct-conversion technologies. ParkerVision also developed 

complementary wireless communications technologies that involved interactions, 

processes, and controls between the baseband processor and the transceiver, which 

improved and enhanced the operation of transceivers that incorporate ParkerVision’s 

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down-converter and up-converter technologies. To date, ParkerVision has been granted 

over 200 patents related to its innovations including, the patents-in-suit. 

25. After spending millions of dollars developing RF technologies, 

ParkerVision sought to partner with larger, well-established companies who could use 

ParkerVision’s innovations to manufacture highly integrated circuits on a large scale for 

the consumer market. In the late 1990s, ParkerVision began meeting with companies such 

as Qualcomm, an industry leader in RF chip technology. 

26. Qualcomm quickly recognized the significance of ParkerVision’s directconversion technology. In internal communications, Qualcomm engineers and senior 

executives lauded ParkerVision’s technology: “This is virtually the holy grail of RF 

receiver designs –- achievable and within practical limits!”; “[w]e are very impressed 

with the performance! We can make a phone with [ParkerVision’s] parts with higher 

dynamic range than today’s phones” and “[t]he truth is Parker Vision have [sic] stumbled 

on something revolutionary.” After testing ParkerVision’s technology, a Qualcomm 

senior executive and former engineer stated “[t]o tell you the truth, I am more of a 

believer now than when I started talking with [ParkerVision]” and Qualcomm’s thendivision President stated “this is critical technology that we must land based on what we 

have seen so far. It offers revolutionary rf versus power performa[n]ce based on early 

te[s]t resul[t]s.” 

27. Qualcomm and ParkerVision never entered into an agreement. 

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28. Then, in the mid-2000s, with the rise in popularity of smartphones, there 

became a critical need for smaller, more efficient receivers capable of supporting multiple 

frequency bands. ParkerVision’s technology addressed this need. 

29. In 2011, a ParkerVision engineer found a Qualcomm conference paper 

describing Qualcomm’s then-current RF technology. The technology was strikingly 

similar to the technology that ParkerVision disclosed to Qualcomm years earlier. 

Through reverse engineering of Qualcomm’s RF chips, ParkerVision confirmed that 

Qualcomm had been using ParkerVision’s patented technology. And, Qualcomm has 

enjoyed great financial success by doing so. ParkerVision sued Qualcomm and its 

customers for patent infringement and has been locked in litigation ever since. 

30. The damage to ParkerVision, however, was already done. On information 

and belief, seeing Qualcomm’s success, other chip manufacturers such as Intel shifted to 

using ParkerVision’s technology. This shift in the industry ultimately led to the 

abandonment of super-heterodyne technology. 

31. ParkerVision’s technology helped make today’s mobile devices, such as 

smart phones and tablets, a reality by enabling RF chips used in these devices to be 

smaller, cheaper, and more efficient, and with higher performance. 

INTEL CHIPS 

32. Until recently, Intel (or those acting on its behalf) made, used, sold, offered 

to sell and/or imported RF transceiver chips/modems, for example, for use in 

smartphones. These chips include, without limitation, the Intel PMB 5750, PMB 5757 and 

PMB 5762 (each an “Intel Chip”; collectively, the “Intel Chips”). 

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33. Intel Chips provide cellular connectivity for devices such as Apple iPhones.

34. On information and belief, the PMB 5750 was incorporated into devices 

including, without limitation, the Apple iPhone 7 and 7 Plus.1 On information and belief, 

the PMB 5757 was incorporated into devices including, without limitation, the Apple 

iPhone 8, 8 Plus and X.2 On information and belief, the PMB 5762 was incorporated into 

devices including, without limitation, the Apple iPhone XR, XS and XS Max. 3

35. On information and belief, in December 2019, Apple acquired Intel’s 

smartphone modem business for $1 billion. https://www.engadget.com/2019-12-02-

apple-owns-intel-modem-business.html. 

THE ASSERTED PATENTS 

United States Patent No. 6,049,706

36. On April 11, 2000, the United States Patent and Trademark Office duly and 

legally issued United States Patent No. 6,049,706 (“the ‘706 patent”) entitled “Integrated 

Frequency Translation and Selectivity” to inventor Robert W. Cook et al. A true and 

correct copy of the ‘706 patent is attached as Exhibit 1. 

37. The ‘706 patent is presumed valid under 35 U.S.C. § 282. 

1 See Wegner et al., Apple iPhone 7 Teardown, TechInsights (Sept. 15, 2016), 

https://techinsights.com/blog/apple-iphone-7-teardown; see also Srivatsan Sridhar, Apple iPhone 7 and 7 

Plus teardown confirms bigger battery, Intel LTE modem in some models and more, FoneArena (Sept. 16, 2016), 

https://www.fonearena.com/blog/197580/apple-iphone-7-and-7-plus-teardown-confirms-biggerbattery-intel-lte-modem-in-some-models-and-more.html.

2 See Yang et al., Apple iPhone X Teardown, TechInsights (last modified Nov. 8, 2017), 

https://www.techinsights.com/blog/apple-iphone-x-teardown.

3 See iPhone XS and XS Max Teardown, iFixit (Sept. 21, 2018), 

https://www.ifixit.com/Teardown/iPhone+XS+and+XS+Max+Teardown/113021; iPhone XR Teardown, 

iFixit (Oct. 26, 2018), https://www.ifixit.com/Teardown/iPhone+XR+Teardown/114123. 

Case 6:20-cv-00108-ADA Document 14 Filed 05/15/20 Page 9 of 31
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38. ParkerVision owns all rights, title, and interest in the ‘706 patent. 

United States Patent No. 6,266,518 

39. On July 24, 2001, the United States Patent and Trademark Office duly and 

legally issued United States Patent No. 6,266,518 (“the ‘518 patent”) entitled “Method and 

System for Down-Converting Electromagnetic Signals by Sampling and Integrating Over 

Apertures” to inventor David F. Sorrells et al. A true and correct copy of the ‘518 patent 

is attached as Exhibit 2. 

40. The ‘518 patent is presumed valid under 35 U.S.C. § 282. 

41. ParkerVision owns all rights, title, and interest in the ‘518 patent. 

United States Patent No. 6,580,902

42. On June 17, 2003, the United States Patent and Trademark Office duly and 

legally issued United States Patent No. 6,580,902 (“the ‘902 patent”) entitled “Frequency 

Translation Using Optimized Switch Structures” to inventor David F. Sorrells et al. A true 

and correct copy of the ‘902 patent is attached as Exhibit 3. 

43. The ‘902 patent is presumed valid under 35 U.S.C. § 282. 

44. ParkerVision owns all rights, title, and interest in the ‘902 patent. 

United States Patent No. 7,110,444

45. On September 19, 2006, the United States Patent and Trademark Office duly 

and legally issued United States Patent No. 7,110,444 (“the ‘444 patent”) entitled 

“Wireless Local Area Network (WLAN) Using Universal Frequency Translation 

Technology Including Multi-Phase Embodiments and Circuit Implementations” to 

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inventor David F. Sorrells et al. A true and correct copy of the ‘444 patent is attached as 

Exhibit 4. 

46. The ‘444 patent is presumed valid under 35 U.S.C. § 282. 

47. ParkerVision owns all rights, title, and interest in the ‘444 patent. 

United States Patent No. 7,539,474

48. On May 26, 2009, the United States Patent and Trademark Office duly and 

legally issued United States Patent No. 7,539,474 (“the ‘474 patent”) entitled “DC Offset, 

Re-Radiation, and I/Q Solutions Using Universal Frequency Translation Technology” to 

inventor David F. Sorrells et al. A true and correct copy of the ‘474 patent is attached as 

Exhibit 5. 

49. The ‘474 patent is presumed valid under 35 U.S.C. § 282. 

50. ParkerVision owns all rights, title, and interest in the ‘474 patent. 

United States Patent No. 8,588,725

51. On November 19, 2013, the United States Patent and Trademark Office duly 

and legally issued United States Patent No. 8,588,725 (“the ‘725 patent”) entitled 

“Apparatus, System, and Method For Down Converting and Up-Converting 

Electromagnetic Signals” to inventor David F. Sorrells et al. A true and correct copy of 

the ‘725 patent is attached as Exhibit 6. 

52. The ‘725 patent is presumed valid under 35 U.S.C. § 282. 

53. ParkerVision owns all rights, title, and interest in the ‘725 patent. 

United States Patent No. 8,660,513

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54. On February 25, 2014, the United States Patent and Trademark Office duly 

and legally issued United States Patent No. 8,660,513 (“the ‘513 patent”) entitled “Method 

and System for Down-Converting an Electromagnetic Signal, and Transforms for Same, 

and Aperture Relationships” to inventor David F. Sorrells et al. A true and correct copy 

of the ‘513 patent is attached as Exhibit 7. 

55. The ‘513 patent is presumed valid under 35 U.S.C. § 282. 

56. ParkerVision owns all rights, title, and interest in the ‘513 patent. 

United States Patent No. 9,118,528

57. On August 25, 2015, the United States Patent and Trademark Office duly 

and legally issued United States Patent No. 9,118,528 (“the ‘528 patent”) entitled “Method 

and System for Down-Converting an Electromagnetic Signal, and Transforms for Same, 

and Aperture Relationships” to inventor David F. Sorrells et al. A true and correct copy 

of the ‘528 patent is attached as Exhibit 8. 

58. The ‘528 patent is presumed valid under 35 U.S.C. § 282. 

59. ParkerVision owns all rights, title, and interest in the ‘528 patent. 

United States Patent No. 9,246,736

60. On January 26, 2016, the United States Patent and Trademark Office duly 

and legally issued United States Patent No. 9,246,736 (“the ‘736 patent”) entitled “Method 

and System for Down-Converting an Electromagnetic Signal” to inventor David F. 

Sorrells et al. A true and correct copy of the ‘736 patent is attached as Exhibit 9. 

61. The ‘736 patent is presumed valid under 35 U.S.C. § 282. 

62. ParkerVision owns all rights, title, and interest in the ‘736 patent. 

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United States Patent No. 9,444,673 

63. On September 13, 2016, the United States Patent and Trademark Office duly 

and legally issued United States Patent No. 9,444,673 (“the ‘673 patent”) entitled 

“Methods and Systems for Down-Converting a Signal Using a Complementary 

Transistor Structure” to inventor David F. Sorrells et al. A true and correct copy of the 

‘673 patent is attached as Exhibit 10. 

64. The ‘673 patent is presumed valid under 35 U.S.C. § 282. 

65. ParkerVision owns all rights, title, and interest in the ‘673 patent. 

CLAIMS FOR RELIEF 

COUNT I - Infringement of United States Patent No. 6,049,706 

66. The allegations set forth above are re-alleged and incorporated by reference 

as if they were set forth fully here. 

67. Intel directly infringes (literally and/or under the doctrine of equivalents) 

the ’706 patent by making, using, selling, offering for sale, and/or importing into the 

United States products covered by at least claim 1 of the ’706 patent. 

68. Intel products that infringe one or more claims of the ’706 patent include, 

but are not limited to, the Intel Chips, and any other Intel device that is capable of filtering 

and down-converting a higher-frequency signal to a lower-frequency signal as claimed 

in the ’706 patent. On information and belief, Intel uses the Intel Chips at least by testing 

the Intel Chips in the United States. 

69. Each Intel Chip is/includes an apparatus for filtering and down-converting 

(e.g., a higher frequency RF signal to a lower frequency signal). Each Intel Chip includes 

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a frequency translator, comprising a down-convert and delay module to under-sample 

an input signal (e.g., high frequency RF signal) to produce an input sample of a downconverted image of said input signal, and to delay said input sample. Each Intel Chip also 

includes a filter, comprising at least a portion of said down-convert and delay module, at 

least one delay module to delay instances of an output signal, and an adder (e.g., 

operational amplifier with parallel resistor-capacitor feedback) to combine at least said 

delayed input sample with at least one of said delayed instances of said output signal to 

generate an instance of said output signal. 

70. The down-convert and delay module under-samples (e.g., at a sample rate 

below the Nyquist rate) said input signal according to a control signal (e.g., local oscillator 

(LO) signal), wherein a frequency of said control signal is equal to a frequency of said 

input signal plus or minus a frequency of said down-converted image, divided by n, 

where n represents a harmonic or sub-harmonic of said input signal. 

71. ParkerVision has been damaged by the direct infringement of Intel and is 

suffering and will continue to suffer irreparable harm and damages as a result of this 

infringement. 

COUNT II – Infringement of United States Patent No. 6,266,518 

72. The allegations set forth above are re-alleged and incorporated by reference 

as if they were set forth fully here. 

73. Intel directly infringes (literally and/or under the doctrine of equivalents) 

the ‘518 patent by making, using, selling, offering for sale, and/or importing into the 

United States products covered by at least claim 67 of the ‘518 patent. 

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74. Intel products that infringe one or more claims of the ‘518 patent include, 

but are not limited to, the Intel Chips, and any other Intel device that is capable of downconverting a higher-frequency signal to a lower-frequency signal as claimed in the ‘518 

patent. On information and belief, Intel uses the Intel Chips at least by testing the Intel 

Chips in the United States. 

75. Each Intel Chip is/includes an apparatus for down-converting a carrier 

signal (e.g., high frequency RF signal) to a lower frequency signal (e.g., baseband signal). 

Each Intel Chip has a universal frequency down-converter (UFD), including a switch 

(e.g., transistor), an integrator (e.g., one or more capacitors) coupled to said switch, a 

pulse generator (e.g., LO) coupled to said switch, and a reactive structure (e.g., active 

filter) coupled to said UFD. 

76. The pulse generator (e.g., LO) outputs pulses (e.g., LO signal) to said switch 

at an aliasing rate that is determined according to a frequency of the carrier signal +/− a 

frequency of the lower frequency signal) divided by N. 

77. The pulses have apertures (e.g., 25% duty cycle) and cause said switch to 

close and sample said carrier signal (e.g., high frequency RF signal). Energy is transferred 

from said carrier signal and integrated using said integrator (e.g., one or more capacitors) 

during apertures of said pulses, and said lower frequency signal (e.g., baseband signal) 

is generated from the transferred energy. 

78. The energy is transferred to a load (e.g., one or more resistors) during an 

off-time (e.g., when the switch is open). 

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79. ParkerVision has been damaged by the direct infringement of Intel, and is 

suffering and will continue to suffer irreparable harm and damages as a result of this 

infringement. 

COUNT III – Infringement of United States Patent No. 6,580,902 

80. The allegations set forth above are re-alleged and incorporated by reference 

as if they were set forth fully here. 

81. Intel directly infringes (literally and/or under the doctrine of equivalents) 

the ’902 patent by making, using, selling, offering for sale, and/or importing into the 

United States products covered by at least claim 1 of the ’902 patent. 

82. Intel products that infringe one or more claims of the ’902 patent include, 

but are not limited to, the Intel Chips, and any other Intel device that is capable of downconverting a higher-frequency signal to a lower-frequency signal as claimed in the ’902 

patent. On information and belief, Intel uses the Intel Chips at least by testing the Intel 

Chips in the United States. 

83. Each Intel Chip is/includes a circuit for down-converting an 

electromagnetic signal (e.g., high frequency RF signal) to a lower frequency signal. Each 

Intel Chip includes an energy transfer module having a switch module (e.g., module with 

one or more transistors) and an energy storage module (e.g., module with one or more 

capacitors). The energy transfer module of the Intel Chip samples the electromagnetic 

signal at an energy transfer rate (e.g., LO rate with a 25% duty cycle), according to an 

energy transfer signal (e.g., LO signal), to obtain sampled energy. The sampled energy is 

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stored by said energy storage module (e.g., one or more capacitors). A down-converted 

signal (e.g., baseband signal) is generated from the sampled energy. 

84. The energy transfer module of each Intel Chip has transistors coupled 

together. The transistors have a common first port, a common second port, and a common 

control port. The electromagnetic signal is accepted at the common first port and the 

sampled energy is present at the common second port. 

85. The common control port accepts the energy transfer signal, which has a 

control frequency that is substantially equal to said energy transfer rate. 

86. Each of the transistors of the Intel Chip has a drain, a source, and a gate. 

The common first port couples together drains of the transistors, the common second port 

couples together sources of the transistors, and the common control port couples together 

gates of the transistors. 

87. ParkerVision has been damaged by the direct infringement of Intel and is 

suffering and will continue to suffer irreparable harm and damages as a result of this 

infringement. 

COUNT IV - Infringement of United States Patent No. 7,110,444 

88. The allegations set forth above are re-alleged and incorporated by reference 

as if they were set forth fully here. 

89. Intel directly infringes (literally and/or under the doctrine of equivalents) 

the ’444 patent by making, using, selling, offering for sale, and/or importing into the 

United States products covered by at least claim 2 of the ‘444 patent. 

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90. Intel products that infringe one or more claims of the ’444 patent include, 

but are not limited to, the Intel Chips, and any other Intel device that is capable of downconverting a higher-frequency signal to a lower-frequency signal as claimed in the ’444 

patent. On information and belief, Intel uses the Intel Chips at least by testing the Intel 

Chips in the United States. 

91. Each Intel Chip is/includes a wireless modem apparatus (e.g., a 

modulation/demodulation device providing bi-directional, over-the-air data 

transmission) having a receiver for frequency down-converting an input signal (e.g., high 

frequency RF signal). The receiver for frequency down-converting an input signal 

includes a first frequency down-conversion module to down-convert the input signal, 

wherein said first frequency down-conversion module down-converts said input signal 

according to a first control signal (e.g., LO signal) and outputs a first down-converted 

signal (e.g., baseband signal); a second frequency down-conversion module to downconvert said input signal, wherein said second frequency down-conversion module 

down-converts said input signal according to a second control signal (e.g., LO signal) and 

outputs a second down-converted signal (e.g., baseband signal); and a subtractor module 

(e.g., module with differential amplifier) that subtracts said second down-converted 

signal from said first down-converted signal and outputs a down-converted signal. 

92. The first frequency down-conversion module under-samples (e.g., at a 

sample rate below the Nyquist rate) the input signal according to the first control signal, 

and the second frequency down-conversion module under-samples samples (e.g., at a 

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sample rate below the Nyquist rate) the input signal according to said second control 

signal. 

93. ParkerVision has been damaged by the direct infringement of Intel, and is 

suffering and will continue to suffer irreparable harm and damages as a result of this 

infringement. 

COUNT V - Infringement of United States Patent No. 7,539,474 

94. The allegations set forth above are re-alleged and incorporated by reference 

as if they were set forth fully here. 

95. Intel directly infringes (literally and/or under the doctrine of equivalents) 

the ‘474 patent by making, using, selling, offering for sale, and/or importing into the 

United States products covered by at least claim 1 of the ‘474 patent. 

96. Intel products that infringe one or more claims of the ‘474 patent include, 

but are not limited to, the Intel Chips, and any other Intel device that is capable of downconverting a higher-frequency signal to a lower-frequency signal as claimed in the ‘474 

patent. On information and belief, Intel uses the Intel Chips at least by testing the Intel 

Chips in the United States. 

97. Each Intel Chip is/includes an apparatus for down-converting an input 

signal (e.g., high frequency RF signal) to a lower frequency signal. Each Intel Chip 

includes a first frequency down-conversion module that receives an input signal (e.g., 

high frequency RF signal), wherein the first frequency down-conversion module downconverts the input signal according to a first control signal (e.g., LO signal) and outputs 

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conversion module that receives the input signal, wherein the second frequency downconversion module down-converts the input signal according to a second control signal 

(e.g., LO signal) and outputs a second down-converted signal (e.g., baseband signal); and 

a combining module (e.g., module with a differential amplifier) that combines the second 

down-converted signal with the first down-converted signal and outputs a single channel 

down-converted signal. 

98. The first frequency down-conversion module of each Intel Chip includes a 

first switch (e.g., transistor) and a first storage element (e.g., one or more capacitors), 

wherein the first switch is coupled to the first storage element at a first node (e.g., port) 

and coupled to a first reference potential (e.g., ground). 

99. The second frequency down-conversion module of each Intel Chip includes 

a second switch (e.g., transistor) and a second storage element (e.g., one or more 

capacitors), wherein the second switch is coupled to the second storage element at a 

second node (e.g., port) and coupled to a second reference potential (e.g., ground). 

100. ParkerVision has been damaged by the direct infringement of Intel, and is 

suffering and will continue to suffer irreparable harm and damages as a result of this 

infringement. 

COUNT VI - Infringement of United States Patent No. 8,588,725 

101. The allegations set forth above are re-alleged and incorporated by reference 

as if they were set forth fully here. 

Case 6:20-cv-00108-ADA Document 14 Filed 05/15/20 Page 20 of 31
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102. Intel directly infringes (literally and/or under the doctrine of equivalents) 

the ’725 patent by making, using, selling, offering for sale, and/or importing into the 

United States products covered by at least claim 1 of the ’725 patent. 

103. Intel products that infringe one or more claims of the ’725 patent include, 

but are not limited to, the Intel Chips and any other Intel device that is capable of downconverting a higher-frequency signal to a lower-frequency signal as claimed in the ’725 

patent. On information and belief, Intel uses the Intel Chips at least by testing the Intel 

Chips in the United States. 

104. Each Intel Chip is/includes an apparatus for down-converting an 

electromagnetic signal (e.g., high frequency RF signal) to a lower frequency signal. Each 

Intel Chip has an aliasing module comprising a switching device (e.g., transistor) and a 

storage module (e.g., capacitor). The aliasing module receives as an input an RF 

information signal and provides as an output a down-converted signal. The switching 

device of the aliasing module receives as an input a control signal (e.g., LO signal) that 

controls a charging and discharging cycle of the storage module by controlling the 

switching device so that a portion of energy is transferred from the RF information signal 

to the storage module during a charging part of the cycle and a portion of the transferred 

energy is discharged during a discharging part of the cycle. 

105. The control signal operates at an aliasing rate (e.g., LO rate with a 25% duty 

cycle) selected so that energy of the RF information signal is sampled and applied to the 

storage module at a frequency that is equal to or less than twice the frequency of the RF 

information signal. The storage module generates the down-converted signal from the 

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alternate charging and discharging applied to the storage module using the control 

signal. 

106. ParkerVision has been damaged by the direct infringement of Intel, and is 

suffering and will continue to suffer irreparable harm and damages as a result of this 

infringement. 

COUNT VII - Infringement of United States Patent No. 8,660,513 

107. The allegations set forth above are re-alleged and incorporated by reference 

as if they were set forth fully here. 

108. Intel directly infringes (literally and/or under the doctrine of equivalents) 

the ‘513 patent by making, using, selling, offering for sale, and/or importing into the 

United States products covered by at least claim 19 of the ’513 patent. 

109. Intel products that infringe one or more claims of the ‘513 patent include, 

but are not limited to, the Intel Chips and any other Intel device that is capable of downconverting a higher-frequency signal to a lower-frequency signal as claimed in the ’513 

patent. On information and belief, Intel uses the Intel Chips at least by testing the Intel 

Chips in the United States. 

110. Each Intel Chip is/includes a system for frequency down-converting a 

modulated carrier signal (e.g., a high frequency RF signal) to a lower frequency signal. 

Each Intel Chip has (a) a first switch (e.g., transistor), (b) a first control signal (e.g., LO 

signal) which comprises a sampling aperture (e.g., 25% duty cycle) with a specified 

frequency, and (c) a first energy storage element (e.g., one or more capacitors) that downCase 6:20-cv-00108-ADA Document 14 Filed 05/15/20 Page 22 of 31
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converts the modulated carrier signal according to the first control signal and outputs a 

down-converted in-phase signal portion of the modulated carrier signal. 

111. Each Intel Chip has (a) a second switch (e.g., transistor), (b) a second control 

signal (e.g., LO signal) which comprises a sampling aperture (e.g., 25% duty cycle) with 

a specified frequency, and (c) a second energy storage element (e.g., one or more 

capacitors) that down-converts the modulated carrier signal according to the second 

control signal and outputs a down-converted inverted in-phase signal portion of the 

modulated carrier signal. 

112. Each Intel Chip has a first differential amplifier circuit that combines the 

down-converted in-phase signal portion with the inverted in-phase signal portion and 

outputs a first channel down-converted differential in-phase signal. 

113. Each Intel Chip has (a) a third switch (e.g., transistor), (b) a third control 

signal (e.g., LO signal) which comprises a sampling aperture (e.g., 25% duty cycle) with 

a specified frequency, and (c) a third energy storage element (e.g., one or more capacitors) 

that down-converts the modulated carrier signal according to the third control signal and 

outputs a down-converted quadrature-phase signal portion of the modulated carrier 

signal. 

114. Each Intel Chip has (a) a fourth switch (e.g., transistor), (b) a fourth aperture 

signal (e.g., LO signal), and (c) a fourth energy storage element (e.g., one or more 

capacitors) that down-converts the modulated carrier signal according to the fourth 

control signal and outputs a down-converted inverted quadrature-phase signal portion 

of the modulated carrier signal. 

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115. Each Intel Chip has a second differential amplifier circuit that combines the 

down-converted quadrature-phase signal portion with the inverted quadrature-phase 

signal portion and outputs a second channel down-converted differential quadraturephase signal. 

116. ParkerVision has been damaged by the direct infringement of Intel, and is 

suffering and will continue to suffer irreparable harm and damages as a result of this 

infringement. 

COUNT VIII – Infringement of United States Patent No. 9,118,528 

117. The allegations set forth above are re-alleged and incorporated by reference 

as if they were set forth fully here. 

118. Intel directly infringes (literally and/or under the doctrine of equivalents) 

the ‘528 patent by making, using, selling, offering for sale, and/or importing into the 

United States products covered by at least claim 1 of the ‘528 patent. 

119. Intel products that infringe one or more claims of the ‘528 patent include, 

but are not limited to, the Intel Chips and any other Intel device that is capable of downconverting a higher-frequency signal to a lower-frequency signal as claimed in the ‘528 

patent. On information and belief, Intel uses the Intel Chips at least by testing the Intel 

Chips in the United States. 

120. Each Intel Chip is/includes a system for frequency down-converting a 

modulated carrier signal (e.g., high frequency RF signal) to a baseband signal. Each Intel 

Chip includes a first switch (e.g., transistor) coupled to a first control signal (e.g., LO 

signal) which comprises a sampling aperture (e.g., 25% duty cycle) with a specified 

Case 6:20-cv-00108-ADA Document 14 Filed 05/15/20 Page 24 of 31
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frequency, wherein the first switch is on and a portion of energy that is distinguishable 

from noise is transferred from the modulated carrier signal (e.g., high frequency RF 

signal) as an output of said first switch during the sampling aperture of the first control 

signal. 

121. Each Intel Chip includes a first energy storage element (e.g., one or more 

capacitors) that stores the transferred energy from the modulated carrier signal and 

outputs a down-converted in-phase baseband signal portion of said modulated carrier 

signal. 

122. Each Intel Chip includes a second switch (e.g., transistor) coupled to a 

second control signal (e.g., LO signal) which comprises a sampling aperture (e.g., 25% 

duty cycle) with a specified frequency, wherein the second switch is on and a portion of 

energy that is distinguishable from noise is transferred from the modulated carrier signal 

(e.g., high frequency RF signal) as an output of said second switch during the sampling 

aperture of the second control signal. 

123. Each Intel Chip includes a second energy storage element (e.g., one or more 

capacitors) that stores the transferred energy from the modulated carrier signal and 

outputs a down-converted inverted in-phase baseband signal portion of said modulated 

carrier signal. 

124. The portions of transferred energy from each of the first and second switch 

are integrated over time to accumulate said portions of transferred energy from which 

said down-converted in-phase baseband signal portion and said down-converted 

inverted in-phase baseband signal portion are derived. 

Case 6:20-cv-00108-ADA Document 14 Filed 05/15/20 Page 25 of 31
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125. Each Intel Chip includes a first differential amplifier circuit that combines 

said down-converted in-phase baseband signal portion with said down-converted 

inverted in-phase baseband signal portion and outputs a first channel down-converted 

differential in-phase baseband signal. 

126. ParkerVision has been damaged by the direct infringement of Intel, and is 

suffering and will continue to suffer irreparable harm and damages as a result of this 

infringement. 

COUNT IX - Infringement of United States Patent No. 9,246,736 

127. The allegations set forth above are re-alleged and incorporated by reference 

as if they were set forth fully here. 

128. Intel directly infringes (literally and/or under the doctrine of equivalents) 

the ‘736 patent by making, using, selling, offering for sale, and/or importing into the 

United States products covered by at least claim 1 of the ‘736 patent. 

129. Intel products that infringe one or more claims of the ‘736 patent include, 

but are not limited to, the Intel Chips and any other Intel device that is capable of downconverting a higher-frequency signal to a lower-frequency signal as claimed in the ‘736 

patent. On information and belief, Intel uses the Intel Chips at least by testing the Intel 

Chips in the United States. 

130. Each Intel Chip is/includes a system for frequency down-converting a 

modulated carrier signal (e.g., high frequency RF signal) to a demodulated baseband 

signal. Each Intel Chip has a first switch (e.g., transistor) coupled to a first control signal 

(e.g., LO signal) which comprises a first sampling aperture (e.g., 25% duty cycle) with a 

Case 6:20-cv-00108-ADA Document 14 Filed 05/15/20 Page 26 of 31
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specified frequency, wherein the first switch is on during the first sampling aperture and 

wherein the first switch is off outside the first sampling aperture. 

131. Each Intel Chip has a first energy storage element (e.g., one or more 

capacitors), coupled to said first switch, that outputs a down-converted in-phase 

baseband signal portion of the modulated carrier signal. 

132. Each Intel Chip has a second switch (e.g., transistor) coupled to a second 

control signal (e.g., LO signal) which comprises a second sampling aperture (25% duty 

cycle) with a specified frequency, wherein the second switch is on during the second 

sampling aperture and wherein the first switch is off outside the second sampling 

aperture. 

133. Each Intel Chip has a second energy storage element (e.g., one or more 

capacitors), coupled to the second switch, that outputs a down-converted inverted inphase baseband signal portion of the modulated carrier signal. 

134. The first and second control signals each control a charging and discharging 

cycle of their respective energy storage element so that for each switch a portion of energy 

from the modulated carrier signal is transferred to the respective energy storage element 

when the respective switch is on during the charging cycle, and a portion of previously 

transferred energy is discharged during the discharging cycle for each respective switch 

when the respective switch is off. 

135. For each respective energy storage element, the energy discharged during 

any given discharge cycle is not completely discharged, with the remaining undischarged 

Case 6:20-cv-00108-ADA Document 14 Filed 05/15/20 Page 27 of 31
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energy from the given discharge cycle becoming an initial condition for a next charging 

cycle that begins immediately following the given discharge cycle. 

136. The down-converted in-phase baseband signal portion is derived from 

energy accumulated at the first energy storage element during both the charging and the 

discharging cycles for the first energy storage element. The down-converted inverted inphase baseband signal portion is derived from energy accumulated at the second energy 

storage element during both the charging and the discharging cycles for the second 

energy storage element. 

137. Each Intel Chip has a first differential amplifier circuit that combines the 

down-converted in-phase baseband signal portion with the down-converted inverted inphase baseband signal portion and outputs a first channel down-converted differential 

in-phase baseband signal. 

138. ParkerVision has been damaged by the direct infringement of Intel, and is 

suffering and will continue to suffer irreparable harm and damages as a result of this 

infringement.

COUNT X - Infringement of United States Patent No. 9,444,673

139. The allegations set forth above are re-alleged and incorporated by reference 

as if they were set forth fully here. 

140. Intel directly infringes (literally and/or under the doctrine of equivalents) 

the ‘673 patent by making, using, selling, offering for sale, and/or importing into the 

United States products covered by at least claim 1 of the ‘673 patent. 

Case 6:20-cv-00108-ADA Document 14 Filed 05/15/20 Page 28 of 31
29 

141. Intel products that infringe one or more claims of the ‘673 patent include, 

but are not limited to, the Intel Chips and any other Intel device that is capable of downconverting a higher-frequency signal to a lower-frequency signal as claimed in the ‘673 

patent. On information and belief, Intel uses the Intel Chips at least by testing the Intel 

Chips in the United States. 

142. Each Intel Chip is/includes an apparatus for down-converting an input 

modulated carrier signal (e.g., high frequency RF signal) to a demodulated baseband 

signal, wherein the modulated carrier signal has an amplitude variation, a phase 

variation, a frequency variation, or a combination thereof. 

143. Each Intel Chip has a frequency down-conversion module that has a switch 

(e.g., transistor), a capacitor coupled to said switch, and a pulse generator (e.g., LO) 

coupled to the switch. The pulse generator outputs pulses to the switch at a rate (e.g., LO 

rate with a 25% duty cycle) that is a function of a frequency of the modulated carrier 

signal and a frequency of the demodulated baseband signal determined according to: (the 

frequency of the modulated carrier signal +/− a frequency of the demodulated baseband 

signal) divided by N, where N is any integer including 1. 

144. The pulses have apertures and the pulses cause the switch to open outside 

of the apertures and cause the switch to close and sample the modulated carrier signal 

during the apertures by transferring energy from the modulated carrier signal and 

accumulating the transferred energy in the capacitor each time the switch is closed. 

145. Some of the previously accumulated energy is discharged from the 

capacitor into load circuitry (e.g., a differential amplifier) each time said switch is open. 

Case 6:20-cv-00108-ADA Document 14 Filed 05/15/20 Page 29 of 31
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The demodulated baseband signal is generated from (a) the accumulating of the energy 

transferred to the capacitor each time the switch is closed and (b) the discharging of the 

some of the previously accumulated energy into the load circuitry each time the switch 

is opened. 

146. ParkerVision has been damaged by the direct infringement of Intel, and is 

suffering and will continue to suffer irreparable harm and damages as a result of this 

infringement. 

JURY DEMANDED 

Pursuant to Rule 38(b) of the Federal Rules of Civil Procedure, ParkerVision 

hereby requests a trial by jury on all issues so triable. 

PRAYER FOR RELIEF 

WHEREFORE, ParkerVision respectfully requests that the Court enter judgment 

in its favor and against Intel as follows: 

a. finding that Intel directly infringes one or more claims of each of the 

patents-in-suit; 

b. awarding ParkerVision damages under 35 U.S.C. § 284, or otherwise 

permitted by law, including supplemental damages for any continued postverdict infringement; 

c. awarding ParkerVision pre-judgment and post-judgment interest on the 

damages award and costs; 

d. awarding cost of this action (including all disbursements) and attorney fees 

pursuant to 35 U.S.C. § 285, or as otherwise permitted by the law; and 

Case 6:20-cv-00108-ADA Document 14 Filed 05/15/20 Page 30 of 31
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e. awarding such other costs and further relief that the Court determines to be 

just and equitable. 

Dated: May 15, 2020 

OF COUNSEL: 

THE MORT LAW FIRM, PLLC 

/s/ Raymond W. Mort, III 

Ronald M. Daignault 

Chandran Iyer 

Jason Charkow 

Stephanie Mandir 

GOLDBERG SEGALLA 

rdaignault@goldbergsegalla.com 

ciyer@goldbergsegalla.com 

jcharkow@goldbergsegalla.com 

smandir@goldbergsegalla.com 

711 Third Avenue, Suite 1900 

New York, New York 10017 

Telephone: (646) 292-8700 

Raymond W. Mort, III 

Texas State Bar No. 00791308 

raymort@austinlaw.com 

100 Congress Avenue, Suite 2000 

Austin, Texas 78701 

Tel/Fax: 512-865-7950 

Attorneys for Plaintiff ParkerVision, Inc. 

 

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