UNITED STATES DISTRICT COURT 

WESTERN DISTRICT OF TEXAS

WACO DIVISION

PARKERVISION, INC.,

 Plaintiff, 

 v. 

INTEL CORPORATION,

 Defendant.

Case No. 6:20-cv-00108

JURY TRIAL DEMANDED

SECOND 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. 6,266,518; 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”) 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 

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

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

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commercial video 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 then-division 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. Upon information and belief, Intel (or those acting on its behalf) made, 

used, sold, offered to sell and/or imported receiver, transmitter, and/or transceiver 

integrated circuits, for example, for use in cellular devices such as smartphones. These 

chips include, without limitation, the Intel PMB 5750, PMB 5757 and PMB 5762 (“PMB 

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Chips”) and any other receiver, transmitter, and/or transceiver integrated circuits (1) 

which have down-conversion circuitry configured the same as or equivalent to any of 

the PMB Chips and (2) are used (or intended for use in) and/or contained in cellular 

devices, near field communication devices, smart watches, personal area networks, 

cable modems, smart meters, DSL modems, Bluetooth devices and/or Wi-Fi devices.

The receiver, transmitter, and/or transceiver integrated circuits referenced in this 

paragraph shall each be referred to as an “Intel Chip” or collectively the “Intel Chips.”

33. Some of the Intel Chips, specifically the PMB 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

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.

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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. 6,266,518

36. 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. 

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

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

United States Patent No. 6,580,902

39. 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. 

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

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

United States Patent No. 7,110,444

42. 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 

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Technology Including Multi-Phase Embodiments and Circuit Implementations” to 

inventor David F. Sorrells et al. 

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

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

United States Patent No. 7,539,474

45. 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. 

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

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

United States Patent No. 8,588,725

48. 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. 

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

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

United States Patent No. 8,660,513

51. 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 

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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. 

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

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

United States Patent No. 9,118,528

54. 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. 

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

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

United States Patent No. 9,246,736

57. 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. 

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

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

United States Patent No. 9,444,673

60. 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 

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

‘673 patent is attached as Exhibit 10. 

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

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

CLAIMS FOR RELIEF

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

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

reference as if they were set forth fully here. 

64. 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. 

65. Upon information and belief, 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 down-converting a higher-frequency signal to a lowerfrequency 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.

66. Upon information and belief, 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.

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67. 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. 

68. 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.

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

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

70. 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

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

reference as if they were set forth fully here.

72. 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.

73. Upon information and belief, Intel products that infringe one or more 

claims of the ’902 patent include, but are not limited to, the Intel Chips, and any other 

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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.

74. Upon information and belief, 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 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. 

75. 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.

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

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

77. 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.

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78. 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

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

reference as if they were set forth fully here. 

80. 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. 

81. Upon information and belief, 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 down-converting a higher-frequency signal to a lowerfrequency 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.

82. Upon information and belief, 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 downconverting 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 

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conversion module to down-convert 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. 

83. 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 

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

signal.

84. 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

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

reference as if they were set forth fully here. 

86. 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. 

87. Upon information and belief, Intel products that infringe one or more 

claims of the ‘474 patent include, but are not limited to, the Intel Chips, and any other 

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Intel device that is capable of down-converting a higher-frequency signal to a lowerfrequency 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.

88. Upon information and belief, 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 downconversion module down-converts the 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 that receives the input signal, wherein the 

second frequency down-conversion 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 downconverted signal and outputs a single channel down-converted signal.

89. 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).

90. 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 

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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). 

91. 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

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

reference as if they were set forth fully here. 

93. 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. 

94. Upon information and belief, 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 down-converting a higher-frequency signal to a lowerfrequency 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.

95. Upon information and belief, 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.,

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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. 

96. 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 alternate charging and discharging applied to the storage module using the

control signal.

97. 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

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

reference as if they were set forth fully here. 

99. 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. 

100. Upon information and belief, 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 down-converting a higher-frequency signal to a lowerCase 6:20-cv-00108-ADA Document 84 Filed 04/16/21 Page 20 of 30
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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.

101. Upon information and belief, 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 down-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. 

102. 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.

103. 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.

104. 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 

Case 6:20-cv-00108-ADA Document 84 Filed 04/16/21 Page 21 of 30
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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.

105. 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.

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

the down-converted quadrature-phase signal portion with the inverted quadraturephase signal portion and outputs a second channel down-converted differential 

quadrature-phase signal. 

107. 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

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

reference as if they were set forth fully here. 

109. 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. 

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110. Upon information and belief, 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 down-converting a higher-frequency signal to a lowerfrequency 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.

111. Upon information and belief, 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 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.

112. 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.

113. 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 

Case 6:20-cv-00108-ADA Document 84 Filed 04/16/21 Page 23 of 30
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signal (e.g., high frequency RF signal) as an output of said second switch during the 

sampling aperture of the second control signal.

114. 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.

115. 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.

116. 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.

117. 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

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

reference as if they were set forth fully here.

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119. 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. 

120. Upon information and belief, 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 down-converting a higher-frequency signal to a lowerfrequency 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.

121. Upon information and belief, 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 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.

122. 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.

123. 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 

Case 6:20-cv-00108-ADA Document 84 Filed 04/16/21 Page 25 of 30
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sampling aperture and wherein the first switch is off outside the second sampling 

aperture.

124. 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.

125. 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.

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

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

undischarged energy from the given discharge cycle becoming an initial condition for a 

next charging cycle that begins immediately following the given discharge cycle.

127. 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 in-phase 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.

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

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

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

differential in-phase baseband signal.

129. 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

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

reference as if they were set forth fully here. 

131. 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. 

132. Upon information and belief, 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 down-converting a higher-frequency signal to a lowerfrequency 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.

133. Upon information and belief, 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.

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134. 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.

135. 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.

136. 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. 

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.

137. 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.

Case 6:20-cv-00108-ADA Document 84 Filed 04/16/21 Page 28 of 30
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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 

post-verdict 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

e. awarding such other costs and further relief that the Court determines to 

be just and equitable.

Case 6:20-cv-00108-ADA Document 84 Filed 04/16/21 Page 29 of 30
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Dated: April 16, 2021 Respectfully submitted,

OF COUNSEL:

THE MORT LAW FIRM, PLLC

/s/Raymond W. Mort, III

Ronald M. Daignault*

Chandran B. Iyer

Jason S. Charkow*

Stephanie R. Mandir 

DAIGNAULT IYER LLP

rdaignault@daignaultiyer.com 

cbiyer@daignaultiyer.com 

jcharkow@daignaultiyer.com

smandir@daignaultiyer.com

8200 Greensboro Drive, Suite 900

McLean, Virginia 22102

*Not Admitted in Virginia

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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