UNITED STATES DISTRICT COURT 

WESTERN DISTRICT OF TEXAS 

WACO DIVISION 

PARKERVISION, INC., 

 

 Plaintiff, 

 v. 

INTEL CORPORATION, 

 Defendant. 

Case No. 6:20-cv-00562-ADA 

JURY TRIAL DEMANDED

FIRST AMENDED COMPLAINT FOR PATENT INFRINGEMENT 

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

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

patent infringement of United States Patent Nos. 6,049,706, 7,050,508 and 8,190,108 (“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. 

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. 

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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 at least 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 subject matter jurisdiction over this action pursuant to 28 

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

States, 35 U.S.C. §§ 1 et seq. 

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

process and/or the Texas Long Arm Statute because, in part, 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. 

9. This Court has personal jurisdiction over Intel because Intel (directly 

and/or through its subsidiaries, affiliates, or intermediaries) has committed and 

continues to commit acts of infringement in this judicial district in violation of at least 

35 U.S.C. § 271(a). 

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

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

the State of 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 with this State and this 

judicial district; (2) owns, manages, and/or operates facilities in this State and this 

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

judicial district; (4) employs Texas residents in this State and this judicial district; and 

(5) solicits business and markets infringing products in this State and 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. Venue is proper in this judicial district pursuant to 28 U.S.C. § § 1391(b)-

(d) and/or 1400(b). Intel is registered to do business in the State of Texas, maintains a 

regular and established place of business within this judicial district, and has committed 

acts of infringement in this judicial district. 

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

in this judicial district. 

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14. On information and belief, Intel uses its Austin Offices 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. 

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/index.php?searchtext=INTEL+CORPORATION&year=&min

salary=&state=&worksite_city=AUSTIN&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. 

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

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 cameras, e.g., for television broadcasts. The cameras used radio 

frequency (RF) technology to automatically track the camera’s subject. 

https://jobs.intel.com/ListJobs/All/Search/state/tx/ (last visited on June 10, 2020). 

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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. Sorrells 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 developing 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 better 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. Similar to its down-conversion 

technology, ParkerVision’s up-conversion technology provided size and integration 

benefits, improved performance, lower costs and power savings. ParkerVision also 

developed complementary wireless communications technologies involving 

interactions, processes, and controls between the baseband processor and the 

transceiver, which improved and enhanced the operation of transceivers that 

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incorporated ParkerVision’s down-conversion and up-conversion technologies. To date, 

ParkerVision has been granted over 200 patents related to its innovations including, the 

patents-in-suit. 

25. 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, more efficient, and with higher performance. 

INTEL CHIPS 

26. 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 PMB5750, PMB5757 and 

PMB5762 (each an “Intel Chip”; collectively, the “Intel Chips”). 

27. Intel Chips provide cellular connectivity for devices such as Apple 

iPhones.

28. On information and belief, the PMB5750 was incorporated into devices 

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

belief, the PMB5757 was incorporated into devices including, without limitation, the 

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-teardownconfirms-bigger-battery-intel-lte-modem-in-some-models-and-more.html. 

Case 6:20-cv-00562-ADA Document 6 Filed 07/16/20 Page 7 of 16
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Apple iPhone 8, 8 Plus and X.2 On information and belief, the PMB5762 was 

incorporated into devices including, without limitation, the Apple iPhone XR, XS and 

XS Max. 3

29. On February 7, 2017, Intel published a paper entitled “A Digital 

Multimode Polar Transmitter Supporting 40MHz LTE Carrier Aggregation in 28nm 

CMOS,” describing digital polar transmitter architecture with a die micrograph of the 

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-00562-ADA Document 6 Filed 07/16/20 Page 8 of 16
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DPLL and AM path of the transmitter (shown below).4 On information and belief, the 

die micrograph (below) illustrates Intel’s PMB5750 chip. 

30. On information and belief, the structure, function, and operation of Intel’s 

PMB5757 and PMB5762 chips are substantially similar to the PMB5750 with respect to 

the features claimed in the patents-in-suit. 

4 M. Fulde et al., “A Digital Multimode Polar Transmitter Supporting 40MHz LTE 

Carrier Aggregation in 28nm CMOS,” ISSCC, pp. 218-219 (Feb. 2017). 

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31. 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

32. 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. 

33. The ’706 patent is presumed valid under 35 U.S.C. § 282. 

34. ParkerVision owns all rights, title, and interest in the ’706 patent. 

United States Patent No. 7,050,508

35. On May 23, 2006, the United States Patent and Trademark Office duly and 

legally issued United States Patent No. 7,050,508 (“the ’508 patent”) entitled “Method 

and System for Frequency Up-Conversion with a Variety of Transmitter 

Configurations” to inventor David F. Sorrells et al. 

36. The ’508 patent is presumed valid under 35 U.S.C. § 282. 

37. ParkerVision owns all rights, title, and interest in the ’508 patent. 

United States Patent No. 8,190,108 

38. On May 29, 2012, the United States Patent and Trademark Office duly and 

legally issued United States Patent No. 8,190,108 (“the ’108 patent”) entitled “Method 

and System for Frequency Up-Conversion” to inventor David F. Sorrells et al. 

39. The ’108 patent is presumed valid under 35 U.S.C. § 282. 

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40. ParkerVision owns all rights, title, and interest in the ’108 patent. 

CLAIMS FOR RELIEF 

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

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

reference as if they were set forth fully here. 

42. 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. 

43. 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. 

44. Each Intel Chip is/includes an apparatus for filtering and downconverting (e.g., a higher frequency RF signal to a lower frequency signal). Each Intel 

Chip includes 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 down-converted 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 

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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. 

45. 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. 

46. 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. 7,050,508 

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

reference as if they were set forth fully here. 

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

the ’508 patent by making, using, selling, offering for sale, and/or importing into the 

United States products covered by at least claim 3 of the ’508 patent. 

49. Intel products that infringe one or more claims of the ’508 patent include, 

but are not limited to, the Intel Chips, and any other Intel device that is capable of upconverting a lower-frequency signal to a higher-frequency signal as claimed in the ’508 

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

Chips in the United States. 

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50. Each Intel Chip is/includes an apparatus for frequency up-conversion. 

Each Intel Chip includes a pulse shaping means (e.g., logic devices) for shaping a string 

of pulses from a reference signal (e.g., local oscillator (LO) signal); aperture generation 

means (e.g., digital phase locked loop) coupled to said pulse shaping means for 

generating a string of multiple pulses from said string of pulses; and gating means (e.g., 

inverter) for gating a bias signal (e.g., a signal having a steady, predetermined level) 

under the control of said string of multiple pulses to generate a periodic signal having a 

plurality of harmonics at least one of which is at a desired frequency. 

51. On information and belief, the aperture generation means of each Intel 

Chip includes input means for receiving said string of pulses; logic gating means for 

outputting said string of pulses; and first delaying means for delaying said string of 

pulses for a first period of time. 

52. 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. 8,190,108 

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

reference as if they were set forth fully here. 

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

the ’108 patent by making, using, selling, offering for sale, and/or importing into the 

United States products covered by at least claim 8 of the ’108 patent. 

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55. Intel products that infringe one or more claims of the ’108 patent include, 

but are not limited to, the Intel Chips, and any other Intel device that is capable of upconverting a lower-frequency signal to a higher-frequency signal as claimed in the ’108 

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

Chips in the United States. 

56. Each Intel Chip is/includes a frequency conversion module having a first 

switch (e.g., transistor) configured to up-convert a signal (e.g., baseband signal) based 

on a control signal (e.g., modulated oscillating signal) and a bias signal (e.g., a signal 

having a steady, predetermined level), wherein said signal are routed to said frequency 

conversion module via a second switch (e.g., transistor), and wherein said signal is 

transmitted by an antenna connected to a third switch (e.g., transistor). 

57. Each Intel Chip has a pulse shaper (e.g., digital phase locked loop); and an 

oscillating signal generator (e.g., LO). The oscillating signal generator includes a voltage 

controlled oscillator configured to generate an oscillating signal (e.g., LO signal), and 

the pulse shaper is configured to generate a string of pulses based on the oscillating 

signal. 

58. 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. 

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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. 

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Dated: July 16, 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 

*Pro hac vice to be filed Attorneys for Plaintiff ParkerVision, Inc. 

 

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