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Parkervision Inc. Message Board

  • pvnotes pvnotes Feb 21, 2013 2:24 AM Flag

    Prior Art

    I have posted a note on prior art and the impossibility of infringement at pvnotes/pv-summary

    I will try to post it here, if the yahoo message board software will cooperate..

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    • pvnotes - To quote the incomparable Inigo Montoya, "You keep using that word. I do not think it means what you think it means." ;-)

    • I note the confidence that negative posters have in "prior art". It reminds me of what was going on in 2000-2002 when the negative posters (and many highly qualified experts in person) were explaining to me that the PRKR technology violates fundamental laws of physics and CANNOT WORK. For years, posters were assuring us that every reputable company that had looked at the technology had determined that it was non-operable garbage. Now it turns out everybody in the world always knew it would work. Hm. ;-) Maybe there is a way to reconcile the position then with the position now but I don't see it yet.

      • 5 Replies to urspond
      • Thanks urs - I haven't been around that long and did not know what bashers were saying way back in 2000-2002. One more piece of a fascinating story. BTW, how does PV's technology allegedly violate the laws of physics according to them?

        Sentiment: Strong Buy

      • URSPOND,

        LOL! I had similar discussions with Radio Professionals who called D2D impossible, smoke and mirrors, bloated patents, and worse. Now that one of the largest communications companies in the world has commercially implemented D2D (and according to PRKR, they did a pretty good job) its almost time to serve up some crow.

      • I have been totally consistent over the years about "ParkerVision technlogy", i.e. D2D and D2P.

        ParkerVIision has never written a paper describing either D2D (the receiver stuff) or D2P (the transmitter/PA stuff), so one can only go by the patents.

        D2P, as published in the PRKR patents, simply doesn’t and can’t work like they think it does. I have explained this in detail in the pass, and won’t repeat it here. D2P will amplify, but the efficiency will not be good and there will be out-of-band emissions problems and other issues. It’s a non-starter and no-one will ever use it. I have been totally correct about this since I started posting the 2005/2006.

        It's fairly difficult to tell (even after 15 years) what D2D is/was. I wasn't privy to any of the PRKR disclosures, so I can only go by what's in the D2D patents.

        There are many different ideas in the D2D patents, which broadly can be put into two categories (1) *most* of the patents contain possibly new ideas, but which either have no advantage or simply are unworkable in real circuits, and (2) a few which have repackaged, renamed old ideas that indeed work, but that PRKR simply didn’t invent, but gamed the patent system to get issued claims on.

        The patent claims in this case are exactly equivalent to what the industry calls either a “passive mixer” or (less commonly) a “subsampling mixer”. It uses switches to transfer current and voltage (i.e. energy) to a storage device (usually one or more capacitors) directly from (usually amplified) input RF signal. A passive mixer (as compared to an active mixer, which has gain) is basically defined by transferring the bulk of the power (i.e. energy) form the input to the output using switches. By choosing the appropriate timing of the transfers, one can perform a frequency translation from RF carrier to either IF or baseband. This is very standard and very old stuff, and this is what PRKR is now claiming to have invented in 1998-2000 (the priority dates of the patents-in-suit.) I can show you literally hundreds of patents and papers on passive mixers predating those PRKR patents. There were working circuits and radios (both direct conversion and superhet) implemented in the 80’s and 90’s that PRKR claims would directly read upon – an obvious proof of the invalidity of those claims.

        So it depends on what PRKR technology you are referring to – much of it was, indeed unworkable (not sure about violating the laws of physics.) The PRKR patents, *in this case*, do not represent new ideas. Qualcomm knew about this back in 2000, when they showed PRKR the Parssinen1998 reference, among others.

        If you have notes from the 1999-2001 time period, I would be happy to show you which are the new but unworkable ideas, and which are the good, but stolen ideas. Don’t confuse them, as PRKR wants everyone to do.

      • Great post Urspomd

      • urspond:

        How can they reconcile it? They have different names. When was the last time you heard of Manuel Asencio or teddy_kgb_agent? They don't have to be bound by the need for consistency. It's a new day. The short position is the same, but the argument is different.

        But isn't Mike's argument a little different from the one he sold Mr. Alpert at Barron's?

    • The Tayloe patent is available via google. Lookup US patent 6230000.
      For some reason, I can't post a direct link.

    • Added paper at pvnotes/Qualcomm Paper 05746357.pdf

      • 2 Replies to pvnotes
      • 2nd Try:
        One added note: the Qualcomm paper describing the QSC260 ("A 65nm CMOS SoC with embedded HSDPA/EDGE Transceiver, Digital Baseband and Multimedia Processor" refers to the following paper "A 0.2-to-2.0GHz 65nm CMOS Receiver Without LNA Achieving 11dBm IIP3 and 6.5 dB NF" by Soer, which in turn refers to Tayloe.

        Thus Qualcomm can easily show reliance on Tayloe, clearly showing show they had good cause to believe (actually know) that they were implementing a known circuit.

      • One added note: the Qualcomm paper describing the QSC260 ("A 65nm CMOS SoC with embedded HSDPA/EDGE Transceiver, Digital Baseband and Multimedia Processor" refers to the following paper "A 0.2-to-2.0GHz 65nm CMOS Receiver Without LNA Achieving 11dBm IIP3 and

    • Yahoo is not letting me post coherently. Please read the full note at pvnotes/pv-summary

    • The Markman ruling came out on Feb 20, 2012. Qualcomm won a few key terms, but ParkerVision got much of what it wanted. I think the judge made some serious errors, but for now, we have to go with his definitions.

      With the terms defined both sides now can proceed with filings on invalidity.

      The Markman makes infringement contentions easier for ParkerVision, but makes proving invalidity far easier for Qualcomm. I will not attempt to do Qualcomm’s work for them – I’m sure they know how to proceed.

      What I can do is show that because of a fundamental principle of patent law, ParkerVision's patent claims against Qualcomm can easily be show to be meritless – regardless of the Markman.

      • 3 Replies to pvnotes
      • Farmwald - you are what they used to call a "one-note Johnny" No matter what happens in this case, you spin it as a negative for Parkervision. I have been trying to be as objective as possible with this stock, but your statements are positively ludicrous. I believe Judge Dalton adopted Parkervision's proposed claim construction - although in certain cases not word-for-word - in all but one case.

        What impresses me most of all is the obvious amount of just plain work, research, analysis and cogent discussion in Dalton's opinion. I think he took so long to get this ruling out so as to "appeal proof" it as much as possible. I believe the Federal Circuit would be hard put to reject Dalton's analysis and adopt Qualcomm's construction. This is particularly true when you note that most of the limitations that Qualcomm sought to impose on Parkervision's claims construction were based on extrinsic evidence - which is absolutely improper unless there in nothing in the intrinsic evidence, i.e. the language of the patent, the specifications and the prosecution history - to support it. I think Dalton's Markman withstands appeal - although it will never get that far.

        I can guarantee you right now that Keith Hummel is sending Qualcomm's top management and in-house counsel with comprehensive, detailed warnings about the potential exposure in this case- and his recommendations of settlement. He does not want something coming back on him if Q gets hit with a multi-billion dollar verdict.

        Sentiment: Strong Buy

      • Huh? they "won" one of 43 ... and, uh, how was it key, doc?

        Farmy:
        Qualcomm won a few key terms

      • ParkerVision is asserting claims against (among other chips) the QSC6270 chip, which was described in ISSCC 2011 paper 21.3 “A 65nm CMOS SoC with Embedded HSDPA/EDGE Transceiver, Digital Baseband and Multimedia Processor”. Fig 21.3.3 has a detailed receiver block diagram, which uses a 25% duty cycle quadrature passive mixer.

        ParkerVision apparently feels it invented the concept of passive mixers when used in direct conversion receivers (i.e. a passive mixer that is used to convert directly to baseband.). As far as I can tell, ParkerVision never used the words “passive mixer” in their patent filings, instead using variants of “transferring substantial energy from the input to output” – a term used by no one else in the RF technical literature either before or after the ParkerVision patent filings.

        There is a huge amount of prior art on passive mixers, as they have been around for a very long time. I will assume that Qualcomm will do a good job of bringing forward the relevant prior art concerning the various ParkerVision patent claims. What is clear is that a passive mixer very clearly “transfers substantial energy” and meets all of the relevant definitions of the recent Markman ruling.

        I would like to write a short note to prove something fairly simple, i.e., that the Qualcomm chip in-suit implements a mixer that is identical to circuits described in the technical literature well before the ParkerVision patents were filed. This will prove something much simpler in concept for the reader (as well as a judge or jury) to understand, i.e. that the ParkerVision patents can’t possibly be both valid and infringed by the Qualcomm chips, as they implement circuits and concepts that preexisted the ParkerVision patents. This is a fundamental concept of patent law – if you can show that you implemented an identical design or concept that predated the asserted patents, then your design can’t possibly be infringing. To be clear, it might be because the patent claims are invalid or because the patent claims do not read on the design, but one or the other must be true, both logically and by law.

 
PRKR
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