Here in essence is the claimed invention -
1. A method for down-converting a carrier signal to a lower frequency signal, comprising transferring energy from the carrier signal and generating a lower frequency signal from the transferred energy.
23. An apparatus for down-converting a carrier signal to a lower frequency signal, comprising an energy transfer signal generator; a switch module controlled by said energy transfer signal generator; and a storage module coupled to said switch module; wherein said storage module receives energy transferred from a carrier signal wherein a lower frequency signal is generated from the transferred energy.
ParkerVision's sole independent expert witness confirmed that the use of a storage device is essential for infringement -
Q: And in order to have energy transfer as defined in every one of the claims at issue in this case, you need to have current from the carrier signal flow into the storage device, correct?
Q: And then the energy -- then the current from the carrier signal, which is flowed into the storage device, is then used to generate the baseband, correct?
The scope of the claimed invention is therefore beyond reasonable dispute - a method for down-converting a carrier signal to a lower frequency signal via a storage device.
Prucnal also testified that the mixer in the accused products performs the down-conversion -
Q: So at least in Qualcomm's architecture, the double balanced mixer not only is capable of, it does, in fact, create the baseband before it hits the TX filter that you're talking about now, correct?
If any shareholder who uses this forum is confident that Judge Dalton will refuse Qualcomm's request for a JMOL of non-infringement - would you mind helping us all out please by pointing to the evidence that the mixer in the accused products incorporates a storage device?
Teamrep - I'm quite hopeful that Judge Dalton will now do the right thing.
ParkerVision simply failed to offer evidence that the accused products down-convert from carrier wave to baseband via energy accumulation and discharge - unless evidence was supplied that the mixer in the accused products incorporates a storage device.
Absent such evidence, ParkerVision's only hope is that Judge Dalton deems the testimony that the filter incorporates a storage device as acceptable (by a "reasonable mind") evidence of infringement.
But to do so, Judge Dalton would have to interpret the scope of the asserted patents as being wider than simply "down-converting a carrier signal to a lower frequency signal" - as irrespective of the part the filter plays, Prucnal testified that it is a post-downconversion part of the process.
Which leads us directly to the key question - will Judge Dalton deem it reasonable to attribute a meaning to the word "generate" in this key phrase which is any wider than "create"? -
[ wherein a lower frequency signal is generated from the transferred energy. ]
Assuming his decision is consistent with his earlier ruling that there is no valid basis for limiting "generation" to devices which discharge energy, I fail to see how any of the evidence could be deemed by Judge Dalton to be acceptable evidence of infringement.
Watch this space for the FIRST honest response by a Long to the all-important question -
will Judge Dalton have justifiable cause for refusing Qualcomm's request for a JMOL of non-infringement, by citing evidence that the mixer in the accused products down-converts by energy accumulation and discharge?
Apologies for the interruption Longs. You can now go back to weaving your fantastic tales which pretend that this potentially-catastrophic approaching threat to your investment does not exist.
I have looked at PV's patents beyond those used in PV vs. Q in order to ponder how the technology might be used. The core methods describe variance of sampling period, whether that is using the mystical energy sampling method or just voltage sampling across a R-C circuit. The hard part was to imagine its use in today's multiple-band radio applications that require all the complimentary circuitry, preconditioning, etc. and could take advantage of multiple RF stages, etc. Years ago I thought PV's patents were probably useless because they were not practical... however, there was a possibility for the fairy dust principles to be borne out IF PV would show it in practical application... using what looked to be necessary, coupled methods of signal processing. PV has never done so nor gotten anyone else to use it... VIA nor anyone else have generated revenue despite years of payments from PV to try the tech. The basic problem derives down to it being more not less complex than other methods... just to see if it can be made to work. As compared to what has evolved over the past several years, PV's approach looks even less likely to find success thant that early 'fairy dust' imagineering. Varying of signal apertures as suggested in PV's patents creates problems of higher noise figure, complexity rather than simplicity, and is blown away by the inherently elegant quadrature signal aperture/sampling method of the double-balanced mixer. That structure lends itself to use with the complimentary technologies as has been borne out in practical applications... that continue to win out over other approaches, each of which may have particular advantages as partial solutions to the overall requirements.
teamrep, AKA Mr. Google, None of your blather has anything to do with the case, and that's all that matters now. Whether PV will be sprinkling fairy dust on $Billions of licensing revenue over the next 10 years or not.
BTW, for others that you attempt to confuse, varying the sample aperture allows the device to act also as a tunable matched filter; an added benefit! QCOM has demonstrated the performance and value by locking up the marketplace. Its no longer a question!
Do any of you clowns - and by that I mean pvnotes, statesrep and teamrep - understand that there has been a trial and that your side lost? You keep arguing vehemently - and infinitum and ad nauseum - about technical arguments - without addressing the question of - if your arguments are so persuasive, why didn't Mr. Neal have a witness testify as to those issues? I have asked this question repeatedly, and you have all ducked it. You guys are laughable - with your snarky remarks about Mr. Fairy -Dust - but you seem to forget that Mr. Fairy Dust and Co. were successful in obtaining the 9th largest patent infringement verdict in history - $173 million - nothing to sneeze about.
I find the joke is Dr. "I am Extraordinarily Skilled in the Art" Razavi - who made a complete and utter fool of himself on the stand. The reason Mr. Neal didn't put Dr. Wolf on the stand was because he saw Josh Budwin salivating on the sidelines with a knife in his hand waiting to slice up Wolf into little itty bitty pieces.
Do you really think that Judge Dalton or the Federal Circuit are going to consider arguments that were never made by any of Qualcomm's witnesses - excuse me, that is witness (singular)? You have all been spewing the same garbage for the last 2 years - and I guess you will continue to do so right up to the point where this verdict is affirmed . Being consistently and uniformly wrong doesn't seem to bother you.
What I find more interesting is whether Dalton enters an injunction with an 18 month sunset period. I think he will and then this case will be over - before April
Sentiment: Strong Buy
You continue to make very stupid posts so I guess you are very stupid which is why you have probably been, financially relatively unsuccessful in life. Why don't you cite, lets say, three of my posts which argue vehemently about technical issues. If you can't then that is evidence you are a complete idiot!!!
We understand it more fully than you apparently. The course of the trial was discussed prior to it taking place. I posited that PV would pursue the 'paint the picture for the jury strategy' that is often the ruse and was likely more so based on PV's past and choice of law firms. Leading up to the trial, my perception of how PV's attorneys might shape the case led me to think Judge Dalton would reign in the degree of their use of red lipstick. Boy was I wrong. The talk here was almost exclusively about old emails and prior discussions... and little about how the industry had since moved on or how RF was only one small piece of the puzzle.
The 'jury has decided' and so it is... until the erroneous decision gets appealed or a new trial is undertaken or the parochial feudal system Judge comes to his senses and reverses (imo of course).