Tampa - take a break from contributing nothing of value in as many words as possible.
Do you recall one of the Appeal Court panel asking the ParkerVision attorney to explain how it is possible for a capacitor to convert a signal of one frequency to a signal of another frequency?
From Sorrells' new White Paper -
The process of Energy Transfer Sampling (ETS) to create a frequency down-converted output signal is accomplished by successive steps of:
1) Transferring a portion of the energy from the input signal into a storage element and
2) Transferring a portion of the energy in the storage element to the output or load.
The explanation is accompanied by a couple of diagrams - one showing the energy from the input signal charging the capacitor when the switch is closed, the other showing the capacitor discharging when the switch is open.
This recent argument of yours confirms that the charging and discharging is controlled by the same switch (or set of switches) -
"Obviously the jury also listened to Prucnal explain the time varying charging and discharging of the capacitor caused by the switch which traces out the baseband waveform to the load."
I don't recall seeing anything in the evidence record about Magic Capacitors.
On a physical level we have current flowing through a circuit. The down-converted baseband signal is represented by fluctuations in the flow of current.
For the current to exit the capacitor in a manner which duplicates the baseband fluctuations it would have to enter the capacitor in a manner which duplicates the baseband fluctuations, no?
Therefore logic dictates that the capacitor cannot generate the baseband signal unless something elsewhere in the circuit recovers the baseband signal.
The recovery of the baseband signal is called down-conversion. The alleged infringement is of a METHOD OF DOWN-CONVERSION requiring energy storage.
Tell me if I've misunderstood anything - in words even Longprkr should understand.
How would a "reasonable juror" reconcile the two logical conclusions noted in the post below with the remainder of Prucnal's testimony?
Note the word "following" in the testimony ParkerVision has been highlighting since the trial, implying that the capacitor itself is not doing the generating -
[ The energy from the baseband signal ... from the carrier signal is transferred through the switch. It's accumulated by the capacitor. And that energy is then used to generate the baseband signal following the capacitor ]
Prucnal's refusal to claim that the mixer would be unable to down-convert the baseband signal in the absence of the TX filter implies that his argument was -
1. Without the TX filter in the circuit - the mixer creates the baseband signal.
2. With the TX filter in the circuit - the mixer creates the baseband signal, it passes through the TX filter by a route which avoids the "broken wire" capacitors, and is then generated by the TX filter using energy accumulated by the capacitors.
Judge Dalton noted -
[ There is no dispute that Mr.Sorrells' opinions - like those of Dr.Prucnal - were not based on appropriate testing or simulations ]
Absent any supporting testing or simulations, Prucnal's theory of operation - which wasn't supported by the schematics upon which he based his testimony either - would not have constituted a legally sufficient evidentiary basis for a verdict.
However Judge Dalton went further than that, ruling that Prucnal's testimony actually "precludes" a verdict of infringement because it confirms that -
[ the baseband signal is created in the Qualcomm products before the storage capacitors ]
Recall the admission of the lead inventor that the accused products do not infringe his patent if they -
[ get the baseband signal somehow or somewhere other than from the carrier signal energy that has been stored in the capacitor ]
Tampa - the point is that the Appeal Court panel must interpret the evidence as would a "reasonable juror".
ParkerVision told the jury that 0.11 microamps of baseband signal go in one end of the TX filter and come out the other end.
Logical conclusion: 0.11 microamps of baseband signal is finding a path through the TX filter.
ParkerVision told the jury that to a low frequency signal a capacitor is effectively a broken wire.
Logical conclusion: The path the 0.11 microamps of baseband signal is finding through the TX filter doesn't pass through any of the capacitors.
Given the tacit admission that there are no capacitors in the mixer, a reasonable juror would see this as evidence that the accused products do not get the baseband signal from stored energy.
The precise method by which the Qualcomm mixer down-converts the baseband signal is irrelevant to the Appeal.
All that matters is whether or not ParkerVision supplied evidence that the mixer creates the baseband signal from energy stored in a capacitor.
Recall that both the Qualcomm attorney and the ParkerVision attorney prompted Prucnal to opine on what would happen if the TX filter was removed from the circuit. In both instances Prucnal refused to claim that the mixer would be unable to down-convert the baseband signal in the absence of the TX filter.
But he was never going to make that claim, as he'd never disputed the accuracy of the schematic he chose to use for his testimony. The schematic he chose depicted a double balanced mixer. He could scarcely argue that a double balanced mixer is unable to down-convert a baseband signal.
That was quick Longprkr. Tampa says -
"The testimony was broken wire to low frequency (DC or less than 1 cycle/sec - Hz) and not the Millions of cycles/sec MHz range of the baseband."
Here IS the testimony.
Why don't you ask Tampa to show you where Prucnal told the jury what he meant by "low frequency"?
Q: As a general matter, a low frequency current signal will not flow through a capacitor. Would you agree with that?
A: Yes. The voltage has to be changing for a current to flow through a capacitor.
Q: You gave so many "yes" answers to Mr.Budwin. You seem incapable of giving one to me. So let me try and ask you a question again. Do you agree that low frequency current signals can't flow through a capacitor?
Q: And low frequency signals, therefore, are blocked by a capacitor, correct?
Q: Let's talk about what a capacitor looks like to a high frequency signal. At very high frequencies, a capacitor looks like a short-circuit, correct?
Q: A high frequency signal can't flow straight through a capacitor, correct?
Q: Well, a high frequency will flow through and be captured by the capacitor, correct?
A: I can't agree with ...
Q: Okay. So let me go back to what you said earlier ... Do you see the top circle and the bottom circle and no line between it?
Q: Do you see that?
Q: If you've got a very low frequency, it comes in at the top, it's not going to go through the capacitor, correct?
A: At sufficiently low frequency, yes.
Q: So at sufficiently low frequency, a capacitor will essentially look like a broken or disconnected wire, correct?
Q: And to a high frequency going through the wire, the capacitor will look like a wire that it can freely move through, correct?
Q: Okay. And those are fundamental principles of how capacitors work. Would you agree with that?
A: I think this figure could be used to illustrate that point.
Re your -
"Fud, you're obviously paid to bash ... the stock is down to 37 cents and you post multiple times every day?"
- a simple click on my ID will reveal that I've posted 110 times in 90 days.
No wonder you need an adviser to tell you what to think.
Furthermore, if I was being paid to bash - how could my "reason for optimism" post (currently at the top of the second page) suit the agenda of my employer?
Perhaps it's time you asked your adviser if this makes more sense .....
The Appeal Court panel will discover that by the time the jurors retired - with ParkerVision's closing argument ringing in their ears -
[ .25 microamps go into the mixer. .11 go out and into the TX filter, where it's undisputed there are capacitors. And .11 comes out of the TX filter, the capacitors, to form the baseband signal. ]
- the jurors had evidence that -
1. the mixer which creates the baseband signal does not store energy in a capacitor
2. 0.11 microamps of baseband signal enter the TX filter
3. the capacitors within the TX filter are effectively "broken wires" to a baseband signal
4. 0.11 microamps of baseband signal exit the TX filter
5. there is no infringement if the baseband signal is not created from energy stored in a capacitor.
As your friends have been unable to produce any contradictory evidence - perhaps you should consider the possibility that the group of wannabe shysters here feigning confidence in the outcome of the Appeal are as tolerable to some people as a cockroach infestation.
1. What Teamrep posts always makes sense. What you post is frequently fabrication to suit your agenda.
2. How could I be in over my head when there's no reason to venture any deeper than the average juror can handle?
I've referred you to ParkerVision's closing argument on numerous occasions -
[ .25 microamps go into the mixer. .11 go out and into the TX filter, where it's undisputed there are capacitors. And .11 comes out of the TX filter, the capacitors, to form the baseband signal. ]
- but you still don't appear to have grasped the fact that ParkerVision needed to match the steps of the patent to the accused products in a way the average juror could understand.
Concepts such as folding space and time were necessarily discarded in favour of far more simple concepts - such as a period of energy accumulation which starts and finishes at different points in time, and a mixer and a filter at different points in a circuit.
Consequently the theories to which you've been clinging like a drowning man are not supported by anything in the evidence record. The Appeal Court panel's decision will instead be heavily influenced by relative terms such as "then" and "before" -
[ The energy from the baseband signal ... from the carrier signal is transferred through the switch. It's accumulated by the capacitor. And that energy is then used to generate the baseband signal ]
[ That is the filter that contains the capacitors that we've been talking about ]
[ The double balanced mixture(sic) not only is capable of, it does, in fact, create the baseband before it hits the TX filter" ]
[ If the accused products get the baseband signal somehow or somewhere other than from the carrier signal energy that has been stored in the capacitor, then those products do not infringe ]
Although we have to dismiss arguments unsupported by the case made to the jury - in years to come I predict we'll all be dining out on the fact that WE WERE THERE when Tampa discovered two new laws of physics.
1. Prucnal testified that the capacitor accumulates energy during each aperture period, and "generates" the baseband signal at the end of the aperture period via discharge of energy -
"The energy from the baseband signal ... from the carrier signal is transferred through the switch. It's accumulated by the capacitor. And that energy is then used to generate the baseband signal following the capacitor."
However he later admitted that the baseband signal is down-converted "before" it hits the TX filter he identified as the location of the capacitor.
Logical conclusion: Baseband "generation" must be separated in time from baseband down-conversion by an aperture period.
But had the jurors been familiar with Tampa's First Law of Quantum Mechanics - LOW FREQUENCY ENERGY WAVES FOLD TIME - they would have reasoned as Tampa does -
[ One must look at waveforms! ... before/after has no relevance. It's the same point electrically supporting the simultaneous operation. ]
2. Prucnal testified that to the baseband signal the capacitor is effectively a "broken wire" -
Q: "So at sufficiently low frequency, a capacitor will essentially look like a broken or disconnected wire, correct?"
Logical conclusion: The argument that the baseband signal after the mixer is the baseband signal after the capacitor because "all points on a wire are the same" is invalid.
But had the jurors been familiar with Tampa's Second Law of Quantum Mechanics - LOW FREQUENCY ENERGY WAVES FOLD SPACE - they would have reasoned as Tampa does -
[ You say PV "conceded that the baseband was generated at the output of the mixer." That point is also the output of the capacitor ... the admission argument is technically irrelevant because a single point can't have a before or after. ]
Tampa, you're doomed to be a waste of space in this forum until you face reality - ParkerVision had to settle for a portrayal of the circuitry likely to be understood by jurors NOT "skilled in the art".
The reality is that the panel of judges can only consider whether or not a verdict of infringement was "properly" supported by the EVIDENCE PRESENTED.
ParkerVision's closing argument confirms that the independent expert witness portrayed a vastly simplified, one-way sequence of processes - involving a mixer creating the baseband signal and then outputting it to a TX filter containing capacitors, which then "generates" it.
He matched each of the steps of the patented method of down-conversion in turn to a process he'd described - the last two processes occurring in the TX filter.
He then admitted that the baseband signal is down-converted by the mixer "before" it hits the TX filter.
Because Qualcomm was clever enough to get the lead inventor to admit that if the accused products do not "get the baseband signal" from stored energy they do not infringe his patent, the Appeal Court panel will first look for evidence that the mixer gets the baseband signal from the energy-integrating capacitors in the TX filter.
Recall the dispute during the recent preliminary oral hearing - the ParkerVision attorney claiming that the record contains evidence of capacitors in the mixer, despite the Qualcomm's attorney's simple statement of fact that there are no capacitors in the mixer.
Prucnal's testimony was quite clear on that point - confirming that the capacitors to which he had referred are in the TX filter.
Any investor who took the trouble to read the testimony to which I directed them a few days ago (see the "lazy investor" thread) knows by now that there is no evidence that the mixer gets the baseband signal from the TX filter.
To minimize the "looping back", let me know when you're ready to discuss the evidence the Appeal Court panel will find in the record.
Re your -
" The baseband is generated in the capacitor from the sampled carrier energy and transferred to the low impedance load. That baseband is available at the output of the mixer which just so happens to share the same output of the capacitor because by definition they are shorted together by a wire or conductor. Cut that wire and no baseband is generated in either theory. Rezavi testified that all points on a wire are the same; which is just fact."
- didn't Prucnal testify that a capacitor is effectively a "broken wire" to signals of certain frequencies?
Did he subsequently explain why the energy-integrating capacitor should be viewed as a continuous wire for the purposes of his infringement argument?
However - in arguing that the mixer and the TX filter are effectively inseparable you're overlooking a far more obvious flaw.
Do you recall Prucnal's testimony concerning the outputs labelled "BBOP" and "BBOM" on the schematic upon which Prucnal chose to base his infringement testimony?
Does the schematic position those outputs at the exit of the TX filter - or does it position them at the exit of the mixer?
Recall ParkerVision's CLOSING ARGUMENT to the jury -
.25 microamps go into the mixer.
.11 go out and into the TX filter, where it's undisputed there are capacitors.
And .11 comes out of the TX filter, the capacitors, to form the baseband signal.
If the jury was told that the schematic chosen by ParkerVision positions those baseband outputs at the exit of the MIXER - then doesn't it logically follow that it's the mixer - not the TX filter - that creates the baseband signal?
If so - what supports the conclusion that the mixer is in fact getting the baseband signal from the TX filter?
Tampa re your -
1. "Fud, I struggle technically to understand Neal's hypothetical circuit setup leading to the "Admission". There just isn't any precedence for before/after on a wire; especially in an ac circuit."
- the jury heard a Professor of Electrical Engineering admit that the baseband signal is down-converted by the mixer "before" it hits the TX filter he had earlier identified as the location of energy-integrating capacitors.
Did you testify? If not, the jury had no reason to doubt the testimony of the independent expert witness.
Prucnal never disputed the accuracy of the schematic upon which he chose to base his testimony, which depicted a mixer with baseband outputs. Neither did he claim, when asked what would happen if the TX filter was removed, that the mixer would no longer function.
The Appeal Court panel must decide whether or not the EVIDENCE PRESENTED "properly" supported a verdict of infringement.
2. "Why did Judge Dalton decide to resolve this conflict over the jury?"
Note the word "properly" -
[ The question is not whether there is literally no evidence supporting the party against whom the (JMOL) motion is directed, but whether there is evidence upon which a jury could properly find a verdict for that party. ]
Prucnal matched the energy integration and baseband "generation" steps of the patented "method for down-converting a carrier signal to a baseband signal" to processes he later admitted occur after the baseband signal has been down-converted.
The jury ignored his admission.
But Judge Dalton knew that in order to "properly" show infringement, all four steps of the patented method of down-conversion had to be matched to the method of down-conversion in the accused products -
[ Dr.Prucnal's concessions during cross-examination as well as his direct testimony are fatal to ParkerVision's infringement case, which points to the TX filter as the location of the capacitors that "generate" the baseband by charging and discharging. ]
Re your -
"See Prucnal direct. The baseband comes from sampled carrier energy stored in the caps and transfered to the load."
- isn't that what Neal and Prucnal were referring to here? -
Q: And let's go to figure 32 of Exhibit 605. And you talked about this a fair amount in your direct testimony, correct?
Q: And if you look at the box that's called TX filter ... do you see that?
Q: That is the filter that contains the capacitors that we've been talking about ... you've been talking about both in your direct and your cross, correct?
Didn't Prucnal testify that the TX filter processes occur AFTER the baseband signal has been down-converted by the mixer?
And didn't Judge Dalton rule that Prucnal's testimony therefore actually points to NON-infringement? -
[ Dr. Prucnal's concessions during cross-examination as well as his direct testimony are fatal to ParkerVision's infringement case, which points to the TX filter as the location of the capacitors that "generate" the baseband by charging and discharging. ]
Why would the Appeal Court panel disagree, without evidence that the mixer gets the baseband signal from stored energy?
1. Am I correct that your theory of how the Qualcomm mixer operates was never presented to the jury - and is therefore completely irrelevant to the Appeal?
2. There's no need to apologize for drawing attention to Prucnal's testimony concerning the TX filter processes.
Evidence that a storage device within the TX filter creates the baseband signal from integrated energy is irrelevant. ParkerVision needed to supply evidence that the MIXER creates the baseband signal from integrated (stored) energy.*
The alleged infringement is of a patented method of down-conversion. The TX filter processes undisputedly occur after the baseband signal down-converted by the mixer hits the TX filter (see Prucnal's specific testimony on that key issue).
Furthermore, ParkerVision's explanation to the jury of its claimed invention logically dictates that the later baseband "generation" must be separated in time from the baseband down-conversion by a minimum of an aperture period.
Why would the Appeal Court panel consider energy accumulation in the TX filter to be of any more relevance to infringement of the method of down-conversion than energy accumulation in the cell phone's battery?
* Bear in mind that the obvious starting point of the Appeal Court panel is the undisputed testimony of ParkerVision's lead inventor that if the accused products do not "get the baseband signal" from stored energy then they do not infringe.
Have you been able to find anything at all in the evidence record suggesting that the mixer gets the baseband signal from stored energy in the first place?
Tampa, re your -
"Qualcomm, on the other hand samples at a non-continuous 25% duty cycle which necessitates further processing with a storage device"
- is this just another example of your compulsion to use this forum to pleasure your intellectual weenie in public?
It's my understanding that the Qualcomm mixer does indeed mix continuously - but that because it sequentially routes the signal along four paths, ParkerVision argues that it falls within the defininition of "sampling" adopted under the "Markman" rulings.
Are you arguing that because it meets the Court's definition of "sampling" it cannot be a continuous mixer, and must therefore store energy?
Kindly do try to grasp the point that it's not for you to understand the method by which the mixer down-converts the baseband signal. The evidence that it does indeed discharge the function of a mixer confirmed by Sorrells during his testimony is both overwhelming and undisputed.
You're too late. Deal with the fact that the mixer undisputedly down-converts the baseband signal.
All you need to do is show us SOME evidence the Appeal Court panel will find in the record suggesting that the mixer gets the baseband signal from stored energy, and therefore meets the undisputed infringement criterion confirmed by Sorrells during his testimony.
How are you coming along with that?
I can only offer you my understanding based upon what I've read about the technology.
The four balanced transistor pairs Prucnal confirmed are present mix the incoming carrier signal with a local oscillator signal - a long-established technique which results in the generation of the baseband signal and predates ParkerVisions claimed invention of the generation of the baseband signal via the charge and discharge of a capacitor.
If you're genuinely interested, try an internet search for quadrature down-conversion.
Speedlake - read Prucnal's testimony. ParkerVision chose to base its infringement argument upon a schematic of a Qualcomm receiver, as the report Prucnal had originally prepared was exposed as being comprehensively flawed.
ParkerVision therefore showed the jury a schematic of a receiver incorporating the "Magellan" chip - which depicted a double-balanced mixer with baseband outputs to a TX filter.
ParkerVision never suggested that the schematic PARKERVISION chose to use was in any way inaccurate.
ParkerVision's star witness admitted that the mixer "does, in fact, create the baseband before it hits the TX filter".
Therefore the precise method by which the mixer creates the baseband signal is completely irrelevant. The onus was simply upon ParkerVision to show that the mixer gets its baseband signal from stored energy.
Kindly have the honesty to admit that you understand this.
Sadly the resident pumpers are so completely clueless that I need to do their job for them.
By pointing out the reasons why the Appeal Court panel is likely to find in favour of Qualcomm it's never been my intention to encourage anybody so sell their shares. There is also a potential driver of share price appreciation of which investors should be aware.
PRKR currently has a Russell 3000 listing. Unless the share price has appreciated substantially by the last trading day of May, PRKR will be delisted from the Russell 3000 at the end of June.
This has nothing to do with the Nasdaq listing, which will be safeguarded provided the share price increases to above a dollar in the coming months.
One way of looking at ParkerVision's business is that it's only ever been a shell for PRKR as a trading vehicle.
That trading vehicle has generated millions of dollars in profits for certain investors over the last fifteen years - and has never needed anything more substantial than optimism that the official business will at some stage become profitable.
Consider the possibility that -
1. the investors for whom PRKR has been the goose that lays the golden eggs all these years could easily walk the share price back up over a dollar on the back of a fluff PR.
2. those investors are happy to allow the share price to drop for the moment, so that the funds which track the Russell 3000 automatically sell at the end of June several million shares at or below the current price.
3. those investors are planning to walk the share price back up over a dollar once they have picked up the shares in the forced sale.
I am not predicting this will happen. That call is yours to own.
Oops, sorry pumpers. Guess this destroys your argument that I've been doing what you've been doing - trying to further my personal financial interests by deceiving other investors.
All you need to know is that ParkerVision's star witness admitted to the jury that the mixer down-converts the baseband signal "before it hits" the storage device he had told them earlier performs the energy storage and baseband "generation" steps of the patented method of down-conversion.
"All this goes to weight of evidence.."
Judge Dalton disagrees. In fact he ruled that Prucnal's testimony "precludes" a verdict of infringement.
Instead of complaining that I'm not posting the right testimony - why don't YOU post the testimony you believe will cause the Appeal Court panel to conclude that the Qualcomm mixer gets its baseband signal from stored energy?