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Case 2:19-cv-00117-JRG Document 1 Filed 04/11/19 Page 1 of 8 PageID #: 1

IN THE UNITED STATES DISTRICT COURT


FOR THE EASTERN DISTRICT OF TEXAS
MARSHALL DIVISION

§
RED ROCK ANALYTICS, LLC, § Civil Action No. _________
§
Plaintiff, §
§ Jury Trial Requested
v. §
§
APPLE INC. §
§
Defendant. §
§
§
§
§

RED ROCK ANALYTICS, LLC’S COMPLAINT FOR PATENT INFRINGEMENT

Plaintiff Red Rock Analytics, LLC (“Red Rock” or “Plaintiff”) hereby submits this

Complaint for patent infringement against Defendant Apple Inc. (“Apple” or “Defendant”).

THE PARTIES

1. Plaintiff Red Rock is a limited liability company existing under the laws of

Massachusetts with its principal place of business at 177 Bradlee Ave., Swampscott,

Massachusetts 01907.

2. Red Rock is informed and believes, and on that basis alleges, that Defendant Apple is a

California corporation with its principal place of business at 1 Infinite Loop, Cupertino,

California 95014. Apple may be served with process through its registered agent, CT

Corporation System, 1999 Bryan St. Ste. 900, Dallas, TX 75201-3136.


Case 2:19-cv-00117-JRG Document 1 Filed 04/11/19 Page 2 of 8 PageID #: 2

3. A true and correct copy of the patent asserted in this lawsuit, United States Patent No.

7,346,313 (“the ’313 Patent”) together with its certificates of correction are attached as

Exhibit A.

4. Red Rock’s L.R. CV-38 Jury Demand is attached as Exhibit B.

5. Red Rock’s Fed. R. Civ. P. 7.1 Disclosure Statement is attached as Exhibit C.

JURISDICTION AND VENUE

6. This Court has subject matter jurisdiction 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. §§ 101 et seq.

7. The Court has personal jurisdiction over Defendant, including because Defendant has

minimum contacts within the State of Texas; Defendant has purposefully availed itself of the

privileges of conducting business in the State of Texas; Defendant regularly conducts business

within the State of Texas; and Plaintiff’s cause of action arises directly from Defendant’s

business contacts and other activities in the State of Texas, including at least by virtue of

Defendant’s infringing systems, devices, and methods, which are at least sold, practiced, and/or

used in the State of Texas. Further, this Court has general jurisdiction over Defendant, including

due to its continuous and systematic contacts with the State of Texas. Further, on information

and belief, Defendant is subject to the Court’s jurisdiction, including because Defendant has

committed patent infringement in the State of Texas. Defendant has regular and established

places of business in this district and regularly sells, markets, and supports its products and

services within this judicial district. Defendant is subject to this Court’s specific and general

personal jurisdiction pursuant to due process and/or the Texas Long Arm Statute, due at least to

its substantial and pervasive business in this State and judicial district, including: (i) at least part

of its infringing activities alleged herein; and (ii) regularly doing or soliciting business, engaging

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in other persistent conduct, and/or deriving substantial revenue from goods sold and services

provided to Texas residents.

8. Venue is proper in this federal district pursuant to 28 U.S.C. §§1391(b)-(c) and 1400(b).

Without limitation, Defendant has regular and established places of business in this District, and

in Texas, and at least some of its infringement of the patent-in-suit occurs in this District, and in

Texas.

9. Without limitation, venue is proper in this District because Defendant has physical places

from which its business is conducted within this District comprising Apple stores, including at

6121 West Park Boulevard in Plano, Texas (a.k.a. Apple Willow Bend) and 2601 Preston Road

in Frisco, Texas (a.k.a. Apple Stonebriar). The business conducted at such places is steady,

uniform, orderly, and/or methodical, and is settled and not transient, including, but not limited to,

distribution, sales, and/or offers for sale of infringing products. On information and belief,

Defendant also has Apple Stores in multiple locations throughout the state of Texas, and it has

significant corporate facilities in Austin, Texas as well. Further, on information and belief,

Defendant is subject to venue in this District, including because Defendant has committed patent

infringement in this District. Pursuant to 35 U.S.C. § 271, Defendant infringes the patent-in-suit

by the infringing acts described herein in this District. Further, Defendant solicits and induces

customers/users in this District, including via its stores and website at www.apple.com. On

information and belief, Defendant has customers/users who are residents of this District and who

purchase, acquire, and/or use Defendant’s infringing products in this District.

10. The ’313 Patent was previously asserted in this District against Samsung Electronics Co.,

Ltd., Samsung Electronics America, Inc., Samsung Semiconductor, Inc., and Samsung Austin

Semiconductor, LLC. Case No. 2:17-cv-101-RWS-RSP. During that lawsuit, this Court

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Case 2:19-cv-00117-JRG Document 1 Filed 04/11/19 Page 4 of 8 PageID #: 4

conducted proceedings regarding the asserted patent and the accused products including, e.g.,

construing the meaning of certain terms and phrases from the patent; ruling on motions to amend

infringement contentions; ruling on Daubert motions concerning liability and damages; denying

summary judgment of non-infringement; and conducting a pretrial conference. Given this

history, this Court has significant knowledge regarding the asserted patent, and principles of

judicial economy further support venue in this Judicial District.

INFRINGEMENT OF U.S. PATENT NO. 7,346,313

11. On March 18, 2008, United States Patent No. 7,346,313 was duly and legally issued for

inventions entitled “Calibration of I-Q Balance in Transceivers.” Red Rock was assigned the

’313 Patent and continues to hold all rights and interest in the ’313 Patent.

12. The ’313 Patent is valid, enforceable, and was duly issued in full compliance with Title

35 of the United States Code.

13. On information and belief and pursuant to 35 U.S.C. § 271(a), Apple has directly

infringed and continues to directly infringe numerous claims of the ’313 Patent, including at least

claims 7, 12, 15, 16, 18, 21, 44, 49, 52, 53, 55, and 58 by its manufacture, use, sale, importation,

and/or offer for sale of products (e.g., computers, cellular phones, tablets, watches) that include

wireless transceivers that comply with the IEEE 802.11n “Wi-Fi” standard and/or that comply

with later versions of IEEE 802.11 (e.g. 802.11ac, 802.11ad, and/or 802.11ax) (the “Infringing

Products”). Based on Apple’s public statements and third party analyses of Apple’s products, the

Infringing Products include, for example, 802.11n and later wireless transceivers made by

Broadcom Inc. On the basis of information and belief, the 802.11n and later wireless transceivers

in the Infringing Products include a direct conversion transceiver with a transmit chain, a receive

chain, a processor, and a calibration subsystem that performs I-Q gain imbalance calibration

using a calibration RF signal, a signal path for injecting the calibration RF signal from the
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Case 2:19-cv-00117-JRG Document 1 Filed 04/11/19 Page 5 of 8 PageID #: 5

transmit RF signal port to the receive RF signal port, a processor for processing the baseband

receive calibration RF signal to forms an observable indicator of I-Q imbalance, a channel gain

adjuster, and a calibration cycle that determines transmitter and receiver I-Q gain settings

according to the systems and methods claimed by the ’313 Patent.

14. Apple’s Infringing Products include, but are not limited to: iPhone XR; iPhone XS;

iPhone XS Max; iPhone X; iPhone 8; iPhone 8 Plus; iPhone 7; iPhone 7 Plus; iPhone SE; iPhone

6; iPhone 6 Plus; iPhone 5; iPhone 5S; iPhone 5C; iPhone 4; iPhone 4S; iPad Pro (3rd

Generation); iPad (2018); iPad Pro (2nd Generation); iPad (2017); iPad Pro (1st Generation);

iPad Air 2; iPad Air; iPad 4th Generation; iPad 3rd Generation; iPad 2; iPad; iPad mini 4; iPad

mini 3; iPad mini 2; iPad mini; iPod Touch 6th Generation; iPod Touch 5th Generation; iPod

Touch 4th Generation; Apple Watch, Series 4; Apple Watch Series 3; Apple Watch Series 2;

Apple Watch Series 1; Apple TV 4K; Apple TV 5th Generation; Apple TV 4th Generation;

Apple TV 3rd Generation; Apple TV 2nd Generation; Apple TV 1st Generation; AirPort

Extreme; Airport Express; Airport Time Capsule 802.11ac; Airport Time Capsule 802.11n 3rd

Generation; MacBook; MacBook Pro; MacBook Air; iMac Pro; Mac Mini; iMac; Mac Pro;

HomePod; and all other devices that use IEEE 802.11n or later.

15. On information and belief, at least as of the filing of this complaint, Defendant has

knowledge of the ’313 Patent and indirectly infringes at least claims 7, 12, 15, 16, 18, 21, 44, 49,

52, 53, 55, and 58 of the ’313 Patent by active inducement under 35 U.S.C. § 271(b) and/or

§ 271(f). Defendant has induced, caused, urged, encouraged, aided and abetted its direct and

indirect customers to make, use, sell, offer for sale and/or import Infringing Products. Defendant

has done so by acts including but not limited to selling Infringing Products to its customers;

marketing Infringing Products; and providing instructions, technical support, and other support

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and encouragement (available via https://support.apple.com/, for instance) for the use of

Infringing Products. Such conduct by Defendant was intended to and actually resulted in direct

infringement, including the making, using, selling, offering for sale, and/or importation of

Infringing Products in the United States.

16. On information belief, at least as of the filing of this complaint, Defendant has knowledge

of the ’313 Patent and indirectly infringes by contributing to the infringement of, and continuing

to contribute to the infringement of, one or more claims of the ’313 Patent under 35 U.S.C.

§ 271(c) and/or 271(f) by selling, offering for sale, and/or importing into the United States, the

Infringing Products and/or components of the Infringing Products. Defendant knows that the

Infringing Products include hardware components and software instructions that work in concert

to perform specific, intended functions. Such specific, intended functions, carried out by these

hardware and software combinations, are a material part of the inventions of the ’313 Patent and

are not staple articles of commerce suitable for substantial non-infringing use.

17. The acts of infringement by Defendant have caused damage to Red Rock, and Red Rock

is entitled to recover from Defendant the damages sustained by Red Rock as a result of

Defendant’s wrongful acts in an amount subject to proof at trial. The infringement of Red Rock’s

exclusive rights under the ’313 Patent by Defendant has damaged and will continue to damage

Red Rock, causing irreparable harm, for which there is no adequate remedy at law, unless

enjoined by this Court.

18. Upon information and belief, since at least the filing of this lawsuit, Apple’s

aforementioned actions have been, and continue to be, committed in a knowing and willful

manner and constitute willful infringement of the ’313 Patent.

PRAYER FOR RELIEF

WHEREFORE, Red Rock prays for the following relief:


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19. A judgment in favor of Red Rock that Defendant has infringed and is infringing, either

literally and/or under the doctrine of equivalents, U.S. Patent No. 7,346,313;

20. An Order permanently enjoining Defendant, its respective officers, agents, employees,

and those acting in privity with them, from further direct and/or indirect infringement of U.S.

Patent No. 7,346,313;

21. An award of damages to Red Rock arising out of Defendant’s infringement of U.S. Patent

No. 7,346,313, including supplemental damages for any continuing post-verdict infringement up

until entry of the final judgment, with an accounting, as needed, and enhanced damages pursuant

to 35 U.S.C. § 284, together with prejudgment and post-judgment interest, in an amount

according to proof;

22. An award of an ongoing royalty for Defendant’s post-judgment infringement in an

amount according to proof in the event that a permanent injunction preventing future acts of

infringement is not granted;

23. A declaration that Defendant’s infringement was willful and an award of treble damages

pursuant to 35 U.S.C. § 284;

24. An award of attorneys’ fees pursuant to 35 U.S.C. § 285 or as otherwise permitted by

law; and

25. Granting Red Rock its costs and further relief as the Court may deem just and proper.

DEMAND FOR JURY TRIAL

26. Red Rock demands a trial by jury of any and all issues triable of right before a jury.

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Case 2:19-cv-00117-JRG Document 1 Filed 04/11/19 Page 8 of 8 PageID #: 8

DATED: April 11, 2019

/s/ Leslie V. Payne


Leslie V. Payne (Texas Bar No. 00784736) (Lead Attorney)
lpayne@hpcllp.com
Michael F. Heim (Texas Bar No. 09380923)
mheim@hpcllp.com
Miranda Y. Jones (Texas Bar No. 24065519)
mjones@hpcllp.com
R. Allan Bullwinkel (Texas Bar No. 24064327)
abullwinkel@hpcllp.com
J. Boone Baxter (Texas Bar No. 24087150)
bbaxter@hpcllp.com
Alden G. Harris (Texas Bar No. 24083138)
aharris@hpcllp.com
HEIM, PAYNE & CHORUSH, L.L.P.
1111 Bagby, Suite 2100
Houston, Texas 77002
Telephone: (713) 221-2000
Facsimile: (713) 221-2021

T. John Ward, Jr. (Texas Bar No. 00794818)


jw@wsfirm.com
Claire Abernathy Henry (Texas Bar No. 24053063)
claire@wsfirm.com
WARD, SMITH & HILL, PLLC
1507 Bill Owens Parkway
Longview, Texas 75604
Telephone (903) 757-6400
Facsimile (903) 757-2323

S. Calvin Capshaw (Texas Bar No. 03783900)


ccapshaw@capshawlaw.com
Elizabeth L. DeRieux (TX Bar No. 05770585)
ederieux@capshawlaw.com
CAPSHAW DERIEUX LLP
114 E. Commerce Ave.
Gladewater, TX 75647
Telephone: (903) 845-5770

ATTORNEYS FOR RED ROCK ANALYTICS, LLC

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USOO7346313B2

(12) United States Patent (10) Patent No.: US 7,346,313 B2


Cafarella (45) Date of Patent: Mar. 18, 2008
(54) CALIBRATION OF I-Q BALANCE IN 6,072,427 A 6/2000 McEwan
TRANSCEIVERS 6,075,820 A 6/2000 Comino et al.
6,134,281 A 10/2000 Green et al.
(76) Inventor: John H. Cafarella, 65 Galloupes Point, 85. R
4-1 w
838. R. urgin
Swampscott, MA (US) 01907 6,307,902 B1 10/2001 Walley
(*) Notice: Subject to any disclaimer, the term of this ge R ck 458, SA 375,219
patent is extended or adjusted under 35 6,842,489 B2 1/2005 Masenten ................... 375,261
U.S.C. 154(b) by 673 days. 2002fOO42255 A1 * 4, 2002 Prentice ..... ... 455.232.1
2003/01652O3 A1* 9, 2003 Mohindra ................... 375,324
(21) Appl. No.: 10/379,352 2003/0206.603 A1* 11/2003 Husted ....................... 375,324

(22) Filed: Mar. 4, 2003 * cited by examiner


(65) Prior Publication Data Primary Examiner Matthew Anderson
Assistant Examiner Tuan Pham
US 2003/022348O A1 Dec. 4, 2003 74) Attorney,V, Ag
Agent, or Firm—McDermott Will & Emery
(51) Int. Cl. LLP
H04B 700 (2006.01) (57) ABSTRACT
(52) U.S. Cl. ................................ 455/67.11; 455/67.13;
455/69; 455/70; 375/219; 375/222; 375/259 Transceivers using9. direct conversion between baseband and
(58) Field of Classification Search ......... 455/67.11, RF have become popular for low-cost designs. Bandwidth
455/67.13, 69, 70, 78,83; 375/219, 222, efficient modulations employ information on both phases of
375/259, 377 the carrier, and for high-order signaling alphabets, it
See application file for complete search history. becomes problematic to realize Direct-Conversion trans
(56) References Cited ceivers for which adequate gain balance between I and Q
channels throughout the transmit and receive chains. For
U.S. PATENT DOCUMENTS heterodyne transceivers I-Q balance is often less of an issue,
5,559,516 A 9, 1996 Didomizio et al. by contrast, because most of the required gain operates at an
5,673,108 A 9, 1997 Takeuchi Intermediate Frequency. In both cases, the trend toward
5,705,949 A 1/1998 Alelyunas et al. lower supply voltages further exacerbates this problem
5,732,111 A 3/1998 Walley because of the poorer control of analog parameters at low
5,847,619 A 12/1998 Kirisawa voltage. The present invention addresses this difficulty via a
5,872,538 A 2, 1999 Fowler calibration method and system in which a calibration signal
5,930,286 A 7/1999 Walley is generated in the transmit stage and injected into the
5,933,106 A 8, 1999. He et al. receive stage so that any mismatches in gain can be observed
5,959,294 A 9, 1999 Green et al. and corrected.
5,969,667 A 10, 1999 Farmer et al.
6,008,900 A 12/1999 Green et al.
6,058,291 A 5, 2000 Ketcham 74 Claims, 11 Drawing Sheets
100
TRANSMT 04 106
GENERATE - He- RF
BASEBAND TRANSMT SGNAL t
CALIBRATION CHAIN wa
SGNAL --- 12
120 110
R -
NJECT RF
CALIBRATION TIR t
SIGNAL 108
BPF
16 14
118
122-y pa

PROCESS
RECEIVE BASEBAND
CHAIN CALIBRATION
RECEIVE SIGNAL
RF
SIGNAL
Case 2:19-cv-00117-JRG Document 1-1 Filed 04/11/19 Page 3 of 25 PageID #: 11

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U.S. Patent Mar. 18, 2008 Sheet 4 of 11 US 7,346,313 B2

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U.S. Patent Mar. 18, 2008 Sheet S of 11 US 7,346,313 B2

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U.S. Patent Mar. 18, 2008 US 7,346,313 B2


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U.S. Patent Mar. 18, 2008 Sheet 7 of 11


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U.S. Patent Mar. 18, 2008 Sheet 9 of 11 US 7,346,313 B2

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U.S. Patent Mar. 18, 2008 Sheet 10 of 11 US 7,346,313 B2


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U.S. Patent Mar. 18, 2008 Sheet 11 of 11 US 7,346,313 B2


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US 7,346,313 B2
1. 2
CALIBRATION OF I-Q BALANCE IN The present invention is designed to improve the quality
TRANSCEIVERS of transceivers operating with low voltage power Supplies so
as to Support higher signaling alphabets. The calibration
FIELD OF THE INVENTION technique must be comprehensive in the sense of calibrating
the transmit and receive chains independently and also
This invention relates generally to transceivers for digital including all relevant gains in the calibration process.
communications whose modulations require gain balance Finally, the calibration process should place less design
between I and Q channels, and more particularly for low stress on the circuitry than would be required using com
cost applications of Such transceivers, such as wireless monly known alternate calibration approaches such as the
LANS. 10 ones described below.

BACKGROUND OF THE INVENTION SUMMARY OF THE INVENTION

Wireless communication systems can employ different A system and method is described for calibrating a
types of transceivers. Traditional heterodyne transceivers, 15 transceiver system for transmitting and receiving data using
for example, employ most of the required gain at an Inter both I and Q channels and including a transmit chain and a
mediate-Frequency (IF), between the Radio Frequency (RF) receive chain. A calibration RF signal, generated in response
and baseband. While very attractive for high-performance to and as a function of a signal generated through the
applications, heterodyne transceivers require IF compo transmit chain, is injected into the receive chain of the
nents, which cannot be integrated on-chip, thereby increas transceiver in order to independently calibrate the I-Q gain
ing the cost. Direct-conversion transceivers, as the name balance of the both transmit and receive chains in their
implies, convert directly between RF and baseband, and entirety.
hence have become popular for Integrated Circuits (ICs) to In accordance with one embodiment, the calibration RF
be used in low-cost equipment. 25
signal originates at baseband in the transmit channel, and is
It is well known in the art that the bandwidth of wireless observed at baseband in the receive channel.
transmissions can be increased by transmitting data as The transceiver can be a direct-conversion transceiver, or
complex components, e.g., general electronic signals can be a heterodyne-conversion transceiver.
represented as complex quantities mathematically, and that The channel gain can be adjusted so as to vary the
this can be viewed as using both phases of a carrier signal. 30 differential I-Q gain in the transmit and receive chains
Thus, it is generally accepted that a signal can have a real independently in response to the calibration RF signal being
component synonymous with the real signal impressed upon injected into the receiver chain. The channel gain is adjusted
the cosine carrier and identical to the in-phase (I) signal, and So as to vary the differential I-Q gain in the imbalanced chain
an imaginary component synonymous with the real signal in response to the calibration RF signal being injected into
impressed upon the sine carrier and identical to the quadra 35 the receiver chain.
ture (Q) signal. When not on a carrier, which is referred to In one embodiment a system and method calibrates a
as baseband, these I and Q signals exists as real signals in transceiver system for transmitting and receiving data using
two channels commonly called I and Q, respectively. both I and Q channels, wherein the transceiver comprises (a)
Because direct-conversion transceivers must realize most of a transmit chain including a signal generator for generating
the gain required for transmission and for reception at 40 a baseband transmit signal; baseband I-Q amplification
baseband, it becomes problematic to realize direct-conver Subsystem for providing baseband amplification of the base
sion transceivers with adequate gain balance between the I band transmit signal; a direct-conversion Subsystem for
and Q channels for some applications. Even heterodyne converting the baseband transmit signal to an RF transmit
conversion transceivers can be difficult in Such situations; signal, and including an RF transmit signal port; and (b) a
their baseband elements may not achieve adequate I-Q gain 45 receive chain including an RF receive port for receiving an
balance, especially at low Supply Voltages. RF receive signal; direct-conversion subsystem for convert
Bandwidth-efficient digital modulations, e.g., M-QAM ing the RF receive signal to a baseband receive signal;
and M-PSK, employ information on both in-phase and baseband I-Qamplification Subsystem for providing ampli
quadrature components of the carrier. As the number of fication of the baseband receive signal; a processor for
constellation points M becomes large, the constellation 50 processing of the baseband receive signal as required for the
points become close together, distortions of the complex normal function of the transceiver. The system and method
amplitude eventually become the limiting factor in reducing includes using a calibration RF signal, generated as a
symbol errors. The trend toward lower supply voltages baseband transmit signal; injecting the calibration RF signal
further exacerbates this problem. While the performance of from the RF transmit signal port to the RF receive signal
digital ICs eventually suffer at supply voltages below 55 port; processing the baseband receive calibration RF signal
approximately 1 V, poorer control of circuit parameters to form an observable indicator of I-Q imbalance; and
makes the performance of analog ICs difficult with power varying the differential I-Q gain in the transmit and receive
supplies below about 2.5V. Thus, calibration in order to chains independently.
balance the gains provided in the I and Q channels for both In one embodiment the injection of the calibration RF
transmit and receive becomes critical for ICs designed to 60 signal is prevented from permanently imparting an unfavor
operate on low-voltage Supplies. able net phase shift from baseband transmit to baseband
While injection of DC calibration signals to calibrate the receive. In one embodiment phase-calibration cycling is
baseband transmit and receive gains is possible, the inclu used to prevent the injection of the calibration RF signal
sion of this function presents a layout difficulty for critical from permanently imparting an unfavorable net phase shift
circuitry. Furthermore, such signals would not provide cali 65 from baseband transmit to baseband receive, while in
bration of the effective conversion gains of the RF up another embodiment slowly time-varying phase modulation
conversion and down-conversion mixer elements. is used for that purpose.
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US 7,346,313 B2
3 4
In one embodiment the calibration RF signal includes mining the receiver I-Q gain settings which minimizes the
generating a sequence of pulses taking on purely real or observable indicator while holding the transmit I-Q gain
imaginary values at any instant, a sampled phasor, or a settings constant.
discrete phasor, the latter, for example, comprising" or j'. In another embodiment the calibration RF signal includes
In one embodiment, the calibration RF signal includes a Successive calibration cycles, and the system and method
calibration cycle, and further includes using the calibration further include using Successive calibration cycles to refine
cycle so as to determine the transmitter I-Q gain settings so or maintain I-Q balance.
as to minimize the observable indicator while holding the In one embodiment, at least one stage of frequency
receive I-Q gain settings constant, and determining the conversion includes amplification means for amplifying the
receiver I-Q gain settings So as to minimize the observable 10 transmit signal at the intermediate frequency.
indicator while holding the transmit I-Q gain settings con In one embodiment, a system and method is used to
Stant. calibrate a transceiver System of the type comprising: (a) a
In one embodiment the calibration RF signal includes transmit chain including: a signal generator for generating a
Successive calibration cycles, and further including using the baseband transmit signal; a baseband I-Q amplification
Successive calibration cycles to refine or maintain I-Q bal 15 Subsystem for providing baseband amplification of the base
aCC.
band transmit signal; at least one stage of frequency con
In one embodiment, the system and method includes version of the baseband transmit signal to an intermediate
varying the differential I-Q gain in the imbalanced chain so frequency; a conversion Subsystem for converting the base
as to adjust the gain. band transmit signal at the intermediate frequency to an RF
Generating the calibration RF signal includes generating transmit signal, and an RF transmit signal port; and (b) a
a sequence of pulses taking on purely real or imaginary receive chain including an RF receiving port for receiving an
values at any instant. The calibration RF signal includes a RF receive signal; at least one stage of frequency conversion
sampled phasor, or a discrete phasor. The discrete phasor can of the receive signal to an intermediate frequency; a con
comprise" or j'. Successive calibration cycles can be used version Subsystem for converting the RF receive signal to a
to refine or maintain I-Q balance. 25 baseband receive signal; baseband I-Q amplification Sub
In one embodiment a system and method is used to system for providing amplification of the baseband receive
calibrate a transceiver system of the type comprising (a) a signal; and a processor for processing of the baseband
transmit chain including a signal generator for generating a receive signal as required for the normal function of the
baseband transmit signal; a baseband I-Q amplification transceiver. The system and method comprise: generating a
Subsystem for providing baseband amplification of the base 30 calibration RF signal as a baseband transmit signal; injecting
band transmit signal; at least one stage of frequency con the calibration RF signal from the RF transmit signal port to
version of the baseband transmit signal to an intermediate the RF receive signal port; processing the baseband receive
frequency; a conversion Subsystem for converting the base calibration RF signal to form an observable indicator of I-Q
band transmit signal at the intermediate frequency to an RF imbalance; and varying the differential I-Q gain in the
transmit signal, and an RF transmit signal port; and (b) a 35
imbalanced chain so as to balance the I-Q gain.
receive chain including an RF receiving port for receiving an The calibration RF signal includes, in various embodi
RF receive signal; at least one stage of frequency conversion ments, a sequence of pulses taking on purely real or imagi
of the receive signal to an intermediate frequency; a con nary values at any instant, a sampled phasor, or a discrete
version Subsystem for converting the RF receive signal to a phasor. The discrete phasor can comprise" or j'.
baseband receive signal; baseband I-Q amplification Sub 40
The system or method can use Successive calibration
system for providing amplification of the baseband receive cycles to refine or maintain I-Q balance.
signal; a processor for processing the baseband receive
signal as required for the normal function of the transceiver. BRIEF DESCRIPTION OF THE DRAWINGS
The calibration system and method comprises generating a
calibration RF signal as a baseband transmit signal; injecting 45
In the drawings, similar parts are shown with the same
the calibration RF signal from the RF transmit signal port to numerals for ease of exposition only.
the RF receive signal port, processing the baseband receive
calibration RF signal to form an observable indicator of I-Q FIGS. 1a and 1b show a typical prior art direct-conversion
imbalance; and varying the differential I-Q gain in the transceiver block diagram. FIG. 1a depicts the transmit
transmit and receive chains independently so as to adjust the 50 chain. FIG. 1b depicts the receive chain.
differential I-Q gain so as to minimize any difference. FIGS. 2a and 2b show a typical prior art heterodyne
In one embodiment the calibration RF signal is performed conversion transceiver block diagram. FIG. 2a depicts the
in Such as way so as to prevent the calibration RF signal transmit chain. FIG. 2b depicts the receive chain.
from permanently imparting an unfavorable net phase shift FIGS. 3a and 3b show a conventional prior art approach
from baseband transmit to baseband receive. This is accom 55 to calibration of the baseband gains in the transmit and
plished, for example, by a phase-calibration cycling, or a receive chains which could be used for the baseband section
slowly time-varying phase modulation. of either direct-conversion or heterodyne-conversion trans
The calibration RF signal includes, in various embodi ceivers. FIG. 3a depicts the transmit chain. FIG. 3b depicts
ments, a sequence of pulses taking on purely real or imagi the receive chain.
nary values at any instant, a sampled phasor, or a discrete 60 FIG. 4 shows one preferred embodiment of a typical
phasor. Regarding the latter, a discrete phasor can comprise transceiver incorporating the present invention and compris
i" ori". ing transmit and receive chains plus a transmit power
In one embodiment the calibration RF signal includes a amplifier, receive low-noise amplifier, transmit/receive
calibration cycle, wherein the method further includes using Switch, band-pass filter, an antenna and an automatic gain
the calibration cycle to determine the transmitter I-Q gain 65 control.
settings which minimize the observable indicator while FIG. 5 shows a block diagram of one preferred embodi
holding the receive I-Q gain settings constant, and deter ment of an approach utilizing purely real or imaginary
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calibration pulses, and forcing the observation to also be The overall calibration process preferably proceeds by
purely real or imaginary using a phase shift. minimizing the imbalance observable with respect to gain
FIGS. 6a and 6b present graphical representations of adjustments in the transmit chain while holding the gains in
phasor ghost generation due to gain imbalance. FIG. 6a the receive chain fixed, then minimizing the imbalance
shows a system with I-Q gain balance, such that a phasor observable with respect to gain adjustments in the receive
experiences the same amplification independent of its chain while holding the gains in the transmit chain fixed. Of
instantaneous phase, while FIG. 6b shows a system with course, whether the transmit or receive chain is adjusted first
gain imbalance between the I and Q channels. is immaterial. Furthermore, the process could alternate sev
FIG. 7a shows the overlay of transmit and receive gain eral times if required, for example, after initial application of
ellipses in the degenerate case of 90° net phase rotation, 10 power to the transceiver. In addition, after stable operation
while FIG. 7b shows the non-degenerate case when the is achieved some form of prediction or adaptation algorithm
principle axes are not aligned. could be used to minimize the frequency of calibration
FIG. 8 depicts a preferred embodiment of the preferred cycles required.
embodiment of a system having calibration based upon a In some applications the need for recurrent calibration
phasor calibration signal with phase selection to avoid 15 cycles might be objectionable. However, commonly a trans
degenerate alignment of the gain ellipses for transmit and ceiver operates in half-duplex, and often with substantial
receive. structure in the pattern of transmissions and receptions. For
example, there is usually a guard time interval, for example
DETAILED DESCRIPTION OF THE DRAWINGS the inter-frame space in wireless LANs, during which a
transceiver just having finished a transmission could per
The present invention is directed to a system for and form a calibration cycle with no impact on system operation.
method of injecting the transmit signal into the receive chain Referring specifically to the drawing Figures:
of the transceiver in order to Support calibration indepen FIG. 1 shows a typical direct-conversion transceiver
dently of the I-Q gain balance of the both transmit and block diagram. FIG. 1a depicts the transmit chain. The
receive chains in their entirety, as required for proper 25 baseband I and Q digital signals are converted by digital
operation among multiple users. This provides comprehen to-analog (A/D) converters 10a and 10b, respectively, to
sive I-Q gain balance, and in addition can be effected with analog signals, and passed through low-pass anti-aliasing
non-critical circuit layout for the injection signal path. filters 12a and 12b to form the analog version of the
Furthermore, the calibration signals can originate at base baseband transmit waveform. The resulting signals are
band in the transmit channel, and be observed at baseband 30 amplified by the in-phase and quadrature transmit gains G.
in the receive channel. Consequently, there is minimal and Go amplifiers 14a and 14b, low-pass filtered again by
impact on the circuit layout to implement this calibration low pass filters 16a and 16b to limit the noise bandwidth,
technique. While motivated primarily to enable realization then converted to the complex RF signal in a complex
of direct-conversion transceivers, this calibration method modulator 18, as shown here using cosine and sine mixers
can be applied to heterodyne-conversion or alternative trans 35 20a and 20b and summation at 22.
ceiver structures which implement less of the required gain FIG. 1b depicts the receive chain. The RF signal is
at baseband. converted using demodulator 30 to baseband by mixing with
More specifically, in order to attain high accuracy in the cosine and sine signals at the RF frequency, and the I and Q
I-Q gain balance, a calibration signal is applied to the components Subsequently passed through low-pass filters
baseband input of the transmit chain. This signal is amplified 40 32a and 32b to suppress undesired frequencies. The result
and converted to a signal at the transmit RF port as would ing signals are amplified by the in-phase and quadrature
be any transmit signal during normal operation. Thus, this receive gains Gr, and Gre of amplifiers 34a and 34b then
transmit RF signal includes all gains relevant to normal passed through low-pass filters 36a and 36b which limit the
operation in the transmit chain. noise bandwidth before sampling in the analog-to-digital
A signal injection path is made available from the transmit 45 (A/D) converters 38a and 38b.
RF output to the receive RF input of the transceiver. This It is well known in the art that a variety of such direct
injection path would be substantially Suppressed in normal modulator and demodulator design implementations can be
transceiver operation so as not to degrade receiver noise used, including conventional designs as shown in FIG. 1 as
figure. The amplitude and phase accuracy for the injection well as those which utilize sub-harmonic mixers. For
path are generally non-critical, and the overall calibration 50 example, a popular approach is to utilize a mixer driven by
process should be designed to not require excessive design a local oscillator signal at half the RF carrier frequency to
stress on the injection path. minimize the effects of local oscillator signal coupling to
This receiver RF signal is amplified and converted to a various circuit elements. The calibration technique
signal at the receive baseband port as would be any receive described in this patent is applicable to any form of con
signal during normal operation. Thus, this receive baseband 55 version between RF and baseband, and not limited to the
signal includes all gains relevant to normal operation in the conventional approach used as examples in the figures.
receive chain. FIG. 2 shows a typical heterodyne-conversion transceiver
The calibration signal must be designed to be sensitive to block diagram. FIG. 2a depicts the transmit chain. The
I-Q gain imbalance. Furthermore, reasonably simple pro baseband I and Q signals are converted from digital to
cessing should be capable of producing an observable indi 60 analog using D/A converters 40a and 40b, and passed
cator of that imbalance. The calibration signal and Subse through low-pass anti-aliasing filters 42a and 42b to form
quent processing must be such that the observable indicator the analog version of the baseband transmit waveform. The
of gain imbalance can only be minimized when both the resulting signals are amplified by the in-phase and quadra
transmit and receive gain imbalances have been individually ture transmit gains Gr, and G, of amplifiers 44a and 44b,
minimized. That is, it should not be possible for a transmit 65 low-pass filtered again by low pass filters 46a and 46b to
chain I-Q imbalance to be masked by any possible receive limit the noise bandwidth, then converted to the complex IF
chain I-Q gain imbalance. signal in a complex modulator 48, as shown here using
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cosine and sine mixers 50a and 50b and summation 52. The sive calibration technique is needed. The present invention
IF signal is amplified by the transmit IF gain G of overcomes all of these difficulties. This method applies to a
amplifier 54, filtered in the transmit IF filter 56, then mixed direct-conversion transceiver, but could be applied to cali
with the local oscillator 58 to translate to an RF signal. brate I-Q gain balance in the baseband portion of a conven
FIG. 2b depicts the receive chain. The RF signal is 5 tional heterodyne transceiver as well, or any other trans
converted to an IF signal by mixing with the local oscillator ceiver requiring I and Q channel gain balance. In addition,
64, passed through the IF band pass filter 66, and amplified even if the transmit I-Q gain balance is achievable without
by the receive IF gain G. amplifier 68. The receive IF calibration, the method of this invention can be used to
signal is converted to baseband by mixing with cosine and calibrate the I-Q gain balance in the receive chain alone.
sine signals at the IF frequency using mixers 70a and 70b of 10 FIG. 4 shows a typical transceiver comprising the trans
the I and Q channels, and passed through low-pass filters mit and receive chains of FIG. 1 or FIG. 2, for example, and
72a and 72b to suppress undesired frequencies. The result numbered 100 and 102 respectively. The calibration cir
ing signals are amplified by the in-phase and quadrature cuitry preferably includes a bandpass filter 104, transmit
receive gains Gr, and Gre of amplifiers 74a and 74b, then power amplifier (PA) 106, a transmit/receive (TVR) switch
passed through low-pass filters 76a and 76 b which limit the 15 108, a band-pass filter 110, an antenna 112, a receive
noise bandwidth before sampling in the analog-to-digital low-noise amplifier (LNA) 114, a bandpass filter 116 and an
converters 78a and 78b. The transmit and receive IF gains automatic gain control (AGC) 118. These are all well-known
G, and Gre of amplifiers 68, 70a and 70b reduce the elements of transceiver RF design. Operation of the AGC at
amount of gain required at baseband in the heterodyne RF is not essential, but it is a preferred approach because it
conversion transceiver, reducing the stress on baseband I-Q 20 enables fixed baseband amplification, which is more ame
gain balance. However, the method of this patent can be used nable to calibration. The RF signal from the transmit chain
for heterodyne-conversion transceivers if a high degree of is provided a path to the RF receive chain, shown for
baseband I-Q gain balance is needed. example through an attenuator 120. This injection can be
Typical transceiver designs require less gain in the trans effected in many ways. It could be a dedicated signal path
mit chain than used in the receive chain. Nevertheless, when 25 which is disabled in normal transceiver operation but acti
very high accuracy is required to demodulate a particular vated for a calibration cycle. It could also be a controllable
signaling constellation it becomes necessary to calibrate leakage path within the other RF circuitry. In any event, the
both the transmit and receive chains. FIGS. 3a and 3b show amplitude and phase of the transmission path for the injected
a conventional prior art approach to calibration of the signal are not critical because the signal, being on the RF
baseband gains in the transmit and receive chains of a 30 carrier at this point, is not subject to I-Q gain imbalance.
transceiver, the approach being one which can be used for Switch 122 is preferably a simple single throw, double pole
the baseband section of either direct-conversion or hetero switch used to switch between the calibration mode (as
dyne-conversion transceivers. shown) to an operation mode (the Switch being thrown in
FIG. 3a depicts the injection of a calibration signal into opposite position).
the normal I and Q inputs of the baseband transmit chain of 35 The calibration concept shown in FIG. 4 employs the
the type shown in FIG. 1a. Circuitry 84 for forming an normal baseband transmit input for introducing the calibra
observation of the I and Q signals after baseband amplifi tion signal, and the normal baseband receive output for
cation must be included. The switches 86a and 86b shown forming the observable indicative of I-Q gain imbalance.
for diverting the signals to the observation circuitry may not The only additional circuitry required for calibration is that
be necessary, depending upon circuit details. In any case, the 40 to provide injection of the calibration signal from RF
paths to the comparison inputs of the observation circuitry, transmit output to RF receive input. This injection path is not
as well as the response of the observation circuitry to the two critical in its transfer characteristics, nor is it located in
inputs, must match to ensure that the observation circuitry critical layout areas for normal operation. Furthermore, this
can adequately indicate a lack of I-Q gain imbalance in the approach includes in the overall path of the calibration
baseband transmit chain. 45 signal all paths used during normal operation, and therefore
FIG. 3b depicts the injection of a calibration signal into all possible sources of I-Q gain imbalance in the transmit
the I and Q inputs of the baseband receive chain of the type and receive chains.
shown in FIG. 1b. The Switches 88a and 88b shown for A variety of calibration signals could be found useful.
inserting the calibration signals may not be necessary, These should be easy to generate and process, and the effect
depending upon circuit details, but some means must be 50 of I-Q gain imbalance must be directly related to an observ
used to ensure that the calibration signal does not degrade able feature. One example is a sequence of pulses, in any
reception during normal operation, and that received signals order, for which a pulse is either purely real or purely
do not contaminate the calibration signal during the calibra imaginary at the transmit baseband input.
tion process. The normal I-Q outputs of the receive chain can FIG. 5 shows a block diagram describing this approach.
be monitored for forming an observation of the I and Q 55 This corresponds to applying a non-zero value to the I or Q
signals after baseband amplification. The paths from the input of the transmit chain 100 while making the alternate,
calibration signal Source 90 to the gain-chain inputs must Q or I input, respectively, Zero. In this case the signal path
match to ensure that the same calibration signal is delivered providing injection of the calibration signal from transmit
to both I and Q receive gain chains. RF to receive RF must include a phase control 130 for
The extra circuitry required in FIGS. 3a and 3b is not 60 shifting RF carrier phase so that the signal can be made to
extensive, but this circuitry must be included in portions of substantially appear at only the I or Q output of the receive
the overall design in places which are typically sensitive to baseband. The transmit I and Q gains are G, and G,
layout constraints. Furthermore, the individual calibration of respectively, while the receive I and Q gains are G and
baseband gains in the transmit and receive chains does not Gro, respectively. By suitable observation of the receive
include the conversion gains of the up-conversion and 65 baseband output signal for the various transmit baseband
down-conversion mixing elements. Since these conversion input signals, while also adjusting the phase of the injected
gains may not match in the I and Q channels, a comprehen signal from transmit RF to receive RF, it is possible to
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determine the four combinations Gr/Gr, Gr/Gro. GroGr element could be included in the injection path, and capable
and GG. Therefore, it is possible of determine the of two difference phase shift values differing by approxi
transmit-chain I-Q gain imbalance by computing IGG mately 45°.
IG, Grol and/or IG,Gr-IGGre without knowing either FIG. 8 depicts a preferred embodiment where calibration
Gr, or Geo. Similar is true for determining the receive-chain based upon a phasor calibration signal with phase selection
I-Q imbalance. using phase control 140 is used to avoid degenerate align
While the above process would provide adequate calibra ment of the gain ellipses for transmit and receive. An initial
tion for many applications, the phase control in the calibra calibration signal on one phase of the transmit baseband
tion-signal injection path is somewhat difficult. It requires a input should produce amplitudes in the receive baseband I
10 and Q outputs which are of similar magnitude. If these
total range of phase shift in excess of 90°, and precision in magnitudes are too disparate, then existence of the nearly
phase control consistent with the ultimate calibration accu degenerate transmit/receiver phase alignment is indicated,
racy required. It furthermore requires extra time during the and changing the phase by approximately ta-5, is sufficient
calibration process to make the multiple phase adjustments to guarantee non-degenerate phase alignment. This pre
accurately. 15 calibration to avoid degenerate phase alignment could be
A preferred embodiment for the calibration signal is a performed for each calibration operation, or perhaps infre
baseband phasor at non-zero frequency. It is well known in quently if parameters otherwise remain stable.
the radar art that I-Q gain imbalance in a radar receiver Yet another approach would be to modulate the phase in
causes "ghosts' in a Doppler response. That is, for a target the injection path so that the axes do not remain, on the
signal having a temporal modulation e", where () is the average, in a degenerate alignment. It is important to rec
Doppler frequency imparted by the target motion, I-Q gain ognize the greater simplicity in this case, having to avoid a
imbalance in the radar receiver causes a second signal Ye", narrow range of phase shifts, compared to the earlier case in
where Y=(Gr-Gro)/(G+G) is the gain imbalance which the phase had to fall within a narrow range.
parameter. Thus, a target moving away from the radar has a The basic calibration operation comprises applying the
ghost moving toward the radar. In the present invention, a 25 test signal as the baseband transmit signal input, holding the
phasor calibration signal applied as the baseband transmit receive gains fixed, and sequentially varying the difference
input signal will produce a ghost phasor rotating in the in I- and/or Q-channel gains in the transmit chain. The
opposite direction if either the transmit or receive chain have observable, the magnitude squared of the ghost signal in the
gain imbalance between I and Q. This ghost phasor consti case that the test signal is a phasor, will vary in a parabolic
tutes an observable for the calibration process. 30 manner with gain difference in the transmit channel. The
FIG. 6 presents a graphical representation of this ghost transmit gain difference which most nearly minimizes the
generation due to gain imbalance. FIG. 6a shows a system observable is selected and then remains fixed. The process is
with I-Q gain balance. Such that a phasor experiences the now repeated while varying only the receive differential
same amplification independent of its instantaneous phase. gain. This will also produce observable variations which
FIG. 6b shows a system with gain imbalance between the I 35 vary in a parabolic manner with gain difference in the
and Q channels. The gain is now an ellipse, rather than a receive chain. The differential receive gain which most
circle. An input phasor rotating clockwise must be accom nearly minimizes the observable is selected and then
panied by another phasor rotating counterclockwise so that remains fixed. This alternate variation of differential gain in
the two will add along the axis having higher gain and one chain while that of the other chain is held fixed enables
Subtract along the axis with lower gain. 40 the global minimization of the observable, at which point
While the amplitude and phase characteristics for the both the transmit and receive chain will have attained I-Q
balance.
calibration injection path are not critical, it is necessary to
avoid phases which result in a net phase between the The varying of differential I-Q gains in the transmit and
transmit and receive which is a multiple of 90°. This net receive chains can be effected in many ways. It can be
phase includes the transmission phase of the injection path 45 applied in a true differential manner, although this is not
as well as differences in the LO phase. necessary and it is generally simpler to vary either the I or
Q gain while holding the other fixed. In addition, the gains
FIG. 7a shows the overlay of transmit and receive gain may be applied digitally to the digital representations of the
ellipses in the degenerate case of 90° net phase rotation as transmit and/or receive baseband samples, or digital control
the calibration signal goes from baseband in the transmit 50 of analog gain within the transmit and/or receive baseband
chain to baseband in the receive chain. When the principle gain chain. All of these alternatives can be used in accor
axes of the two ellipses align, there can be a net gain balance dance with the principles of the present invention.
in I and Q in going from transmit baseband to receive For bandwidth-efficient modulations it is likely that the
baseband, while at the same time the transmit and receive frequency response of the I and Q channels can be made to
chains each can have Substantial I-Q gain imbalance. Thus, 55 match over frequencies of interest, hence requiring only a
with degenerate axis alignment the calibration could not single gain adjustment to bring the I and Q channels into
produce a feature which ensures the ability to calibrate the adequate balance. If this is not the case, then a series of
transmit and receive chains independently. phasors could be used sequentially, with each Such phasor
FIG. 7b shows the non-degenerate case when the prin providing a spot frequency calibration. Of course, Such a
ciple axes are not aligned. In this case both the transmit- and 60 technique would require Some form of equalizer to set the
receive-chain gains must be individually balanced in order compensating gains at the set of spot frequencies.
to achieve a gain vs. phase which is a circle. For the single-gain case, a particularly convenient fre
There are various ways to avoid degeneracy in the align quency for the test phasor is one quarter of the modulation
ment of the transmit and receive gain axes. If parameter pulse rate, which is the effective sampling rate for the
control is adequate, the circuit layout in forming the injec 65 calibration signal, although it should be understood that the
tion signal path could be designed to be approximately an present invention is not limited to the one quarter relation
odd multiple of 45°. Alternatively, a modest phase-control ship. This signal may be produced by the sequence {1j.-
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1.-j} repeated for the duration of the calibration signal. The I-Q gain settings which minimize an observable indi
original phasor is, of course, the correlation reference for its cator while holding receive I-Q gain settings constant,
ghost signal since they are conjugates. In particular, taking and which in turn determines receiver I-Q gain settings
samples of the baseband receive signal after steady state which minimizes the observable indicator while hold
when any amplitude transients due to filtering have ceased, ing the transmit I-Q gain settings constant.
a sequence of four samples would appear as {1+y,j-jY.-1- 2. A transceiver system according to claim 1, wherein the
Y.-j+jY}, where y is the gain imbalance parameter. Multi calibration signal originates at baseband in the transmit
plying this by the sequence {1j.-1.-j} and Summing results channel, and is observed at baseband in the receive channel.
in 4y. Thus, if the total number of samples taken N is a 3. A transceiver system according to claim 1, wherein the
multiple of four, then in correlation the original phasor 10 transceiver is a direct-conversion transceiver.
component of the receive baseband signal produces identi 4. A transceiver system according to claim 1, wherein the
cally Zero, while the ghost phasor correlates perfectly to transceiver is a heterodyne-conversion transceiver.
produce NY. The coefficients used in correlation do not 5. A transceiver system according to claim 1, further
require any actual multiplies; rather, only additions and including a channel gain adjuster for varying the differential
Subtractions are used. Thus, this test signal may be processed 15 I-Q gain in the transmit and receive chains independently in
in rather simple digital circuits. response to the calibration signal being injected into the
The calibration process can be performed during the receiver chain.
power-on cycle to attain initial operation, with switch 122 of 6. A transceiver system according to claim 1, further
FIG. 4, 5 or 8 being connected as shown. In this case including a channel gain adjuster for varying the differential
convergence of the process might require several basic I-Q gain in the imbalanced chain in response to the calibra
cycles of calibration, each comprising a transmit and a tion signal being injected into the receiver chain.
receive variation of gain, if both are being calibrated. 7. A transceiver system comprising:
Subsequently, at a rate consistent with parameter drift, for A. a transmit chain including: a signal generator for
example due to self-heating of the circuitry, the calibration generating a baseband transmit signal; baseband I-Q
process can be used to update the differential gain settings. 25 amplification Subsystem for providing baseband ampli
In this tracking mode the changes are likely to be small on fication of the baseband transmit signal; a direct-con
each calibration cycle, and a number of algorithms can be version Subsystem for converting the baseband transmit
used for the update process. A variety of algorithms exist for signal to an RF transmit signal, and an RF transmit
maintaining the desired operating point. One algorithm, signal port:
called “tau-dither tracking when applied to track signal 30 B. a receive chain including: an RF receive port for
timing in spread-spectrum communication systems and well receiving an RF receive signal; a direct-conversion
known in the art, seeks to locate a maximum or minimum Subsystem for converting the RF receive signal to a
magnitude of a complex value by varying a parameter and baseband receive signal; a baseband I-Q amplification
using the parabolic nature of the magnitude dependence Subsystem for providing amplification of the baseband
upon that parameter. Any of the algorithmic variations are 35 receive signal;
consistent with the calibration techniques of the present a processor for processing of the baseband receive signal
invention. as required for the normal function of the transceiver,
Thus, the transmit signal is injected into the receive chain and
of the transceiver in order to Support calibration indepen C. a calibration subsystem including: a calibration RF
dently of the I-Q gain balance of the both transmit and 40 signal generator for generating a calibration RF signal
receive chains in their entirety, as required for proper as a baseband transmit signal; a signal path for injecting
operation among multiple users. This provides comprehen the calibration RF signal from the RF transmit signal
sive I-Q gain balance, and in addition can be effected with port to the RF receive signal port; a processor for
non-critical circuit layout for the injection signal path. processing the baseband receive calibration RF signal
Furthermore, the calibration signals originate at baseband in 45 to form an observable indicator of I-Q imbalance; and
the transmit channel, and can be observed at baseband in the a channel gain adjuster for varying the differential I-Q
receive channel. Consequently, there is minimal impact on gain in the transmit and receive chains independently
the circuit layout to implement this calibration technique. wherein the calibration RF signal includes a calibration
While this invention has been particularly shown and cycle, and the calibration cycle determines transmitter
described with references to preferred embodiments thereof, 50 I-Q gain settings which minimize an observable indi
it will be understood by those skilled in the art that various cator while holding receive I-Q gain settings constant,
changes in form and details may be made therein without and which in turn determines receiver I-Q gain settings
departing from the spirit and scope of the invention as which minimizes the observable indicator while hold
defined by the following claims. ing the transmit I-Q gain settings constant.
What is claimed is: 55 8. A transceiver system according to claim 7, further
1. A transceiver system for transmitting and receiving data including means for preventing the signal path for injecting
using both I and Q channels, comprising: the calibration RF signal from permanently imparting an
a transmit chain; unfavorable net phase shift from baseband transmit to base
a receive chain; and band receive.
a calibration Subsystem comprising a signal path for 60 9. A transceiver system according to claim 8, wherein the
injecting a calibration RF signal, generated in response means for preventing the signal path for injecting the
to and as a function of a signal generated through the calibration RF signal from permanently imparting an unfa
transmit chain, into the receive chain of the transceiver vorable net phase shift from baseband transmit to baseband
in order to independently calibrate the I-Q gain balance receive includes a phase-calibration cycling Subsystem.
of the both transmit and receive chains in their entirety; 65 10. A transceiver system according to claim 8, wherein the
wherein the calibration RF signal includes a calibration means for preventing the signal path for injecting the
cycle, and the calibration cycle determines transmitter calibration RF signal from permanently imparting an unfa
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vorable net phase shift from baseband transmit to baseband stage of frequency conversion of the baseband transmit
receive includes a slowly time-varying phase modulation signal to an intermediate frequency; conversion Sub
Subsystem. system for converting the baseband transmit signal at
11. A transceiver system according to claim 7, wherein the the intermediate frequency to an RF transmit signal,
calibration RF signal includes a sequence of pulses taking on and including an RF transmit signal port;
purely real or imaginary values at any instant. B. a receive chain including: an RF receiving port for
12. A transceiver system according to claim 7, wherein the receiving an RF receive signal; at least one stage of
calibration RF signal includes a sampled phasor. frequency conversion of the receive signal to an inter
13. A transceiver system according to claim 7, wherein the mediate frequency; a conversion Subsystem for con
calibration RF signal includes a discrete phasor. 10 verting the RF receive signal to a baseband receive
14. A transceiver system according to claim 7, wherein the signal; baseband I-Q amplification Subsystem for pro
calibration RF signal includes a discrete phasor comprising viding amplification of the baseband receive signal;
i" ori". processing of the baseband receive signal as required for
15. A transceiver system according to claim 7, wherein the the normal function of the transceiver, and
calibration RF signal includes successive calibration cycles, 15 C. a calibration subsystem including: a calibration RF
and Successive calibration cycles are used to refine or signal generator for generating a calibration RF signal
maintain I-Q balance. as a baseband transmit signal; a signal path for injecting
16. A transceiver system comprising: the calibration RF signal from the RF transmit signal
A. a transmit chain including: a signal generator for port to the RF receive signal port; a processor for
generating a baseband transmit signal; baseband I-Q processing the baseband receive calibration RF signal
amplification Subsystem for providing baseband ampli to form an observable indicator of I-Q imbalance; and,
fication of the baseband transmit signal; direct-conver channel gain adjuster for varying the differential I-Q gain
sion Subsystem for converting the baseband transmit in the transmit and receive chains independently
signal to an RF transmit signal, and including an RF wherein the calibration RF signal includes a calibration
transmit signal port; 25 cycle, and the calibration cycle determines the trans
B. a receive chain including: an RF receive port for mitter I-Q gain settings which minimize the observable
receiving an RF receive signal; direct-conversion Sub indicator while holding the receive I-Q gain settings
system for converting the RF receive signal to a base constant, and which in turn determines the receiver I-Q
band receive signal; baseband I-Q amplification Sub gain settings which minimizes the observable indicator
system for providing amplification of the baseband 30 while holding the transmit I-Q gain settings constant.
receive signal; 23. A transceiver System according to claim 22, further
processing of the baseband receive signal as required for including means for preventing the signal path for injecting
the normal function of the transceiver, and the calibration RF signal from permanently imparting an
C. a calibration subsystem including; a calibration RF unfavorable net phase shift from baseband transmit to base
signal generator for generating a calibration RF signal 35 band receive.
as a baseband transmit signal; a signal path for injecting 24. A transceiver system according to claim 23, wherein
the calibration RF signal from the RF transmit signal the means for preventing the signal path for injecting the
port to the RF receive signal port; a processor for calibration RF signal from permanently imparting an unfa
processing the baseband receive calibration RF signal vorable net phase shift from baseband transmit to baseband
to form an observable indicator of I-Q imbalance; and, 40 receive includes a phase-calibration cycling Subsystem.
D. a channel gain adjuster for varying the differential I-Q 25. A transceiver system according to claim 23, wherein
gain in the imbalanced chain, the means for preventing the signal path for injecting the
wherein the calibration RF signal includes a calibration calibration RF signal from permanently imparting an unfa
cycle, and the calibration cycle determines transmitter vorable net phase shift from baseband transmit to baseband
I-Q gain settings which minimize an observable indi 45 receive includes a slowly time-varying phase modulation
cator while holding receive I-Q gain settings constant, Subsystem.
and which in turn determines receiver I-Q gain settings 26. A transceiver system according to claim 22, wherein
which minimizes the observable indicator while hold the calibration RF signal includes a sequence of pulses
ing the transmit I-Q gain settings constant. taking on purely real or imaginary values at any instant.
17. A transceiver system according to claim 16, wherein 50 27. A transceiver system according to claim 22, wherein
the calibration RF signal includes a sequence of pulses the calibration RF signal includes a sampled phasor.
taking on purely real or imaginary values at any instant. 28. A transceiver system according to claim 22, wherein
18. A transceiver system according to claim 16, wherein the calibration RF signal includes a discrete phasor.
the calibration RF signal includes a sampled phasor. 29. A transceiver system according to claim 22, wherein
19. A transceiver system according to claim 16, wherein 55 the calibration RF signal includes a discrete phasor com
the calibration RF signal includes a discrete phasor. prising" or j".
20. A transceiver system according to claim 16, wherein 30. A transceiver system according to claim 22, wherein
the calibration RF signal includes a discrete phasor com the calibration RF signal includes successive calibration
prising" or j". cycles, and Successive calibration cycles are used to refine or
21. A transceiver system according to claim 16, wherein 60 maintain I-Q balance.
Successive calibration cycles are used to refine or maintain 31. A transceiver system according to claim 22, wherein
I-Q balance. the at least one stage of frequency conversion includes
22. A transceiver system comprising: amplification means for amplifying the transmit signal at the
A. a transmit chain including: a signal generator for intermediate frequency.
generating a baseband transmit signal; a baseband I-Q 65 32. A transceiver system comprising:
amplification Subsystem for providing baseband ampli A. a transmit chain including: a signal generator for
fication of the baseband transmit signal; at least one generating a baseband transmit signal; a baseband I-Q
Case 2:19-cv-00117-JRG Document 1-1 Filed 04/11/19 Page 21 of 25 PageID #: 29

US 7,346,313 B2
15 16
amplification Subsystem for providing baseband ampli 41. A method according to claim 38, wherein the trans
fication of the baseband transmit signal; at least one ceiver is a heterodyne-conversion transceiver.
stage of frequency conversion of the baseband transmit 42. A method according to claim 38, further including
signal to an intermediate frequency; a conversion Sub adjusting the channel gain so as to vary the differential I-Q
system for converting the baseband transmit signal at gain in the transmit and receive chains independently in
the intermediate frequency to an RF transmit signal, response to the calibration RF signal being injected into the
and including an RF transmit signal port; receiver chain.
B. a receive chain including: an RF receiving port for 43. A method according to claim 38, further including
receiving an RF receive signal; at least one stage of adjusting the channel gain so as to vary the differential I-Q
frequency conversion of the receive signal to an inter 10 gain in the imbalanced chain in response to the calibration
mediate frequency; a conversion Subsystem for con RF signal being injected into the receiver chain.
verting the RF receive signal to a baseband receive 44. A method of calibrating a transceiver system for
signal; baseband I-Q amplification Subsystem for pro transmitting and receiving data using both I and Q channels
viding amplification of the baseband receive signal; and comprising (a) a transmit chain including a signal
processing of the baseband receive signal as required for 15
generator for generating a baseband transmit signal; base
the normal function of the transceiver, and band I-Q amplification Subsystem for providing baseband
C. a calibration subsystem including: a calibration RF amplification of the baseband transmit signal; direct-con
signal generator for generating a calibration RF signal version Subsystem for convening the baseband transmit
as a baseband transmit signal; a signal path for injecting signal to an RF transmit signal, and including an RF transmit
the calibration RF signal from the RF transmit signal signal port; and (b) a receive chain including an RF receive
port to the RF receive signal port; a processor for port for receiving an RF receive signal; direct-conversion
processing the baseband receive calibration RF signal Subsystem for converting the RF receive signal to a base
to form an observable indicator of I-Q imbalance; and, band receive signal; baseband I-Q amplification Subsystem
D. a channel gain adjuster for varying the differential I-Q for providing amplification of the baseband receive signal; a
gain in the imbalanced chain 25
processor for processing of the baseband receive signal as
wherein the calibration RF signal includes a calibration required for the normal function of the transceiver, the
cycle, and the calibration cycle determines transmitter method comprising:
I-Q gain settings which minimize an observable indi generating a calibration RF signal as a baseband transmit
cator while holding receive I-Q gain settings constant, signal; and
and which in turn determines receiver I-Q gain settings 30
which minimizes the observable indicator while hold injecting the calibration RF signal from the RF transmit
ing the transmit I-Q gain settings constant. signal port to the RF receive signal port;
33. A transceiver system according to claim 32, wherein processing the baseband receive calibration RF signal to
the calibration RF signal includes a sequence of pulses form an observable indicator of I-Q imbalance; and
taking on purely real or imaginary values at any instant. 35 varying the differential I-Q gain in the transmit and
34. A transceiver system according to claim 32, wherein receive chains independently
the calibration RF signal includes a sampled phasor. wherein the calibration RF signal includes a calibration
35. A transceiver system according to claim 32, wherein cycle, and further including using the calibration cycle
the calibration RF signal includes a discrete phasor. So as to determine the transmitter I-Q gain settings so
36. A transceiver system according to claim 32, wherein 40 as to minimize the observable indicator while holding
the calibration RF signal includes a discrete phasor com the receive I-Q gain settings constant, and determining
prising" or j". the receiver I-Q gain settings So as to minimize the
37. A transceiver system according to claim 32, wherein observable indicator while holding the transmit I-Q
Successive calibration cycles are used to refine or maintain gain settings constant.
I-Q balance. 45 45. A method according to claim 44, further including
38. A method of calibrating a transceiver system for preventing the injection of the calibration RF signal from
transmitting and receiving data using both I and Q channels permanently imparting an unfavorable net phase shift from
and including a transmit chain and a receive chain; the baseband transmit to baseband receive.
method comprising: 46. A method according to claim 45, wherein preventing
injecting a calibration RF signal, generated in response to 50
the injection of the calibration RF signal from permanently
and as a function of a signal generated through the imparting an unfavorable net phase shift from baseband
transmit chain, into the receive chain of the transceiver transmit to baseband receive includes phase-calibration
in order to independently calibrate the I-Q gain balance cycling.
of the both transmit and receive chains in their entirety; 47. A method according to claim 45, wherein preventing
wherein the calibration RF signal includes a calibration 55
the injection of the calibration RF signal from permanently
cycle, and further including using the calibration cycle imparting an unfavorable net phase shift from baseband
So as to determine transmitter I-Q gain settings so as to transmit to baseband receive includes slowly time-varying
minimize an observable indicator while holding receive phase modulating.
I-Q gain settings constant, and determining receiver
I-Q gain settings So as to minimize the observable 60 48. A method according to claim 44, wherein generating
indicator while holding transmit I-Q gain settings con the calibration RF signal includes generating a sequence of
Stant. pulses taking on purely real or imaginary values at any
39. A method according to claim 38, wherein the calibra instant.
tion RF signal originates at baseband in the transmit channel, 49. A method according to claim 44, wherein the calibra
and is observed at baseband in the receive channel. 65 tion RF signal includes a sampled phasor.
40. A method according to claim 38, wherein the trans 50. A method according to claim 44, wherein the calibra
ceiver is a direct-conversion transceiver. tion RF signal includes a discrete phasor.
Case 2:19-cv-00117-JRG Document 1-1 Filed 04/11/19 Page 22 of 25 PageID #: 30

US 7,346,313 B2
17 18
51. A method according to claim 44, wherein the calibra baseband receive signal as required for the normal function
tion RF signal includes a discrete phasor comprising" or of the transceiver, the method comprising
-
J. generating a calibration RF signal as a baseband transmit
52. A method according to claim 44, wherein the calibra signal;
tion RF signal includes successive calibration cycles, and 5 injecting the calibration RF signal from the RF transmit
further including using the Successive calibration cycles to signal port to the RF receive signal port;
refine or maintain I-Q balance. processing the baseband receive calibration RF signal to
53. A method of calibrating a transceiver system com form an observable indicator of I-Q imbalance; and
prising (a) a transmit chain including a signal generator for varying the differential I-Q gain in the transmit and
generating a baseband transmit signal; baseband I-Qampli 10 receive chains independently so as to adjust the differ
fication Subsystem for providing baseband amplification of ential I-Q gain so as to minimize any difference
the baseband transmit signal; a direct-conversion Subsystem wherein the calibration RF signal includes a calibration
for converting the baseband transmit signal to an RF trans cycle, wherein the method further includes using the
mit signal, and an RF transmit signal port; and (b) a receive calibration cycle to determine the transmitter I-Q gain
chain including an RF receive port for receiving an RF 15 settings which minimize the observable indicator while
receive signal; a direct-conversion Subsystem for converting holding the receive I-Q gain settings constant, and
the RF receive signal to a baseband receive signal; baseband determining the receiver I-Q gain settings which mini
I-Q amplification Subsystem for providing amplification of mizes the observable indicator while holding the trans
the baseband receive signal; processing of the baseband mit I-Q gain settings constant.
receive signal as required for the normal function of the 60. A method according to claim 59, further including
transceiver, the method comprising preventing the injection of the calibration RF signal from
generating a calibration RF signal as a baseband transmit permanently imparting an unfavorable net phase shift from
signal; baseband transmit to baseband receive.
injecting the calibration RF signal from the RF transmit 61. A method according to claim 60, wherein preventing
signal port to the RF receive signal port; 25 the injection of the calibration RF signal from permanently
processing the baseband receive calibration RF signal to imparting an unfavorable net phase shift from baseband
form an observable indicator of I-Q imbalance; and transmit to baseband receive includes a phase-calibration
varying the differential I-Q gain in the imbalanced chain cycling.
So as to adjust the gain; 62. A method according to claim 60, wherein preventing
wherein the calibration RF signal includes a calibration 30 the injection of the calibration RF signal from permanently
cycle, and further including using the calibration cycle imparting an unfavorable net phase shift from baseband
so as to determine transmitter I-Q gain settings so as to transmit to baseband receive includes slowly time-varying
minimize an observable indicator while holding receive phase modulation.
I-Q gain settings constant, and determining receiver 63. A method according to claim 59, wherein the calibra
I-Q gain settings So as to minimize the observable 35 tion RF signal includes a sequence of pulses taking on purely
indicator while holding transmit I-Q gain settings con real or imaginary values at any instant.
Stant. 64. A method according to claim 59, wherein the calibra
54. A method according to claim 53, wherein generating tion RF signal includes a sampled phasor.
the calibration RF signal includes generating a sequence of 65. A method according to claim 59, wherein the calibra
pulses taking on purely real or imaginary values at any 40 tion RF signal includes a discrete phasor.
instant. 66. A method according to claim 59, wherein the calibra
55. A method according to claim 53, wherein the calibra tion RF signal includes a discrete phasor comprising" or
tion RF signal includes a sampled phasor. -
J.
56. A method according to claim 53, wherein the calibra 67. A method according to claim 59, wherein the calibra
tion RF signal includes a discrete phasor. 45 tion RF signal includes successive calibration cycles, and
57. A method according to claim 53, wherein the calibra the method further includes using Successive calibration
tion RF signal includes a discrete phasor comprising" or
-
cycles to refine or maintain I-Q balance.
J. 68. A method according to claim 59, wherein the at least
58. A method according to claim 53, further including one stage of frequency conversion includes amplification
using Successive calibration cycles to refine or maintain I-Q 50 means for amplifying the transmit signal at the intermediate
balance. frequency.
59. A method of calibrating a transceiver system com 69. A method of calibrating a transceiver system com
prising (a) a transmit chain including a signal generator for prising: (a) a transmit chain including: a signal generator for
generating a baseband transmit signal; a baseband I-Q generating a baseband transmit signal; a baseband I-Q
amplification Subsystem for providing baseband amplifica 55 amplification Subsystem for providing baseband amplifica
tion of the baseband transmit signal; at least one stage of tion of the baseband transmit signal; at least one stage of
frequency conversion of the baseband transmit signal to an frequency conversion of the baseband transmit signal to an
intermediate frequency; a conversion Subsystem for convert intermediate frequency; a conversion Subsystem for convert
ing the baseband transmit signal at the intermediate fre ing the baseband transmit signal at the intermediate fre
quency to an RF transmit signal, and an RF transmit signal 60 quency to an RF transmit signal, and an RF transmit signal
port; and (b) a receive chain including an RF receiving port port; and (b) a receive chain including an RF receiving port
for receiving an RF receive signal; at least one stage of for receiving an RF receive signal; at least one stage of
frequency conversion of the receive signal to an intermedi frequency conversion of the receive signal to an intermedi
ate frequency; a conversion Subsystem for converting the RF ate frequency; a conversion Subsystem for converting the RF
receive signal to a baseband receive signal; baseband I-Q 65 receive signal to a baseband receive signal; baseband I-Q
amplification Subsystem for providing amplification of the amplification Subsystem for providing amplification of the
baseband receive signal; a processor for processing the baseband receive signal; and a processor for processing of
Case 2:19-cv-00117-JRG Document 1-1 Filed 04/11/19 Page 23 of 25 PageID #: 31

US 7,346,313 B2
19 20
the baseband receive signal as required for the normal 70. A method according to claim 69, wherein the calibra
function of the transceiver, the method comprising: tion RF signal includes a sequence of pulses taking on purely
generating a calibration RF signal as a baseband transmit real or imaginary values at any instant.
signal;
injecting the calibration RF signal from the RF transmit 71. A method according to claim 69, wherein the calibra
signal port to the RF receive signal port; tion RF signal includes a sampled phasor.
processing the baseband receive calibration RF signal to 72. A method according to claim 69, wherein the calibra
form an observable indicator of I-Q imbalance; and, tion RF signal includes a discrete phasor.
varying the differential I-Q gain in the imbalanced chain 73. A method according to claim 69, wherein the calibra
So as to balance the I-Q gain; tion RF signal includes a discrete phasor comprising j" or
wherein the calibration RF signal includes a calibration -

cycle, and further including using the calibration cycle


So as to determine transmitter I-Q gain settings so as to 74. A method according to claim 69, further including
minimize an observable indicator while holding receive using Successive calibration cycles to refine or maintain I-Q
I-Q gain settings constant, and determining receiver is balance.
I-Q gain settings So as to minimize the observable
indicator while holding transmit I-Q gain settings con
Stant.
Case 2:19-cv-00117-JRG Document 1-1 Filed 04/11/19 Page 24 of 25 PageID #: 32

UNITED STATES PATENT AND TRADEMARK OFFICE


CERTIFICATE OF CORRECTION
PATENT NO. : 7,346,313 B2 Page 1 of 1
APPLICATION NO. : 10/379352
DATED : March 18, 2008
INVENTOR(S) : John H. Cafarella

It is certified that error appears in the above-identified patent and that said Letters Patent is hereby corrected as shown below:

In the claims

Column 13, line 32, insert --a processor for-prior to “processing of the baseband receive signal as
required for.
Column 14, line 13, insert --a processor for-prior to “processing of the baseband receive signal as
required for.
Column 15, line 15, insert --a processor for-prior to “processing of the baseband receive signal as
required for.

Signed and Sealed this


First Day of November, 2016
74-4-04- 2% 4 Michelle K. Lee
Director of the United States Patent and Trademark Office
Case 2:19-cv-00117-JRG Document 1-1 Filed 04/11/19 Page 25 of 25 PageID #: 33

UNITED STA TES PATENT AND TRADEMARK OFFICE


CERTIFICATE OF CORRECTION

PATENT NO. : 7,346,313 82 Page I of I


APPLICATION NO. : 10/379352
DATED : March 18, 2008
INVENTOR(S) : John H. Cafarella

It is certified that error appears in the above-identified patent and that said Letters Patent is hereby corrected as shown below:

On the Title Page

Left column, immediately above the line that reads '"(51) Int. Cl." and immediately below the
line that reads "US 2003/0223480 A 1 Dec. 4, 2003'' insert -- Related U.S. Application Data
(60) Provisional Application No. 60/361.630, filed on March 4, 2002. --.

In the Specification

Column I, Line 2, after ''TRANSCEIVERS" insert -- Related Applications -This application is related
to and hereby claims priority to provisional application No. 60/361,630, filed March 4,
2002. --.

Signed and Sealed this


Thirty-first Day of January, 2017

Michelle K. Lee
Direc/or ofthe U11iled State., Paten/ and Trademark Office
Case 2:19-cv-00117-JRG Document 1-2 Filed 04/11/19 Page 1 of 3 PageID #: 34
Case 2:19-cv-00117-JRG Document 1-2 Filed 04/11/19 Page 2 of 3 PageID #: 35

IN THE UNITED STATES DISTRICT COURT


FOR THE EASTERN DISTRICT OF TEXAS
MARSHALL DIVISION

§
RED ROCK ANALYTICS, LLC, § Civil Action No. _________
§
Plaintiff, §
§ Jury Trial Requested
v. §
§
APPLE INC. §
§
Defendant. §
§
§
§
§

RED ROCK ANALYTICS, LLC’S JURY DEMAND

Pursuant to Local Rule CV-38(a), Plaintiff Red Rock Analytics, LLC respectfully demands a

jury trial on all issues so triable.


Case 2:19-cv-00117-JRG Document 1-2 Filed 04/11/19 Page 3 of 3 PageID #: 36

DATED: April 11, 2019

/s/ Leslie V. Payne


Leslie V. Payne (Texas Bar No. 00784736)
lpayne@hpcllp.com
Michael F. Heim (Texas Bar No. 09380923)
mheim@hpcllp.com
Miranda Y. Jones (Texas Bar No. 24065519)
mjones@hpcllp.com
R. Allan Bullwinkel (Texas Bar No. 24064327)
abullwinkel@hpcllp.com
J. Boone Baxter (Texas Bar No. 24087150)
bbaxter@hpcllp.com
Alden G. Harris (Texas Bar No. 24083138)
aharris@hpcllp.com
HEIM, PAYNE & CHORUSH, L.L.P.
1111 Bagby, Suite 2100
Houston, Texas 77002
Telephone: (713) 221-2000
Facsimile: (713) 221-2021

T. John Ward, Jr. (Texas Bar No. 00794818)


jw@wsfirm.com
Claire Abernathy Henry (Texas Bar No. 24053063)
claire@wsfirm.com
WARD, SMITH & HILL, PLLC
1507 Bill Owens Parkway
Longview, Texas 75604
Telephone (903) 757-6400
Facsimile (903) 757-2323

S. Calvin Capshaw (Texas Bar No. 03783900)


ccapshaw@capshawlaw.com
Elizabeth L. DeRieux (TX Bar No. 05770585)
ederieux@capshawlaw.com
CAPSHAW DERIEUX LLP
114 E. Commerce Ave.
Gladewater, TX 75647
Telephone: (903) 845-5770

ATTORNEYS FOR RED ROCK ANALYTICS, LLC

2
Case 2:19-cv-00117-JRG Document 1-3 Filed 04/11/19 Page 1 of 3 PageID #: 37
Case 2:19-cv-00117-JRG Document 1-3 Filed 04/11/19 Page 2 of 3 PageID #: 38

IN THE UNITED STATES DISTRICT COURT


FOR THE EASTERN DISTRICT OF TEXAS
MARSHALL DIVISION

§
RED ROCK ANALYTICS, LLC, § Civil Action No. _________
§
Plaintiff, §
§ Jury Trial Requested
v. §
§
APPLE INC. §
§
Defendant. §
§
§
§
§

RED ROCK ANALYTICS, LLC’S RULE 7.1 DISCLOSURE STATEMENT

Pursuant to Federal Rule of Civil Procedure 7.1, Plaintiff Red Rock Analytics, LLC (“Red

Rock”) states that no publicly held corporation owns more than 10% of Red Rock Analytics,

LLC.
Case 2:19-cv-00117-JRG Document 1-3 Filed 04/11/19 Page 3 of 3 PageID #: 39

DATED: April 11, 2019

/s/ Leslie V. Payne


Leslie V. Payne (Texas Bar No. 00784736)
lpayne@hpcllp.com
Michael F. Heim (Texas Bar No. 09380923)
mheim@hpcllp.com
Miranda Y. Jones (Texas Bar No. 24065519)
mjones@hpcllp.com
R. Allan Bullwinkel (Texas Bar No. 24064327)
abullwinkel@hpcllp.com
J. Boone Baxter (Texas Bar No. 24087150)
bbaxter@hpcllp.com
Alden G. Harris (Texas Bar No. 24083138)
aharris@hpcllp.com
HEIM, PAYNE & CHORUSH, L.L.P.
1111 Bagby, Suite 2100
Houston, Texas 77002
Telephone: (713) 221-2000
Facsimile: (713) 221-2021

T. John Ward, Jr. (Texas Bar No. 00794818)


jw@wsfirm.com
Claire Abernathy Henry (Texas Bar No. 24053063)
claire@wsfirm.com
WARD, SMITH & HILL, PLLC
1507 Bill Owens Parkway
Longview, Texas 75604
Telephone (903) 757-6400
Facsimile (903) 757-2323

S. Calvin Capshaw (Texas Bar No. 03783900)


ccapshaw@capshawlaw.com
Elizabeth L. DeRieux (TX Bar No. 05770585)
ederieux@capshawlaw.com
CAPSHAW DERIEUX LLP
114 E. Commerce Ave.
Gladewater, TX 75647
Telephone: (903) 845-5770

ATTORNEYS FOR RED ROCK ANALYTICS, LLC

2
Case 2:19-cv-00117-JRG Document 1-4 Filed 04/11/19 Page 1 of 3 PageID #: 40
JS 44 (Rev. 0) CIVIL COVER SHEET
The JS 44 civil cover sheet and the information contained herein neither replace nor supplement the filing and service of pleadings or other papers as required by law, except as
provided by local rules of court. This form, approved by the Judicial Conference of the United States in September 1974, is required for the use of the Clerk of Court for the
purpose of initiating the civil docket sheet. (SEE INSTRUCTIONS ON NEXT PAGE OF THIS FORM.)

I. (a) PLAINTIFFS DEFENDANTS


RED ROCK ANALYTICS, LLC APPLE INC.

(b) County of Residence of First Listed Plaintiff Essex County, MA County of Residence of First Listed Defendant
(EXCEPT IN U.S. PLAINTIFF CASES) (IN U.S. PLAINTIFF CASES ONLY)
NOTE: IN LAND CONDEMNATION CASES, USE THE LOCATION OF
THE TRACT OF LAND INVOLVED.

(c) Attorneys (Firm Name, Address, and Telephone Number) Attorneys (If Known)

Leslie V. Payne, Heim Payne & Chorush, LLP, 1111 Bagby, Suite 2100,
Houston, Texas 77002, 713-221-2000; see attachment

II. BASIS OF JURISDICTION (Place an “X” in One Box Only) III. CITIZENSHIP OF PRINCIPAL PARTIES (Place an “X” in One Box for Plaintiff
(For Diversity Cases Only) and One Box for Defendant)
u 1 U.S. Government u 3 Federal Question PTF DEF PTF DEF
Plaintiff (U.S. Government Not a Party) Citizen of This State u 1 u 1 Incorporated or Principal Place u 4 u 4
of Business In This State

u 2 U.S. Government u 4 Diversity Citizen of Another State u 2 u 2 Incorporated and Principal Place u 5 u 5
Defendant (Indicate Citizenship of Parties in Item III) of Business In Another State

Citizen or Subject of a u 3 u 3 Foreign Nation u 6 u 6


Foreign Country
IV. NATURE OF SUIT (Place an “X” in One Box Only) Click here for: Nature of Suit Code Descriptions.
CONTRACT TORTS FORFEITURE/PENALTY BANKRUPTCY OTHER STATUTES
u 110 Insurance PERSONAL INJURY PERSONAL INJURY u 625 Drug Related Seizure u 422 Appeal 28 USC 158 u 375 False Claims Act
u 120 Marine u 310 Airplane u 365 Personal Injury - of Property 21 USC 881 u 423 Withdrawal u 376 Qui Tam (31 USC
u 130 Miller Act u 315 Airplane Product Product Liability u 690 Other 28 USC 157 3729(a))
u 140 Negotiable Instrument Liability u 367 Health Care/ u 400 State Reapportionment
u 150 Recovery of Overpayment u 320 Assault, Libel & Pharmaceutical PROPERTY RIGHTS u 410 Antitrust
& Enforcement of Judgment Slander Personal Injury u 820 Copyrights u 430 Banks and Banking
u 151 Medicare Act u 330 Federal Employers’ Product Liability u 830 Patent u 450 Commerce
u 152 Recovery of Defaulted Liability u 368 Asbestos Personal u 835 Patent - Abbreviated u 460 Deportation
Student Loans u 340 Marine Injury Product New Drug Application u 470 Racketeer Influenced and
(Excludes Veterans) u 345 Marine Product Liability u 840 Trademark Corrupt Organizations
u 153 Recovery of Overpayment Liability PERSONAL PROPERTY LABOR SOCIAL SECURITY u 480 Consumer Credit
of Veteran’s Benefits u 350 Motor Vehicle u 370 Other Fraud u 710 Fair Labor Standards u 861 HIA (1395ff) u 485 Telephone Consumer
u 160 Stockholders’ Suits u 355 Motor Vehicle u 371 Truth in Lending Act u 862 Black Lung (923) Protection Act
u 190 Other Contract Product Liability u 380 Other Personal u 720 Labor/Management u 863 DIWC/DIWW (405(g)) u 490 Cable/Sat TV
u 195 Contract Product Liability u 360 Other Personal Property Damage Relations u 864 SSID Title XVI u 850 Securities/Commodities/
u 196 Franchise Injury u 385 Property Damage u 740 Railway Labor Act u 865 RSI (405(g)) Exchange
u 362 Personal Injury - Product Liability u 751 Family and Medical u 890 Other Statutory Actions
Medical Malpractice Leave Act u 891 Agricultural Acts
REAL PROPERTY CIVIL RIGHTS PRISONER PETITIONS u 790 Other Labor Litigation FEDERAL TAX SUITS u 893 Environmental Matters
u 210 Land Condemnation u 440 Other Civil Rights Habeas Corpus: u 791 Employee Retirement u 870 Taxes (U.S. Plaintiff u 895 Freedom of Information
u 220 Foreclosure u 441 Voting u 463 Alien Detainee Income Security Act or Defendant) Act
u 230 Rent Lease & Ejectment u 442 Employment u 510 Motions to Vacate u 871 IRS—Third Party u 896 Arbitration
u 240 Torts to Land u 443 Housing/ Sentence 26 USC 7609 u 899 Administrative Procedure
u 245 Tort Product Liability Accommodations u 530 General Act/Review or Appeal of
u 290 All Other Real Property u 445 Amer. w/Disabilities - u 535 Death Penalty IMMIGRATION Agency Decision
Employment Other: u 462 Naturalization Application u 950 Constitutionality of
u 446 Amer. w/Disabilities - u 540 Mandamus & Other u 465 Other Immigration State Statutes
Other u 550 Civil Rights Actions
u 448 Education u 555 Prison Condition
u 560 Civil Detainee -
Conditions of
Confinement
V. ORIGIN (Place an “X” in One Box Only)
u 1 Original u 2 Removed from u 3 Remanded from u 4 Reinstated or u 5 Transferred from u 6 Multidistrict u 8 Multidistrict
Proceeding State Court Appellate Court Reopened Another District Litigation - Litigation -
(specify) Transfer Direct File
Cite the U.S. Civil Statute under which you are filing (Do not cite jurisdictional statutes unless diversity):
35 U.S.C. § 271; 28 U.S.C. §§ 1331 and 1338(a)
VI. CAUSE OF ACTION Brief description of cause:
Infringement of US Patent No. 7,346,313
VII. REQUESTED IN u CHECK IF THIS IS A CLASS ACTION DEMAND $ CHECK YES only if demanded in complaint:
COMPLAINT: UNDER RULE 23, F.R.Cv.P. JURY DEMAND: u Yes u No
VIII. RELATED CASE(S)
(See instructions):
IF ANY JUDGE Roy S. Payne DOCKET NUMBER 2:17-cv-00101-RSP
DATE SIGNATURE OF ATTORNEY OF RECORD
04/11/2019 /s/ Leslie V. Payne
FOR OFFICE USE ONLY

RECEIPT # AMOUNT APPLYING IFP JUDGE MAG. JUDGE


Case 2:19-cv-00117-JRG Document 1-4 Filed 04/11/19 Page 2 of 3 PageID #: 41
JS 44 Reverse (Rev. 0)

INSTRUCTIONS FOR ATTORNEYS COMPLETING CIVIL COVER SHEET FORM JS 44


Authority For Civil Cover Sheet

The JS 44 civil cover sheet and the information contained herein neither replaces nor supplements the filings and service of pleading or other papers as
required by law, except as provided by local rules of court. This form, approved by the Judicial Conference of the United States in September 1974, is
required for the use of the Clerk of Court for the purpose of initiating the civil docket sheet. Consequently, a civil cover sheet is submitted to the Clerk of
Court for each civil complaint filed. The attorney filing a case should complete the form as follows:

I.(a) Plaintiffs-Defendants. Enter names (last, first, middle initial) of plaintiff and defendant. If the plaintiff or defendant is a government agency, use
only the full name or standard abbreviations. If the plaintiff or defendant is an official within a government agency, identify first the agency and
then the official, giving both name and title.
(b) County of Residence. For each civil case filed, except U.S. plaintiff cases, enter the name of the county where the first listed plaintiff resides at the
time of filing. In U.S. plaintiff cases, enter the name of the county in which the first listed defendant resides at the time of filing. (NOTE: In land
condemnation cases, the county of residence of the "defendant" is the location of the tract of land involved.)
(c) Attorneys. Enter the firm name, address, telephone number, and attorney of record. If there are several attorneys, list them on an attachment, noting
in this section "(see attachment)".

,, Jurisdiction. The basis of jurisdiction is set forth under Rule 8(a), F.R.Cv.P., which requires that jurisdictions be shown in pleadings. Place an "X"
in one of the boxes. If there is more than one basis of jurisdiction, precedence is given in the order shown below.
United States plaintiff. (1) Jurisdiction based on 28 U.S.C. 1345 and 1348. Suits by agencies and officers of the United States are included here.
United States defendant. (2) When the plaintiff is suing the United States, its officers or agencies, place an "X" in this box.
Federal question. (3) This refers to suits under 28 U.S.C. 1331, where jurisdiction arises under the Constitution of the United States, an amendment
to the Constitution, an act of Congress or a treaty of the United States. In cases where the U.S. is a party, the U.S. plaintiff or defendant code takes
precedence, and box 1 or 2 should be marked.
Diversity of citizenship. (4) This refers to suits under 28 U.S.C. 1332, where parties are citizens of different states. When Box 4 is checked, the
citizenship of the different parties must be checked. (See Section III below; NOTE: federal question actions take precedence over diversity
cases.)

,,, Residence (citizenship) of Principal Parties. This section of the JS 44 is to be completed if diversity of citizenship was indicated above. Mark this
section for each principal party.

,9 Nature of Suit. Place an "X" in the appropriate box. If there are multiple nature of suit codes associated with the case, pick the nature of suit code
that is most applicable. Click here for: Nature of Suit Code Descriptions.

9 Origin. Place an "X" in one of the seven boxes.


Original Proceedings. (1) Cases which originate in the United States district courts.
Removed from State Court. (2) Proceedings initiated in state courts may be removed to the district courts under Title 28 U.S.C., Section 1441.
Remanded from Appellate Court. (3) Check this box for cases remanded to the district court for further action. Use the date of remand as the filing
date.
Reinstated or Reopened. (4) Check this box for cases reinstated or reopened in the district court. Use the reopening date as the filing date.
Transferred from Another District. (5) For cases transferred under Title 28 U.S.C. Section 1404(a). Do not use this for within district transfers or
multidistrict litigation transfers.
Multidistrict Litigation – Transfer. (6) Check this box when a multidistrict case is transferred into the district under authority of Title 28 U.S.C.
Section 1407.
Multidistrict Litigation – Direct File. (8) Check this box when a multidistrict case is filed in the same district as the Master MDL docket.PLEASE
NOTE THAT THERE IS NOT AN ORIGIN CODE 7. Origin Code 7 was used for historical records and is no longer relevant due tochanges in
statue.

9, Cause of Action. Report the civil statute directly related to the cause of action and give a brief description of the cause. Do not cite jurisdictional
statutes unless diversity. Example: U.S. Civil Statute: 47 USC 553 Brief Description: Unauthorized reception of cable service

9,, Requested in Complaint. Class Action. Place an "X" in this box if you are filing a class action under Rule 23, F.R.Cv.P.
Demand. In this space enter the actual dollar amount being demanded or indicate other demand, such as a preliminary injunction.
Jury Demand. Check the appropriate box to indicate whether or not a jury is being demanded.

9,,, Related Cases. This section of the JS 44 is used to reference related pending cases, if any. If there are related pending cases, insert the docket
numbers and the corresponding judge names for such cases.

Date and Attorney Signature. Date and sign the civil cover sheet.
Case 2:19-cv-00117-JRG Document 1-4 Filed 04/11/19 Page 3 of 3 PageID #: 42
 

 Additional attorneys for the Plaintiff Red Rock Analytics, LLC: 
 
Michael F. Heim (Texas Bar No. 09380923) 
mheim@hpcllp.com  
Miranda Y. Jones (Texas Bar No. 24065519) 
mjones@hpcllp.com  
R. Allan Bullwinkel (Texas Bar No. 24064327) 
abullwinkel@hpcllp.com  
J. Boone Baxter (Texas Bar No. 24087150) 
bbaxter@hpcllp.com  
Alden G. Harris (Texas Bar No. 24083138) 
aharris@hpcllp.com  
HEIM, PAYNE & CHORUSH, L.L.P. 
1111 Bagby, Suite 2100 
Houston, Texas 77002 
Telephone: (713) 221‐2000 
Facsimile: (713) 221‐2021 
 
T. John Ward, Jr. (Texas Bar No. 00794818) 
jw@wsfirm.com  
Claire Abernathy Henry (Texas Bar No. 24053063) 
claire@wsfirm.com  
WARD, SMITH & HILL, PLLC 
1507 Bill Owens Parkway 
Longview, Texas 75604 
Telephone (903) 757‐6400 
Facsimile (903) 757‐2323 
 
S. Calvin Capshaw (Texas Bar No. 03783900) 
ccapshaw@capshawlaw.com  
Elizabeth L. DeRieux (TX Bar No. 05770585)  
ederieux@capshawlaw.com  
CAPSHAW DERIEUX LLP 
114 E. Commerce Ave. 
Gladewater, TX 75647 
Telephone: (903) 845‐5770