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`David A. Nelson (pro hac vice forthcoming)
`(Ill. Bar No. 6209623)
`davenelson@quinnemanuel.com
`QUINN EMANUEL URQUHART & SULLIVAN, LLP
`500 West Madison St., Suite 2450
`Chicago, Illinois 60661
`Telephone: (312) 705-7400
`
`Karen P. Hewitt (SBN 145309)
`kphewitt@jonesday.com
`Randall E. Kay (SBN 149369)
`rekay@jonesday.com
`JONES DAY
`4655 Executive Drive, Suite 1500
`San Diego, California 92121
`Telephone: (858) 314-1200
`
`Evan R. Chesler (pro hac vice forthcoming)
`(N.Y. Bar No. 1475722)
`echesler@cravath.com
`CRAVATH, SWAINE & MOORE LLP
`Worldwide Plaza, 825 Eighth Avenue
`New York, NY 10019
`Telephone: (212) 474-1000
`
`Attorneys for Plaintiff
`QUALCOMM INCORPORATED
`
`
`UNITED STATES DISTRICT COURT
`SOUTHERN DISTRICT OF CALIFORNIA
`QUALCOMM INCORPORATED,
`Case No.
`Plaintiff,
`COMPLAINT FOR PATENT
`INFRINGEMENT
`[DEMAND FOR A JURY
`TRIAL]
`
`v.
`APPLE INCORPORATED,
`Defendant.
`
`NAI-1503225050v2
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`Plaintiff Qualcomm Incorporated (“Qualcomm”), by its undersigned
`attorneys, alleges, with knowledge with respect to its own acts and on information
`and belief as to other matters, as follows:
`NATURE OF THE ACTION
`Qualcomm brings this action to compel Apple to cease infringing
`1.
`Qualcomm’s patents and to compensate Qualcomm for Apple’s extensive
`infringement of several patented Qualcomm technologies.
`Qualcomm is one of the world’s leading technology companies and a
`2.
`pioneer in the mobile phone industry. Its inventions form the very core of modern
`mobile communication and enable modern consumer experiences on mobile devices
`and cellular networks.
`Since its founding in 1985, Qualcomm has been designing, developing,
`3.
`and improving mobile communication devices, systems, networks, and products. It
`has invented technologies that transform how the world communicates. Qualcomm
`developed fundamental technologies at the heart of 2G, 3G, and 4G cellular
`communications, is one of a handful of companies leading the development of the
`next-generation 5G standard, and has developed numerous innovative features used
`in virtually every modern cell phone.
`Qualcomm also invests in technologies developed by other companies
`4.
`and has acquired companies (and their patented innovative technologies) as part of
`its emphasis on supporting innovation. Qualcomm’s patent portfolio currently
`includes more than 130,000 issued patents and patent applications worldwide.
`Hundreds of mobile device suppliers around the world have taken licenses from
`Qualcomm.
`Apple is the world’s most profitable seller of mobile devices. Its
`5.
`iPhones and other products enjoy enormous commercial success. But without the
`innovative technology covered by Qualcomm’s patent portfolio, Apple’s products
`would lose much of their consumer appeal. Apple was a relatively late entrant in the
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`mobile device industry, and its mobile devices rely heavily on the inventions of
`Qualcomm and other companies that Qualcomm has invested in. Nearly a decade
`before Apple released the iPhone, Qualcomm unveiled its own full-feature, top-of-
`the-line smartphone. According to CNN’s 1999 holiday buying guide, Qualcomm’s
`pdQ 1900 “lets you make calls, keep records, send email, browse the web and run
`over a thousand different applications, all while on the go. Although a cell phone, it
`is one of the first truly portable, mobile and multipurpose Internet devices.”1 While
`Qualcomm no longer markets phones directly to consumers, it continues to lead the
`development of cutting-edge technologies that underpin a wide range of important
`wireless-device features. Other companies, like Apple, now manufacture and
`market phones that feature Qualcomm’s innovations and the innovations of other
`technology pioneers that Qualcomm invested in.
`Qualcomm’s innovations in the mobile space have influenced all
`6.
`modern smartphones, and Apple—like other major mobile device makers—utilizes
`Qualcomm’s technologies. Qualcomm’s patented features enable and enhance
`popular features that drive consumer demand, for example: power-efficient radio
`frequency (RF) transceiver technologies that support enhanced carrier aggregation,
`improve battery life, and reduce signal interference; innovative designs for
`components of processors and memory arrays that decrease power consumption and
`improve device performance; and advanced image processing techniques that allow
`users to recreate photographic effects that typically require bulky and expensive
`camera equipment , among many others.
`In short, Qualcomm invented many core technologies that make the
`7.
`iPhone (and other smartphones and mobile devices) desirable to consumers in their
`daily lives.
`
`
`1 http://edition.cnn.com/1999/TECH/ptech/12/03/qualcomm.pdq/.
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`8. While Apple built the most successful consumer products in history by
`relying significantly on technologies pioneered by Qualcomm, Apple refuses to pay
`for those technologies. Apple’s founder boasted that Apple “steals” the great ideas
`of others—specifically, that “we have always been shameless about stealing great
`ideas.”2 Apple employees likewise admit that Apple—a relatively late entrant in the
`mobile space—did not invent many of the iPhone’s features. Instead, Apple
`incorporated, marketed, and commercialized the work of others: “I don’t know how
`many things we can come up with that you could legitimately claim we did first. . . .
`We had the first commercially successful version of many features but that’s
`different than launching something to market first.”3
`Rather than pay Qualcomm for the technology Apple uses, Apple has
`9.
`taken extraordinary measures to avoid paying Qualcomm for the fair value of
`Qualcomm’s patents. On January 20, 2017, Apple sued Qualcomm in this district,
`asserting an array of excuses to avoid paying fair-market, industry-standard rates for
`the use of certain of Qualcomm’s pioneering patents that are critical to a modern
`smartphone like the iPhone. See Case No. 3:17-cv-00108-GPC-MDD. Apple also
`encouraged the companies that manufacture the iPhone to breach their contracts
`with Qualcomm by refusing to pay for the Qualcomm technology in iPhones,
`something that those manufacturers had done for many years, without complaint,
`before Apple’s direction to stop. Further, Apple misled governmental agencies
`
`
`2 Interview with Steve Jobs, available at
`https://www.youtube.com/watch?v=CW0DUg63lqU (“Picasso had a saying, ‘good
`artists copy, great artists steal.’ And we have always been shameless about stealing
`great ideas.”).
`3 April 2010 email from Apple’s iPhone Product Marketing Manager, Steve
`Sinclair, reported in: Rick Merritt, Schiller ‘shocked at ‘copycat’ Samsung phone,
`Embedded (Aug. 3, 2012), http://www.embedded.com/print/4391702 (April 21,
`2017 snapshot of page, accessed via Google’s cache).
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`around the world into investigating Qualcomm in an effort to indirectly exert
`leverage over Qualcomm.
`10. Many of Qualcomm’s patents are essential to certain cellular or other
`standards (“Standard Essential Patents”), such that the use of an underlying
`technological standard would require use of the patent. Qualcomm also owns a
`wide range of non-standard-essential patents for inventions in various technologies
`related to mobile devices.
`In this suit, Qualcomm asserts a set of non-standard-essential patents
`11.
`infringed by Apple’s mobile electronic devices. The patents asserted in this suit
`represent only a small fraction of the Qualcomm non-standard-essential patents that
`Apple uses without a license.
`12. Qualcomm repeatedly offered to license its patents to Apple. But
`Apple has repeatedly refused offers to license Qualcomm’s patents on reasonable
`terms. Qualcomm therefore seeks to enforce its rights in the patents identified
`below and to address and remedy Apple’s flagrant infringement of those patents.
`PARTIES
`13. Qualcomm is a Delaware corporation with its principal place of
`business at 5775 Morehouse Drive, San Diego, California. Since 1989, when
`Qualcomm publicly introduced Code Division Multiple Access (“CDMA”) as a
`commercially successful digital cellular communications standard, Qualcomm has
`been recognized as an industry leader and innovator in the field of mobile devices
`and cellular communications. Qualcomm owns more than 130,000 patents and
`patent applications around the world relating to cellular technologies and many
`other valuable technologies used by mobile devices. Qualcomm is a leader in the
`development and commercialization of wireless technologies and the owner of the
`world’s most significant portfolio of cellular technology patents. Qualcomm derives
`a substantial portion of its revenues and profits from licensing its intellectual
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`property. Qualcomm is also a world leader in the sale of chips, chipsets, and
`associated software for mobile phones and other wireless devices.
`14. Apple is a corporation organized and existing under the laws of the
`State of California, with its principal place of business at 1 Infinite Loop, Cupertino,
`California. Apple designs, manufactures, and sells throughout the world a wide
`range of products, including mobile devices that incorporate Qualcomm’s multi-
`touch-gesture, autofocus, multitasking-interface, quick-charging, and machine-
`learning patents.
`
`JURISDICTION AND VENUE
`15. This action arises under the patent laws of the United States of
`America, 35 U.S.C. § 1 et seq. This Court has jurisdiction over the subject matter of
`this action pursuant to 28 U.S.C. §§ 1331 and 1338(a).
`16. This Court has personal jurisdiction over Apple because it is organized
`and exists under the laws of California.
`17. Venue is proper in this District pursuant to 28 U.S.C. § 1391(b) and (c)
`and 28 U.S.C. § 1400(b). Venue is appropriate under 28 U.S.C. § 1400(b) at least
`because Apple is incorporated in California and because Apple has committed acts
`of infringement and has a regular and established place of business in this district.
`Apple’s acts of infringement in this district include but are not limited to sales of the
`Accused Products at Apple Store locations in this district, including but not limited
`to 7007 Friars Road, San Diego, CA 92108 and 4505 La Jolla Village Drive, San
`Diego, CA 92122.
`
`STATEMENT OF FACTS
`Qualcomm Background
`18. Qualcomm was founded in 1985 when seven industry visionaries came
`together to discuss the idea of providing quality communications. For more than 30
`years, Qualcomm has been in the business of researching, designing, developing,
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`and selling innovative semiconductor and cellular technology and products for the
`telecommunications and mobile technology industries.
`19. When Qualcomm was founded, cellular phones were cumbersome,
`heavy, and expensive devices that supplied inconsistent voice communications—
`audio quality was poor, users sometimes heard portions of others’ calls, handoffs
`were noisy, and calls frequently dropped. Qualcomm played a central role in the
`revolutionary transformation of cellular communications technologies. Today,
`cellular devices are remarkably powerful and can deliver reliable voice service and
`lightning-fast data to billions of consumers around the world at affordable prices.
`20. Qualcomm is now one of the largest technology, semiconductor, and
`telecommunications companies in the United States. It employs over 18,000 people
`in the United States, 68 percent of whom are engineers, and it occupies more than
`92 buildings (totaling over 6.5 million sq. ft.) in seventeen states and the District of
`Columbia.
`21. Qualcomm’s industry-leading research and development efforts,
`focused on enabling cellular systems and products, are at the core of Qualcomm’s
`business. Since its founding, Qualcomm has invested tens of billions of dollars in
`research and development related to cellular, wireless communications, and mobile
`processor technology. Qualcomm’s massive research and development investments
`have produced numerous innovations. Because of this ongoing investment,
`Qualcomm continues to drive the development and commercialization of successive
`generations of mobile technology and is one of a handful of companies leading the
`development of the next-generation 5G standard.
`In addition to Qualcomm’s investments in research and development
`22.
`internally, Qualcomm has a rich history of investing in and acquiring technologies
`developed by other industry leaders. By purchasing companies and patents from
`companies who desire to sell their innovations, Qualcomm fosters innovation by
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`enabling those companies to realize a return on their research and development
`investments and, therefore, incentivizes additional research and development.
`23. As a result of the strength and value of Qualcomm’s patent portfolio,
`virtually every major handset manufacturer in the world has taken a royalty-bearing
`license to Qualcomm’s patent portfolio. The licenses to Qualcomm’s patents allow
`manufacturers to use numerous forms of critical and innovative Qualcomm
`technology without having to bear the multi-billion dollar, multi-year costs of
`developing those innovations themselves.
`Apple Background
`24. Apple has built the most profitable company in the world, thanks in
`large part to products that rely on Qualcomm’s patented technologies. With a
`market capitalization of more than $700 billion, $246 billion in cash reserves, and a
`global sphere of influence, Apple has more money and more influence than many
`countries. Relying heavily on Qualcomm technology and technology Qualcomm
`has acquired, Apple has become the dominant player in mobile device sales.
`Apple’s dominance has grown every year since the iPhone’s launch in 2007. In
`recent years, Apple has captured upwards of 90 percent of all profits in the
`smartphone industry.
`Qualcomm’s Technology Leadership
`25. The asserted patents reflect the breadth of Qualcomm’s dedication and
`investment in research and development relating to wireless technology and mobile
`electronic devices. Qualcomm invented numerous proprietary solutions that are
`used to optimize products around the globe. Many of these inventions are reflected
`in Qualcomm’s non-standard-essential patents, such as the patents asserted in this
`case.
`
`26. As mobile electronic devices have become more powerful with greater
`functionality, device manufacturers have faced numerous problems with power
`consumption, signal interference, and the performance and efficiency of processors
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`and memory arrays, among others. Device manufacturers have also sought to
`provide more advanced features to users, particularly with regard to photography
`and image processing.
`27. The asserted patents disclose and claim Qualcomm technologies that
`address many of these needs, including RF transceiver technologies that reduce
`power consumption and signal interference, power-efficient and high-performance
`architectures for processor and memory components, and advanced image
`processing techniques to recreate the popular “bokeh” photographic effect using a
`dual-camera mobile electronic device.
`28. For example, Apple has touted the capability of its newest mobile
`electronic devices to support “carrier aggregation” technology. This means that a
`mobile device can receive portions of a single input on multiple carriers at the same
`time to increase the bandwidth of a user. Qualcomm has pioneered and patented
`technologies that allow mobile electronic devices to support carrier aggregation
`while maintaining high power efficiency. These include the ’356 patent, which
`relates to the use of low noise amplifiers (LNAs) to flexibly receive and amplify RF
`signals. As a result of the invention of the ’356 patent, mobile devices can consume
`less power and significantly reduce the number of receiver input signal paths for a
`RF transceiver when deploying carrier aggregation technology.
`29. As another example, Qualcomm has pioneered techniques that allow
`mobile electronic devices to support carrier aggregation technology while avoiding
`signal interferences that can make it difficult or impossible to recover information
`from a signal. The ’336 patent describes a technique of grouping and amplifying RF
`signals in two stages that reduces signal interference without increasing the
`complexity of signal routing pathways. As a result of the invention of the ’336
`patent, RF transceivers in mobile devices can support carrier aggregation and
`address signal interference without increasing routing complexity, which increases
`cost and can negatively impact performance.
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`30. Qualcomm has also invested substantially in developing innovative
`designs for mobile device processors and memory arrays that enhance device
`performance and lower power consumption. For example, the ’674 patent relates to
`an improved design for the power on / off control network (POC network)
`component of a device’s processor. The POC network communicates to
`input/output (I/O) circuits whether core devices are on or off, which is desirable in
`order to have I/O devices operate effectively. The ’674 patent describes a POC
`network design that reduces the leakage of electrical current while improving the
`system’s speed of detection of on / off states. The invention of the ’674 patent thus
`improves processor performance while reducing power consumption and improving
`battery life for the device. As another example, in the ’002 patent Qualcomm
`disclosed an improved memory array design that reduces the power consumption
`due to generating clock signals. As a result of the invention of the ’002 patent,
`mobile devices can operate with lower power consumption and higher speed, which
`improves the devices’ battery life and efficiency.
`31. As a final example, Qualcomm’s innovations have enabled advanced
`mobile device features that generate high demand among users, including in the
`areas of photography and image processing. For instance, the ’633 patent relates to
`depth-based image enhancement, and specifically the use of depth computed from
`two spatially offset images to enhance regions of a monocular image. Mobile
`devices with dual cameras, including certain Apple devices, use this invention to
`perform high quality simulations of photographic effects (such as the so-called
`“bokeh” effect) that can otherwise be generated only with bulky and expensive
`camera equipment. In fact, Apple’s Senior Vice President of Worldwide Marketing
`described the iPhone 7 Plus’s ability to “create a depth map of [an] image from [its]
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`two cameras . . . and apply a beautiful blur to the background” as “a huge
`breakthrough in what can be done in a smartphone in photography.”4
`The Accused Devices
`32. As set forth below, a variety of Apple’s devices—including certain of
`Apple’s iPhones—practice one or more of the Patents-in-Suit.
`The Patents-in-Suit
`33. The following patents are infringed by Apple (“Patents-in-Suit”): U.S.
`Patent No. 9,154,356 (“the ’356 patent”), U.S. Patent No. 9,473,336 (“the ’336
`patent”), U.S. Patent No. 8,063,674 (“the ’674 patent”), U.S. Patent 7,693,002 (“the
`’002 patent”), and U.S. Patent No. 9,552,633 (“the ’633 patent”).
`34. As described below, Apple has been and is still infringing, contributing
`to infringement, and/or inducing others to infringe the Patents-in-Suit by making,
`using, offering for sale, selling, or importing devices that practice the Patents-in-
`Suit. Apple’s acts of infringement have occurred within this District and elsewhere
`throughout the United States.
`U.S. Patent No. 9,154,356
`35. The ’356 patent was duly and legally issued on October 6, 2015 to
`Qualcomm, which is the owner of the ’356 patent and has the full and exclusive
`right to bring actions and recover damages for Apple’s infringement of the ’356
`patent. The ’356 patent is valid and enforceable. A copy of the ’356 patent is
`attached hereto as Exhibit A.
`36. The ’356 patent relates generally to RF transceivers using low noise
`amplifiers (LNAs) to support carrier aggregation. The ’356 patent discloses a multi-
`stage LNA circuit topology, where each amplifier stage can be independently
`controlled to receive and amplify a common input RF signal and provide an output
`
`
`4 https://singjupost.com/apple-iphone-7-keynote-september-2016-launch-event-
`full-transcript/8/
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`RF signal to a separate load circuit. The topology flexibly supports multiple I/Q
`mixer/downconverter loads for a corresponding number of component carriers at
`different frequencies. As a result of the invention of the ’356 patent, mobile devices
`can more efficiently deploy carrier aggregation technology and have longer battery
`life.
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`U.S. Patent No. 9,473,336
`37. The ’336 patent was duly and legally issued on October 18, 2016 to
`Qualcomm, which is the owner of the ’336 patent and has the full and exclusive
`right to bring action and recover damages for Apple’s infringement of the ’336
`patent. The ’336 patent is valid and enforceable. A copy of the ’336 patent is
`attached hereto as Exhibit B.
`38. The ’336 patent relates generally to RF transceivers for use with carrier
`aggregation technology. With the advent of carrier aggregation technology, RF
`transceivers in mobile devices must be designed to handle an increasing number of
`different frequencies in multiple communication bands. In many cases, receivers
`include multiple signal paths, which must be subject to stringent isolation
`requirements to prevent signal interference, which can make recovering information
`from a signal difficult or impossible. The ’336 patent discloses a two-stage
`amplification of RF signals, where carrier signals are grouped into carrier groups
`including a respective portion of the carrier signals in a first stage amplifier module
`and provided to second stage amplifiers. The first stage amplifier includes multiple
`low noise amplifiers (LNAs) that generate amplified outputs each having a portion
`of the carrier signals and a routing module that provides the amplified outputs to
`different output ports. Second stage amplifiers then amplify the carrier groups to
`generate second stage output signals that may be output to different demodulation
`stages that demodulate a selected carrier signal. Without the invention of the ’336
`patent, RF transceivers would not be able to address issues of interference without
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`increasing the routing complexity of the design, which increases cost and can impact
`performance.
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`U.S. Patent No. 8,063,674
`39. The ’674 patent was duly and legally issued on November 22, 2011 to
`Qualcomm, which is the owner of the ’674 patent and has the full and exclusive
`right to bring action and recover damages for Apple’s infringement of the ’674
`patent. The ’674 patent is valid and enforceable. A copy of the ’674 patent is
`attached hereto as Exhibit C.
`40. The ’674 patent relates generally to an improved power up / power
`down detector for computing devices with integrated circuits requiring multiple
`voltages. The power on / power off control (POC network) of a device is a
`component of a processor that communicates to input/output (I/O) circuits whether
`core devices are on or off, which is desirable in order to have I/O devices operate
`effectively. The ’674 patent describes an improved design for a POC network
`architecture that uses power up / down detectors to detect the on / off state of the
`core devices on the POC network, processing circuitry to generate signals depending
`on their power state, and feedback circuits to adjust electrical current capacity in the
`POC network in order to reduce the leakage of that current while improving the
`speed with which the system detects the on/off state of the core devices. The
`invention of the ’674 patent thereby improves the performance of the POC network
`and processor while also reducing power consumption and improving the battery
`life of the computing device.
`U.S. Patent No. 7,693,002
`41. The ’002 patent was duly and legally issued on April 6, 2010 to
`Qualcomm, which is the owner of the ’002 patent and has the full and exclusive
`right to bring action and recover damages for Apple’s infringement of the ’002
`patent. The ’002 patent is valid and enforceable. A copy of the ’002 patent is
`attached hereto as Exhibit D.
`NAI-1503225050v2
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`COMPLAINT FOR PATENT INFRINGEMENT
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`Case 3:17-cv-02398-DMS-MDD Document 1 Filed 11/29/17 PageID.14 Page 14 of 38
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`42. The ’002 patent relates generally to an improved memory array design
`that saves power. Specifically, the ’002 patent discloses improved designs for
`wordline drivers, which are components connected to memory arrays. The design
`allows for the selective application of clock signals to activate groups of wordline
`drivers, which reduces the power consumption due to generating clock signals
`relative to previous designs. As a result of the invention of the ’002 patent,
`computing devices can operate with lower power consumption and higher speed,
`which in turn prolongs the battery life and efficiency of those devices.
`U.S. Patent No. 9,552,633
`43. The ’633 patent was duly and legally issued on January 24, 2017 to
`Qualcomm, which is the owner of the ’633 patent and has the full and exclusive
`right to bring action and recover damages for Apple’s infringement of the ’633
`patent. The ’633 patent is valid and enforceable. A copy of the ’633 patent is
`attached hereto as Exhibit E.
`44. The ’633 patent relates generally to depth-based image enhancement,
`and specifically the use of depth computed from multiple images. The ’633 patent
`discloses using two images to generate a depth map and enhance a portion of the
`scene. As a result of the invention of the ’633 patent, mobile device cameras are
`now able to perform a high quality simulation of the “bokeh effect,” a popular
`artistic photography effect that emphasizes a portion of the scene, giving a 3D effect
`to the photograph without the use of bulky and expensive high-end cameras and
`lenses.
`COUNT 1 (PATENT INFRINGEMENT – U.S. PATENT NO. 9,154,356)
`45. Qualcomm repeats and re-alleges the allegations of paragraphs 1
`through 44 above as if fully set forth herein.
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`NAI-1503225050v2
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`COMPLAINT FOR PATENT INFRINGEMENT
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`Case 3:17-cv-02398-DMS-MDD Document 1 Filed 11/29/17 PageID.15 Page 15 of 38
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`46. Qualcomm is the lawful owner of the ’356 patent and has the full and
`exclusive right to bring actions and recover damages for Apple’s infringement of
`said patent.
`In violation of 35 U.S.C. § 271, Apple has been and is still infringing,
`47.
`contributing to infringement, and/or inducing others to infringe the ’356 patent by
`making, using, offering for sale, selling, or importing mobile devices that practice
`the patent, including but not limited to the Apple iPhone 7, Apple iPhone 7 Plus, and
`on information and belief, Apple iPhone 8, Apple iPhone 8 Plus, and Apple iPhone
`X.
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`48. Each of the Apple iPhone 7 and Apple iPhone 7 Plus, and on
`information and belief, Apple iPhone 8, Apple iPhone 8 Plus, and Apple iPhone X is
`equipped with RF transceivers that contain multi-stage low noise amplifiers (LNAs)
`with at least a first amplifier stage and a second amplifier stage, each of which is
`configured to be independently enabled or disabled, to receive and amplify an input
`RF signal in carrier aggregation, and to provide an output RF signal, where the
`output signals of the different amplifier stages include distinct carriers.
`49. The accused devices infringe at least claims 1, 7, 8, 10, 11, 17, and 18
`of the ’356 patent.
`50. The accused devices infringe claims 1 and 17 of the ’356 patent as
`follows. Each of the Apple iPhone 7 and Apple iPhone 7 Plus is an apparatus that
`contains two multimode RF transceivers, such as, for example, Intel PMB5750
`Multimode RF Transceivers (the “iPhone 7 transceivers”). Each iPhone 7
`transceiver includes a first amplifier stage with circuitry that allows the first
`amplifier stage to be independently enabled or disabled. The first amplifier stage
`receives and amplifies an input RF signal and provides an output RF signal to a load
`circuit comprising an I/Q mixer core. Each iPhone 7 transceiver also includes a
`second amplifier stage with separate enable circuitry, which receives and amplifies
`the input RF signal and provides a second output RF signal to a second load circuit
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`COMPLAINT FOR PATENT INFRINGEMENT
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`Case 3:17-cv-02398-DMS-MDD Document 1 Filed 11/29/17 PageID.16 Page 16 of 38
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`comprising an I/Q mixer core. As the Apple iPhone 7 and Apple iPhone 7 Plus each
`supports LTE downlink carrier aggregation across many operating bands and
`carriers, the input RF signal employs carrier aggregation comprising transmissions
`sent on multiple carrier