Directv baseband converter

You will develop strong working relationships with Content Team, Engineering, and other stakeholders to ensure a high level of quality is maintained and continuously improve the customer experience. Leveraging broadcast and utility tools for service restoral Installation, diagnosis, and maintenance of critical on-air video, audio, RF, baseband, signal processing, transport, and transmission equipment.

The incident, Change, and participate in Lifecycle Management. Summarize, document, and present technical information in verbal and written form. In this role, you will be a part of a technical team working to ensure that incidents are managed effectively, with minimal impact on our business and customers. Run incident command during availability incidents and follow-up with appropriate teams and vendors during live and post-incident recovery.

Defendants move for summary judgment claiming that none of their products store all four of a desired program start time, a desired program end time, a desired program service and a desired program type, as specified in Claim 1 of the patent.

Gemstar has cross-moved for summary judgment against EchoStar only, arguing that its products meet each of the criteria specified in Claim 1. Thus, the accused products must be compared to Claim 1 of Hallenbeck ' DirecTV and EchoStar provide direct broadcast satellite television services. In addition to its television services, DirecTV broadcasts program guides. Declaration of Robert G. Arsenault, filed November 8, , at 3.

Supplemental Declaration of Michael Cavanaugh, filed November 29, , at 2. Thus, the DirecTV Defendants' accused products will first be considered followed by a discussion related to EchoStar's accused devices. Arsenault Declaration, at 3. Each MPG contains two hours of programming schedule information beginning with the current half hour. The sole exception to this requirement are those IRD's which store only local programming, known as market MPG's, and which store only the information relevant to the subscriber's zip code.

DirecTV also broadcasts SPG's which contain information for programming that begins or ends within a six hour window outside the two hour window provided by the MPG's. McLane Declaration, at 2. The IRD's which receive MPG's and SPG's cannot selectively store program guide information based on the actual start or end time of a television program or based on a desired program service, i. Arsenault Declaration, at 4. In other words, the IRD's store the entire set of programming information and do not have the capability of acquiring particular types of programming information from the broadcast stream based on user selected criteria.

As previously noted, each transponder in the DirecTV satellite system transmits a digital data stream which will contain information for multiple national broadcasts as well as local broadcasts. McLane Declaration, at 3. Defendants' motion for summary judgment is based on their claim that none of the accused IRD's, whether manufactured by Thomson or Hughes, provide for the storage of the selection criteria claimed in Hallenbeck ', i.

Since the undersigned's claim construction requires the storage of each selection criteria, SuperGuide, like Gemstar, does not oppose summary judgment. Despite this admission in its brief, SuperGuide has submitted an expert's declaration in which it is opined that the DirecTV products do, in fact, store each selection criteria and SuperGuide has submitted argument in support thereof. In an abundance of caution, this position will be addressed. However, the undersigned is compelled to note that counsel's litigation strategy of admission on the one hand and argument on the other is, at best, confusing and at worst, disingenuous.

Ishida Co. Taylor, F. Storage Tech. Here, the function of the claim is storage of at least one of a desired program start time, a desired program end time, a desired program service and a desired program type.

Neither the function nor the structure for performing it is literally identical to the accused devices. Interactive Pictures Corp. Infinite Pictures, Inc. The issue, then, is whether the function is substantially the same, a comparison which invokes the function-way-result test. Hallenbeck ', at Col. Moreover, in Hallenbeck ', if the packet does not contain information with the required start time, it is not stored. The accused devices are stored based on the current time, a function which may not be changed by the user.

And, unlike Hallenbeck ', "[t]he IRDs do not store selected portions of any single program guide. However, at least one MPG is always stored automatically. SuperGuide claims that when the subscriber first requests the program guide, the guide displays programming for the current time and a period of hours in the future.

However, the user can request information for a different time than that displayed. Thus, which programs are included in a particular block of time is a function of their start times and end times. It is an accurate statement that the SPG's contain "grid times" which correlate to the program guide grid that will be displayed on the subscriber's screen. Grid times "define the time interval of program guide information which [is] displayable to a subscriber. Thus, whereas in the invention, the program selection is based on program start time, in the accused devices, the selection is based on programming information available at the time of day when the user activates the system or a window into the future.

The grid end time is not a desired program end time. Neither the grid start time nor the grid end time [is] used to select a group of programs that start or end at a particular time. Instead, they are used to select a[] SPG that contains information for programs with many different start and end times.

SuperGuide argues this is tantamount to a service, i. Finally, SuperGuide claims that the use of adult programming blocks is tantamount to a selected program type, i. However, the adult programming is always stored within the system; it is the actual display of the program itself, not its storage, which is blocked. Thus, storage of the programming is not dependent on selection and this argument, as well, fails.

It is clear that the accused products do not use any structure which is identical to that used in Hallenbeck ' It is also clear that the accused products do not function in a manner which is substantially similar.

The Court, therefore, finds that the DirecTV Defendants' accused products do not infringe the Hallenbeck ' patent either literally or by the doctrine of equivalents. The most concise description of the EchoStar system was provided in an opinion letter to EchoStar's in-house counsel by an outside attorney. Gemstar attached it as an exhibit to its motion for summary judgment and EchoStar did not object. Because Gemstar placed the letter in the record in support of its position, the undersigned will quote the description of the EchoStar system, a description identical to but more concise than that of EchoStar's experts.

Miller Waste Mills, Inc. However, the undersigned has not considered or relied on any portion of the opinion concerning non-infringement contained in the letter in ruling on the parties' summary judgment motions. Miller, dated April 2, , attached to Declaration of David A. Patents 5,, and 5,, and for Permanent Injunction, filed November 8, , at footnote added.

In order to be placed within this six hour window, the "start time of the program plus the end time of the program must be greater than the block start time value, and the program start time must be less than the block end time value. Unless both conditions are met, the program data will not be stored. The selection process occurs by use of an algorithm which does not evaluate the start or end times of individual programs.

In addition, program data stored in the grid event pool "is used to enable 2 modes of EchoStar electronic program guide operation—the Grid guide mode and the Themes mode. The "Themes" mode is actually a type of program such as, movies, news, sports, etc. Cavanaugh Supplemental Declaration, at 2.

Themes value is used only to filter program guide data that has already been stored; and even after filtering, unlike the Hallenbeck ' invention, the data is not overwritten. As previously noted, each EIT carries programming information for one television service. The Defendants have moved for summary judgment of non-infringement of the accused EchoStar devices. Gemstar has cross-moved for summary judgment against EchoStar. The standard of review for summary judgment motions has been previously discussed.

Both motions involve the same issue: whether the block start time selection criteria used in the EchoStar IRD is the equivalent of the program start time and program end time selection criteria of Hallenbeck ' EchoStar argues there is neither literal nor equivalent infringement; Gemstar argues there is both. At the claim construction stage of this litigation, Gemstar did not argue that "a desired start time" and "a desired end time" constituted a block or range of time.

As demonstrated by virtually all program guides, whether paper or electronic, programs generally start and end on the hour or half hour None of the above appears to be in dispute.

Indeed, the EchoStar Defendants joined in that construction. Defendants' Joint Claim Construction Brief Regarding the Hallenbeck ' Patent, filed March 12, , at 10 "Because these criteria on their face refer specifically to two different aspects of a given television program i. Now, however, Gemstar argues that "the ' patent specifically contemplates storage of a window or block of program schedule information based on a program start time Gemstar's position is precluded by the doctrine of judicial estoppel which "is designed to prevent litigants from playing fast and loose with the courts.

Groupe Procycle, Inc. Maine, U. Wakelee, U. American Airlines, Inc. Based on this doctrine, then, Gemstar's motion must be denied. However, the Court will address infra its other contentions. Considering first EchoStar's motion, there is no literal infringement because all of the limitations specified in the Hallenbeck ' claim are not found in the accused devices exactly; i. Enercon GmbH v. The issue is whether a time block, range or window is the equivalent of a specific start or end time.

The undersigned finds that, as used in the accused device, it is not. Unique Coupons, Inc. Northfield Corp. First, Hallenbeck ' operates on a user selected start and end time; EchoStar's IRD's automatically turn on at the current time and provide a six hour window.

Telemac Cellular Corp. Topp Telecom, Inc. Regardless of any user input, and indeed without any capability therefore, the system automatically turns on at the current time. The manual entry of selections is not the equivalent of electronic transmission of data. There is no comparison, as in Hallenbeck ', to ascertain if a particular program falls within the appropriate start and end time.

Second, EchoStar's IRD's store all of the programming data for the programs which are in the six hour window, regardless of whether they may ultimately match other criteria selected by the user. Hallenbeck performs a check for all four criteria before any data is stored. Altech Controls Corp. Eil Instrument, Inc. Moreover, if programming data for a program which does not fit into the six hour window is discarded, EchoStar's IRD's have the capability of reacquiring that data from the datastream because the EchoStar system provides a continuous stream of data.

And, assuming arguendo that the EchoStar system uses as preselection criteria program start time and service, there is no use of program end time or program type as preselection criteria. Maltezos v. The program must be placed within the six hour window before other selection criteria are applied. In Hallenbeck ', the program is not placed in storage unless it has already met the criteria of start time, end time, service and type.

Finally, Gemstar maintains that EchoStar IRD's use the equivalent of program type as a selection criterion by virtue of its adult programming "supervisory features. Cavanaugh Supplemental Declaration, at 4. Thus, Gemstar's argument is without merit. Although the user may choose to prevent viewing of such programs, the IRD downloads and stores program guide information about them. It is the user's subsequent choice to view the program. There is no pre-selection criteria which discards the program information prior to storage in the system's memory.

Thus, the Adult Guard actually blocks the receipt of services, not types of programming. Gemstar, however, maintains that the blocking of "adult" channels offering pornographic or sexually explicit programming is tantamount to selecting a program based on its "type. EchoStar's IRD allows the blanket blocking of a series of channels, i. Blocking the reception of certain channels is not the same as a pro-active choice each time the system is automated.

In conclusion, the way the Defendants' accused IRD's perform the function of providing television programming information is so substantially different from the Hallenbeck ' that no reasonable jury could find infringement.

Defendants have moved for summary judgment of non-infringement as to the Hallenbeck ' invention. Gemstar opposes summary judgment only as to the EchoStar Defendants while SuperGuide opposes summary judgment as to all Defendants. In addition, Gemstar has cross-moved for summary judgment against the EchoStar Defendants seeking a declaration of infringement.

The Hallenbeck ' patent discloses a method of controlling a recording device for the unattended recording of a television program to air in the future. Only Claim 1 of the patent is in dispute and the Court has construed it as follows:. Thus, the Hallenbeck ' was designed to activate a recording device by event timer information instead of by information contained in the program guide.

From the plethora of information in the program guide, Hallenbeck ' used only program start time, stop time and channel information thus reducing the amount of data necessary for storage in nonvolatile memory. Amended Declaration of Steven P. If the recording device is external to the IRD, it sends an infrared signal which initiates a "record" or "stop" function.

This signal mimics the signal that would be sent from a remote control to a VCR; however, the signal does not contain any program data for the program slated for recording. In those IRD's which have internal recording mechanisms, the event timer sends an activation signal which causes the IRD's hard drive or tape mechanism to record a program.

Again, the activation signal does not contain the program data for the program slated for recording. The user must individually enter data for the time the recording is to begin, the time it is to stop and the service number for the event to be recorded. Manual creation also does not use any program data stored in memory.

VCR type event timers can be created by the user's designation from the electronic program guide display of a future event to be recorded. In this use, the event timer software extracts the program data for the event to be recorded from IRD memory and uses that information "to populate an event timer data structure. This data includes the start time, duration and service identification for the program.

In this process, the data which is loaded into the event timer is in the same form as when it was initially stored in IRD memory. Defendants' first argument in support of summary judgment is that their accused products do not convert the programming data into event timer sequences which are used to actually control the recording function as is done in the Hallenbeck ' invention.

In EchoStar's IRD's, either an infrared signal controls the recording, as was well known in prior art, or an "activation" signal which does not contain the programming data is used to turn on and off the recording function. As noted by Hallenbeck,. Hallenbeck ', Col. In EchoStar's IRD's, the data for events to be recorded is placed in event timer structures located in volatile memory, a process acknowledged by Hallenbeck to have been "well known to those having skill in the VCR art.

When an accused device reads on the prior art, as here, this "in and of itself mandates a finding of non-infringement. Shoketsu Kinzoku Kogyo Kabushiki Co. Gemstar argues that the removal of this offset is the equivalent of a conversion into event timer sequences. Assuming arguendo that Gemstar's argument is correct, EchoStar's IRD's turn on and off the recording function by an infrared or activation signal, not the programming data contained within the event timer data structure.

Baker, Inc. Harwood, U. Moreover, the service ID, and other data contained within the event timer data structure, is not reformatted. Thus, there is no infringement. The Hallenbeck invention proclaimed its uniqueness over prior art by the use of limited programming data stored in non-volatile memory to control the recording device instead of an infrared signal. This limited the data which needed to be stored in non-volatile memory and allowed the invention to become commercially viable.

While a back-up copy of event timer data is stored in a non-volatile memory "NVM" , that copy is not used to trigger the transmission of record or stop commands to external or internal recording mechanisms. Hallenbeck distinguished his invention by the use of less data to control recording stored in non-volatile memory. EchoStar's devices both store and operate in the volatile realm. Gemstar argues that it "is much easier to access and use information stored in volatile memory as compared to information stored in non-volatile memory.

In fact, it is almost always the case that information stored in non-volatile memory will be copied into volatile memory for use as opposed to storage. EchoStar openly acknowledges that the programming data is stored "for use" in volatile memory. It is the Hallenbeck invention which is described as unique by virtue of the "use" of non-volatile memory to control the recording device. Thus, according to Gemstar's expert, Hallenbeck performed the function in the more difficult manner.

Moreover, in the EchoStar devices, the programming information is not used to actually initiate the recording process but merely identifies the program so that when the program actually airs, the IRD will use that information to obtain the transponder frequency and SCID code in order to extract the program from the downlink signal. EchoStar's IRD's also have the capability of refreshing or updating programming data.

In contrast, Hallenbeck noted,. A second port 74 of the circulator 72 is coupled to a first input of a mixer A second input of the mixer 76 receives a baseband signal via a driver circuit 80 and a multiplexer Both the multiplexer 82 and the driver circuit 80 are selected to have a sufficient rise time to fulfill the speed requirements of the converter.

The mixer 76 mixes the sinusoidal signal and the baseband signal to from a biphase modulated signal. The biphase modulated signal is applied to a variable attenuator 84 which attenuates the biphase modulated signal by a preselected attenuation in accordance with equation 7. The preselected attenuation is dictated by a control voltage received from a DC and bias circuit In the illustrated embodiment, the DC and bias circuit 86 receives the control voltage from an external source not specifically illustrated.

The DC and bias circuit 86 uses the supply voltages to power the multiplexer 82 and the driver circuit The above-described biphase modulator and attenuator circuit produces an attenuated, biphase modulated signal at the output of the variable attenuator The attenuated signal may then be combined with other attenuated, biphase modulated signals to form a converted RF signal.

The above-described circuit may be physically embodied on a 2 inch by 2 inch surface for radio frequencies in the neighborhood of 6 GHz. Referring to FIGS. A radio frequency carrier signal is applied to a first microstrip A baseband data signal is filtered by a low-pass filter 92 before being applied to the first microstrip The length of the first microstrip 90 terminates in proximity to a first end of an oval-shaped slot 94 of a slotline As illustrated in FIG.

On an opposing surface of the substrate are slots in a ground plane which form the slotline Referring back to FIG.

The baseband data signal is directly coupled to the interior portion from the microstrip 90 by a via hole Two Schottky diodes and connect the interior portion to the exterior portion In particular, the Schottky diode has its anode connected to the interior portion and its cathode connected to the exterior portion , and the Schottky diode has its anode connect to the exterior portion and its anode connected to the interior portion Hence, the applied baseband signal forward-biases one of the diodes and reverse-biases the other.

The effect of this biasing is to connect only one side of the slotline 96 to the output at any instant of time. The slotline 96 has a rectangular slot connected to a second end of the oval-shape slot A second microstrip is located proximate to the rectangular slot of the slotline The second microstrip includes a first rectangular portion transverse to the rectangular slot of the slotline The second microstrip further includes a second rectangular portion connected to the first rectangular portion to form an L-shape.

The above-described slotline embodiment of a biphase modulator produces a biphase modulated signal along the second rectangular portion of the second microstrip One embodiment of this slotline design has been realized for operation at K-band, and has been tested to 3. The multiplexer was not employed at Mbps but is required at higher data rates. With this predistortion the transmitted signal becomes: EQU6 The predistorted, transmitted signal x t can be expressed as:. This approach may be extended to more complex nonlinear channels.

The above-described embodiments of the present invention have many advantages. By following a bank of biphase modulators with a plurality of attenuators configured as a ladder network configuration in powers of two, an architecture is realized for performing a digital-to-analog conversion at the RF level.

As a result, embodiments of the present invention overcome the speed limitation imposed by digital-to-analog conversion in prior digital-to-RF converters. Since the converter consists primarily of a bank of identical biphase circuits, the architecture is easily amenable to a monolithic microwave integrated circuit MMIC implementation.

Further, the disclosed architecture of a digital-to-RF vector modulator is versatile and permits extension of high-order modulation formats to high speed applications. Embodiments of the present invention have application to any area requiring high frequency modulation of digital data. This includes any receiver, transmitter, and bandwidth efficient circuitry in both military and commercial applications. While the best mode for implementing the invention has been described in detail, those familiar with the art to which this invention relates will recognize various alternative designs and embodiments for practicing the invention as defined by the following claims.

What is claimed is: 1. A system for predistorting a digital signal and converting the digital signal to a radio frequency signal, the digital signal representative of a time-dependent data word having a plurality of bits, the system comprising: a plurality of biphase modulators, each of the biphase modulators modulating a sinusoidal radio frequency signal with a corresponding one of the bits to form a biphase modulated signal based upon the corresponding one of the bits, whereby the biphase modulators form a plurality of biphase modulated signals; and.

The system of claim 1 wherein the attenuators are connected in a ladder network configuration. The system of claim 1 wherein each of the attenuators includes a corresponding field-effect transistor attenuator.

The system of claim 1 wherein the attenuators differ in attenuation by powers of two.