`FOR THE WESTERN DISTRICT OF TEXAS
`WACO DIVISION
`
`PARKERVISION, INC.,
`
` v.
`
`INTEL CORPORATION,
`
` Plaintiff,
`
`Case No. 6:20-cv-00108
`
`JURY TRIAL DEMANDED
`
` Defendant.
`
`PARKERVISION, INC.’S IDENTIFICATION OF PROPOSED CLAIM TERMS FOR
`CONSTRUCTION
`
`Pursuant to this Court’s Scheduling Order (Dkt. No. 34), Plaintiff ParkerVision, Inc.
`
`(“ParkerVision”) hereby identifies its proposed claim terms for construction. This identification
`
`addresses the asserted claims of U.S. Patent Nos. 6,266,518 (the “’518 patent”); 6,580,902 (the
`
`“’902 patent”); 7,110,444 (the “’444 patent”); 7,539,474 (the “’474 patent”); 8,588,725 (the
`
`“’725 patent”); 8,660,513 (the “’513 patent”); 9,118,528 (the “’528 patent”); 9,246,736 (the
`
`“’736 patent”); and 9,444,673 (the “’673 patent”) (collectively, the “patents-in-suit”) as set forth
`
`in ParkerVision’s Preliminary Infringement Contentions and identified below:
`
`(cid:120) Claims 50 and 67 of the ’518 patent.
`
`(cid:120) Claims 1, 2, 4, and 5 of the ’902 patent.
`
`(cid:120) Claims 2-4 of the ’444 patent.
`
`(cid:120) Claims 1, 6, 10, and 11 of the ’474 patent.
`
`(cid:120) Claims 1, 6, 7, 13, 14, and 16-19 of the ’725 patent.
`
`(cid:120) Claims 19, 24, 27, and 28 of the ’513 patent.
`
`Intel v. ParkerVision
`IPR2020-01265
`Intel 1034
`
`
`
`
`
`(cid:120) Claims 1, 5, 9, 14, 15, and 17 of the ’528 patent.
`
`(cid:120) Claims 1, 11, 15, 19, 21, 26, and 27 of the ’736 patent.
`
`This identification does not address any claims other than those identified above. To the
`
`extent ParkerVision later amends its infringement contentions to add any claims, ParkerVision
`
`reserves the right to serve a supplemental identification of claim terms for construction to
`
`address any such additional claims. Further, ParkerVision makes these disclosures based on
`
`information currently available to ParkerVision including, but not limited to, its current and
`
`preliminary understanding of the patents-in-suit, and Defendants’ Preliminary Invalidity
`
`Contentions. ParkerVision has not completed its investigation of the facts relating to this case.
`
`Accordingly, ParkerVision reserves the right to supplement its list of proposed terms for
`
`construction, including in response to Defendants’ identification of proposed claim terms for
`
`construction. Subject to the forgoing, ParkerVision identifies the following claim terms for
`
`construction:
`
`Claim Term No.
`1
`
`Claim Term
`“frequency down-conversion module”
`
`Patent(s); Claim Nos.
`’444 patent; claims 2 and 3
`
`2
`
`3
`
`4
`
`5
`
`6
`
`7
`
`8
`
`
`
`
`
`“subtractor module”
`
`“combining module”
`
`’474 patent; claim 1
`
`’444 patent; claims 2 and 3
`
`’474 patent; claims 1, 10
`
`“energy storage element”
`
`’528 patent; claim 1
`
`“integrated”
`
`’528 patent; claims 1, 17
`
`“modulated carrier signal”
`
`’528 patent; claims 1, 5, 14
`
`“sampling aperture”
`
`’528 patent; claim 1
`
`“switch”
`
`’528 patent; claim 1, 5, 17
`
`2
`
`
`
`
`
`Dated: September 25, 2020
`
`
`OF COUNSEL:
`
`Ronald M. Daignault
`Chandran Iyer
`Jason Charkow
`Stephanie Mandir
`GOLDBERG SEGALLA
`rdaignault@goldbergsegalla.com
`ciyer@goldbergsegalla.com
`jcharkow@goldbergsegalla.com
`smandir@goldbergsegalla.com
`711 Third Avenue, Suite 1900
`New York, New York 10017
`Telephone: (646) 292-8700
`
`
`
`
`THE MORT LAW FIRM, PLLC
`
`/s/ Raymond W. Mort, III
`Raymond W. Mort, III
`Texas State Bar No. 00791308
`raymort@austinlaw.com
`100 Congress Avenue, Suite 2000
`Austin, Texas 78701
`Tel/Fax: 512-865-7950
`
`
`Attorneys for Plaintiff ParkerVision, Inc.
`
`
`
`
`3
`
`
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