`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`Intel Corporation
`Petitioner
`v.
`ParkerVision, Inc.
`Patent Owner
`
`Case IPR2020-01265
`U.S. Patent No. 7,110,444
`
`PETITIONER’S SUPPLEMENTAL NOTICE
`REGARDING CLAIM CONSTRUCTION
`
`
`
`Case IPR2020-01265
`U.S. Patent No. 7,110,444
`Intel Corporation (“Petitioner”) submits this supplemental notice regarding
`
`the District Court’s October 22, 2021 Amended Claim Construction Order in a
`
`related district court litigation, ParkerVision, Inc. v. Intel Corp., No. 6:20-cv-562-
`
`ADA (W.D. Tex.).1
`
`By way of background, Petitioner challenges claims 1, 3, and 5 of U.S.
`
`Patent No. 7,110,444 (“the ʼ444 patent”) in this instituted IPR.2 Of those claims,
`
`ParkerVision, Inc. (“Patent Owner”) asserts claim 3 in a related litigation
`
`ParkerVision, Inc. v. Intel Corp., No. 6:20-cv-108-ADA (W.D. Tex.) (“First
`
`Related Litigation”).3
`
`On January 28, 2021, in the First Related Litigation, the Court construed
`
`“storage element” in asserted claim 3 of the ’444 patent as follows:
`
`ʼ444 Patent
`Claim Term
`“storage element” (claim 3)
`
`District Court’s Construction
`
`“an element of an energy transfer
`system that stores non-negligible
`amounts of energy from an input
`electromagnetic signal”
`
`ParkerVision v. Intel Corp., No. 6:20-cv-108-ADA (W.D. Tex.), D.I. 75 (Jan. 28,
`
`2021) at 5; see also Paper No. 12 (providing Notice of this Claim Construction
`
`Order to the Board in this IPR2020-01265).
`
`1 The district court did not issue a written claim construction opinion.
`2 Patent Owner has stated that it intends to disclaim claims 1 and 5 of the ’444
`patent. (POR at 1 n.1.)
`3 Patent Owner also asserts claims 2 and 4 in the First Related litigation.
`
`1
`
`
`
`Case IPR2020-01265
`U.S. Patent No. 7,110,444
`On July 22, 2021, in another separate, but related, litigation ParkerVision,
`
`Inc. v. Intel Corp., No. 6:20-cv-562-ADA (W.D. Tex.) (“Second Related
`
`Litigation”), the Court construed a similar term—“storage module”—in the
`
`asserted claims of U.S. Patent No. 6,049,706 (“the ’706 patent”) to include “for
`
`driving a low impedance load”:
`
`ʼ706 Patent
`Claim Term
`“storage module” (claims 105, 114,
`164, 175, 179, 186, 190)
`
`District Court’s Construction
`
`“a module of an energy transfer system
`that stores non-negligible amounts of
`energy from an input electromagnetic
`signal for driving a low impedance
`load”
`
`ParkerVision, Inc. v. Intel Corp., No. 6:20-cv-562-ADA (W.D. Tex.), D.I. 61 (July
`
`22, 2021) at 2; see also Paper 21 at 16, n.4 (providing Notice of this Claim
`
`Construction Order to the Board in this IPR2020-01265); Ex. 1038 (same).
`
`Recently, on October 22, 2021, in the Second Related Litigation, the Court
`
`amended sua sponte its construction of “storage module” in the asserted claims of
`
`the ’706 patent to delete the reference to “driving a low impedance load,” as noted
`
`below:
`
`ʼ706 Patent
`Claim Term
`“storage module” (claims 105, 114,
`164, 175, 179, 186, 190))
`
`District Court’s Amended
`Construction
`“a module of an energy transfer system
`that stores non-negligible amounts of
`energy from an input electromagnetic
`signal for driving a low impedance
`load”
`
`2
`
`
`
`Case IPR2020-01265
`U.S. Patent No. 7,110,444
`ParkerVision, Inc. v. Intel Corp., No. 6:20-cv-562-ADA (W.D. Tex.), D.I. 66 (Oct.
`
`22, 2021) at 2. Now, the constructions of “storage element” and “storage module”
`
`in the First and Second Related Litigations are substantively identical.
`
`Respectfully submitted,
`
`/Grant K. Rowan/
`Grant K. Rowan,
`Reg. No. 41,278
`
`3
`
`
`
`CERTIFICATE OF SERVICE
`I hereby certify that on October 26, 2021, I caused a true and correct copy of
`
`Case IPR2020-01265
`U.S. Patent No. 7,110,444
`
`the foregoing materials:
`
`•
`
`Petitioner’s Supplemental Notice Regarding Claim Construction to be
`
`served via electronic mail on the following counsel of record for Patent Owner:
`
`jcharkow@daignaultiyer.com
`cbiyer@daignaultiyer.com
`smandir@daignaultiyer.com
`rjuang@daignaultiyer.com
`ksprenger@daignaultiyer.com
`
`Respectfully Submitted
`/Brian J. Lambson/
`Brian J. Lambson
`Registration No. 72,570
`
`i
`
`
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