`FOR THE EASTERN DISTRICT OF TEXAS
`MARSHALL DIVISION
`
`TQ DELTA, LLC,
` Plaintiff,
`
`v.
`
`COMMSCOPE HOLDING COMPANY,
`INC., COMMSCOPE INC., ARRIS
`INTERNATIONAL LIMITED, ARRIS
`GLOBAL LTD., ARRIS US HOLDINGS,
`INC., ARRIS SOLUTIONS, INC., ARRIS
`TECHNOLOGY, INC., and ARRIS
`ENTERPRISES, LLC,
`
`NOKIA CORP., NOKIA SOLUTIONS
`AND NETWORKS OY, and NOKIA OF
`AMERICA CORP.
`
` Defendants.
`
`
`
`§
`§
`§
`§
`§
`§
`§
`§
`§
`§
`§
`§
`§
`§
`§
`§
`§
`§
`
`
`
`JURY TRIAL DEMANDED
`
`Civil Action 2:21-cv-310-JRG
`(Lead Case)
`
`Civil Action No. 2:21-cv-309-JRG
`(Member Case)
`
`PLAINTIFF’S DISCLOSURE OF ASSERTED CLAIMS AND INFRINGEMENT
`CONTENTIONS AND ACCOMPANYING DOCUMENT PRODUCTION
`
`Under Local Patent Rule 3-1 and 3-2, TQ Delta, LLC (“TQ Delta”) makes the following
`
`Disclosure of Asserted Claims and Infringement Contentions and Accompanying Document
`
`Production as to Defendants CommScope Holding Company, Inc., CommScope Inc., ARRIS US
`
`Holdings, Inc., ARRIS Solutions, Inc., ARRIS Technology, Inc., and ARRIS Enterprises, LLC
`
`(the “CommScope Defendants”) and Nokia of America Corp., Nokia Corp. and Nokia Solutions
`
`and Networks Oy’s (“Nokia Defendants”). TQ Delta, LLC does not waive any claim, contention,
`
`or argument regarding the factual and/or legal details of the following preliminary infringement
`
`contentions. Moreover, the following should not be construed as TQ Delta, LLC’s preliminary
`
`construction of any asserted claim or claim term.
`
`TQ Delta, LLC reserves the right to modify, amend, supplement, or otherwise alter these
`
`Page 1 of 11
`
`IPR2022-00833
`CommScope, Inc. Exhibit 1031
`Page 1 of 11
`
`
`
`contentions based on receipt of further information that will be furnished by, produced by, or
`
`otherwise made available by Defendant through discovery that is not available at the time of these
`
`disclosures. For example, but without limitation, because Defendants’ accused products and
`
`services use software and/or firmware to perform certain operations, details regarding the
`
`operation of the Accused Products are presently unavailable to TQ Delta. Accordingly, TQ Delta
`
`reserves the right to amend its contentions pursuant to the Court’s Discovery Order, should
`
`supplementation become necessary as a result. Moreover, TQ Delta reserves the right to contend
`
`that the claims do not require further construction, clarification, or interpretation.
`
`The claim charts submitted herewith in the attached Exhibits are not designed to represent
`
`the entire scope of infringement, but are merely to illustrate examples of manners in which the
`
`Accused Products infringe the identified claims of TQ Delta’s Patents. Further, the division of
`
`claim elements in the attached claim charts is neither intended to be a modification of the claim
`
`language itself nor an admission that the claims should be construed by the division. Rather, the
`
`division of claim elements is provided for purposes of convenience and clarity.
`
`Disclosure of Asserted Claims and Infringement Contentions
`
`I. Disclosure Under P.R. 3-1(a)
`
`TQ Delta asserts that the CommScope Defendants infringe at least claims 17, 18, 21, 23,
`
`25, 26, 29, 31, 33, 34, 37, and 38 of 7,453,881 (“the ’881 Patent”); at least claims 17, 18, 19, 36,
`
`37, 38, and 40 of 7,570,686 (“the ’686 Patent”); at least claims 9, 13, 14, and 15 of 7,844,882
`
`(“the ’882 Patent”); at least claim 14 8,090,008 (“the ’008 Patent”); at least claims 1, 5, 6, and 7
`
`of 8,276,048 (“the ’048 Patent”); at least claims 8, 10, 24, and 26 of 8,462,835 (“the ’835
`
`Patent”); at least claims 10, 11, 17, 17, 18, and 25 of 8,468,411 (“the ’411 Patent”); at least claims
`
`16 and 22 of 8,937,988 (“the ’988 Patent”); at least claims 1, 2, 3, 4, 9, 10, 11, and 12 of 9,094,348
`
`(“the ’348 Patent”); at least claims 10 and 11 9,154,354 (“the ’354 Patent”); at least claims 11,
`
`Page 2 of 11
`
`IPR2022-00833
`CommScope, Inc. Exhibit 1031
`Page 2 of 11
`
`
`
`17, and 19 of 9,485,055 (“the ’055 Patent”); at least claims 8, 10, 11, 12, and 14 of 10,567,112
`
`(“the ’112 Patent”); and at least claims 1, 2, 3, 4, 6, 8, 9, 10, 11, 13, 22, 23, 24, 25, and 27 of
`
`10,833,809 (“the ’809 Patent”) (collectively, “the Asserted CommScope Claims”). TQ Delta
`
`alleges that the CommScope Defendants infringe each of the Asserted Claims of the Patent-in-
`
`Suit directly, contributorily, and/or by inducement (including under 35 U.S.C. § 271(f)(1) and
`
`(f)(2)), as alleged in the Complaint.
`
`TQ Delta asserts that the Nokia Defendants infringe at least claims 17, 18, 19, 36, 37, 38,
`
`and 40 of 7,570,686 (“the ’686 Patent”); at least claims 9, 13, 14, and 15 of 7,844,882 (“the ’882
`
`Patent”); at least claim 14 of 8,090,008 (“the ’008 Patent”); at least claims 10, 11, 17, 17, 18, and
`
`25 of 8,468,411 (“the ’411 Patent”); at least claims 10, 28, and 36 of 8,495,473 (“the ’5473
`
`Patent”); at least claims 8, 9, and 11 of 8,594,162 (“the ’162 Patent”); at least claims 16, 17, 18,
`
`30, 31, 32, 37, 38, 39, 44, 53, 54, 55, and 60 of 8,595,577 (“the ’577 Patent”); at least claims 16
`
`and 22 of 8,937,988 (“the ’988 Patent”); at least claims 1, 9, 10, 12, and 13 of 9,014,193 (“the
`
`’193 Patent”); at least claims 1, 2, 3, 4, 9, 10, 11, and 12 of 9,094,348 (“the ’348 Patent”); at least
`
`claims 10, 11, and 12 of 9,154,354 (“the ’354 Patent”); at least claims 8, 9, 13, 14, 15, 16, 17, 18,
`
`and 21 of 9,300,601 (“the ’601 Patent”); at least claims 11, 17, and 19 of 9,485,055 (“the ’055
`
`Patent”); at least claims 2, 3, and 4 of 9,547,608 (“the ’608 Patent”); at least claims 1 and 3 of
`
`9,894,014 (“the ’014 Patent”); at least claims 1, 2, 3, 4, and 8 of 10,044,473 (“the ’4473 Patent”);
`
`at least claims 21, 22, and 23 of 10,409,510 (“the ’510 Patent”); at least claims 8, 10, 11, 12, and
`
`14 of 10,567,112 (“the ’112 Patent”); and at least claims 1, 2, 3, 4, 6, 8, 9, 10, 11, 13, 15, 16, 17,
`
`18, 20, 22, 23, 24, 25, 27 of 10,833,809 (“the ’809 Patent) (collectively, “the Asserted Nokia
`
`Claims”). TQ Delta alleges that the Nokia Defendants infringe each of the Asserted Claims of
`
`the Patent-in-Suit directly, contributorily, and/or by inducement (including under 35 U.S.C. §
`
`Page 3 of 11
`
`IPR2022-00833
`CommScope, Inc. Exhibit 1031
`Page 3 of 11
`
`
`
`271(f)(1) and (f)(2)), as alleged in the Complaint.
`
`II. Disclosure Under P.R. 3-1(b)
`
`TQ Delta alleges that CommScope’s DSL Products infringe the claims recited above and
`
`detailed in the attached charts based on:
`
`•
`
`•
`
`•
`
`•
`
`Utilizing the VDSL2 standards (e.g., ITU-T 993.2) in the manner described
`in the attached charts for the ’686, ’882, ’048, ’008, ’835, and ’354 Patents;
`
`Utilizing the G.Bond standards (e.g., ITU- 998.2) in the manner described
`in the attached charts for the ’881 Patent;
`
`Utilizing the G.INP standards (e.g., ITU-T 998.4) in the manner described
`in the attached charts for the ’411, ’809, and ’354 Patents; and
`
`Utilizing the G.fast standards (e.g., G.9701) in the manner described in the
`attached charts for the ’112, ’348, ’809, ’055, and ’988 Patents.1
`
`On information and belief, the functionality of each version of CommScope’s DSL
`
`Products since their launch has utilized the functionality in the attached claim charts.
`
`Identification of the above products is based on the reasonably available public information, and
`
`TQ Delta reserves the right to amend this list should additional products be identified during
`
`discovery.
`
`
`1 TQ Delta accuses all CommScope products that are capable of utilizing any of these standards,
`including but not limited to the following customer premises equipment products as well as those
`with testing reflected in the claim charts: 5168N vDSLGateway; 5168NV vDSLGateway; 5268AC
`vDSL Gateway (AT&T use); Arris 3360; BGW210-700 (for AT&T?); FST1000 G.fast Bridge
`Modem (SFP Module), phone; FST1002 G.fast Bridge Modem (SFP Module), coax; FST1203
`G.fast Bridge Modem (Wall / Desk Mount), phone, coax; FST1305 G.fast Bridge Modem (Wall /
`Desk Mount) VDSL2 35b, phone, coax; GA2305 | GA2305 xDSL Gateway; GA4305 | GA4305
`xDSL Voice Gateway; GVT V5471 vDSL IAD Gateway?; GZ5NVG3XXX; NG764x xDSL
`Gateway CPE; NM55 Bonded vDSL2 Business Modem (for AT&T); NVG34x Series xDSL
`Gateway; NVG3XX; NVG448X [May be the same sas NVG44x]; NVG44X | NVG44x xDSL
`Voice Gateway; NVG46X | NVG46x Ethernet Voice Gateways; NVG510; NVG589; NVG599
`Triple Play Residential Modem; Pace 4111N aDSL Gateway; Pace 5031NV vDSL Gateway; Pace
`GA2305 aDSL Gateway; Pace GA4305 aDSL Gateway; Pace GV2305 vDSL2 Gateway; Pace
`GV4305 vDSL2 Gateway; Pace GV5705 vDSL2 Gateway; Pace GV5707 vDSL2 Gateway.
`
`Page 4 of 11
`
`IPR2022-00833
`CommScope, Inc. Exhibit 1031
`Page 4 of 11
`
`
`
`TQ Delta alleges that Nokia’s DSL Products infringe the claims recited above and
`
`detailed in the attached charts based on:
`
`•
`
`•
`
`•
`
`•
`
`Utilizing the VDSL2 standards (e.g., ITU-T 993.2) in the manner described
`in the attached charts for the ’686, ’882, ’5473, ’608, ’510, ’008, ’162, and
`’354 Patents;
`
`Utilizing the bonding standards for VDSL2 and ADSL2 (ATM and PTM)
`in the manner described in the attached charts for the ’193, ’601, and ’014
`Patents;
`
`Utilizing the G.INP standards (e.g., ITU-T 998.4) in the manner described
`in the attached charts for the ’577, ’348, ’4473, ’809, and ’354 Patents; and
`
`Utilizing the G.fast standards (e.g., G.9701) in the manner described in the
`attached charts for the ’112, ’348, ’4473, ’809, ’577, ’055, and ’988
`Patents.2
`
`
`2 TQ Delta accuses all Nokia products that are capable of utilizing any of these standards, including
`but not limited to the following central office and customer premises equipment products as well
`as those with testing reflected in the claim charts: 5530 NA-C (Network Analyzer - Copper); 7300
`ASAM UD (ABLT-D); 7300 ASAM HD (ADLT-J); 7300 ASAM HD ADLT-K (Annex B); 7300
`ASAM UD (ABLT-B); 7300 ASAM UD ABLT-F (Annex B); 7302 ISAM (NDLT-G); 7302
`ISAM FTTN ETSI; 7310 LVG (Loop Voice Gateway); 7330 ISAM FTTN ETSI; 7330 ISAM
`FTTN Remote Aggregator; 7330 ISAM XD EBLT-C; 7330 ISAM XD EBLT-E; 7330 ISAM XD
`EBLT-Q; 7330 ISAM XD EVLT-K; 7330 ISAM XD EVLT-N; 7330 ISAM XD VSEM-D; 7352
`ISAM FTTB ONT (Optical Network Terminal); 7353 ISAM CX Compact FleXible Modular
`ONU; 7353 ISAM FTTB Modular ONU; 7354 ISAM FTTB Remote Unit (24 port eth VDSL2;
`7356 ISAM FTTB Remote Expansion Module (48p / 96p mini MSAN 2 LT slots); 7357 ISAM
`FTTB Sealed Expansion Module (48p sealed VDSL2 remote); 7360 ISAM FX; 7362 ISAM; 7363
`ISAM MX Remote; 7363 ISAM MX-6 (ETSI); 7367 ISAM SX/DX; 7367 ISAM SX/DX (Sealed
`or Dense Flexibility); 7368 ISAM CPE; 8950 DSL Assurance; Cellpipe 7130; ISAM 48 ports
`VDSL2 POTS Line Termination Board with System-level Vectoring (NDLT-G); ISAM 48 ports
`low power VDSL2 ISDN Line Termination Board (NVLT-Q); ISAM 48 ports low power VDSL2
`POT LT Board (NVLT-P); ISAM 48 ports low power VDSL2 POTS Line Termination Board with
`integrated splitter (NVLS-A); ISAM 48 ports low power VDSL2 POTS LT Board with MELT
`(NVLT-N); ISAM 48 ports VDSL2 ISDN Line Termination Board (NVLT-D); ISAM 48 ports
`VDSL2 ISDN Line Termination Board (NVLT-H); ISAM 48 ports VDSL2 Line Termination
`Board with MELT (NVLT-M); ISAM 48 ports VDSL2 POTS Line Termination Board (NVLT-
`C); ISAM 48 ports VDSL2 POTS Line Termination Board (NVLT-G); ISAM 48 ports VDSL2
`POTS Line Termination Board with Board-level Vectoring (NDLT-C); ISAM 48 ports VDSL2
`POTS Line Termination Board with MELT and Board-level Vectoring (NDLT-F); ISAM 48 ports
`VDSL2 POTS Line Termination Board with System-level Vectoring (NDLT-K); ISAM 72 ports
`VDSL2 POTS Line Termination Board (NVLT-R); ISAM 72 ports VDSL2 POTS Line
`Termination Board with MELT (NVLT-S); ISAM 7353 Linecard (16 x VDSL) (MVLT-E); ISAM
`
`Page 5 of 11
`
`IPR2022-00833
`CommScope, Inc. Exhibit 1031
`Page 5 of 11
`
`
`
`TQ Delta alleges that the CommScope Defendants infringe each of the Asserted Claims
`
`of the Patent-in-Suit directly, contributorily, and/or by inducement (including under 35 U.S.C. §
`
`271(f)(1) and (f)(2)), as alleged in the Complaint.
`
`On information and belief, the functionality of each version of Nokia’s DSL Products
`
`since their launch has utilized the functionality in the attached claim charts. Identification of the
`
`above products is based on the reasonably available public information, and TQ Delta reserves
`
`the right to amend this list should additional products be identified during discovery.
`
`III. Disclosure of Under P.R. 3-1(c)
`
`Charts identifying where each element of each asserted claim is found within the Accused
`
`Instrumentalities are in the attached Exhibits. TQ Delta expressly reserves the right to augment
`
`and supplement its infringement contentions based upon additional information obtained,
`
`including but not limited to source code, through formal discovery.
`
`IV. Disclosure Under P.R. 3-1(d)
`
`TQ Delta believes that each element of each asserted claim is literally present in the
`
`Accused Products. Nonetheless, TQ Delta contends that any claim element not literally present
`
`in the accused products or methods is found in those products or methods under the doctrine of
`
`equivalents because the differences between such claim element and corresponding accused
`
`
`7353 Linecard (32 x VDSL) (MVLT-D); ISAM 7363 32 Port Linecard (MELT); ISAM MX 32
`port POTS voice board with integrated VDSL2/ADSL2 splitter (RPOT-A); ISAM MX 32 port
`xDSL SLV LT (RDLT-A); ISAM MX 32 port xDSL SLV LT (RDLT-B); ISAM MX 32 port
`xDSL SLV LT Linecard (MELT) (RDLT-C); ISAM MX 32 port xDSL SLV LT Linecard with
`MELT and VDSL2 provile 35b support (RDLT-E); ISAM MX 32 port xDSL SLV LT Linecard
`with VDSL2 provile 35b support (RDLT-D); ISAM MX 32 port xDSL SLV LT with integrated
`POTS splitters (RDLS-A); Lightspan access node SX/DX; Litespan 2000; ADLUD4EP; Litespan
`2000; ADLUE4EP; MiniRAM; ADLT-E 3EC 15240; NDLT-J; NDLT-K; Stinger FS; STGR-
`LIM-AP-72.
`
`Page 6 of 11
`
`IPR2022-00833
`CommScope, Inc. Exhibit 1031
`Page 6 of 11
`
`
`
`element or step are insubstantial and/or the claim element and the accused element or step
`
`perform substantially the same function, in substantially the same way, to achieve substantially
`
`the same result. TQ Delta will supplement its infringement contentions should the Court’s claim
`
`construction rulings or discovery indicate that a doctrine of equivalents theory is appropriate.
`
`V. Disclosure Under P.R. 3-1(e)
`
`Each of the Asserted Claims of the ’686 Patent is entitled to a priority date of January 7,
`
`2000, or, in the alternative, August 10, 2000, or in the alternative, January 8, 2001.
`
` Each of the Asserted Claims of the ’881 Patent is entitled to a priority date of October
`
`5, 2001 or, in the alternative, October 4, 2002, or, in the alternative, October 8, 2008.
`
` Each of the Asserted Claims of the ’193 Patent is entitled to a priority date of October
`
`5, 2001 or, in the alternative, October 4, 2002, or, in the alternative, October 8, 2008.
`
` Each of the Asserted Claims of the ’601 Patent is entitled to a priority date of October
`
`5, 2001 or, in the alternative, October 4, 2002, or, in the alternative, October 8, 2008.
`
` Each of the Asserted Claims of the ’014 Patent is entitled to a priority date of October
`
`5, 2001 or, in the alternative, October 4, 2002, or, in the alternative, October 8, 2008.
`
` Each of the Asserted Claims of the ’882 Patent is entitled to a priority date of October
`
`12, 2004 or, in the alternative, October 11, 2005, in the alternative, April 16, 2010.
`
` Each of the Asserted Claims of the ’5473 Patent is entitled to a priority date of October
`
`12, 2004 or, in the alternative, October 11, 2005, in the alternative, April 16, 2010.
`
` Each of the Asserted Claims of the ’608 Patent is entitled to a priority date of October
`
`12, 2004 or, in the alternative, October 11, 2005, in the alternative, April 16, 2010.
`
` Each of the Asserted Claims of the ’510 Patent is entitled to a priority date of October
`
`12, 2004 or, in the alternative, October 11, 2005, in the alternative, April 16, 2010.
`
`Page 7 of 11
`
`IPR2022-00833
`CommScope, Inc. Exhibit 1031
`Page 7 of 11
`
`
`
` Each of the Asserted Claims of the ’048 Patent is entitled to a priority date of October
`
`12, 2004 or, in the alternative, October 11, 2005, or, in the alternative, April 16, 2010.
`
` Each of the Asserted Claims of the ’008 Patent is entitled to a priority date of November
`
`9, 1999 or, in the alternative, November 9, 2000, or, in the alternative, August 26, 2005, or, in
`
`the alternative, September 28, 2007, or, in the alternative, October 22, 2008.
`
` Each of the Asserted Claims of the ’835 Patent is entitled to a priority date of March 3,
`
`2004 or, in the alternative, March 24, 2004, or, in the alternative, March 3, 2005.
`
` Each of the Asserted Claims of the ’112 Patent is entitled to a priority date of March 3,
`
`2004 or, in the alternative, March 24, 2004, or, in the alternative, March 3, 2005, or in the
`
`alternative, April 28, 2010, or, in the alternative, June 11, 2013.
`
` Each of the Asserted Claims of the ’162 Patent is entitled to a priority date of March 3,
`
`2004 or, in the alternative, March 24, 2004, or, in the alternative, March 3, 2005, or in the
`
`alternative, April 28, 2010, or, in the alternative, June 11, 2013.
`
` Each of the Asserted Claims of the ’411 Patent is entitled to a priority date of April 12,
`
`2006 or, in the alternative, October 5, 2006, or, in the alternative, April 12, 2007, or in the
`
`alternative, April 15, 2010.
`
` Each of the Asserted Claims of the ’577 Patent is entitled to a priority date of April 12,
`
`2006 or, in the alternative, October 5, 2006, or, in the alternative, April 12, 2007, or in the
`
`alternative, April 15, 2010.
`
` Each of the Asserted Claims of the ’348 Patent is entitled to a priority date of April 12,
`
`2006 or, in the alternative, October 5, 2006, or, in the alternative, April 12, 2007, or in the
`
`alternative, April 15, 2010.
`
` Each of the Asserted Claims of the ’4473 Patent is entitled to a priority date of April 12,
`
`Page 8 of 11
`
`IPR2022-00833
`CommScope, Inc. Exhibit 1031
`Page 8 of 11
`
`
`
`2006 or, in the alternative, October 5, 2006, or, in the alternative, April 12, 2007, or in the
`
`alternative, April 15, 2010.
`
` Each of the Asserted Claims of the ’809 Patent is entitled to a priority date of April 12,
`
`2006 or, in the alternative, October 5, 2006, or, in the alternative, April 12, 2007, or in the
`
`alternative, April 15, 2010, in the alternative, November 8, 2013.
`
` Each of the Asserted Claims of the ’055 Patent is entitled to a priority date of April 12,
`
`2006 or, in the alternative, October 5, 2006, or, in the alternative, April 12, 2007, or in the
`
`alternative, May 10, 2010, in the alternative, February 13, 2013.
`
` Each of the Asserted Claims of the ’988 Patent is entitled to a priority date of April 18,
`
`2000 or, in the alternative, April 18, 2001, or, in the alternative, October 4, 2005, or in the
`
`alternative, January 10, 2008, in the alternative, January 26, 2010.
`
` Each of the Asserted Claims of the ’354 Patent is entitled to a priority date of April 18,
`
`2000 or, in the alternative, April 18, 2001, or, in the alternative, October 4, 2005, or in the
`
`alternative, January 10, 2008, in the alternative, January 26, 2010.
`
`TQ Delta reserves its rights to amend the priority date of the Patents based on discovery
`
`in this case, including any discovery from third parties.
`
`VI. Disclosure Under P.R. 3-1(f)
`
`TQ Delta does not identify any such products under Patent Local Rule 3-1(f).
`
`Document Production Accompanying Disclosure
`
`I. Disclosure Under P.R. 3-2(a)
`
`TQ Delta is not presently aware of any such discoverable documents in its possession,
`
`custody, or control.
`
`II. Disclosure Under P.R. 3-2(b)
`
`Page 9 of 11
`
`IPR2022-00833
`CommScope, Inc. Exhibit 1031
`Page 9 of 11
`
`
`
`TQ Delta is not presently aware of any such discoverable documents in its possession,
`
`custody, or control.
`
`III. Disclosure Under P.R. 3-2(c)
`
`TQ Delta produces a copy of the file histories of the Patents-in-Suit at TQD_TX-
`
`00000001-TQD_TX-00044308.
`
`
`
`Dated: November 4, 2021
`
`
`
`
`
`
`
` Respectfully submitted,
`
`By: /s/ Christian Hurt
`
`William E. Davis, III
`Texas State Bar No. 24047416
`bdavis@bdavisfirm.com
`
`Christian Hurt
`Texas State Bar No. 24059987
`churt@bdavisfirm.com
`
`Rudolph “Rudy” Fink IV
`Texas State Bar No. 24082997
`rfink@davisfirm.com
`
`THE DAVIS FIRM, PC
`213 N. Fredonia Street, Suite 230
`Longview, Texas 75601
`Telephone: (903) 230-9090
`Facsimile: (903) 230-9661
`
`Counsel for TQ Delta, LLC
`
`
`
`
`Page 10 of 11
`
`IPR2022-00833
`CommScope, Inc. Exhibit 1031
`Page 10 of 11
`
`
`
`CERTIFICATE OF SERVICE
`
`The undersigned certifies that a true and correct copy of the above and foregoing document is being
`served on this November 4, 2021, via e-mail on all counsel of record, each of whom is deemed to have
`consented to electronic service per Local Rule CV-5(a)(3).
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`/s/Christian J. Hurt
`Christian J. Hurt
`
`Page 11 of 11
`
`IPR2022-00833
`CommScope, Inc. Exhibit 1031
`Page 11 of 11
`
`
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