`MBernstein@perkinscoie.com
`D. +1.858.720.5721
`F. +1.858.720.5821
`
`March 14, 2024
`
`VIA E-MAIL
`Jason Charkow
`Daignualt Iyer LLP
`8618 Westwood Center Drive
`Suite 150
`Vienna, VA 22182
`
`VIA U.S.P.S. MAIL
`Workman Nydegger
`1000 Eagle Gate Tower
`60 East South Temple
`Salt Lake City, UT 84111
`
`Re:
`
`ParkerVision, Inc. v. MediaTek Inc., Case No. 6:22-cv-01163 (W.D. Tex.)
`MediaTek Inc. v. ParkerVision, Inc., IPR2024-00150
`
`Counsel:
`
`In connection with IPR2024-00150, Petitioners MediaTek Inc. and MediaTek USA Inc.
`(collectively, “MediaTek”) hereby stipulate and agree that, if the PTAB institutes an inter partes
`review proceeding (“IPR”) for U.S. Patent No. 7,292,835 on the grounds presented in MediaTek’s
`petition, MediaTek will not pursue an invalidity defense in ParkerVision, Inc. v. MediaTek Inc.,
`Case No. 6:22-cv-01163 (W.D. Tex.) that the patent claims subject to the instituted IPR are invalid
`based on the same grounds as in the petition or any grounds that could have reasonably been raised
`in the petition. This stipulation and agreement is not intended and should not be construed to limit
`MediaTek’s ability to assert invalidity of any claims of the ’835 patent on any other ground.
`
`Very truly yours,
`
`Matthew C. Bernstein
`
`cc:
`
`Ronald Daignault, rdaignault@daignaultiyer.com
`Ramachandran Iyer, cbiyer@daignaultiyer.com
`Scott Samay, ssamay@daignaultiyer.com
`Stephanie Rose Mandir, smandir@daignaultiyer.com
`Zachary Ellis, zellis@daignaultiyer.com
`Ray Mort, raymort@austinlaw.com
`
`MEDIATEK EX. 1025
`
`
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