Case 6:22-cv-01163-ADA Document 1 Filed 11/10/22 Page 1 of 15
`
`UNITED STATES DISTRICT COURT
`WESTERN DISTRICT OF TEXAS
`WACO DIVISION
`
`PARKERVISION, INC.,
`
`v.
`
`MEDIATEK INC. and
`MEDIATEK USA INC.
`
`Plaintiff,
`
`Defendants.
`
`Case No. 6:22-cv-01163
`
`JURY TRIAL DEMANDED
`
`COMPLAINT FOR PATENT INFRINGEMENT
`
`Plaintiff ParkerVision, Inc. (“ParkerVision”), by and through its undersigned counsel,
`
`files this Complaint against Defendants MediaTek Inc. and MediaTek USA Inc. (collectively,
`
`“MediaTek” or “Defendants”) for patent infringement of United States Patent Nos. 6,049,706;
`
`6,266,518; 7,292,835; and 8,660,513 (the “patents-in-suit”) and alleges as follows:
`
`NATURE OF THE ACTION
`
`1.
`
`This is an action for patent infringement arising under the patent laws of the
`
`United States, 35 U.S.C. §§ 1 et seq.
`
`PARTIES
`
`2.
`
`Plaintiff ParkerVision is a Florida corporation with its principal place of business
`
`at 4446-1A Hendricks Avenue, Suite 354, Jacksonville, Florida 32207.
`
`3.
`
`On information and belief, MediaTek Inc. is a foreign corporation organized and
`
`existing under the laws of Taiwan with a principal place of business located at No. 1, Dusing
`
`Road 1, Hsinchu Science Park, Hsinchu City 30078, Taiwan.
`
`MEDIATEK EX. 1012
`
`

`

`Case 6:22-cv-01163-ADA Document 1 Filed 11/10/22 Page 2 of 15
`
`4.
`
`On information and belief, Defendant MediaTek USA Inc. is a corporation
`
`organized and existing under the laws of the state of Delaware with a place of business in the
`
`Western District of Texas, including at 5914 West Courtyard Drive, Suite 400, Austin, TX
`
`78730. https://corp.mediatek.com/about/office-locations/mediatek-usa-offices. On information
`
`and belief, MediaTek USA Inc. is a subsidiary of MediaTek Inc.
`
`5.
`
`MediaTek designs, develops, manufactures, and sells integrated circuits/wireless
`
`chips.
`
`
`
`https://cdn-www.mediatek.com/posts/2021-English-Annual-Report_Final.pdf at page 64.
`
`JURISDICTION AND VENUE
`
`6.
`
`This Court has jurisdiction over the subject matter of this action pursuant to 28
`
`U.S.C. §§ 1331 and 1338(a) because the action arises under the patent laws of the United States,
`
`35 U.S.C. §§ 1 et seq.
`
`7.
`
`MediaTek is subject to this Court’s personal jurisdiction in accordance with due
`
`process and/or the Texas Long-Arm Statute. See Tex. Civ. Prac. & Rem. Code §§ 17.041 et seq.
`
`
`
`2
`
`MEDIATEK EX. 1012
`
`

`

`Case 6:22-cv-01163-ADA Document 1 Filed 11/10/22 Page 3 of 15
`
`8.
`
`This Court has personal jurisdiction over MediaTek because MediaTek has
`
`sufficient minimum contacts with this forum as a result of business conducted within the State of
`
`Texas and this judicial district. In particular, this Court has personal jurisdiction over MediaTek
`
`because, inter alia, MediaTek, on information and belief, has substantial, continuous, and
`
`systematic business contacts in this judicial district, and derives substantial revenue from goods
`
`provided to individuals in this judicial district.
`
`9.
`
`MediaTek has purposefully availed itself of the privileges of conducting business
`
`within this judicial district, has established sufficient minimum contacts with this judicial district
`
`such that it should reasonably and fairly anticipate being hauled into court in this judicial district,
`
`has purposefully directed activities at residents of this judicial district, and at least a portion of
`
`the patent infringement claims alleged in this Complaint arise out of or are related to one or more
`
`of the foregoing activities.
`
`10.
`
`This Court has personal jurisdiction over MediaTek because MediaTek (directly
`
`and/or through its subsidiaries, affiliates, or intermediaries) has committed and continues to
`
`commit acts of infringement in this judicial district in violation of at least 35 U.S.C. § 271(a). In
`
`particular, on information and belief, MediaTek (or those acting on its behalf) uses, sells, offers
`
`for sale, imports, advertises, and/or otherwise promotes infringing products (receiver,
`
`transmitter, and/or transceiver integrated circuits (e.g., chips for use in wireless devices)) in the
`
`United States, the State of Texas, and this judicial district. The infringing products include,
`
`without limitation, the MediaTek MT7612UN (“MediaTek Chips”).
`
`11.
`
`On information and belief, MediaTek has a regular and established place of
`
`business within the Western District of Texas, including 5914 West Courtyard Drive, Suite 400,
`
`Austin, TX 78730. On information and belief, MediaTek has physical facilities and employees in
`
`
`
`3
`
`MEDIATEK EX. 1012
`
`

`

`Case 6:22-cv-01163-ADA Document 1 Filed 11/10/22 Page 4 of 15
`
`this judicial district. On information and belief, MediaTek maintains additional offices and
`
`employees in Texas including at 825 Watters Creek Blvd, Suite 265, Allen, TX 75103.
`
`12.
`
`This case is related to at least the following cases before this Court and involves
`
`common patents and products: ParkerVision, Inc. v. Hisense Co., Ltd. et al., 6-20-CV-00870
`
`(W.D. Tex.) and ParkerVision, Inc. v. LG Electronics, Inc., 6:21-CV-00520 (W.D. Tex.).
`
`13.
`
`Venue is proper in this judicial district under 28 U.S.C. §§ 1391(b)-(d) and/or
`
`1400(b) at least because MediaTek Inc. is a foreign corporation subject to personal jurisdiction in
`
`this judicial district and has committed acts of infringement within this judicial district giving
`
`rise to this action.
`
`PARKERVISION
`
`14.
`
`In 1989, Jeff Parker and David Sorrells started ParkerVision in Jacksonville,
`
`Florida. Through the mid-1990s, ParkerVision focused on developing commercial video
`
`cameras, e.g., for television broadcasts. The cameras used radio frequency (RF) technology to
`
`automatically track the camera’s subject.
`
`15. When developing consumer video cameras, however, ParkerVision, encountered
`
`a problem – the power and battery requirements for RF communications made a cost effective,
`
`consumer-sized product impractical. So, Mr. Sorrels and ParkerVision’s engineering team began
`
`researching ways to solve this problem.
`
`16.
`
`At the time, a decade’s-old RF technology called super-heterodyne dominated the
`
`consumer products industry. But this technology was not without its own problems – the circuity
`
`was large and required significant power.
`
`
`
`4
`
`MEDIATEK EX. 1012
`
`

`

`Case 6:22-cv-01163-ADA Document 1 Filed 11/10/22 Page 5 of 15
`
`17.
`
`From 1995 through 1998, ParkerVision engineers developed an innovative
`
`method of RF direct conversion by a process of sampling a RF carrier signal and transferring
`
`energy to create a down-converted baseband signal.
`
`18.
`
`After creating prototype chips and conducting tests, ParkerVision soon realized
`
`that its technology led to improved RF receiver performance, lower power consumption, reduced
`
`size and integration benefits. In other words, RF receivers could be built smaller, cheaper and
`
`with greater improved performance.
`
`19.
`
`ParkerVision’s innovations did not stop there. ParkerVision went on to develop
`
`additional RF down-conversion technologies, RF up-conversion technologies and other related
`
`direct-conversion technologies. ParkerVision also developed complementary wireless
`
`communications technologies that involved interactions, processes, and controls between the
`
`baseband processor and the transceiver, which improved and enhanced the operation of
`
`transceivers that incorporate ParkerVision’s down-converter and up-converter technologies. To
`
`date, ParkerVision has been granted over 200 patents related to its innovations, including the
`
`patents-in-suit.
`
`20.
`
`ParkerVision’s technology helped make today’s wireless devices, such as
`
`televisions, a reality by enabling RF chips used in these devices to be smaller, cheaper, and more
`
`efficient, and with higher performance.
`
`THE ASSERTED PATENTS
`
`United States Patent No. 6,049,706
`
`21.
`
`On April 11, 2000, the United States Patent and Trademark Office duly and
`
`legally issued United States Patent No. 6,049,706 (“the ’706 patent”) entitled “Integrated
`
`Frequency Translation and Selectivity” to inventor Robert W. Cook et al.
`
`22.
`
`The ’706 patent is presumed valid under 35 U.S.C. § 282.
`
`
`
`5
`
`MEDIATEK EX. 1012
`
`

`

`Case 6:22-cv-01163-ADA Document 1 Filed 11/10/22 Page 6 of 15
`
`23.
`
`24.
`
`ParkerVision owns all rights, title, and interest in the ’706 patent.
`
`United States Patent No. 6,266,518
`
`On July 24, 2001, the United States Patent and Trademark Office duly and legally
`
`issued United States Patent No. 6,266,518 (“the ’518 patent”) entitled “Method and System for
`
`Down-Converting Electromagnetic Signals by Sampling and Integrating Over Apertures” to
`
`inventor David F. Sorrells et al.
`
`25.
`
`26.
`
`27.
`
`The ’518 patent is presumed valid under 35 U.S.C. § 282.
`
`ParkerVision owns all rights, title, and interest in the ’518 patent.
`
`United States Patent No. 7,292,835
`
`On November 6, 2007, the United States Patent and Trademark Office duly and
`
`legally issued United States Patent No. 7,292,835 (“the ’835 patent”) entitled “Wireless and
`
`Wired Cable Modem Applications of Universal Frequency Translation Technology” to inventor
`
`David F. Sorrells et al.
`
`28.
`
`29.
`
`30.
`
`The ’835 patent is presumed valid under 35 U.S.C. § 282.
`
`ParkerVision owns all rights, title, and interest in the ’835 patent.
`
`United States Patent No. 8,660,513
`
`On February 25, 2014, the United States Patent and Trademark Office duly and
`
`legally issued United States Patent No. 8,660,513 (“the ’513 patent”) entitled “Method and
`
`System for Down-Converting an Electromagnetic Signal, and Transforms for Same, and
`
`Aperture Relationships” to inventor David F. Sorrells et al.
`
`31.
`
`32.
`
`The ’513 patent is presumed valid under 35 U.S.C. § 282.
`
`ParkerVision owns all rights, title, and interest in the ’513 patent.
`
`
`
`6
`
`MEDIATEK EX. 1012
`
`

`

`Case 6:22-cv-01163-ADA Document 1 Filed 11/10/22 Page 7 of 15
`
`CLAIMS FOR RELIEF
`
`COUNT I - Infringement of United States Patent No. 6,049,706
`
`33.
`
`The allegations set forth above are re-alleged and incorporated by reference as if
`
`they were set forth fully here.
`
`34. MediaTek directly infringes (literally and/or under the doctrine of equivalents) the
`
`’706 patent by using, selling, offering for sale, and/or importing in/into the United States
`
`products covered by at least claim 19 of the ’706 patent. MediaTek infringes each step of claim
`
`19 because the MediaTek Chips automatically, and without user modification, performed each of
`
`the claimed steps.
`
`35.
`
`On information and belief, MediaTek products that infringe by at least claim 19 of
`
`the ’706 patent include, but are not limited to, the MediaTek Chips and any other MediaTek
`
`device that is capable of filtering and down-converting an input signal as claimed in the ’706
`
`patent. On information and belief, MediaTek uses the MediaTek Chips at least by testing the
`
`MediaTek Chips in the United States.
`
`36.
`
`On information and belief, each MediaTek Chip performs a method of filtering
`
`and down-converting an input signal (e.g., a radio frequency (RF) signal at a transmission
`
`frequency). The method is performed on the receiver side of each MediaTek Chip.
`
`37.
`
`On information and belief, each MediaTek Chip filters and down-converts an
`
`input signal in an integrated manner using a switch (e.g., one or more transistors), capacitor(s),
`
`and low impedance load (e.g., one or more resistors). On information and belief, a down-
`
`converted signal (e.g., a baseband signal) is formed from energy from a transistor(s) when the
`
`transistor(s) is ON and energy from a capacitor(s) when the transistor(s) is OFF.
`
`
`
`7
`
`MEDIATEK EX. 1012
`
`

`

`Case 6:22-cv-01163-ADA Document 1 Filed 11/10/22 Page 8 of 15
`
`38.
`
`On information and belief, each MediaTek Chip tunes at least one of the filtering
`
`operation and down-converting operation (e.g., the MediaTek Chip selects components/adjusts
`
`component values).
`
`39.
`
`On information and belief, a transistor(s) in each MediaTek Chip under-samples
`
`(e.g., at a sample rate below the Nyquist rate) the input signal according to a control signal (e.g.,
`
`local oscillator (LO) signal). The frequency of the control signal is equal to a frequency of the
`
`input signal plus or minus a frequency of a down-converted image, divided by n, where n
`
`represents a harmonic or sub-harmonic of the input signal.
`
`40.
`
`ParkerVision has been damaged by the direct infringement of MediaTek and is
`
`suffering and will continue to suffer irreparable harm and damages as a result of this
`
`infringement.
`
`COUNT II – Infringement of United States Patent No. 6,266,518
`
`41.
`
`The allegations set forth above are re-alleged and incorporated by reference as if
`
`they were set forth fully here.
`
`42. MediaTek directly infringes (literally and/or under the doctrine of equivalents) the
`
`’518 patent by using, selling, offering for sale, and/or importing in/into the United States
`
`products covered by at least claim 27 of the ’518 patent. MediaTek infringes each step of claim
`
`27 because the MediaTek Chips automatically, and without user modification, performed each of
`
`the claimed steps.
`
`43.
`
`On information and belief, MediaTek products that infringe at least claim 27 of
`
`the ’518 patent include, but are not limited to, the MediaTek Chips, and any other MediaTek
`
`device that is capable of down-converting a carrier signal to a baseband signal as claimed in the
`
`
`
`8
`
`MEDIATEK EX. 1012
`
`

`

`Case 6:22-cv-01163-ADA Document 1 Filed 11/10/22 Page 9 of 15
`
`’518 patent. On information and belief, MediaTek uses the MediaTek Chips at least by testing
`
`the MediaTek Chips in the United States.
`
`44.
`
`On information and belief, each MediaTek Chip performs a method of down-
`
`converting a carrier signal (e.g., an RF signal at a transmission frequency) to a baseband signal.
`
`The method is performed on the receiver side of each MediaTek Chip.
`
`45.
`
`On information and belief, each MediaTek Chip receives a carrier signal that
`
`includes at least one of amplitude variations, phase variations, or frequency variations at a
`
`frequency lower than a carrier frequency of the carrier signal (e.g., a modulated carrier signal,
`
`such as a quadrature amplitude modulation (QAM) signal). The carrier signal includes a
`
`baseband signal that has been imparted on the carrier signal.
`
`46.
`
`On information and belief, each MediaTek Chip samples the carrier signal by a
`
`transistor(s) turning ON and OFF. The sampling occurs over aperture periods (e.g., periods of
`
`time when the transistor(s) is ON/receives an LO signal) to transfer energy from the carrier
`
`signal at an aliasing rate, which is determined according to a frequency of the carrier signal
`
`divided by N, wherein N indicates a harmonic or sub-harmonic of the carrier signal.
`
`47.
`
`On information and belief, a capacitor(s) in each MediaTek Chip integrates
`
`energy from a transistor(s) over the aperture periods (e.g., when the transistor(s) is ON).
`
`48.
`
`On information and belief, each MediaTek Chip generates a baseband signal
`
`including from the integrated energy that comes from a capacitor(s) when the transistor is OFF.
`
`49.
`
`On information and belief, a capacitor(s) in each MediaTek Chip transfers energy
`
`to a load (e.g., one or more resistors) during an off-time (e.g., when the transistor(s) is OFF).
`
`
`
`9
`
`MEDIATEK EX. 1012
`
`

`

`Case 6:22-cv-01163-ADA Document 1 Filed 11/10/22 Page 10 of 15
`
`50.
`
`ParkerVision has been damaged by the direct infringement of MediaTek and is
`
`suffering and will continue to suffer irreparable harm and damages as a result of this
`
`infringement.
`
`COUNT III - Infringement of United States Patent No. 7,292,835
`
`51.
`
`The allegations set forth above are re-alleged and incorporated by reference as if
`
`they were set forth fully here.
`
`52. MediaTek directly infringes (literally and/or under the doctrine of equivalents) the
`
`’835 patent by using, selling, offering for sale, and/or importing in/into the United States
`
`products covered by at least claims 1 and 17 of the ’835 patent.
`
`53.
`
`On information and belief, MediaTek products that infringe one or more claims of
`
`the ’835 patent include, but are not limited to, the MediaTek Chips and any other MediaTek
`
`device used e.g., in televisions (“MediaTek TV Chips”) that is capable of down-converting a
`
`higher-frequency signal to a lower-frequency signal as claimed in the ’835 patent. On
`
`information and belief, MediaTek uses the MediaTek TV Chips at least by testing the MediaTek
`
`TV Chips in the United States.
`
`54.
`
`The MediaTek TV Chips used in televisions enable users to watch live TV and on
`
`demand programming from their cable service providers over a wireless network. For example,
`
`some of the MediaTek TV Chips provide wireless connectivity for televisions, such as Hisense
`
`and LG televisions.1 The MediaTek TV Chips are configured to function/capable of functioning
`
`
`1 See, e.g., https://fccid.io/BEJLGSWFAC71/Users-Manual/User-Manual-3136306;
`https://fccid.io/BEJLGSWFAC71/Internal-Photos/Internal-Photos-3136304.pdf;
`https://fccid.io/W9HLCDF0098; https://fccid.io/W9HLCDF0098/Internal-
`Photos/TempConfidential-W9HLCDF0098-Internal-Photos-3264487.pdf.
`
`
`
`10
`
`MEDIATEK EX. 1012
`
`

`

`Case 6:22-cv-01163-ADA Document 1 Filed 11/10/22 Page 11 of 15
`
`as wireless cable modems. For example, the MediaTek TV Chips provide a wireless connection
`
`to cable services.
`
`55.
`
`On information and belief, each MediaTek TV Chip is/includes a cable modem
`
`(e.g., wireless modem for communicating with a cable television network) for down-converting
`
`an electromagnetic signal (e.g., a high frequency RF signal), having complex modulations (e.g.,
`
`QAM), to a lower frequency signal. The electromagnetic signal is transmitted by a wireless
`
`method to the cable modem.
`
`56.
`
`Each MediaTek TV Chip has (a) an oscillator (e.g., LO) to generate an in-phase
`
`oscillating signal (e.g., in-phase LO signal), (b) a phase shifter (e.g., a flip-flop) to receive the in-
`
`phase oscillating signal and to create a quadrature-phase oscillating signal (e.g., quadrature-phase
`
`LO signal), (c) a first frequency down-conversion module (e.g., a first module that includes at
`
`least one switch and at least one capacitor) to receive the electromagnetic signal and the in-phase
`
`oscillating signal and (d) a second frequency down-conversion module (e.g., a second module
`
`that includes at least one switch and at least one capacitor) to receive the electromagnetic signal
`
`and the quadrature-phase oscillating signal.
`
`57.
`
`On information and belief, the first frequency down-conversion module includes a
`
`first frequency translation module (e.g., a module having one or more switches) and a first
`
`storage module (e.g., a module having one or more capacitors). The first frequency translation
`
`module samples the electromagnetic signal at a rate (e.g., LO rate with a 25% duty cycle) that is
`
`a function of the in-phase oscillating signal, thereby creating a first sampled signal.
`
`58.
`
`The second frequency down-conversion module includes a second frequency
`
`translation module (e.g., a module having one or more switches) and a second storage module
`
`(e.g., a module having one or more capacitors). The second frequency translation module
`
`
`
`11
`
`MEDIATEK EX. 1012
`
`

`

`Case 6:22-cv-01163-ADA Document 1 Filed 11/10/22 Page 12 of 15
`
`samples the electromagnetic signal at a rate (e.g., LO rate with a 25% duty cycle) that is a
`
`function of the quadrature-phase oscillating signal, thereby creating a second sampled signal.
`
`59.
`
`ParkerVision has been damaged by the direct infringement of MediaTek and is
`
`suffering and will continue to suffer irreparable harm and damages as a result of this
`
`infringement.
`
`COUNT IV - Infringement of United States Patent No. 8,660,513
`
`60.
`
`The allegations set forth above are re-alleged and incorporated by reference as if
`
`they were set forth fully here.
`
`61. MediaTek directly infringes (literally and/or under the doctrine of equivalents) the
`
`’513 patent by using, selling, offering for sale, and/or importing in/into the United States
`
`products covered by at least claim 19 of the ’513 patent.
`
`62.
`
`On information and belief, MediaTek products that infringe one or more claims of
`
`the ’513 patent include, but are not limited to, the MediaTek Chips, and any other MediaTek
`
`device that is capable of down-converting a higher-frequency signal to a lower-frequency signal
`
`as claimed in the ’513 patent. On information and belief, MediaTek uses the MediaTek Chips at
`
`least by testing the MediaTek Chips in the United States.
`
`63.
`
`On information and belief, each MediaTek Chip is/includes a system for
`
`frequency down-converting a modulated carrier signal (e.g., high frequency RF signal) to a lower
`
`frequency signal. Each MediaTek Chip has (a) a first switch (e.g., one or more transistors), (b) a
`
`first control signal (e.g., LO signal) which comprises a sampling aperture (e.g., 25% duty cycle)
`
`with a specified frequency, and (c) a first energy storage element (e.g., one or more capacitors)
`
`that down-converts the modulated carrier signal according to the first control signal and outputs a
`
`down-converted in-phase signal portion of the modulated carrier signal.
`
`
`
`12
`
`MEDIATEK EX. 1012
`
`

`

`Case 6:22-cv-01163-ADA Document 1 Filed 11/10/22 Page 13 of 15
`
`64.
`
`On information and belief, each MediaTek Chip has (a) a second switch (e.g., one
`
`or more transistors), (b) a second control signal (e.g., LO signal) which comprises a sampling
`
`aperture (e.g., 25% duty cycle) with a specified frequency, and (c) a second energy storage
`
`element (e.g., one or more capacitors) that down-converts the modulated carrier signal (e.g., high
`
`frequency RF signal) according to the second control signal and outputs a down-converted
`
`inverted in-phase signal portion of the modulated carrier signal.
`
`65.
`
`On information and belief, each MediaTek Chip has a first differential amplifier
`
`circuit that combines the down-converted in-phase signal portion with the inverted in-phase
`
`signal portion and outputs a first channel down-converted differential in-phase signal.
`
`66.
`
`On information and belief, each MediaTek Chip has (a) a third switch (e.g., one or
`
`more transistors), (b) a third control signal (e.g., LO signal) which comprises a sampling aperture
`
`(e.g., 25% duty cycle) with a specified frequency, and (c) a third energy storage element (e.g.,
`
`one or more capacitors) that down-converts the modulated carrier signal (e.g., high frequency RF
`
`signal) according to the third control signal and outputs a down-converted quadrature-phase
`
`signal portion of the modulated carrier signal.
`
`67.
`
`On information and belief, each MediaTek Chip has (a) a fourth switch (e.g., one
`
`or more transistors), (b) a fourth aperture signal (e.g., LO signal), and (c) a fourth energy storage
`
`element (e.g., one or more capacitors) that down-converts the modulated carrier signal (e.g., high
`
`frequency RF signal) according to the fourth control signal and outputs a down-converted
`
`inverted quadrature-phase signal portion of the modulated carrier signal.
`
`68.
`
`On information and belief, each MediaTek Chip has a second differential
`
`amplifier circuit that combines the down-converted quadrature-phase signal portion with the
`
`
`
`13
`
`MEDIATEK EX. 1012
`
`

`

`Case 6:22-cv-01163-ADA Document 1 Filed 11/10/22 Page 14 of 15
`
`inverted quadrature-phase signal portion and outputs a second channel down-converted
`
`differential quadrature-phase signal.
`
`69.
`
`ParkerVision has been damaged by the direct infringement of MediaTek and is
`
`suffering and will continue to suffer irreparable harm and damages as a result of this
`
`infringement.
`
`JURY DEMANDED
`
`Pursuant to Rule 38(b) of the Federal Rules of Civil Procedure, ParkerVision hereby
`
`requests a trial by jury on all issues so triable.
`
`PRAYER FOR RELIEF
`
`WHEREFORE, ParkerVision respectfully requests that the Court enter judgment in its
`
`favor and against MediaTek as follows:
`
`a.
`
`finding that MediaTek directly infringes one or more claims of each of the
`
`patents-in-suit;
`
`b.
`
`awarding ParkerVision damages under 35 U.S.C. § 284, or otherwise permitted
`
`by law, including supplemental damages for any continued post-verdict
`
`infringement;
`
`c.
`
`awarding ParkerVision pre-judgment and post-judgment interest on the damages
`
`award and costs;
`
`d.
`
`awarding cost of this action (including all disbursements) and attorney fees
`
`pursuant to 35 U.S.C. § 285, or as otherwise permitted by the law; and
`
`e.
`
`awarding such other costs and further relief that the Court determines to be just
`
`and equitable.
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`14
`
`MEDIATEK EX. 1012
`
`

`

`Case 6:22-cv-01163-ADA Document 1 Filed 11/10/22 Page 15 of 15
`
`Dated: November 9, 2022
`
`
`OF COUNSEL:
`
`Ronald M. Daignault*#
`Chandran Iyer*
`Jason Charkow*#
`Scott Samay*#
`Stephanie Mandir*
`DAIGNAULT IYER LLP
`rdaignault@daignaultiyer.com
`cbiyer@daignaultiyer.com
`jcharkow@daignaultiyer.com
`ssamay@daignaultiyer.com
`smandir@daignaultiyer.com
`8618 Westwood Center Drive
`Suite 150
`Vienna, VA 22182
`
`#Not admitted in Virginia
`*Pro hac vice to be filed
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`THE MORT LAW FIRM, PLLC
`
`/s/ Raymond W. Mort, III
`Raymond W. Mort, III
`Texas State Bar No. 00791308
`raymort@austinlaw.com
`501 Congress Avenue, Suite 150
`Austin, Texas 78701
`Tel/Fax: 512-865-7950
`
`Attorneys for Plaintiff ParkerVision, Inc.
`
`
`
`15
`
`MEDIATEK EX. 1012
`
`