`
`Exhibit 1
`
`
`
`Case 2:22-cv-00134-JRG-RSP Document 31-2 Filed 07/11/22 Page 2 of 4 PageID #: 272
`
`From:
`Sent:
`To:
`Cc:
`Subject:
`
`Hi Eric,
`
`Benson, Robert <rbenson@orrick.com>
`Friday, July 1, 2022 9:42 AM
`Eric Findlay
`Brian Craft; Johnson, Jeffrey
`RE: AMD v. TCL, Realtek, et al. (Case No. 22-cv-00134-JRG-RSP)
`
`In general, we do not think any extensions should be needed. Nevertheless, after substantial internal
`discussion this week of the two-week extension that you previously proposed, Realtek is willing to agree to a
`10-day extension of time for both deadlines.
`
`The extension of time for TCL may not be relevant if TCL requests the automatic stay. However, if TCL does
`not request the automatic stay under §1659, and if AMD believes a further extension is warranted in order to
`sync the deadlines, we can consider that further issue next week.
`
`Best regards,
`Robert
`
`From: Eric Findlay <efindlay@findlaycraft.com>
`Sent: Friday, July 01, 2022 5:57 AM
`To: Benson, Robert <rbenson@orrick.com>
`Cc: Brian Craft <bcraft@findlaycraft.com>; Johnson, Jeffrey <jj@orrick.com>
`Subject: Re: AMD v. TCL, Realtek, et al. (Case No. 22‐cv‐00134‐JRG‐RSP)
`
`Robert,
`
`Just an update on our end. AMD and TCL are close to coming to an agreement which will actually extend the
`contentions deadline (both sides’) by 3 weeks. AMD's to July 26, and the same 3 week extension for TCL’s invalidity
`contentions. Assuming you all are unopposed, just wanted to update you on the latest. We think it makes sense to keep
`those deadlines the same across the parties.
`
`Thanks again. Look forward to hearing back from you.
`
`Eric
`
`Eric H. Findlay
`Findlay Craft, P.C.
`102 N. College Avenue, Suite 900
`Tyler, Texas 75702
`(903) 534‐1100 M: (903) 571‐6963
`www.findlaycraft.com
`
`National Experience Local Expertise
`
`1
`
`
`
`Case 2:22-cv-00134-JRG-RSP Document 31-2 Filed 07/11/22 Page 3 of 4 PageID #: 273
`
`On Jun 30, 2022, at 12:49 PM, Eric Findlay <efindlay@findlaycraft.com> wrote:
`
`Robert,
`
`Thanks very much.
`
`Will stand by.
`
`Eric
`
`
`Eric H. Findlay
`Findlay Craft, P.C.
`102 N. College Avenue, Suite 900
`Tyler, Texas 75702
`(903) 534‐1100 M: (903) 571‐6963
`www.findlaycraft.com
`
`National Experience Local Expertise
`
`
`On Jun 30, 2022, at 12:45 PM, Benson, Robert <rbenson@orrick.com> wrote:
`
`Hi Eric,
`
`
`We are discussing the extension request with Realtek and we anticipate having a
`response on that issue by tomorrow.
`
`
`Thanks for your patience,
`
`
`Robert
`
`
`
`From: Eric Findlay <efindlay@findlaycraft.com>
`Sent: Thursday, June 30, 2022 9:04 AM
`To: Benson, Robert <rbenson@orrick.com>
`Cc: Brian Craft <bcraft@findlaycraft.com>; Johnson, Jeffrey <jj@orrick.com>
`Subject: Re: AMD v. TCL, Realtek, et al. (Case No. 22‐cv‐00134‐JRG‐RSP)
`
`
`Robert,
`
`
`Hi. Any update here?
`
`
`We would like to get this wrapped up this week, given the upcoming long holiday
`weekend.
`
`
`And Jeff, hi! Long time. Hope alls well and staying cool down there in H’town.
`
`
`Thanks very much.
`
`
`Eric
`
`
`Eric H. Findlay
`Findlay Craft, P.C.
`102 N. College Avenue, Suite 900
`
`2
`
`
`
`Case 2:22-cv-00134-JRG-RSP Document 31-2 Filed 07/11/22 Page 4 of 4 PageID #: 274
`Tyler, Texas 75702
`(903) 534‐1100 M: (903) 571‐6963
`www.findlaycraft.com
`
`National Experience Local Expertise
`
`
`
`On Jun 28, 2022, at 5:42 PM, Benson, Robert <rbenson@orrick.com>
`wrote:
`
`
`Hi Eric,
`
`
`Our apologies for the slow response.
`
`
`Regarding the issue of a stay, we do not currently intend to
`request a mandatory stay under §1659, but we will continue to
`evaluate the option with our client prior to the deadline for filing.
`
`
`Concerning the request to push back the infringement and
`invalidity contention deadlines by two weeks, we are consulting
`with Realtek and hope to get back to you in the next day or
`two. Thanks for your patience.
`
`
`Best regards,
`Robert
`
`
`
`
`From: Eric Findlay <efindlay@findlaycraft.com>
`Sent: Tuesday, June 28, 2022 9:31 AM
`To: Benson, Robert <rbenson@orrick.com>
`Cc: Brian Craft <bcraft@findlaycraft.com>
`Subject: AMD v. TCL, RealTek, et al. (Case No. 22‐cv‐00134‐JRG‐RSP)
`
`
`Robert,
`
`
`Hi. Wanted to touch base and follow up on our call last
`week. Any update on 1) our request to push back the infringement
`and invalidity contention deadlines by two weeks, respectively?;
`and 2) if you know RealTek’s intention w/r/t seeking a mandatory
`stay in light of the ITC action?
`
`
`
`Thank you.
`
`
`
`Eric
`
`
`
`
`Eric H. Findlay
`Findlay Craft, P.C.
`102 N. College Avenue, Suite 900
`Tyler, Texas 75702
`
`3
`
`
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