`Case 2:22-cv-00134-JRG-RSP Document 43-7 Filed 08/05/22 Page 1of3PagelD#: 726
`
`EXHIBIT 6
`EXHIBIT 6
`
`
`
`Case 2:22-cv-00134-JRG-RSP Document 43-7 Filed 08/05/22 Page 2 of 3 PageID #: 727
`
`From:
`Sent:
`To:
`
`Cc:
`
`Subject:
`
`Robert,
`
`Rizk, Adam <ARizk@mintz.com>
`Thursday, August 04, 2022 11:53 AM
`Benson, Robert; Karambelas, Matthew; Blake@TheMannFirm.com;
`Mark@TheMannFirm.com
`Eric Findlay; Brian Craft; De Renzis, Megan; Renaud, Michael; Davenport, Samuel; Debby
`Gunter; Sarah Hene
`RE: 2:22-cv-00134: E.D. Tex.
`
`We understand Realtek’s position.
`
`AMD does not agree to Realtek’s proposed stipulation, but is open to discussing other potential stipulations to promote
`efficiencies after the discretionary stay is lifted, such as, for example reuse of ITC document productions, contentions,
`expert reports, fact/expert testimony, etc.
`
`At a minimum even absent stipulation, and as you are aware, there are procedures available for promoting efficiencies
`after the stay has been lifted, such as requesting transfer of the Commission record and/or seeking discovery with
`respect to relevant material generated in the course of the ITC proceeding, but that are not technically part of the
`Commission record.
`
`Kind regards,
`Adam
`
`From: Benson, Robert <rbenson@orrick.com>
`Sent: Thursday, August 4, 2022 11:09 AM
`To: Rizk, Adam <ARizk@mintz.com>; Karambelas, Matthew <MAKarambelas@mintz.com>; Blake@TheMannFirm.com;
`Mark@TheMannFirm.com
`Cc: Eric Findlay <efindlay@findlaycraft.com>; Brian Craft <bcraft@findlaycraft.com>; De Renzis, Megan
`<MADeRenzis@mintz.com>; Renaud, Michael <MTRenaud@mintz.com>; Davenport, Samuel
`<SFDavenport@mintz.com>; Debby Gunter <dgunter@findlaycraft.com>; Sarah Hene <shene@findlaycraft.com>
`Subject: RE: 2:22-cv-00134: E.D. Tex.
`
`Adam,
`
`Your assumption is not correct. AMD is seeking a stay of the district court litigation, not Realtek. There is no
`rationale for “reciprocity.”
`
`In connection with its motion for a stay of the district court case, we are asking AMD if it will stipulate to be
`bound by any final determination by the Commission in the 1318 investigation that Realtek products do not
`infringe the ‘053, ‘547, ‘381 or ‘628 patents, any final determination by the Commission that any claims of those
`patents are invalid, and any other determination adverse to AMD related to the merits of the claims and
`defenses asserted in the 1318 investigation.
`
`Best regards,
`Robert
`
`1
`
`
`
`Case 2:22-cv-00134-JRG-RSP Document 43-7 Filed 08/05/22 Page 3 of 3 PageID #: 728
`
`From: Rizk, Adam <ARizk@mintz.com>
`Sent: Thursday, August 04, 2022 8:04 AM
`To: Benson, Robert <rbenson@orrick.com>; Karambelas, Matthew <MAKarambelas@mintz.com>;
`Blake@TheMannFirm.com; Mark@TheMannFirm.com
`Cc: Eric Findlay <efindlay@findlaycraft.com>; Brian Craft <bcraft@findlaycraft.com>; De Renzis, Megan
`<MADeRenzis@mintz.com>; Renaud, Michael <MTRenaud@mintz.com>; Davenport, Samuel
`<SFDavenport@mintz.com>; Debby Gunter <dgunter@findlaycraft.com>; Sarah Hene <shene@findlaycraft.com>
`Subject: RE: 2:22-cv-00134: E.D. Tex.
`
`Robert,
`
`I presume that what Realtek is proposing is reciprocity where both AMD/Realtek will stipulate to be bound by any final
`determination by the Commission in the 1318 investigation that Realtek products infringe or do not infringe the ‘053,
`‘547, ‘381 or ‘628 patents, any final determination by the Commission that any claims of those patents are valid or
`invalid, and any other determination adverse to AMD/Realtek related to the merits of the claims and defenses asserted
`in the 1318 investigation.
`
`Please confirm that this is what you mean so we can take the proposal to our client and get you a response.
`
`Regards,
`Adam
`
`From: Benson, Robert <rbenson@orrick.com>
`Sent: Thursday, August 4, 2022 10:47 AM
`To: Karambelas, Matthew <MAKarambelas@mintz.com>; Blake@TheMannFirm.com; Mark@TheMannFirm.com
`Cc: Eric Findlay <efindlay@findlaycraft.com>; Brian Craft <bcraft@findlaycraft.com>; De Renzis, Megan
`<MADeRenzis@mintz.com>; Rizk, Adam <ARizk@mintz.com>; Renaud, Michael <MTRenaud@mintz.com>; Davenport,
`Samuel <SFDavenport@mintz.com>; Debby Gunter <dgunter@findlaycraft.com>; Sarah Hene
`<shene@findlaycraft.com>
`Subject: RE: 2:22-cv-00134: E.D. Tex.
`
`Eric and Matt,
`
`In connection with AMD’s current motion to stay, please advise whether AMD will stipulate to be bound by any
`final determination by the Commission in the 1318 investigation that Realtek products do not infringe the ‘053,
`‘547, ‘381 or ‘628 patents, any final determination by the Commission that any claims of those patents are
`invalid, and any other determination adverse to AMD related to the merits of the claims and defenses asserted
`in the 1318 investigation.
`
`Best regards,
`
`Robert
`
`2
`
`
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