`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE WESTERN DISTRICT OF TEXAS
`AUSTIN DIVISION
`
`Plaintiff,
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`
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`v.
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`§
`§
`§ Civil Action No. 1:20-cv-00765-LY
`§
`§
`§ Jury Trial Demanded
`§
`§
`§
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`BANDSPEED LLC,
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`REALTEK SEMICONDUCTOR CORPORATION.,
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`Defendants.
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`PLAINTIFF’S MOTION FOR ISSUANCE OF REQUEST
`FOR INTERNATIONAL JUDICIAL ASSISTANCE
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`Plaintiff Bandspeed LLC (“Bandspeed” or “Plaintiff”) files this Motion for Request for
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`International Judicial Assistance upon Realtek Semiconductor Corporation (“Realtek” or
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`“Defendant”).
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`Bandspeed (“Bandspeed”) filed its Complaint against Realtek for infringement of United
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`States Patent Nos. 7,027,418 (“the ’418 Patent”), 7,477,624 (“the ’624 Patent”), 7,570,614 (“the
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`’614 patent”), 7,903,608 (“the ’608 Patent”), 8,542,643 (“the ’643 Patent), 8,873,500 (“the ’500
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`Patent), 9,379,769 (“the ’769 Patent), and 9,883,520 (“the ’520 Patent) (collectively, the “Patents-
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`in-Suit”) on July 20, 2020. Bandspeed alleges that Realtek manufactures, provides, sells, uses,
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`imports, supplies, offers for sale, and/or distributes Infringing Products, such as integrated circuits,
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`or a set of integrated circuits for wireless communications devices, that use, practice, and/or
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`comply with the Bluetooth Core Specification Version 2.0+EDR or higher, and other products that
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`operate in a reasonably similar manner (“Infringing Bluetooth Classic Products”) as well as
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`Infringing Products that use, practice and/or comply with the Bluetooth low energy protocol as
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`described in Version 4.0 and any later version of the Bluetooth Core Specification, and other
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`products that operate in a reasonably similar manner (“Infringing Bluetooth LE Products”).
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`1
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`Case 1:20-cv-00765-DAE Document 8 Filed 09/14/20 Page 2 of 3
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`
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`Bandspeed served Realtek Semiconductor Corporation through the Texas Secretary of
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`State on July 24, 2020. Bandspeed also requested Realtek to waive service under Fed. R. Civ. P.
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`by letter received by Realtek on August 31, 2020. Despite these efforts, Realtek has not responded
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`to the Complaint. On September 10, 2020, counsel for Realtek contacted counsel for Bandspeed
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`and stated that Realtek will not respond to Bandspeed’s Complaint until it is served through a
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`Request for Judicial Assistance. Use of a Request for International Judicial Assistance is an
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`acceptable procedure for service of process under the laws of Taiwan. Accordingly, Bandspeed
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`hereby requests this Court to issue a Request for International Judicial Assistance for service of
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`process on Realtek. A draft Request is attached hereto as Exhibit A.
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`
`
`
`
`Respectfully submitted,
`
`By: /s/ Adam G. Price
`Adam G. Price
`Texas State Bar No. 24027750
`Christopher V. Goodpastor
`Texas State Bar No. 00791991
`DINOVO PRICE LLP
`7000 N. MoPac Expressway
`Suite 350
`Austin, Texas 78731
`Telephone: (512) 539-2626
`Facsimile: (512) 539-2627
`Email: aprice@dinovoprice.com
`cgoodpastor@dinovoprice.com
`
`ATTORNEYS FOR PLAINTIFF
`BANDSPEED, LLC
`
`
`Dated: September 14, 2020.
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`2
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`Case 1:20-cv-00765-DAE Document 8 Filed 09/14/20 Page 3 of 3
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`CERTIFICATE OF SERVICE
`
`I hereby certify that this document(s) filed through the CM/ECF system will be sent
`electronically to the registered participants as identified on the Notice of Electronic Filing (NEF),
`and a copy will be sent by Federal Express to those indicated as non-registered participants, on
`September 14, 2020.
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`/s/ Adam G. Price
`Adam G. Price
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`
`
`3
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