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Case 6:20-cv-00945-ADA Document 24 Filed 03/08/21 Page 1 of 5
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`UNITED STATES DISTRICT COURT
`FOR THE WESTERN DISTRICT OF TEXAS
`WACO DIVISION
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`
`
`
`
`
`
`Case No. 6:20-cv-00945-ADA
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`JURY TRIAL DEMANDED
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`PARKERVISION, INC.,
`
`
`Plaintiff,
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`
`v.
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`TCL INDUSTRIES HOLDINGS CO.,
`LTD., TCL ELECTRONICS HOLDINGS
`LTD., SHENZHEN TCL NEW
`TECHNOLOGY CO., LTD., TCL KING
`ELECTRICAL APPLIANCES (HUIZHOU)
`CO., LTD., TCL MOKA INT’L LTD., and
`TCL MOKA MANUFACTURING S.A. DE
`C.V.,
`
`
`Defendants.
`
`
`CASE READINESS STATUS REPORT
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`Plaintiff ParkerVision, Inc. and Defendants TCL Industries Holdings Co., Ltd.
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`TCL Electronics Holdings Ltd., Shenzhen TCL New Technology Co., Ltd., TCL King
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`Electrical Appliances (Huizhou) Co., Ltd., TCL Moka Int’l Ltd., and TCL Moka
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`Manufacturing S.A. DE C.V. hereby provide the following status report in advance of
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`the initial Case Management Conference (CMC).
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`FILINGS AND EXTENSIONS
`Plaintiff’s Complaint was filed on October 12, 2020. There has been one
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`extension for thirty-one (31) days.
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`1
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`

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`Case 6:20-cv-00945-ADA Document 24 Filed 03/08/21 Page 2 of 5
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`RESPONSE TO THE COMPLAINT
`Defendants responded to the Complaint on February 8, 2021 by filing their
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`Answer. See Dkt. No. 16.
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`PENDING MOTIONS
`There are no pending motions.
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`
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`RELATED CASES IN THIS JUDICIAL DISTRICT
`There are five (5) related cases in the Judicial District, all of which assert one or
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`more of the same patents asserted in this case. See ParkerVision, Inc. v. Intel
`
`Corporation, Case No. 6:20-cv-108-ADA, ParkerVision, Inc. v. Intel Corporation, Case
`
`No. 6:20-cv-562-ADA, ParkerVision, Inc. v. Hisense Co., Ltd. et al., Case No. 6: 20-cv-
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`870-ADA, ParkerVision, Inc. v. Buffalo Inc., Case No. 6:20-cv-1009-ADA, and
`
`ParkerVision, Inc. v. ZyXEL Communications Corporation, Case No. 6:20-cv-1010-
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`ADA.
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`IPR, CBM, AND OTHER PGR FILINGS
`IPR2020-01265, related to U.S. Patent No. 7,110,444, was filed on July 13, 2020 by
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`Intel Corporation and docketed on August 21, 2020. A Final Written decision is
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`expected on or before January 28, 2022. Other than IPR2020-01265, there are no known
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`IPR, CBM or other PGR filings.
`
`NUMBER OF ASSERTED PATENTS AND CLAIMS
`Plaintiff has asserted ten (10) patents, namely, U.S. Pat. Nos. 6,049,706 (“’706
`
`patent”); 6,266,518 (“’518 patent”); 6,580,902 (“’902 patent”); 7,110,444 (“’444 patent”);
`
`7,292,835 (“’835 patent”); 8,588,725 (“’725 patent”); 8,660,513 (“’513 patent”); 9,118,528
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`(“’528 patent”); 9,246,736 (“’736 patent”) and 9,444,673 (“’673 patent”). Plaintiff has not
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`
`
`2
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`

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`Case 6:20-cv-00945-ADA Document 24 Filed 03/08/21 Page 3 of 5
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`yet served its Preliminary Infringement Contentions (PICs) and will identify the claims
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`to be asserted in its PICs. The parties agree as follows:
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`• On or before March 17, 2021, Plaintiff shall serve a list of all asserted
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`claims for each asserted patent.
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`• On or before March 17, 2021, Plaintiff shall serve claim charts for one
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`asserted claim for each asserted patent;
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`• On or before March 26, 2021, Plaintiff shall serve any additional claim
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`charts not previously served, along with all associated documents under the Court’s
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`local rules and standing orders. Any and all claim charts served on or before March 26,
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`2021, shall match the list of asserted claims served by Plaintiff on March 17, 2021.
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`• On or before June 4, 2021, Defendants shall serve their invalidity
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`contentions, along with the associated documents under the Court’s local rules and
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`standing orders.
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`APPOINTMENT OF TECHNICAL ADVISOR
`The parties do not request the appointment of any technical advisor at this time,
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`but the Parties do not oppose the appointment of a technical advisor should the Court
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`deem it appropriate or helpful to the Court.
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`MEET AND CONFER STATUS
`Plaintiff and Defendant conducted a meet and confer conference on March 1,
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`2021. The parties have no pre-Markman issues to raise at the CMC.
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`3
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`

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`Case 6:20-cv-00945-ADA Document 24 Filed 03/08/21 Page 4 of 5
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`
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`Dated: March 8, 2021
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`
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`OF COUNSEL:
`
`
`
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`
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`Ronald M. Daignault*
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`Chandran B. Iyer*
`
`
`Jason S. Charkow*
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`
`Stephanie R. Mandir*
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`DAIGNAULT IYER LLP
`rdaignault@daignaultiyer.com
`cbiyer@daignaultiyer.com
`jcharkow@daignaultiyer.com
`smandir@daignaultiyer.com
`8200 Greensboro Drive, Suite 900
`Mclean, Virginia 22102
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`*pro hac vice to be filed
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`
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`Respectfully submitted,
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`/s/Raymond W. Mort, III
`Raymond W. Mort, III
`Texas State Bar No. 00791308
`raymort@austinlaw.com
`THE MORT LAW FIRM, PLLC
`100 Congress Avenue, Suite 2000
`Austin, Texas 78701
`Tel/Fax: 512-865-7950
`
`Attorneys for Plaintiff ParkerVision, Inc.
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`
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`4
`
`

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`Case 6:20-cv-00945-ADA Document 24 Filed 03/08/21 Page 5 of 5
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`By:
`
`KILPATRICK TOWNSEND & STOCKTON
`LLP
`
`
`/s/Steve R. Borgman
`Steve R. Borgman (State Bar No. 02670300)
`sborgman@kilpatricktownsend.com
`Suite 4300, 700 Louisiana Street
`Houston, TX 77002
`Telephone: (281) 809-4081
`Facsimile: (281) 990-6826
`Kristopher L. Reed
`kreed@kilpatricktownsend.com
`Kevin M. Bell
`kbell@kilpatricktownsend.com
`Edward J. Mayle
`tmayle@kilpatricktownsend.com
`Suite 600, 1400 Wewatta Street
`Denver, CO 80202
`Telephone: (303) 571-4000
`Facsimile: (303) 571-4321
`Steven D. Moore
`smore@kilpatricktownsend.com
`Two Embarcadero Center, Suite 1900
`San Francisco, CA 94111
`Telephone: (415) 576-0200
`Facsimile: (415) 576-0300
`Megan Chung
`mchung@kilpatricktownsend.com
`12255 El Camino Real, Ste. 250
`San Diego, CA 92130
`Telephone: (858) 350-6144
`Facsimile: (858) 430-3851
`Attorneys for Defendants
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`5
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`

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