`
`UNITED STATES DISTRICT COURT
`WESTERN DISTRICT OF TEXAS
`WACO DIVISION
`
`
`
`PARKERVISION, INC.,
`
` Plaintiff,
`
` v.
`
`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.;
`
`HISENSE CO., LTD. and HISENSE
`VISUAL TECHNOLOGY CO., LTD. (F/K/A
`QINGDAO HISENSE ELECTRONICS CO.),
`LTD. and HISENSE ELECTRIC CO., LTD.
`
`Defendants.
`
`
`
`
`
`
`
`
`
`
`Case No. 6:20-cv-00945-ADA
`
`
`
`
`
`
`
`
`Case No. 6:20-cv-00870-ADA
`
`
`JURY TRIAL DEMANDED
`
`
`DECLARATION OF EDWARD J. MAYLE IN SUPPORT OF
`DEFENDANTS’ OPENING CLAIM CONSTRUCTION BRIEF
`
`
`
`
`
`
`
`Case 6:20-cv-00945-ADA Document 33-1 Filed 08/23/21 Page 2 of 3
`
`I Edward J. Mayle, upon personal knowledge or information and belief, state as follows:
`
`1.
`
`I am a lawyer with Kilpatrick Townsend & Stockton LLP, and am counsel for
`
`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 Moka Manufacturing S.A. De C.V. (collectively “TCL”) in Case No. 6:20-cv-00945-ADA,
`
`and am counsel for Hisense Co., Ltd. and Hisense Visual Technology Co., Ltd. (f/k/a Qingdao
`
`Hisense Electronics Co., Ltd. and Hisense Electric Co., Ltd.) (collectively “Hisense”) in Case No.
`
`6:20-cv-00870-ADA. I am admitted to the bars of Colorado and the District of Columbia, and
`
`admitted in both of the above-referenced cases pro hac vice. I am over the age of 18 and
`
`otherwise competent to make this declaration.
`
`2.
`
`I make this declaration on my own knowledge, except where otherwise noted. If
`
`called upon to testify regarding the contents of this declaration, I could and would completely
`
`testify to its accuracy.
`
`3.
`
`4.
`
`5.
`
`6.
`
`7.
`
`8.
`
`9.
`
`10.
`
`11.
`
`12.
`
`Attached as Exhibit 1 is a true and correct copy of USP No. 6,049,706.
`
`Attached as Exhibit 2 is a true and correct copy of USP No. 6,266,518.
`
`Attached as Exhibit 3 is a true and correct copy of USP No. 6,580,902.
`
`Attached as Exhibit 4 is a true and correct copy of USP No. 7,110,444.
`
`Attached as Exhibit 5 is a true and correct copy of USP No. 7,292,835.
`
`Attached as Exhibit 6 is a true and correct copy of USP No. 8,588,725.
`
`Attached as Exhibit 7 is a true and correct copy of USP No. 8,660,513.
`
`Attached as Exhibit 8 is a true and correct copy of USP No. 9,118,528.
`
`Attached as Exhibit 9 is a true and correct copy of USP No. 9,246,736.
`
`Attached as Exhibit 10 is a true and correct copy of USP No. 9,444,673.
`
`1
`
`
`
`Case 6:20-cv-00945-ADA Document 33-1 Filed 08/23/21 Page 3 of 3
`
`13.
`
`Attached as Exhibit 11 is a true and correct copy of the Claim Construction Order
`
`in ParkerVision v. Intel Corporation, Case No. 6:20-cv-00108-ADA (Jan. 26, 2021).
`
`14.
`
`Attached as Exhibit 12 is a true and correct copy of the Claim Construction Order
`
`in ParkerVision v. Intel Corporation, Case No. 6:20-cv-00562-ADA (July 22, 2021).
`
`15.
`
`Attached as Exhibit 13 is a true and correct copy of the Patent Owner Preliminary
`
`Response in IPR2014-00948 (Sept. 24, 2014).
`
`16.
`
`Attached as Exhibit 14 is a true and correct copy of the Institution Decision in
`
`IPR2014-00948 (Dec. 18, 2014).
`
`17.
`
`Attached as Exhibit 15 is a true and correct copy of “Subharmonic Sampling of
`
`Microwave Signal Processing Requirements,” by Peter A. Weisskopf (“Weisskopf ”) (Weisskopf
`
`was filed as Petitioner’s Ex. 1023 in IPR2014-00948).
`
`18.
`
`Attached as Exhibit 16 is a true and correct copy of the Patent Owner Response
`
`in IPR2014-00948 (Mar. 19, 2015).
`
`19.
`
`Attached as Exhibit 17 is a true and correct copy of the Motion for Adverse
`
`Judgment in IPR2014-00948 (Oct. 22, 2015).
`
`20.
`
`Attached as Exhibit 18 is a true and correct copy of the Judgment / Final Written
`
`Decision in IPR2014-00948 (Oct. 29, 2015).
`
`21.
`
`I declare, under penalty of perjury, that the foregoing is true and correct to the
`
`best of my knowledge.
`
`Executed on August 23, 2021, in Denver, Colorado.
`
`
`
`
`
`18824972v.1
`
`/s/ Edward J. Mayle
`Edward J. Mayle
`
`
`
`
`
`
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`2
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