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`UNITED STATES DISTRICT COURT
`WESTERN DISTRICT OF TEXAS
`WACO DIVISION
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`Case No. 6:20-cv-00945
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`JURY TRIAL DEMANDED
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`PARKERVISION, INC.,
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`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.
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`Defendants.
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`UNOPPOSED MOTION TO SUBSTITUTE EXHIBITS 17 AND 18 TO
`DEFENDANTS' OPENING CLAIM CONSTRUCTION BRIEF
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`Defendants TCL Industries Holdings Co., TCL Electronics Holdings Ltd., Shenzhen TCL
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`New Technology Co., Ltd., TCL King Electrical Appliances (Huizhou) Co., Ltd., TCL Moka
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`Int’l Ltd., and TCL Moka Manufacturing S.A. DE C.V. (collectively, “TCL” or “Defendants”),
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`hereby move to substitute Exhibit 17 (Attachment 33-18) and Exhibit 18 (Attachment 33-19) to
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`Defendants’ Opening Claim Construction Brief (Dkt. 33) with the attached corrected Exhibit 17
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`(Attachment 33-18) and corrected Exhibit 18 (Attachment 33-19).
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`1
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`Case 6:20-cv-00945-ADA Document 35 Filed 09/14/21 Page 2 of 3
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`DATED: September 14, 2021
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`Respectfully submitted,
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`KILPATRICK TOWNSEND & STOCKTON LLP
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`By: /s/ Kristopher L. Reed
` Kristopher L. Reed (pro hac vice)
`kreed@kilpatricktownsend.com
`Kevin M. Bell (pro hac vice)
`kbell@kilpatricktownsend.com
`Edward J. Mayle (pro hac vice)
`tmayle@kilpatricktownsend.com
`Suite 600, 1400 Wewatta Street
`Denver, CO 80202
`Telephone: (303) 571-4000
`Facsimile: (303) 571-4321
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`Steve R. Borgman
`sborgman@kilpatricktownsend.com
`Suite 4300, 700 Louisiana Street
`Houston, TX 77002
`Telephone: (281) 809-4081
`Facsimile: (281) 990-6826
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`Steven D. Moore (pro hac vice)
`smoore@kilpatricktownsend.com
`Two Embarcadero Center, Suite 1900
`San Francisco, CA 94111
`Telephone: (415) 576-0200
`Facsimile: (415) 576-0300
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`Attorneys for Defendants
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`Case 6:20-cv-00945-ADA Document 35 Filed 09/14/21 Page 3 of 3
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`CERTIFICATE OF SERVICE
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`The undersigned hereby certifies that a true and correct copy of the above and foregoing
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`document has been served on September 14, 2021, to all counsel of record who are deemed to have
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`consented to electronic service via the Court’s CM/ECF system per Local Rule CV-5(b).
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`/s/ Edward J. Mayle
`Edward J. Mayle
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`CERTIFICATE OF CONFERENCE
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`The undersigned hereby certifies that Edward J. Mayle, counsel for Defendants, conferred
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`with Ronald Daignault, counsel for Plaintiff, on September 12, 2021 regarding this Motion, and
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`Plaintiff does not oppose this Motion.
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`/s/ Edward J. Mayle
`Edward J. Mayle
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