`Case 6:21-cv-00520-ADA Document 32-19 Filed 02/23/22 Page 1 of 4
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`EXHIBIT 19-1
`EXHIBIT 19-1
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`Case 6:20-cv-00870-ADA Document 34-1 Filed 08/23/21 Page 1 of 3Case 6:21-cv-00520-ADA Document 32-19 Filed 02/23/22 Page 2 of 4
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`UNITED STATES DISTRICT COURT
`WESTERN DISTRICT OF TEXAS
`WACO DIVISION
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`
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`PARKERVISION, INC.,
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` 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.
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`Defendants.
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`
`
`Case No. 6:20-cv-00945-ADA
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`Case No. 6:20-cv-00870-ADA
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`JURY TRIAL DEMANDED
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`DECLARATION OF EDWARD J. MAYLE IN SUPPORT OF
`DEFENDANTS’ OPENING CLAIM CONSTRUCTION BRIEF
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`Case 6:20-cv-00870-ADA Document 34-1 Filed 08/23/21 Page 2 of 3Case 6:21-cv-00520-ADA Document 32-19 Filed 02/23/22 Page 3 of 4
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`I Edward J. Mayle, upon personal knowledge or information and belief, state as follows:
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`1.
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`I am a lawyer with Kilpatrick Townsend & Stockton LLP, and am counsel for
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`TCL Industries Holdings Co., Ltd., TCL Electronics Holdings Ltd., Shenzhen TCL New
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`Technology Co., Ltd., TCL King Electrical Appliances (Huizhou) Co., Ltd., TCL Moka Int'l Ltd.,
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`and Moka Manufacturing S.A. De C.V. (collectively “TCL”) in Case No. 6:20-cv-00945-ADA,
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`and am counsel for Hisense Co., Ltd. and Hisense Visual Technology Co., Ltd. (f/k/a Qingdao
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`Hisense Electronics Co., Ltd. and Hisense Electric Co., Ltd.) (collectively “Hisense”) in Case No.
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`6:20-cv-00870-ADA. I am admitted to the bars of Colorado and the District of Columbia, and
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`admitted in both of the above-referenced cases pro hac vice. I am over the age of 18 and
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`otherwise competent to make this declaration.
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`2.
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`I make this declaration on my own knowledge, except where otherwise noted. If
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`called upon to testify regarding the contents of this declaration, I could and would completely
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`testify to its accuracy.
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`3.
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`4.
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`5.
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`6.
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`7.
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`8.
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`9.
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`10.
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`11.
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`12.
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`Attached as Exhibit 1 is a true and correct copy of USP No. 6,049,706.
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`Attached as Exhibit 2 is a true and correct copy of USP No. 6,266,518.
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`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.
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`Attached as Exhibit 7 is a true and correct copy of USP No. 8,660,513.
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`Attached as Exhibit 8 is a true and correct copy of USP No. 9,118,528.
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`Attached as Exhibit 9 is a true and correct copy of USP No. 9,246,736.
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`Attached as Exhibit 10 is a true and correct copy of USP No. 9,444,673.
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`1
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`Case 6:20-cv-00870-ADA Document 34-1 Filed 08/23/21 Page 3 of 3Case 6:21-cv-00520-ADA Document 32-19 Filed 02/23/22 Page 4 of 4
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`13.
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`Attached as Exhibit 11 is a true and correct copy of the Claim Construction Order
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`in ParkerVision v. Intel Corporation, Case No. 6:20-cv-00108-ADA (Jan. 26, 2021).
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`14.
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`Attached as Exhibit 12 is a true and correct copy of the Claim Construction Order
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`in ParkerVision v. Intel Corporation, Case No. 6:20-cv-00562-ADA (July 22, 2021).
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`15.
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`Attached as Exhibit 13 is a true and correct copy of the Patent Owner Preliminary
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`Response in IPR2014-00948 (Sept. 24, 2014).
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`16.
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`Attached as Exhibit 14 is a true and correct copy of the Institution Decision in
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`IPR2014-00948 (Dec. 18, 2014).
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`17.
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`Attached as Exhibit 15 is a true and correct copy of “Subharmonic Sampling of
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`Microwave Signal Processing Requirements,” by Peter A. Weisskopf (“Weisskopf ”) (Weisskopf
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`was filed as Petitioner’s Ex. 1023 in IPR2014-00948).
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`18.
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`Attached as Exhibit 16 is a true and correct copy of the Patent Owner Response
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`in IPR2014-00948 (Mar. 19, 2015).
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`19.
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`Attached as Exhibit 17 is a true and correct copy of the Motion for Adverse
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`Judgment in IPR2014-00948 (Oct. 22, 2015).
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`20.
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`Attached as Exhibit 18 is a true and correct copy of the Judgment / Final Written
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`Decision in IPR2014-00948 (Oct. 29, 2015).
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`21.
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`I declare, under penalty of perjury, that the foregoing is true and correct to the
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`best of my knowledge.
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`Executed on August 23, 2021, in Denver, Colorado.
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`
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`
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`18824972v.1
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`/s/ Edward J. Mayle
`Edward J. Mayle
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`2
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