Case 6:21-cv-00520-ADA Document 61-1 Filed 07/12/22 Page 1 of 38
`Case 6:21-cv-00520-ADA Document 61-1 Filed 07/12/22 Page 1 of 38
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`UNITED STATES DISTRICT COURT
`WESTERN DISTRICT OF TEXAS
`
`WACO DIVISION
`
`
`PARKERVISION,INC.,
`
`Plaintiff,
`
`v.
`
`Civil Action No. 6:21-cv-00520-ADA
`
`LG ELECTRONICS,INC.,
`
`Defendant.
`
`
`
`TO THE APPROPRIATE JUDICIAL AUTHORITY OF TAIWAN:
`
`The United States District Court for the Western District of Texas presentsits
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`compliments to the Appropriate Judicial Authority of Taiwan, and requests judicial
`
`assistance to obtain evidenceto be used in a civil proceeding before this Court in the
`
`above-captioned matters.
`
`I
`
`Request.
`
`The Court respectfully requests that the Appropriate Judicial Authority of
`
`Taiwan compel production of documents and testimony of a representative or
`
`representatives from the following corporate entity:
`
`MediaTekInc.
`No.1, Dusing 1% Rd.,
`Hsinchu Science Park,
`Hsinchu 300, Taiwan
`
`Specifically, the Court requests MediaTekInc. (“MediaTek”) to produce the
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`documents and things set forth in Attachment A to this Request and thereafter produce
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`

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`Case 6:21-cv-00520-ADA Document 61-1 Filed 07/12/22 Page 2 of 38
`Case 6:21-cv-00520-ADA Document 61-1 Filed 07/12/22 Page 2 of 38
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`a witness or witnessesto testify regarding the deposition topics set forth in Attachment
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`B. The Court requests the witness to be placed under oath, subject to questioning by
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`counsel for the parties to the above-captioned matters, and that a verbatim transcript of
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`the testimony be taken.
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`The Court understandsthat the documents and information requested maybe of
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`a confidential nature. As such,there is a Protective Orderin this case to protect the
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`confidentiality of any documents produced. A copyof the Protective Order is appended
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`as Attachment C.
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`If service cannot be effected at the address indicated above, this Court
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`respectfully requests judicial assistance to effect service by any means permitted under
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`Taiwanese law.
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`This Court further requests that the executed Letters Rogatory and any evidence
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`producedin responsebesent by international courier and through a secure FTPlink via
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`email directly to counsel for the Requesting Party, ParkerVision,Inc. (“ParkerVision”),
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`at the following mailing and email addresses:
`
`Ronald M.Daignault
`Daignault Iyer LLP
`8618 Westwood Center Drive - Suite 105
`Vienna, VA 22182
`rdaignault@daignaultiyer.com
`
`with copiesto:
`ChandranB. Iyer at cbiyer@daignaultiyer.com
`and Cathy Pampinella at cpampinella@daignaultiyer.com.
`
`

`

`Case 6:21-cv-00520-ADA Document 61-1 Filed 07/12/22 Page 3 of 38
`Case 6:21-cv-00520-ADA Document 61-1 Filed 07/12/22 Page 3 of 38
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`II.
`
`Facts.
`
`Plaintiff ParkerVision filed a lawsuit against Defendant LG Electronics,Inc.
`
`(“LGE”)in the United States District Court for the Western District of Texas.
`
`ParkerVision seeks a judgment that LGE infringes U.S. Patent Nos. 6,049,706; 6,266,518;
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`6,580,902; 7,110,444; 7,292,835; 8,588,725; 8,660,513; 9,118,528; 9,246,736 and 9,444,673
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`(the “Asserted Patents”). The technology described and claimed in the Asserted Patents
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`relates to, among other things, integrated circuit chips used for wi-fi, Bluetooth and
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`cellular communications. ParkerVision alleges that LGE televisions, and other products,
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`use integrated circuit chips that MediaTek manufactures andsells to LGE either directly
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`or throughthird parties and that these chips read on claimsin the Asserted Patents
`
`(“MediaTek Chips”). ParkerVision seeks an award of damages from LGE to compensate
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`ParkerVision for LGE’s use of the MediaTek Chipsin its products and alleged patent
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`infringement.
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`In response to ParkerVision’s infringement claims, LGE has asserted defenses
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`that include noninfringementand patent invalidity. The documents requested in
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`Attachment A providecircuit-level detail of the accused chips used in LGE’s accused
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`products, technical information regarding the MediaTek Chips that MediaTek has sold
`
`or otherwise provided to LGE directly or through a third party, the agreements between
`
`MediaTek and LGEandotherthird parties relating to the MediaTek Chips, and the
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`marketing and sale of the MediaTek Chips. The deposition topics recited in Attachment
`
`B relate to the documents requested in AttachmentA, as described generally above, and
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`the authentication and business-record nature of the requested documents. The
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`

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`Case 6:21-cv-00520-ADA Document 61-1 Filed 07/12/22 Page 4 of 38
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`requested documents and deposition testimony are therefore important to
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`ParkerVision’s ability to demonstrate LGE’s infringement of the Asserted Patents and to
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`properly and fully respond to LGE’s defenses.
`
`III.
`
`Offer of Reciprocal Assistance.
`
`The United States District Court for the Western District of Texas is willing to
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`provide similar assistance to the Appropriate Judicial Authority of Taiwan. See 28
`
`U.S.C. § 1782.
`
`IV.
`
`Reimbursementfor Costs.
`
`This Court, through Plaintiff ParkerVision, is willing to reimburse the
`
`Appropriate Judicial Authority of Taiwan for costs and expenses incurred in executing
`
`these Letters Rogatory.
`
`DATEDthis
`
`day of
`
`, 2022.
`
`Respectfully Requested,
`
`The Honorable Alan D Albright
`United States District Judge
`for the Western District of Texas
`800 Franklin Avenue
`Waco, Texas 76701
`United States of America
`Tel.: +1 (254) 750-1519
`
`(SEAL OF THE COURT)
`
`

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`Case 6:21-cv-00520-ADA Document 61-1 Filed 07/12/22 Page 5 of 38
`Case 6:21-cv-00520-ADA Document 61-1 Filed 07/12/22 Page 5 of 38
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`ATTACHMENT A
`
`DEFINITIONS
`
`Asusedin herein, the following terms shall have the following meanings:
`
`1.
`
`“And”and “or” shall have both the conjunctive and disjunctive meaning
`
`andshall be construedto include, rather than exclude material from the scope of the
`
`request.
`
`2.
`
`“Any”or “each” shall be construed to encompass“all.” “Any” includes
`
`both “any” and “every.” “All” shall be construed to include and encompass“any.”
`
`3.
`
`“Concerning,”
`
`“referring to,” or “relating to” means pertainingto,
`
`ut
`
`mentioning, commenting on, connected with, discussing, describing, analyzing,
`
`explaining, showing,reflecting, dealing with, comprising, consisting of, containing,
`
`constituting, referring to, resulting from, or recording a particular subject in wholeor in
`
`part and either directly or indirectly.
`
`4.
`
`5.
`
`“Communication” means the transmittal of information.
`
`“Component Provider” means any entity that manufacturers, sells, offers
`
`for sale, and/or provides any module, componentor part containing a MediaTek Chip
`
`where such module, componentor part is incorporated into, intended to be
`
`incorporated into, or used in any LGE Products.
`
`6.
`
`“Control” shall mean actual and constructive control, custody,
`
`knowledge, and/or possession by any one or a combination of the following persons:
`
`a.
`
`MediaTek;
`
`

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`Case 6:21-cv-00520-ADA Document 61-1 Filed 07/12/22 Page 6 of 38
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`b.
`
`Anycorporation or other entity controlled by, directed by, or
`
`affiliated with MediaTek;
`
`c.
`
`Anyofficer, principal, director, trustee, employee, staff member,
`
`agent, joint venturer, partner, accountant, consultant, advisor, investigator, or
`
`any other representative of MediaTek;
`
`d.
`
`Anyofficer, principal, director, trustee, employee, staff member,
`
`agent, joint venturer, partner, accountant, consultant, advisor, investigator, or
`
`any other representative belonging to a corporation or other entity controlled by,
`
`directed by,oraffiliated with MediaTek;
`
`e.
`
`f.
`
`Counsel for MediaTek; and
`
`Counsel for any corporation or other entity controlled by, directed
`
`by,or affiliated with MediaTek.
`
`7.
`
`“Document” is used in a comprehensive senseasset forth in Rule 34(a) of
`
`the Federal Rules of Civil Procedure, including withoutlimitation, electronic or
`
`computerized data compilations. A draft or non-identical copy is a separate document
`
`within the meaning of this term.
`
`8.
`
`“MediaTek” means MediaTekInc. and(a) any of its present or former
`
`divisions, departments, businesses, subsidiaries, or other organization or operational
`
`units; (b) all predecessor, successor, or assignee entities; (c) all present or former
`
`member companies, corporations, partnerships, associations, or other businessentities;
`
`and (d) present or formerofficers, directors, employees, agents, consultants,
`
`

`

`Case 6:21-cv-00520-ADA Document 61-1 Filed 07/12/22 Page 7 of 38
`Case 6:21-cv-00520-ADA Document 61-1 Filed 07/12/22 Page 7 of 38
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`accountants, attorneys (including in-house and outside counsel), or other
`
`representatives (in their individual or representative capacities).
`
`9.
`
`“MediaTek Chip(s)” means any andall receiver, transmitter and/or
`
`transceiver integrated circuits, and/or components/ modules containing or
`
`incorporating any andall receiver, transmitter and/or transceiver integrated circuits
`
`that (a) MediaTek has sold to LGE from 2014 to the present including, but not limited
`
`to, the MediaTek MT7612UN; or (b) MediaTek has sold to a Component Provideror
`
`any other third party from 2015 to the present and that is incorporated into, intended to
`
`be incorporated into, or used in any LGE Products including, but not limited to, the
`
`MediaTek MT7612UN.
`
`10.
`
`“LGE Products” means any product that LGE has made, used,sold,
`
`imported in/into the United States and/or offered for sale, including but not limited to
`
`modules, LGE-brandedtelevisions, Sharp-brandedtelevisions, or televisions sold under
`
`any other brand that incorporate and use MediaTek Chip(s).
`
`11.
`
`“ParkerVision” or “Plaintiff” means ParkerVision, Inc. and any parents,
`
`divisions, subsidiaries, and affiliates, or any present or formerofficers, directors,
`
`employees, agents, consultants, or other representatives thereof.
`
`12.
`
`“Patents-in-suit” mean U.S. Patent Nos. 6,049,706; 6,266,518; 6,580,902;
`
`7,110,444; 7,292,835; 8,588,725; 8,660,513; 9,118,528; 9,246,736 and 9,444,673.
`
`INSTRUCTIONS
`
`The following instructions are applicable to terms in each discovery request
`
`unless otherwise explicitly stated:
`
`

`

`Case 6:21-cv-00520-ADA Document 61-1 Filed 07/12/22 Page 8 of 38
`Case 6:21-cv-00520-ADA Document 61-1 Filed 07/12/22 Page 8 of 38
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`1.
`
`In producing the documents and things requested, you shall furnishall
`
`documents and things knownoravailable to you within your possession, custody, or
`
`control, including all documents and things in possession, custody, or control of your
`
`attorneys, as well as anyoneacting on your behalf.
`
`2.
`
`These Requests extendto all things within your actual or constructive
`
`possession, custodyor control, or the possession, custody, or control of those acting at
`
`yourdirection or on your behalf.
`
`3.
`
`All documents produced in response to a discovery request should be
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`producedin their full and complete form, includingall their original unredacted
`
`material. If an English language version or translation of non-English documents or
`
`business records exists, both the non-English documents or business records and the
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`English languageversion or translation should be produced.
`
`4.
`
`If any documents are withheld on the basis of any claim of privilege or
`
`immunity from discovery, please produce a log of such documents with enough detail
`
`to assess the claim, including without limitation:
`
`a.
`
`b.
`
`c.
`
`d.
`
`e.
`
`the reasons the documentis not being produced.If the documentis
`withheld on the basis of privilege, identify the nature of the privilege
`(including work product);
`
`the general nature of the document or communication (memorandum,
`pamphlet, report, etc.);
`
`the general subject matter of the document or communication;
`
`the date of the document or communication;
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`the identity of each person involved in preparation of the document or
`communication;
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`

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`Case 6:21-cv-00520-ADA Document 61-1 Filed 07/12/22 Page 9 of 38
`Case 6:21-cv-00520-ADA Document 61-1 Filed 07/12/22 Page 9 of 38
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`the identity of each person whosigned the document or communication;
`
`the identity of each person designated as an addressee;
`
`the identity of each person designated to receive a copy of the document
`or communication;
`
`the date and mannerof distribution or publication of the original and each
`copy of the document;
`
`the identity of each person whoreceived the original of the document;
`
`the identity of each person whoreceived a copy of the document; and
`
`the present location of the documentandthefiles within which the
`documentwasfound.
`
`5.
`
`If the meaning of any term in these Requests is unclear, you should
`
`assumea reasonable meaning, state what the assumed meaningis, and produce
`
`documents based on that assumed meaning.
`
`6.
`
`If any requested document is knownor believed to have existed and
`
`cannot nowbelocated or has been destroyed or discarded, identify the documentby:
`
`a.
`
`b.
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`nature(e.¢., letter, memorandum, email, invoice);
`
`subject matter;
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`numberof pages;
`
`title, file name, and any identifying codeor file number;
`
`date of creation;
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`date of transmittal;
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`author(s) and/or last known custodian of the document;
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`actual and intended recipient(s);
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`the identity of each person whoactually read the original or a copy of the
`document(to the extent that the identity can be ascertained from the
`original or any copy);
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`

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`Case 6:21-cv-00520-ADA Document 61-1 Filed 07/12/22 Page 10 of 38
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`j.
`
`k.
`
`1.
`
`7.
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`the date, manner, and reason for the document’sloss or destruction;
`
`the persons authorizing, responsible for, and participating in the
`document's loss or destruction; and
`
`the efforts made to locate such document.
`
`Each Request shall be answered separately, and you shall indicate for each
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`answerthe Request to which they respond.
`
`REQUESTS FOR PRODUCTION
`
`REQUEST FOR PRODUCTIONNO.1.
`
`Documents sufficient to show the design, layout, architecture, configuration,
`
`operation, manufacture, and/or implementation of each MediaTek Chip, including
`
`withoutlimitation, (1) the system architecture and design of each MediaTek Chip,(2) any
`
`andall design guidelines and specifications, including withoutlimitation, guidelines and
`
`specifications that MediaTek or a third party acting on MediaTek’s behalf provided to
`
`LGErelating to a MediaTek Chip,(3) the correlation between each MediaTek Chip code
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`name(s) and model number(s) of each LGE Product, (4) any andall operating bands and
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`operating modesof each LGE Product, (5) the foundry used to make each MediaTek Chip,
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`(6) any and all process nodesfor each MediaTek Chip,(7) any andall register settings for
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`each of the operating bands and operating modes of each LGE Product, (8) any and all
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`components values including, without limitation, the values of any andall capacitors and
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`resistors, (9) chip top including, withoutlimitation,all internal and external labels/names
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`of connections, and (10) any andall configurations of, modifications to, and/or changes
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`to the MediaTek Chip that resulted in the reduction and/or elimination of components
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`

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`Case 6:21-cv-00520-ADA Document 61-1 Filed 07/12/22 Page 11 of 38
`Case 6:21-cv-00520-ADA Document 61-1 Filed 07/12/22 Page 11 of 38
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`(including, without limitation, pads, connections, SAW filters and/or BAW filters) on
`
`andoff chip.
`
`REQUEST FOR PRODUCTIONNO.2.
`
`All schematics for each of the MediaTek Chips.
`
`REQUEST FOR PRODUCTIONNO.3.
`
`Anyand all documentsrelated to (1) research and developmentand(2) design
`
`review of each MediaTek Chip.
`
`REQUEST FOR PRODUCTIONNO.4.
`
`For each MediaTek Chip, documents sufficient to show (1) design document
`
`hierarchy and (2) the hierarchy of schematics with library nameandcell name for each
`
`cell.
`
`REQUEST FOR PRODUCTIONNO.5.
`
`All documents related to product roadmapsfor each MediaTek Chip and/or
`
`MediaTek products incorporating MediaTek Chips.
`
`REQUEST FOR PRODUCTIONNO.6.
`
`Anyandall documents relating to whether a MediaTek Chip for use in an LGE
`
`Product can be used with, and/or is compatible with, wireless technologies and/or
`
`standards(including, but not limited to Bluetooth and 802.11) in the United States.
`
`REQUEST FOR PRODUCTIONNO.7.
`
`Anyand all documentsrelating to the testing of each MediaTek Chip
`
`incorporated into each LGE Product.
`
`

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`Case 6:21-cv-00520-ADA Document 61-1 Filed 07/12/22 Page 12 of 38
`Case 6:21-cv-00520-ADA Document 61-1 Filed 07/12/22 Page 12 of 38
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`REQUEST FOR PRODUCTIONNO.8.
`
`Documents sufficient to identify each and every model of MediaTek Chip that
`
`LGEhas purchased from MediaTek and/or from any third party for use in a LGE
`
`Product.
`
`REQUEST FOR PRODUCTIONNO.9.
`
`Documents sufficient to identify any and all LGE Products incorporating a
`
`MediaTek Chip.
`
`REQUEST FOR PRODUCTION NO.10.
`
`Any andall documentsrelated to the marketing of the MediaTek Chips and/or
`
`MediaTek products incorporating MediaTek Chips.
`
`REQUEST FOR PRODUCTION NO.11.
`
`Regarding any MediaTek Chip and/or LGE Products incorporating MediaTek
`
`Chips, any and all communications between MediaTek and LGEregarding the design,
`
`layout, architecture, configuration, operation, manufacture, implementation, research,
`
`development, specifications, guidelines, requirements, features, testing, operating
`
`bands, operating modes, componentvalues, and register settings for each of the
`
`operating bands and operating modes.
`
`REQUEST FOR PRODUCTION NO.12.
`
`All agreements (1) between MediaTek and LGErelating to any MediaTek Chip
`
`and/or any LGE Product; (2) between MediaTek and any manufacturer of a MediaTek
`
`Chip; (3) between MediaTek and any manufacturer of a LGE Product containing a
`
`MediaTek Chip (4) between MediaTek and any Component Provider, and/or (5)
`
`

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`Case 6:21-cv-00520-ADA Document 61-1 Filed 07/12/22 Page 13 of 38
`Case 6:21-cv-00520-ADA Document 61-1 Filed 07/12/22 Page 13 of 38
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`between MediaTek and anythird party providing MediaTek Chipsdirectly or indirectly
`
`to a ComponentProvider.
`
`REQUEST FOR PRODUCTIONNO.13.
`
`Anyandall reseller agreements relating to each MediaTek Chip and/or
`
`MediaTek products incorporating MediaTek Chips.
`
`REQUEST FOR PRODUCTIONNO.14.
`
`From 2013 to the present, documents sufficient to show on a quarterly basis(1)
`
`the total unit number of MediaTek Chips sold or provided to LGE or a Component
`
`Provider (or any third party providing MediaTek Chipsdirectly or indirectly to a
`
`ComponentProvider) and the unit price for each such MediaTek Chip, and (2) with
`
`regardto (1), the identity of the entity to which MediaTek Chips weresold, offered for
`
`sale, provided or delivered and the location where (and entity to which) such MediaTek
`
`Chips were delivered.
`
`REQUEST FOR PRODUCTIONNO.15.
`
`Anyand all documents referencing ParkerVision or any ParkerVision patents
`
`(including, without limitation, the Patents-in-suit) or any code nameoridentifier for
`
`ParkerVision including, withoutlimitation, any and all documentsrelating to any
`
`effort(s) or attempt(s) to (1) design, redesign, or modify any MediaTek Chips and/or
`
`MediaTek products incorporating MediaTek Chips in view of any ParkerVision patents
`
`(including, withoutlimitation, the Patents-in-suit) and/or (2) design around any
`
`ParkerVision patents (including, withoutlimitation, the Patents-in-suit).
`
`

`

`Case 6:21-cv-00520-ADA Document 61-1 Filed 07/12/22 Page 14 of 38
`Case 6:21-cv-00520-ADA Document 61-1 Filed 07/12/22 Page 14 of 38
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`ATTACHMENTB
`
`DEFINITIONS
`
`Asusedin herein, the following terms shall have the following meanings:
`
`1.
`
`“And” and “or” shall have both the conjunctive and disjunctive meaning
`
`andshall be construedto include, rather than exclude material from the scope of the
`
`request.
`
`2.
`
`“Any”or “each” shall be construed to encompass“all.” “Any” includes
`
`both “any” and “every.” “All” shall be construed to include and encompass“any.”
`
`3.
`
`“Concerning,”
`
`“referring to,” or “relating to” means pertainingto,
`
`ut
`
`mentioning, commenting on, connected with, discussing, describing, analyzing,
`
`explaining, showing,reflecting, dealing with, comprising, consisting of, containing,
`
`constituting, referring to, resulting from, or recording a particular subject in whole or in
`
`part and either directly or indirectly.
`
`4.
`
`5.
`
`“Communication” means the transmittal of information.
`
`“Component Provider” means any entity that manufacturers, sells, offers
`
`for sale, and/or provides any module, componentor part containing a MediaTek Chip
`
`where such module, componentor part is incorporated into, intended to be incorporated
`
`into, or used in any LGE Products.
`
`6.
`
`“Control” shall mean actual and constructive control, custody, knowledge,
`
`and/or possession by any oneor a combination of the following persons:
`
`a.
`
`b.
`
`MediaTek;
`
`Anycorporation or other entity controlled by, directed by, or
`
`

`

`Case 6:21-cv-00520-ADA Document 61-1 Filed 07/12/22 Page 15 of 38
`Case 6:21-cv-00520-ADA Document 61-1 Filed 07/12/22 Page 15 of 38
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`affiliated with MediaTek;
`
`c.
`
`Anyofficer, principal, director, trustee, employee, staff member,
`
`agent, joint venturer, partner, accountant, consultant, advisor, investigator, or any
`
`other representative of MediaTek;
`
`d.
`
`Anyofficer, principal, director, trustee, employee, staff member,
`
`agent, joint venturer, partner, accountant, consultant, advisor, investigator, or any
`
`other representative belonging to a corporation or other entity controlled by,
`
`directed by,or affiliated with MediaTek;
`
`e.
`
`f.
`
`Counsel for MediaTek; and
`
`Counsel for any corporation or other entity controlled by, directed
`
`by,or affiliated with MediaTek.
`
`7.
`
`“Document”is used in a comprehensive senseasset forth in Rule 34(a) of
`
`the Federal Rules of Civil Procedure, including withoutlimitation, electronic or
`
`computerized data compilations. A draft or non-identical copy is a separate document
`
`within the meaning of this term.
`
`8.
`
`“MediaTek” means MediaTekInc. and(a) any of its present or former
`
`divisions, departments, businesses, subsidiaries, or other organization or operational
`
`units; (b) all predecessor, successor, or assignee entities; (c) all present or former member
`
`companies, corporations, partnerships, associations, or other business entities; and (d)
`
`present or formerofficers, directors, employees, agents, consultants, accountants,
`
`attorneys(including in-house and outside counsel), or other representatives (in their
`
`individual or representative capacities).
`
`

`

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`Case 6:21-cv-00520-ADA Document 61-1 Filed 07/12/22 Page 16 of 38
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`9.
`
`“MediaTek Chip(s)” means any andall receiver, transmitter and/or
`
`transceiver integrated circuits, and/or components/ modules containing or incorporating
`
`any andall receiver, transmitter and/or transceiver integrated circuits that (a) MediaTek
`
`has sold to LGE from 2014 to the present including, but not limited to, the MediaTek
`
`MT7612UN;or (b) MediaTek has sold to a ComponentProvider or any other third party
`
`from 2015 to the present and that is incorporated into, intended to be incorporated into, or
`
`used in any LGE Products including, but not limited to, the MediaTek MT7612UN.
`
`10.
`
`“LGE Products” means any product that LGE has made, used,sold,
`
`imported in/into the United States and/or offered for sale, including but not limited to
`
`modules, LGE-brandedtelevisions, Sharp-brandedtelevisions, or televisions sold under
`
`any other brand that incorporate and use MediaTek Chip(s).
`
`11.
`
`“ParkerVision” or “Plaintiff” means ParkerVision, Inc. and any parents,
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`divisions, subsidiaries, and affiliates, or any present or formerofficers, directors,
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`employees, agents, consultants, or other representatives thereof.
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`12.
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`“Patents-in-suit” mean U.S. Patent Nos. 6,049,706; 6,266,518; 6,580,902;
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`7,110,444; 7,292,835; 8,588,725; 8,660,513; 9,118,528; 9,246,736 and 9,444,673.
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`TOPICS FOR DEPOSITION
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`You are required to provide one or more individuals who are knowledge and
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`competent to provide testimony aboutthe following topics:
`
`Topic No.1.
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`The design, layout, architecture, configuration, operation, manufacture, and/or
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`implementation of each MediaTek Chip including, without limitation, (1) system
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`

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`Case 6:21-cv-00520-ADA Document 61-1 Filed 07/12/22 Page 17 of 38
`Case 6:21-cv-00520-ADA Document 61-1 Filed 07/12/22 Page 17 of 38
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`architecture and design, (2) any andall design guidelines and specifications including,
`
`withoutlimitation, guidelines and specifications that MediaTek madeor makesavailable
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`to any third party including, without limitation, LGE, (3) correspondence between
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`MediaTek Chip code name(s) and model number(s), (4) any andall operating bands and
`
`operating modes, (5) the foundry used to make the MediaTek Chip,(6) any andall
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`process nodesfor the MediaTek Chip,(7) any andall register settings for each of the
`
`operating bands and operating modes,(8) any and all components valuesincluding,
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`withoutlimitation, the values of any andall capacitors andresistors, (9) chip top
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`including, withoutlimitation, all internal and external labels/names of connections, and
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`(10) any andall configurations of, modifications to, and/or changes to the MediaTek Chip
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`that resulted in the reduction and/or elimination of components (including, without
`
`limitation, pads, connections, SAW filters and/or BAWfilters) on and off chip.
`
`Topic No.2.
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`All schematics for each of the MediaTek Chips.
`
`Topic No.3.
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`For each MediaTek Chip, documents sufficient to show (1) design document
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`hierarchy and (2) the hierarchy of schematics with library name and cell name for each
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`cell.
`
`Topic No.4.
`
`The research and development, and design review of each MediaTek Chip.
`
`Topic No.5.
`
`The testing of each MediaTek Chip incorporated into each LGE Product.
`
`

`

`Case 6:21-cv-00520-ADA Document 61-1 Filed 07/12/22 Page 18 of 38
`Case 6:21-cv-00520-ADA Document 61-1 Filed 07/12/22 Page 18 of 38
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`Topic No.6.
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`Marketing of the MediaTek Chips and/or MediaTek products incorporating
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`MediaTek Chips.
`
`Topic No.7.
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`The identification of each and every model of MediaTek Chip that LGE has
`
`purchased from MediaTek and/or from any third party for use in a LGE Product.
`
`Topic No.8.
`
`Communications between MediaTek and LGEregardingthe design, layout,
`
`architecture, configuration, operation, manufacture, implementation, research,
`
`development, specifications, guidelines, requirements, features, testing, operating bands,
`
`operating modes, componentvalues, and register settings for each of the operating bands
`
`and operating modes.
`
`Topic No.9.
`
`All agreements (1) between MediaTek and LGErelating to any MediaTek Chip
`
`and/or any LGE Product; (2) between MediaTek and any manufacturer of a MediaTek
`
`Chip; (3) between MediaTek and any manufacturer of an LGE Product containing a
`
`MediaTek Chip; (4) between MediaTek and any ComponentProvider; and/or(5)
`
`between MediaTek and anythird party providing MediaTek Chipsdirectly or indirectly
`
`to a ComponentProvider.
`
`Topic No. 10.
`
`From 2014to the present, (1) the total unit number of MediaTek Chipssold or
`
`provided to LGE or a ComponentProvider(or any third party providing MediaTek Chips
`
`directly or indirectly to a Component Provider) and the unit price for each such
`
`5
`
`

`

`Case 6:21-cv-00520-ADA Document 61-1 Filed 07/12/22 Page 19 of 38
`Case 6:21-cv-00520-ADA Document 61-1 Filed 07/12/22 Page 19 of 38
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`MediaTek Chip, and (2) with regardto (1), the identity of the entity to which MediaTek
`
`Chips were sold, offered for sale, provided or delivered and the location where (and
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`entity to which) such MediaTek Chips were delivered.
`
`Topic No. 11.
`
`Anyeffort(s) or attempt(s) to (1) design, redesign, or modify any MediaTek Chips
`
`and/or MediaTek products incorporating MediaTek Chips in view of any ParkerVision
`
`patents (including, without limitation, the Patents-in-suit) and/or (2) design around any
`
`ParkerVision patents (including, withoutlimitation, the Patents-in-suit).
`
`Topic No. 12.
`
`The authentication and business-record nature of the documents MediaTek
`
`produced in response to ParkerVision’s document subpoena.
`
`

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`ATTACHMENT C
`ATTACHMENT C
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`

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`Case 6:21-cv-00520-ADA Document 61-1 Filed 07/12/22 Page 21 of 38
`Céss6 @PD-rcQOGR2AABRA DBnoura6ha Riedl OG/29/22 Page 2 doiss
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`IN THE UNITED STATES DISTRICT COURT
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`FOR THE WESTERN DISTRICT OF TEXAS
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`WACODIVISION
`
`-cv-520-
`1
`Case No. 6:21-cv-520-ADA
`
`§ §
`
`§ §
`
`§ §
`
`§
`§
`
`§ § § §
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`PARKERVISION,INC.,
`
`Plaintiff,
`
`v.
`LG ELECTRONICS,INC.,
`
`Defendant.
`
`PROTECTIVE ORDER
`
`WHEREAS, Plaintiff PARKERVISION,INC. and Defendant LG ELECTRONICS, INC.,
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`hereafter referred to individually as a “Party”! and collectively as “the Parties,” believe that certain
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`informationthat is or will be encompassed by discovery demandsbythe Parties involves the
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`production or disclosure of trade secrets, confidential business information, or other proprietary
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`information;
`
`WHEREAS, the Parties seek a protective orderlimiting disclosure thereofin accordance with
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`Federal Rule of Civil Procedure 26(c):
`
`THEREFORE,it is hereby stipulated among the Parties and ORDEREDthat:
`
`' This Protective Order also protects confidential documents, information, or materials produced
`in this litigation by a non-party to the litigation (“Third Party”) pursuant to subpoena or other
`similar discovery request. Such Third Party will be considered a producing “Party” for purposes
`of this Protective Order. Nothing in the Protective Order prevents such a Third Party from
`seeking a supplement or addendum to this Protective Order with provisionsthat are different or
`morerestrictive than the provisions herein.
`
`

`

`Case 6:21-cv-00520-ADA Document 61-1 Filed 07/12/22 Page 22 of 38
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`1.
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`Each Party may designate as confidential for protection underthis Order, in wholeorin part,
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`any document, information, or material that constitutes or includes, in whole orin part,
`
`confidential or proprietary information ortradesecrets ofthe Party or a Third Party” to
`
`whom the Party reasonably believes it owes an obligation of confidentiality with respect
`
`to such document, information, or material (“Protected Material”). Protected Material
`
`shall be designated by the Party producing it by affixing a legend or stamp on such
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`document, information, or material as follows: “CONFIDENTIAL,” “CONFIDENTIAL-
`
`ATTORNEYS’ EYES ONLY,” “CONFIDENTIAL - OUTSIDE ATTORNEYS’ EYES
`
`ONLY,”or “CONFIDENTIAL - SOURCE CODE”(“DESIGNATED MATERIAL”).?
`
`The designation shall be placed clearly on each pageofthe Protected Material (except
`
`deposition and hearing transcripts) for which such protection is sought. For deposition
`
`and hearing transcripts, the designation shall be placed on the cover page ofthe transcript
`
`(if not already present on the cover page of the transcript when received from the court
`
`reporter) by each attorney receiving a copy of the transcript after that attorney
`
`receives notice of the designation of someorall of that transcript as DESIGNATED
`
`MATERIAL.
`
`2.
`
`Any documentproduced before issuance of this Order, including pursuant to the Court’s
`
`Order Governing Proceedings- Patent Case, with the designation “Confidential” or the
`
`* Nothing in this Protective Order obligates a Party to produce confidential documents,
`information, or materials in violation of a legal or contractual obligation of nondisclosure to a
`Third Party. The parties agree to use best efforts to obtain consent to produce Third Party
`materials subject to a legal or contractual restriction.
`3 The term DESIGNATED MATERIAL.”is used throughoutthis Protective Orderto refer to the
`class of Protected Material designated as “CONFIDENTIAL,” “CONFIDENTIAL-
`ATTORNEYS’ EYES ONLY,” “CONFIDENTIAL - OUTSIDE ATTORNEYS’ EYES ONLY,”
`or “CONFIDENTIAL - SOURCE CODE,”individually and collectively.
`
`

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`Case 6:21-cv-00520-ADA Document 61-1 Filed 07/12/22 Page 23 of 38
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`like, shall receive the same treatmentas if designated “CONFIDENTIAL”underthis
`
`order and any such documents produced with the designation “Confidential - Outside
`
`Attorneys’ Eyes Only”shall receive the same treatmentas if designated
`
`“CONFIDENTIAL - OUTSIDE ATTORNEYS’ EYES ONLY”underthis Order, unless
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`and until such documentis re-designated to have a different classification underthis
`
`Order.
`
`With respect to documents, information, or material designated as DESIGNATED
`
`MATERIALsubject to the provisions herein and unless otherwise stated, this Order
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`governs, without limitation: (a) all documents, electronically stored information, and/or
`
`things as defined by the Federal Rules of Civil Procedure;(