`
`CLERK, U.S. DISTRICT COURT
`WESTERN DISTRICT OF TEXAS
`
`BY: ________________________________
`
`FILED
`
`DEPUTY
`
`July 26, 2022
`
`SV
`
`
`
`Case 6:21-cv-00520-ADA Document 62 Filed 07/26/22 Page 2 of 4
`Case 6:21-cv-00520-ADA Document 62 Filed 07/26/22 Page 2 of 4
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`a witness or witnessesto testify regarding the deposition topics set forth in Attachment
`
`B. The Court requests the witness to be placed underoath, subject to questioning by
`
`counsel for the parties to the above-captioned matters, and that a verbatim transcript of
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`the testimony be taken.
`
`The Court understandsthat the documents and information requested may beof
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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 AttachmentC.
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`If service cannot be effected at the address indicated above,this Court
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`respectfully requests judicial assistanceto 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 responsebe sent by international courier and througha 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 copies to:
`ChandranB. Iyer at cbiyer@daignaultiyer.com
`and Cathy Pampinella at cpampinella@daignaultiyer.com.
`
`
`
`Case 6:21-cv-00520-ADA Document 62 Filed 07/26/22 Page 3 of 4
`Case 6:21-cv-00520-ADA Document 62 Filed 07/26/22 Page 3 of 4
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`IIL.
`
`Facts.
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`Plaintiff ParkerVisionfiled a lawsuit against Defendant LG Electronics,Inc.
`
`(“LGE”)in the United States District Court for the Western District of Texas.
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`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
`
`(the “Asserted Patents”). The technology described and claimed in the Asserted Patents
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`relates to, amongotherthings, 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 manufacturesandsells to LGEeitherdirectly
`
`or throughthird parties and thatthese chips read on claimsin the Asscrted Patents
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`(“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
`
`infringement.
`
`In response to ParkerVision’s infringement claims, LGE hasasserted defenses
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`that include noninfringementand patent invalidity. The documents requested in
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`AttachmentA provide circuit-level detail of the accused chips used in LGE’s accused
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`products, technical information regarding the MediaTek Chips that MediaTekhas sold
`
`or otherwise provided to LGE directly or through a third party, the agreements between
`MediaTek and LGEandotherthirdparties 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 62 Filed 07/26/22 Page 4 of 4
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`A true copy of the original, I certify.
`Clerk, U.S. District Court
`By___________________________
`Deputy
`
`sv
`
`July 26, 2022
`
`
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