`
`CLERK, U.S. DISTRICT COURT
`WESTERN DISTRICT OF TEXAS
`
`BY: ________________________________
`
`FILED
`
`DEPUTY
`
`July 26, 2022
`
`SV
`
`
`
`Case 6:21-cv-00520-ADA Document 63 Filed 07/26/22 Page 2 of 4
`Case 6:21-cv-00520-ADA Document 63 Filed 07/26/22 Page 2 of 4
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`thereafter produce a witness or witnessesto testify regarding the deposition topicsset
`
`forth in Attachment B. The Court requests the witness to be placed underoath, subject
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`to questioning by counselfor the parties to the above-captioned matters, and thata
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`verbatim transcript of the testimony be taken.
`
`The Court understands that the documents and information requested may be of
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`a confidential nature. As such,there is a Protective Order in this case to protect the
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`confidentiality of any documents produced. A copyof the Protective Orderis appended
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`as Attachment C.
`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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`Taiwaneselaw.
`
`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 FTP link via
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`email directly to counsel for the Requesting Party, ParkerVision,Inc. (“ParkerVision”),
`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 63 Filed 07/26/22 Page 3 of 4
`Case 6:21-cv-00520-ADA Document 63 Filed 07/26/22 Page 3 of 4
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`IL.
`
`Facts.
`
`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 claimedin the Asserted Patents
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`relates to, amongotherthings, integratedcircuit chips used for wi-fi, Bluetooth and
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`cellular communications. ParkerVision alleges that LGEtelevisions, and other products,
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`use integrated circuit chips that Realtek manufactures andsells to LGEeither directly or
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`throughthird parties and that these chips read on claimsin the Asserted Patents
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`(“Realtek Chips”). ParkerVision seeks an award of damages from LGE to compensate
`ParkerVision for LGE’s useof the RealtekChips in its products and alleged patent
`
`infringement.
`
`In response to ParkerVision’s infringementclaims, LGEhasasserted defenses
`
`that include noninfringementand patentinvalidity. 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 Realtek Chips that Realtek has sold or
`
`otherwise provided to LGEdirectly or through a third party, the agreements between
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`Realtek and LGE andotherthird parties relating to the Realtek Chips, and the
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`marketing andsale of the Realtek Chips. The deposition topics recited in Attachment B
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`relate to the documents requested in Attachment A, 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 63 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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