Case 6:21-cv-00520-ADA Document 64 Filed 11/08/22 Page 1 of 4
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`IN THE UNITED STATES DISTRICT COURT
`FOR THE WESTERN DISTRICT OF TEXAS
`WACO DIVISION
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`PARKERVISION, INC.,
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`LG ELECTRONICS, INC.,
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`v.
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`Plaintiff,
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`Defendant.
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`Case No. 6:21-cv-00520-ADA
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`JURY TRIAL DEMANDED
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`JOINT MOTION TO STAY
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`Plaintiff ParkerVision, Inc. (“ParkerVision”) and Defendant LG Electronics, Inc. (“LGE”)
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`(collectively, “the Parties”) jointly move to stay all deadlines in this matter for 3 months until and
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`through February 3, 2023, to provide ParkerVision with additional time to secure third-party
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`discovery from Realtek and MediaTek related to the accused products.
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`On July 12, 2022, ParkerVision filed an unopposed motion for issuance of Letters Rogatory
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`to Realtek and MediaTek. Dkt. Nos. 60 & 61. In its Motions, ParkerVision stated that the
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`information in Realtek and MediaTek’s possession is “important to ParkerVision’s ability to
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`demonstrate LGE’s infringement of the Asserted Patents.” Id. at 4.
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`On July 26, 2022, this Court granted issuance of Letters Rogatory to Realtek and
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`MediaTek. Dkt. Nos. 62 & 63.
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`As of November 4, 2022, ParkerVision has not received any discovery from either third
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`party and is seeking to stay the case to allow the Letters Rogatory to proceed. LGE does not
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`oppose ParkerVision’s request. Sequent Energy Management, L.P. v. CPS Energy, No. SA-21-
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`CV-00395, Dkt. No. 31 (W.D. Tex. Dec. 13, 2021) (granting joint stipulation to extend case
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`1
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`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE WESTERN DISTRICT OF TEXAS
`WACO DIVISION
`
`
`
`PARKERVISION, INC.,
`
`
`
`
`
`LG ELECTRONICS, INC.,
`
`
`
`
`v.
`
`
`
`Plaintiff,
`
`Defendant.
`
`
`
`
`
`
`
`
`
`
`Case No. 6:21-cv-00520-ADA
`
`JURY TRIAL DEMANDED
`
`
`
`JOINT MOTION TO STAY
`
`Plaintiff ParkerVision, Inc. (“ParkerVision”) and Defendant LG Electronics, Inc. (“LGE”)
`
`(collectively, “the Parties”) jointly move to stay all deadlines in this matter for 3 months until and
`
`through February 3, 2023, to provide ParkerVision with additional time to secure third-party
`
`discovery from Realtek and MediaTek related to the accused products.
`
`On July 12, 2022, ParkerVision filed an unopposed motion for issuance of Letters Rogatory
`
`to Realtek and MediaTek. Dkt. Nos. 60 & 61. In its Motions, ParkerVision stated that the
`
`information in Realtek and MediaTek’s possession is “important to ParkerVision’s ability to
`
`demonstrate LGE’s infringement of the Asserted Patents.” Id. at 4.
`
`On July 26, 2022, this Court granted issuance of Letters Rogatory to Realtek and
`
`MediaTek. Dkt. Nos. 62 & 63.
`
`As of November 4, 2022, ParkerVision has not received any discovery from either third
`
`party and is seeking to stay the case to allow the Letters Rogatory to proceed. LGE does not
`
`oppose ParkerVision’s request. Sequent Energy Management, L.P. v. CPS Energy, No. SA-21-
`
`CV-00395, Dkt. No. 31 (W.D. Tex. Dec. 13, 2021) (granting joint stipulation to extend case
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`1
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`Case 6:21-cv-00520-ADA Document 64 Filed 11/08/22 Page 2 of 4
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`schedule); see also B&D Produce Sales, LLC v. Packman1, Inc., No. SA-16-CV-99-XR, 2016 WL
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`4435275, at *1 (W.D. Tex. Aug. 19, 2016) (“A district court has the inherent power to stay
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`proceedings.”). Third party discovery will proceed during the stay. Upon expiration of the stay,
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`the Parties will propose a new schedule, with fact discovery proceeding for at least 30 days after
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`the stay is lifted to permit the parties to propound additional discovery and complete depositions
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`of fact witnesses.
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`The parties’ requested stay may also streamline the issues before this Court. See, e.g.,
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`Kirsch Research & Development, LLC v. IKO Indus., Inc., No. 6:20-CV-00317-ADA, 2021 WL
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`4555610, at *2 (E.D. Tex. Mar. 11, 2015) (outlining factors considered by courts in the stay
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`context, including potential for simplifying issues, prejudice to the nonmovant, and the state of the
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`case). For example, final written decisions are expected by the end of November in TCL Indus.
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`Holdings Co., Ltd. v. ParkerVision, Inc. IPR2021-00990 and in TCL Indus. Holdings Co., Ltd. v.
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`ParkerVision, Inc. IPR2021-00985. IPR2021-00990 and IPR2021-00985 involve U.S. Patent Nos.
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`7,110,444 and 7,292,835, respectively, which are the only unexpired patents asserted in this case.
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`The Patent Trial and Appeal Board’s final written decisions in IPR2021-00990 and IPR2021-
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`00985, therefore, may streamline the issues before this Court. There is also no prejudice to either
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`party as the motion is joint and the parties will benefit from the potential streamlining of issues in
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`this case.
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`Thus, to allow ParkerVision to proceed through its Letters Rogatory, and to avoid wasting
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`the Court’s and the Parties’ time and resources, the Parties jointly request that the Court grant a
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`modest 3-month stay.
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`Case 6:21-cv-00520-ADA Document 64 Filed 11/08/22 Page 3 of 4
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`Dated: November 8, 2022
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`/s/Raymond W. Mort, III
`Raymond W. Mort, III
`Texas State Bar No. 00791308
`raymort@austinlaw.com
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`THE MORT LAW FIRM, PLLC
`100 Congress Avenue, Suite 2000
`Austin, Texas 78701
`Tel/Fax: 512-865-7950
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`Of Counsel:
`Ronald M. Daignault (pro hac vice)*
`Chandran B. Iyer (pro hac vice)
`Jason S. Charkow (pro hac vice)*
`rdaignault@daignaultiyer.com
`cbiyer@daignualtiyer.com
`jcharkow@daignaultiyer.com
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`DAIGNAULT IYER LLP
`8618 Westwood Center Drive
`Suite 150
`Vienna, VA 22182
`*Not admitted in Virginia
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`Attorneys for ParkerVision, Inc.
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`Respectfully submitted,
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`/s/ Steven Pepe
`Melissa R. Smith
`GILLAM & SMITH, LLP
`TX State Bar No. 24001351
`303 S. Washington Avenue
`Marshall, Texas 75670
`Telephone: (903) 934-8450
`Facsimile: (903) 934-9257
`melissa@gillamsmithlaw.com
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`Steven Pepe
`Matthew Shapiro
`Michael Morales
`James Stevens
`ROPES & GRAY LLP
`1211 Avenue of the Americas
`New York, NY 10036-8704
`Tel: 212.596.9000
`Fax: 212.596.9090
`Steven.Pepe@ropesgray.com
`Matthew.Shapiro@ropesgray.com
`Michael.Morales@ropesgray.com
`James.Stevens@ropesgray.com
`
`David S. Chun
`Stepan Starchenko
`ROPES & GRAY LLP
`1900 University Ave., 6th Floor
`East Palo Alto, CA 94303-2284
`Tel: 650.617.4000
`Fax: 650.617.4090
`David.Chun@ropesgray.com
`Stepan.Starchenko@ropesgray.com
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`Scott Taylor
`(Admission application forthcoming)
`ROPES & GRAY LLP
`Prudential Tower
`800 Boylston Street
`Boston, MA 02199-3600
`Tel: 617.951.7000
`Fax: 617.951.7050
`Scott.Taylor@ropesgray.com
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`Attorneys for Defendant LG Electronics Inc.
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`Case 6:21-cv-00520-ADA Document 64 Filed 11/08/22 Page 4 of 4
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`CERTIFICATE OF SERVICE
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`The undersigned hereby certifies that, on November 8, 2022, all counsel of record who are
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`deemed to have consented to electronic service are being served with a copy of this document via
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`the Court’s CM/ECF system per Local Rule CV-5(b)(1).
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`/s/ Melissa R. Smith
`Melissa R. Smith
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