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`PARKERVISION, INC.,
`
`
`
`
`
`LG ELECTRONICS, INC.,
`
`
`
`
`v.
`
`
`
`Plaintiff,
`
`Defendant.
`
`
`
`
`
`
`
`
`
`
`Case No. 6:21-cv-00520-ADA
`
`NOTICE OF SUPPLEMENTAL
`AUTHORITY
`
`Case 6:21-cv-00520-ADA Document 65 Filed 11/22/22 Page 1 of 3
`
`
`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE WESTERN DISTRICT OF TEXAS
`WACO DIVISION
`
`
`
`
`In connection with Defendant LG Electronics, Inc.’s (“LGE”) Miscellaneous Objections
`
`(“Objections”) to Magistrate Judge Gilliland’s Claim Construction Order and Memorandum in
`
`Support Thereof (Dkt. No. 59), LGE provides this notice of supplemental authority to inform the
`
`Court of the Patent Trial and Appeal Board’s (“PTAB”) recent Final Written Decisions in
`
`IPR2021-00985 and IPR2022-00246, finding unpatentable claims 1, 12-15, and 17-20 of U.S.
`
`Patent No. 7,292,835 (“the ’835 patent”), and IPR2021-00990 finding unpatentable claims 2-4 of
`
`U.S. Patent No. 7,110,444 (“the ’444 patent”). A true and correct copy of the Final Written
`
`Decision in IPR2021-00985 and IPR2021-00246, dated November 17, 2022, is attached hereto as
`
`Exhibit A, and the same for the Final Written Decision in IPR2021-00990, dated November 21,
`
`2022, is attached hereto as Exhibit B.
`
`The PTAB construed the “storage module” term in the ’835 patent (see Ex. A at 14-21) in
`
`IPR2021-00985 and IPR2021-00246, in addition to the “storage element” term in the ’444 patent
`
`(see Ex. B at 14-21) in IPR2021-00990. Both terms are at issue in LGE’s Objections. Dkt. No.
`
`59 at 2-8; see also Dkt. No. 55 at 12.
`
`
`
`
`
`1
`
`

`

`Case 6:21-cv-00520-ADA Document 65 Filed 11/22/22 Page 2 of 3
`
`
`
`Dated: November 22, 2022
`
`
`
`
`
`Respectfully submitted,
`
`/s/ Melissa R. Smith
`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
`
`Steven Pepe
`Matthew Shapiro
`James Stevens
`Michael Morales
`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
`James.Stevens@ropesgray.com
`Michael.Morales@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
`
`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
`Attorneys for Defendant LG Electronics Inc.
`
`
`
`2
`
`

`

`Case 6:21-cv-00520-ADA Document 65 Filed 11/22/22 Page 3 of 3
`
`
`
`CERTIFICATE OF SERVICE
`
`The undersigned hereby certifies that, on November 22, 2022, all counsel of record who
`
`are deemed to have consented to electronic service are being served with a copy of this
`
`document.
`
`
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`/s/ Melissa R. Smith
`Melissa R. Smith
`
`
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`3
`
`

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