Case 6:22-cv-01162-ADA Document 111-2 Filed 07/12/24 Page 1 of 47
`Case 6:22-cv-01162-ADA Document 111-2 Filed 07/12/24 Page 1 of 47
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`EXHIBIT B
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`EXHIBIT B
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`Case 6:22-cv-01162-ADA Document 111-2 Filed 07/12/24 Page 2 of 47
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`IN THE UNITED STATES DISTRICT COURT
`FOR THE WESTERN DISTRICT OF TEXAS
`WACO DIVISION
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` Plaintiff,
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`PARKERVISION, INC.,
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` v.
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`REALTEK SEMICONDUCTOR CORP.,
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` Defendant.
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`Case No. 6:22-cv-01162-ADA
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`JURY TRIAL DEMANDED
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`PLAINTIFF PARKERVISION INC.’S RESPONSES AND OBJECTIONS TO
`DEFENDANT REALTEK SEMICONDUCTOR CORP.’S FIRST SET OF
`REQUESTS FOR PRODUCTION (NOS. 1-63)
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`Pursuant to Rules 26 and 34 of the Federal Rules of Civil Procedure and the Local Rules of
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`this Court, Plaintiff ParkerVision, Inc. (“ParkerVision” or “Plaintiff”) hereby responds to
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`Defendant Realtek Semiconductor Corp.’s (“Realtek” or “Defendant”) First Set of Requests for
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`Production (Nos. 1-63) as follows:
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`GENERAL OBJECTIONS
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`ParkerVision makes the following general responses and objections (“General Objections”),
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`which apply to each individual Request, whether specifically restated therein, and shall have the
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`same force and effect as if fully set forth or specifically cited in response to each individual
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`Request.
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`1.
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`ParkerVision objects to each Request to the extent that it seeks information,
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`documents, or things protected by any applicable privilege including, without limitation, the
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`attorney-client privilege, the work product doctrine, or any other applicable privilege, immunity
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`and valid grounds for withholding documents or information from production (“privileged
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`Case 6:22-cv-01162-ADA Document 111-2 Filed 07/12/24 Page 3 of 47
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`material”). Nothing contained in ParkerVision’s responses is intended to be, or in any way shall be
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`deemed to be, a waiver of any applicable privilege or immunity. In responding to each Request,
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`ParkerVision will not provide privileged or otherwise protected information, documents, or things.
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`Any inadvertent release of privileged information, documents, or material shall not constitute a
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`waiver of any applicable privilege or immunity with respect to the information, documents, or
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`things produced.
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`2.
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`ParkerVision objects to each Request to the extent that it seeks information,
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`documents, or things, that are not in ParkerVision’s possession, custody, or control and/or require
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`more than a reasonable search to locate. ParkerVision further objects to each Request to the extent
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`it seeks information, documents, or things that are already in the possession, custody, or control of
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`Defendant or third parties. ParkerVision further objects to each Request to the extent it seeks
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`information, documents or things that are in the public domain and are of no greater burden for
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`Defendant to obtain than ParkerVision. In responding to the Requests, ParkerVision will not
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`conduct searches of publicly accessible databases, publicly available literature, or publicly
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`accessible libraries, or collect or organize information, documents, or things that are as accessible
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`to Defendant as they are to ParkerVision. Unless otherwise indicated specifically below,
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`ParkerVision will not produce such documents or disclose such information.
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`3.
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`ParkerVision objects to each and every Request, Definition, and Instruction to the
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`extent they seek to impose obligations or responsibilities on ParkerVision in addition to or different
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`from those mandated by the Federal Rules of Civil Procedure, the Local Rules of the United States
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`District Court for the Western District of Texas, or any other applicable rule, law, or doctrine.
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`4.
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`ParkerVision further objects to these “Definitions” and “Instructions” to the extent
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`they purport to alter the plain meaning or scope of any Request on the ground that such alteration
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`renders the Request vague, ambiguous, overly broad, or unduly burdensome.
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`5.
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`ParkerVision objects to Defendant’s definition of “You,” “Plaintiff,” and/or
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`“ParkerVision” as overly broad, unduly burdensome, vague, ambiguous, and imposing on
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`ParkerVision a burden of production that exceeds those required under the Federal Rules of Civil
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`Procedure.
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`6.
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`ParkerVision objects to Defendant’s definitions of “Related Application” and
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`“Related Patent” as overly broad, unduly burdensome, vague, and ambiguous. ParkerVision further
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`objects to each definition as it is used to seek information that is neither relevant nor reasonably
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`calculated to lead to the discovery of admissible evidence.
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`7.
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`ParkerVision objects to Defendant’s definitions of “document,” “communication,”
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`“thing(s),” and “agreement” as overly broad, unduly burdensome, vague, and ambiguous.
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`ParkerVision further objects to the definitions to the extent they seek to impose discovery
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`obligations in excess of those required by Rules 26 and 34 of the Federal Rules of Civil Procedure,
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`the Court’s Local Rules, or any applicable court order.
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`8.
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`ParkerVision objects to Defendant’s definition of “discuss,” “concern,”
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`“concerning,” “refer to,” “relate to,” and “relating to” as overly broad, unduly burdensome, vague,
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`ambiguous, and imposing on ParkerVision a burden of production that exceeds those required by
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`Rules 26 and 34 of the Federal Rules of Civil Procedure, the Court’s Local Rules, or any applicable
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`court order.
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`9.
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`ParkerVision objects to each Request to the extent it seeks information or
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`documents containing private, confidential, trade secret, proprietary and/or sensitive business
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`information of ParkerVision, its employees, and/or third parties to the extent that ParkerVision is
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`under any obligation—imposed by a third party, a court, tribunal, legislature, or any other body
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`with authority to impose or enforce such an agreement, statute, regulation, or order—to maintain it
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`in confidence and not disclose it.
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`3
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`10.
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`ParkerVision objects to each Request to the extent it seeks: (i) information regarding
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`any right, title, or interest in the outcome of this litigation; and/or (ii) information regarding any
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`financing related to the litigation.
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`11.
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`ParkerVision objects to each Request to the extent it calls for competitively
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`sensitive documents or information comprising trade secrets or other confidential research,
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`development, or commercial information.
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`12.
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`ParkerVision objects to each Definition, Instruction, and Request to the extent it is
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`vague, ambiguous, overly broad, unduly burdensome, irrelevant, duplicative, cumulative, or not
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`proportional to the needs of the case.
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`13.
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`ParkerVision objects to each Request to the extent it is cumulative or duplicative of
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`other discovery, including other interrogatories, requests for production, and requests for
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`admission. ParkerVision further objects to the extent it seeks information, documents, or things that
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`are more properly addressed by other forms of discovery.
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`14.
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`ParkerVision objects to each Request to the extent it is compound and contains
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`multiple impermissible subparts.
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`15.
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`ParkerVision objects to each Request as overly broad, unduly burdensome, and not
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`proportional to the needs of the case, particularly to the extent it seeks “all,” “each,” “every,” or
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`“any” of a category of information.
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`16.
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`ParkerVision objects to each Request to the extent it is premature, and
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`ParkerVision’s response to each Request is without prejudice to this objection. ParkerVision
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`reserves the right to amend, and/or supplement each of its responses, including in response to any
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`Court Order or agreement between the parties.
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`17.
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`ParkerVision objects to each Request to the extent it is unbounded in time and seeks
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`information for periods of time that are not relevant to any claim or defense.
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`18.
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`ParkerVision objects to each Request to the extent it calls for the disclosure of
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`information, documents, or things that were created or obtained after the commencement of this
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`lawsuit.
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`19.
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`ParkerVision objects to each Request to the extent it seeks information, documents,
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`or things that are not relevant to any claim or defense and not proportional to the needs of the case,
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`considering the importance of the issues at stake in the action, the amount in controversy, the
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`parties’ relative access to relevant information, documents, or things, the parties’ resources, the
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`importance of the discovery in resolving the issues, and whether the burden or expense of the
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`proposed discovery outweighs its likely benefit.
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`20.
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`ParkerVision’s response that it will produce documents responsive to any particular
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`Request does not mean that it has any such documents, and its response should not be construed in
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`that manner.
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`21.
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`The responses and information given herein, or the production of documents and/or
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`things by ParkerVision in response to any one or more of the Requests, shall not be deemed to
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`waive any claim of privilege or immunity that ParkerVision may have as to any response,
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`document or thing, or any objection that ParkerVision may have as to a demand for further
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`response to these or other requests.
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`22.
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`In furnishing these responses and producing any documents in response to any
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`Requests, ParkerVision does not admit or concede the relevancy, materiality, authenticity, or
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`admissibility in evidence of any such request or document. All objections to the use, at trial or
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`otherwise, of any document produced or information provided in response to the Requests and to
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`any further production are hereby expressly reserved.
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`23.
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`Where ParkerVision has agreed to produce documents, the response should be
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`construed to mean that ParkerVision has agreed to produce documents located after a reasonable
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`Case 6:22-cv-01162-ADA Document 111-2 Filed 07/12/24 Page 7 of 47
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`inquiry of those employees whom, and a reasonable search of those files which it reasonably
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`believes may provide relevant, responsive, and non-duplicative information and documents.
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`24.
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`Any response herein provided by ParkerVision is given without prejudice to
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`ParkerVision using, or relying on at trial, subsequently discovered information omitted from these
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`responses because of mistake, error, oversight, or inadvertence.
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`25.
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`ParkerVision further objects on the grounds that Defendant’s Requests for
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`Production seek to compel ParkerVision to conduct a search beyond the scope of permissible
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`discovery and because they impose an undue burden and expense.
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`26.
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`ParkerVision states that these responses are accurate as of the date made. But
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`ParkerVision’s investigation of information that may be responsive to these discovery requests is
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`ongoing and ParkerVision reserves the right to supplement its responses when its investigation is
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`complete.
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`27.
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`28.
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`ParkerVision reserves the right to supplement these General Objections.
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`ParkerVision reserves the right to at any time revise, correct, supplement, or clarify
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`any of the responses set forth herein.
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`29.
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`The applicable foregoing general objections are incorporated into each of the
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`specific objections and responses that follow. The stating of a specific objection or response shall
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`not be construed as a waiver of ParkerVision’s general objections.
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`SPECIFIC RESPONSES
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`ParkerVision incorporates the foregoing General Objections into each and every response
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`below. Subject to and without waiving the foregoing General Objections, ParkerVision provides
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`the following Specific Objections and Responses to the Defendant’s First Set of Requests for
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`Production.
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`REQUEST FOR PRODUCTION NO. 1:
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`Case 6:22-cv-01162-ADA Document 111-2 Filed 07/12/24 Page 8 of 47
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`All Documents and Things referring or relating to the Asserted Patents.
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`RESPONSE:
`ParkerVision objects to this Request as overly broad, unduly burdensome, and
`disproportionate to the needs of the case, particularly insofar as it seeks “[a]ll Documents and
`Things referring or relating to the Asserted Patents,” without any reasonable limitation.
`ParkerVision also objects to this Request to the extent that it seeks information that is not relevant
`to a claim or defense of any party in this litigation or to the subject matter of this litigation, and is
`not reasonably calculated to lead to the discovery of admissible evidence. ParkerVision further
`objects to this Request to the extent that it purports to request information that is outside of the
`possession, custody, or control of ParkerVision. ParkerVision also objects to this Request to the
`extent it seeks documents and information that is at least equally available to Defendant, already in
`Defendant’s possession, and/or equally obtainable by Defendant from an alternative source.
`ParkerVision also objects to this Request to the extent it seeks information that requires the
`disclosure of information, documents, and things protected from disclosure by the attorney-client
`privilege, work product doctrine, or any other applicable privilege, doctrine, or immunity.
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`Subject to and without wavier of the foregoing general and specific objections,
`ParkerVision states that it will produce responsive, non-privileged documents sufficient to evaluate
`the legal and factual issues related to the Asserted Patents in this case to the extent such documents
`exist, are in ParkerVision’s possession, custody, or control, can be located after a reasonable
`search, and have not already been produced.
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`REQUEST FOR PRODUCTION NO. 2:
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`All Documents and Things relating to any plan or decision to file this Action against
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`Realtek.
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`RESPONSE:
`ParkerVision objects to this Request as overly broad, unduly burdensome, and
`disproportionate to the needs of the case, particularly insofar as it seeks “[a]ll Documents and
`Things relating to any plan or decision to file this Action,” without any reasonable limitation.
`ParkerVision also objects to this Request to the extent that it seeks information that is not relevant
`to a claim or defense of any party in this litigation or to the subject matter of this litigation, and is
`not reasonably calculated to lead to the discovery of admissible evidence. ParkerVision also objects
`to this Request to the extent that it purports to request information that is outside of the possession,
`custody, or control of ParkerVision. ParkerVision also objects to this Request to the extent it calls
`for the disclosure of confidential and non-disclosure restrictions imposed by contract or applicable
`law, or otherwise seeks confidential, proprietary and/or trade secret information from Plaintiff.
`ParkerVision also objects to this Request to the extent it seeks information that requires the
`disclosure of information, documents, and things protected from disclosure by the attorney-client
`privilege, work product doctrine, or any other applicable privilege, doctrine, or immunity.
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`REQUEST FOR PRODUCTION NO. 3:
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`All Documents and Things relating to any Third Party’s past or present right, title, or
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`interest in the Patents-in-Suit and the outcome of this Action.
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`RESPONSE:
`ParkerVision objects to this Request as overly broad, unduly burdensome, and
`disproportionate to the needs of the case, particularly insofar as it seeks “[a]ll Documents and
`Things relating to any Third Party’s past or present right, title, or interest” without any reasonable
`limitation. ParkerVision also objects to this Request as unduly burdensome to the extent it purports
`to duplicate or overlap in subject matter with other requests propounded by Defendant.
`ParkerVision also objects to this Request to the extent that it seeks information that is not relevant
`to a claim or defense of any party in this litigation or to the subject matter of this litigation, and is
`not reasonably calculated to lead to the discovery of admissible evidence. ParkerVision also objects
`to this Request to the extent that it is unlimited in time. ParkerVision also objects to this Request to
`the extent that it purports to request information that is outside of the possession, custody, or
`control of ParkerVision. ParkerVision also objects to this Request to the extent it calls for the
`disclosure of confidential and non-disclosure restrictions imposed by contract or applicable law, or
`otherwise seeks confidential, proprietary and/or trade secret information from Plaintiff.
`ParkerVision also objects to this Request to the extent it seeks information that requires the
`disclosure of information, documents, and things protected from disclosure by the attorney-client
`privilege, work product doctrine, or any other applicable privilege, doctrine, or immunity.
`ParkerVision objects to this Request to the extent it seeks discovery related to any right, title, or
`interest in the outcome of this Action.
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`Subject to and without wavier of the foregoing general and specific objections,
`ParkerVision states that it will produce responsive, non-privileged documents sufficient to show
`ownership of the Patents-in-Suit to the extent such documents exist, are in ParkerVision’s
`possession, custody, or control, can be located after a reasonable search, and have not already been
`produced.
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`REQUEST FOR PRODUCTION NO. 4:
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`All Documents and Things relating to ParkerVision’s claim of damages, including
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`Documents and Things supporting or refuting ParkerVision’s contention that this is an exceptional
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`case within the meaning of 35 U.S.C. § 285, and Documents and Things concerning any reasonable
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`royalty to which ParkerVision contends it is entitled and the basis for its computation, including
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`Documents and Things pertaining to the royalty rate ParkerVision relies on for computation, and
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`any of the fifteen factors given for determining a reasonable royalty in Georgia-Pacific Corp. v.
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`U.S. Plywood Corp., 318 F. Supp. 1116, 1120 (S.D.N.Y. 1970), modified and aff’d, 446 F.2d 295
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`(2d Cir. 1971).
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`RESPONSE:
`ParkerVision objects to this Request as overly broad, unduly burdensome, and
`disproportionate to the needs of the case, particularly insofar as it seeks “[a]ll Documents and
`Things relating to ParkerVision’s claim of damages,” without any reasonable limitation.
`ParkerVision also objects to this Request to the extent that it seeks information that is not relevant
`to a claim or defense of any party in this litigation or to the subject matter of this litigation, and is
`not reasonably calculated to lead to the discovery of admissible evidence. ParkerVision also objects
`to this Request to the extent it calls for a legal conclusion and/or expert opinion. ParkerVision also
`objects to this Request to the extent that it purports to request information that is outside of the
`possession, custody, or control of ParkerVision. ParkerVision also objects to this Request to the
`extent it seeks information that requires the disclosure of information, documents, and things
`protected from disclosure by the attorney-client privilege, work product doctrine, or any other
`applicable privilege, doctrine, or immunity.
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`Subject to and without wavier of the foregoing general and specific objections,
`ParkerVision states that it will produce responsive, non-privileged documents that ParkerVision
`relies upon as a basis for its damages claims and which are sufficient to perform a damages
`analysis to the extent such documents exist, are in ParkerVision’s possession, custody, or control,
`can be located after a reasonable search, and have not already been produced.
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`REQUEST FOR PRODUCTION NO. 5:
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`All Documents and Things relating to any valuation of the Asserted Patents, including the
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`valuation of any portfolio or collection of patents in which one or more of the Asserted Patents has
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`been offered for sale, license, assignment, or transfer.
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`RESPONSE:
`ParkerVision objects to this Request as overly broad, unduly burdensome, and
`disproportionate to the needs of the case, particularly insofar as it seeks “[a]ll Document and
`Things relating to any valuation of the Asserted Patents,” without any reasonable limitation.
`ParkerVision also objects to this Request to the extent that it seeks information that is not relevant
`to a claim or defense of any party in this litigation or to the subject matter of this litigation, and is
`not reasonably calculated to lead to the discovery of admissible evidence. ParkerVision also objects
`to this Request to the extent that it is unlimited in time or otherwise not limited to this litigation and
`to the patents-in-suit. ParkerVision also objects to this Request to the extent that it purports to
`request information that is outside of the possession, custody, or control of ParkerVision.
`ParkerVision also objects to this Request to the extent it calls for the disclosure of confidential and
`non-disclosure restrictions imposed by contract or applicable law, or otherwise seeks confidential,
`proprietary and/or trade secret information from Plaintiff. ParkerVision also objects to this Request
`to the extent it seeks information that requires the disclosure of information, documents, and things
`protected from disclosure by the attorney-client privilege, work product doctrine, or any other
`applicable privilege, doctrine, or immunity.
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`Subject to and without wavier of the foregoing general and specific objections,
`ParkerVision states that it will produce responsive, non-privileged documents pertaining to the
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`valuations of the Asserted Patents to the extent such documents exist, are in ParkerVision’s
`possession, custody, or control, can be located after a reasonable search, and have not already been
`produced.
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`REQUEST FOR PRODUCTION NO. 6:
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`All Agreements referring or relating to the Asserted Patents.
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`RESPONSE:
`ParkerVision objects to this Request as overly broad, unduly burdensome, and
`disproportionate to the needs of the case, particularly insofar as it seeks “[a]ll Agreements referring
`or relating to the Asserted Patents,” without any reasonable limitation. ParkerVision also objects to
`this Request to the extent that it seeks information that is not relevant to a claim or defense of any
`party in this litigation or to the subject matter of this litigation, and is not reasonably calculated to
`lead to the discovery of admissible evidence. ParkerVision also objects to this Request to the extent
`that it purports to request information that is outside of the possession, custody, or control of
`ParkerVision. ParkerVision also objects to this Request to the extent it seeks information that
`requires the disclosure of information, documents, and things protected from disclosure by the
`attorney-client privilege, work product doctrine, or any other applicable privilege, doctrine, or
`immunity.
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`Subject to and without wavier of the foregoing general and specific objections,
`ParkerVision states that it will produce responsive, non-privileged documents pertaining to the
`Asserted Patents to the extent such documents exist, are in ParkerVision’s possession, custody, or
`control, can be located after a reasonable search, and have not already been produced.
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`REQUEST FOR PRODUCTION NO. 7:
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`All Documents and Things referring or relating to ParkerVision’s claim of ownership or
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`rights to the Asserted Patents, including Documents referring or relating to any assignment, license,
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`offer to license, sale, offer for sale, or transfer of any right or interest (legal or financial) in the
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`Asserted Patents.
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`RESPONSE:
`ParkerVision objects to this Request as overly broad, unduly burdensome, and
`disproportionate to the needs of the case, particularly insofar as it seeks [a]ll Documents and
`Things referring or relating to ParkerVision’s claim of ownership or rights to the Asserted Patents,”
`without reasonable limitation. ParkerVision also objects to this Request as unduly burdensome to
`the extent it purports to duplicate or overlap in subject matter with other requests propounded by
`Defendant. ParkerVision also objects to this Request to the extent that it seeks information that is
`not relevant to a claim or defense of any party in this litigation or to the subject matter of this
`litigation, and is not reasonably calculated to lead to the discovery of admissible evidence.
`ParkerVision also objects to this Request to the extent that it purports to request information that is
`outside of the possession, custody, or control of ParkerVision. ParkerVision also objects to this
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`Request to the extent it seeks information that requires the disclosure of information, documents,
`and things protected from disclosure by the attorney-client privilege, work product doctrine, or any
`other applicable privilege, doctrine, or immunity.
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`Subject to and without wavier of the foregoing general and specific objections,
`ParkerVision states that it will produce responsive, non-privileged documents sufficient to show
`ownership of the Asserted Patents to extent such documents exist, are in ParkerVision’s possession,
`custody, or control, can be located after a reasonable search, and have not already been produced.
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`REQUEST FOR PRODUCTION NO. 8:
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`All Documents and Things referring or relating to the licensing of the Asserted Patents,
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`including but not limited to each Agreement and draft Agreement in which any right, title, or
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`interest in the Asserted Patents was licensed, Communications or Documents reflecting any
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`proposed or actual royalty rate or payment for licensing the Asserted Patents, cease-and-desist
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`letters involving the Asserted Patents and Communications or Documents relating thereto, and
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`Communications or Documents reflecting discussions, negotiations, inquiries, or proposals relating
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`to the licensing of the Asserted Patents, including but not limited to any valuations relating thereto.
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`RESPONSE:
`ParkerVision objects to this Request as overly broad, unduly burdensome, and
`disproportionate to the needs of the case, particularly insofar as it seeks “[a]ll Documents and
`Things referring or relating to the licensing of the Asserted Patents,” without any reasonable
`limitation. ParkerVision further objects to the terms “discussions,” “negotiations,” “inquiries,” and
`“proposals” as vague and ambiguous. ParkerVision also objects to this Request as unduly
`burdensome to the extent it purports to duplicate or overlap in subject matter with other requests
`propounded by Defendant. ParkerVision also objects to this Request to the extent that it seeks
`information that is not relevant to a claim or defense of any party in this litigation or to the subject
`matter of this litigation, and is not reasonably calculated to lead to the discovery of admissible
`evidence. ParkerVision also objects to this Request to the extent that it purports to request
`information that is outside of the possession, custody, or control of ParkerVision. ParkerVision also
`objects to this Request to the extent it seeks information that requires the disclosure of information,
`documents, and things protected from disclosure by the attorney-client privilege, work product
`doctrine, or any other applicable privilege, doctrine, or immunity.
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`Subject to and without wavier of the foregoing general and specific objections,
`ParkerVision states that it will produce responsive, non-privileged documents sufficient to show
`licensing of the Asserted Patents to the extent such documents exist, are in ParkerVision’s
`possession, custody, or control, can be located after a reasonable search, and have not already been
`produced.
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`Case 6:22-cv-01162-ADA Document 111-2 Filed 07/12/24 Page 13 of 47
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`REQUEST FOR PRODUCTION NO. 9:
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`All Documents and Things relating to any non-infringing alternative to any product
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`believed to infringe or accused of infringing any asserted claim of the Asserted Patents, whether or
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`not You contend such items to be non-infringing alternatives by ParkerVision.
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`RESPONSE:
`ParkerVision objects to this Request as overly broad, unduly burdensome, and
`disproportionate to the needs of the case, particularly insofar as it seeks “[a]ll Documents and
`Things relating to any non-infringing alternative,” without any reasonable limitation. ParkerVision
`also objects to this Request to the extent that it seeks information that is not relevant to a claim or
`defense of any party in this litigation or to the subject matter of this litigation, and is not reasonably
`calculated to lead to the discovery of admissible evidence. ParkerVision also objects to this
`Request to the extent it calls for a legal conclusion and/or expert opinion. ParkerVision also objects
`to this Request to the extent that it purports to request information that is outside of the possession,
`custody, or control of ParkerVision. ParkerVision also objects to this Request to the extent it seeks
`information that requires the disclosure of information, documents, and things protected from
`disclosure by the attorney-client privilege, work product doctrine, or any other applicable privilege,
`doctrine, or immunity.
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`REQUEST FOR PRODUCTION NO. 10:
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`All Documents and Things referring or relating to ParkerVision’s costs, revenues, income,
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`profits, or losses, including all financial and income statements on a quarterly and annual basis for
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`each year since ParkerVision was founded, annual reports, and shareholder reports.
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`RESPONSE:
`ParkerVision objects to this Request as overly broad, unduly burdensome, and
`disproportionate to the needs of the case, particularly insofar as it seeks “[a]ll Documents and
`Things referring or relating to ParkerVision’s costs, revenues, income, profits, or losses,” without
`any reasonable limitation. ParkerVision further objects to this Request as overly broad, unduly
`burdensome, and seeks documents not relevant to this case creating a burden not proportional to
`the needs of the case. ParkerVision also objects to this Request to the extent that it seeks
`information that is not relevant to a claim or defense of any party in this litigation or to the subject
`matter of this litigation, and is not reasonably calculated to lead to the discovery of admissible
`evidence. ParkerVision also objects to this Request to the extent that it is unlimited in time or
`otherwise not limited to this litigation and to the patents-in-suit. ParkerVision also objects to this
`Request to the extent it seeks information that requires the disclosure of information, documents,
`and things protected from disclosure by the attorney-client privilege, work product doctrine, or any
`other applicable privilege, doctrine, or immunity.
`
`REQUEST FOR PRODUCTION NO. 11:
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`
`
`
`12
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`

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`Case 6:22-cv-01162-ADA Document 111-2 Filed 07/12/24 Page 14 of 47
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`All Documents and Things supporting or refuting ParkerVision’s contention that as a result
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`of Realtek’s alleged infringement of the Asserted Patents, ParkerVision has been injured and been
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`caused financial damage, including Documents and Things that ParkerVision reviewed, referenced,
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`consulted, or relied upon in forming the basis for its allegations that any alleged infringement was
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`the cause of injury to ParkerVision, Documents and Things referring or relating to the nature and
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`amount of any injury to ParkerVision, and Documents and Things concerning the amount of
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`financial damages which ParkerVision contends it suffered and the basis for its computation.
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`RESPONSE:
`ParkerVision objects to this Request as overly broad, unduly burdensome, and
`disproportionate to the needs of the case, particularly insofar as it seeks “[a]ll Documents and
`Things supporting or refuting ParkerVision’s contention that as a result of Realtek’s alleged
`infringement of the Asserted Patents, ParkerVision has been injured and been caused financial
`damage” without any reasonable limitation. ParkerVision further objects to the terms “reviewed,”
`“referenced,” “consulte