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`Exhibit A
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`PARKERVISION, INC.,
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`Plaintiff,
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`v.
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`REALTEK SEMICONDUCTOR CORP.,
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`Defendants.
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`Case 6:22-cv-01162-ADA Document 14-1 Filed 02/23/23 Page 2 of 3
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`IN THE UNITED STATES DISTRICT COURT
`FOR THE WESTERN DISTRICT OF TEXAS
`WACO DIVISION
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`NO. 6:22-cv-01162-ADA
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`§
`§
`§
`§
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`DEFENDANT’S SUR-REPLY IN OPPOSITION TO
`PLAINTIFF’S MOTION FOR LEAVE TO EFFECT ALTERNATIVE SERVICE
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`Plaintiff ParkerVision, Inc.’s (“Plaintiff” or “ParkerVision”) Reply filed on February
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`17, 2023 (Dkt. 13) should be disregarded (1) as untimely, and (2) for improperly relying on the
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`U.S. Department of State’s website.
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`First, ParkerVision’s Reply was filed four days late. Pursuant to Rule CV-7 of the
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`Local Rules for the Western District of Texas, “[a] reply in support of a motion shall be filed
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`not later than 7 days after the filing of the response to the motion.” Under similar facts, this
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`Court has stricken a party’s untimely reply for being filed more than 7 days after the filing of
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`the response to the motion. Bd. of Regents of U. of Tex. Sys. v. Reynolds, 2019 WL4980445 at
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`*1 (W.D. Tex. April 4, 2019).
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`Second, ParkerVision’s Reply improperly relies on the U.S. Department of State’s
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`website1 to mitigate ParkerVision’s admission that service is only proper in Taiwan through
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`Letters Rogatory. Indeed, the website itself includes a disclaimer that states that the website
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`cannot be relied upon for interpretation of foreign law—a disclaimer that ParkerVision omits
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`from its Reply:
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`1 https://travel.state.gov/content/travel/en/legal/Judicial-Assistance-Country-Information/Taiwan.html
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`1
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`Case 6:22-cv-01162-ADA Document 14-1 Filed 02/23/23 Page 3 of 3
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`DISCLAIMER: THE INFORMATION IS PROVIDED FOR GENERAL
`INFORMATION ONLY AND MAY NOT BE TOTALLY ACCURATE IN A
`SPECIFIC CASE. QUESTIONS INVOLVING INTERPRETATION OF
`SPECIFIC FOREIGN LAWS SHOULD BE ADDRESSED TO THE
`APPROPRIATE FOREIGN AUTHORITIES OR FOREIGN COUNSEL.
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`Accordingly, ParkerVision cannot rely on the website to support its argument that Realtek was
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`“properly served” on December 19, 2022 via FedEx. See Dkt. 13, 1. Regardless, as
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`ParkerVision acknowledges, the website explicitly states that “Taiwan may not consider
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`service by registered mail or by agent acceptable and may require that service be effected
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`pursuant to letters rogatory.” Id., 1-2.
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`Accordingly, for the reasons above and those discussed in Realtek’s Opposition (Dkt.
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`11), the Court should disregard ParkerVision’s Reply and deny Plaintiff’s Motion for Leave to
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`Effect Alternative Service because ParkerVision has not yet attempted proper service.
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`DATED: February 23, 2023
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`Respectfully submitted,
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` /s/ Mark D. Siegmund
`By:
`Mark D. Siegmund
`State Bar No. 24117055
`STECKLER WAYNE CHERRY & LOVE, PLLC
`8416 Old McGregor Road
`Waco, Texas 76712
`Telephone: (254) 651-3690
`Facsimile: (254) 651-3689
`Email: mark@swclaw.com
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`Counsel For Realtek Semiconductor Corp.
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`2
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