Case 6:22-cv-01162-ADA Document 18 Filed 03/03/23 Page 1 of 15
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`IN THE UNITED STATES DISTRICT COURT
`FOR THE WESTERN DISTRICT OF TEXAS
`WACO DIVISION
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`PARKERVISION, INC.,
`
`
`Plaintiff,
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`
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`v.
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`REALTEK SEMICONDUCTOR CORP.,
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`
`Defendant.
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`
`
`
`NO. 6:22-cv-01162-ADA
`
`§
`§
`§
`§
`§
`§
`§
`§
`§
`§
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`DEFENDANT’S OPPOSITION TO
`PLAINTIFF’S MOTION FOR CLERK’S ENTRY OF DEFAULT
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`Case 6:22-cv-01162-ADA Document 18 Filed 03/03/23 Page 2 of 15
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`TABLE OF CONTENTS
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`INTRODUCTION ......................................................................................................... 1
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`BACKGROUND ........................................................................................................... 3
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`
`I.
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`II.
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`III.
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`LEGAL STANDARD .................................................................................................... 5
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`1.
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`2.
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`3.
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`Requirements of Fed. R. Civ. P. 55(a) ............................................................... 5
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`Proper Service on a Taiwanese Entity ............................................................... 6
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`Default is Disfavored ......................................................................................... 7
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`IV.
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`ARGUMENTS ............................................................................................................... 7
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`1.
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`2.
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`3.
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`ParkerVision Failed to Effect Proper Service .................................................... 7
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`Default is Inappropriate Given the Pending Alternative Service Motion .......... 8
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`Realtek Has Defended in this Action ................................................................. 9
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`V.
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`CONCLUSION ............................................................................................................ 10
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`i
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`Case 6:22-cv-01162-ADA Document 18 Filed 03/03/23 Page 3 of 15
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`TABLE OF AUTHORITIES
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`
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`Page(s)
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`Cases
`
`Bass v. Hoagland,
`172 F.2d 205 (5th Cir. 1949) ........................................................................................... 6, 9
`
`Blue Spike, LLC v. ASUS Computer Int’l,
`Case No. 6:15-cv-1384-RWS-KNM, 2018 WL 3301705 (E.D. Tex. Feb.
`20, 2018) .............................................................................................................................. 7
`
`Fujitsu Ltd. v. Beklin Int’l, Inc.,
`782 F.Supp.2d 868 (N.D. Cal. 2011) ................................................................................... 7
`
`Green v. Trinh Dang La,
`No. CIV. A. H-05-2097, 2006 WL 6569946 (S.D. Tex. Jan. 30, 2006) .............................. 8
`
`Lindsey v. Prive Corp.,
`161 F.3d 886 (5th Cir. 1998) ............................................................................................... 7
`
`MDJ Industries, LC v. Kytsa Enter., Co. Ltd.,
`Case No. C20-0069-JCC, 2021 WL 409961 (W.D. Wash. Feb. 5, 2021) ........................... 6
`
`In re OnePlus Tech.,
`2021 WL 4130643 ........................................................................................................... 6, 9
`
`ParkerVision, Inc. v. Hisense Co., Ltd. et al.,
`6:20-CV-00870-ADA ......................................................................................................... 3
`
`ParkerVision, Inc. v. LG Electronics, Inc.,
`6:21-CV-00520 ................................................................................................................... 3
`
`ParkerVision, Inc. v. TCL Industries Holdings Co. Ltd. et al.,
`6:20-CV-00945 ................................................................................................................... 3
`
`Rogers v. Hartford Life & Accident Ins. Co.,
`167 F.3d 933 (5th Cir. 1999) ........................................................................................... 5, 7
`
`Sun Bank of Ocala v. Pelican Homestead & Sav. Ass’n,
`874 F.2d 274 (5th Cir. 1989) ........................................................................................... 7, 9
`
`Trs. of Purdue Univ. v. STMicroelectronics N.V.,
`No. 6:21-CV-00727-ADA, 2021 WL 5393711 (W.D. Tex. Nov. 18, 2021) ....................... 6
`
`Statutes
`
`Code of Civil Procedure, Part I, Chapter IV, Section 2, Article 123 ......................................... 6
`
`Other Authorities
`
`Fed. R. Civ. P. 4(c)(1) ................................................................................................................ 5
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`Case 6:22-cv-01162-ADA Document 18 Filed 03/03/23 Page 4 of 15
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`Fed. R. Civ. P. 4(f)(1)-(3) .......................................................................................................... 6
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`Fed. R. Civ. P. 4(f)(2)(C)(ii) .................................................................................................. 7, 8
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`Fed. R. Civ. P. 4(h)(2)................................................................................................................ 6
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`Fed. R. Civ. P. 12(a) (1)(A)(i) ................................................................................................... 5
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`Fed. R. Civ. P. 19 ....................................................................................................................... 1
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`Fed. R. Civ. P. 55(a) ...................................................................................................... 1, 2, 5, 6
`
`Local Rule CV-7.E.2.................................................................................................................. 5
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`iii
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`Case 6:22-cv-01162-ADA Document 18 Filed 03/03/23 Page 5 of 15
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`Defendant Realtek Semiconductor Corp. (“Defendant” or “Realtek”), specially
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`appearing herein for this limited purpose,1 files this Opposition to Plaintiff’s Motion for Clerk’s
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`Entry of Default (the “Motion”) (Dkt. 12). Plaintiff ParkerVision, Inc. (“Plaintiff” or
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`“ParkerVision”) failed to properly serve Realtek, and is therefore not entitled to entry of
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`default. Moreover, even if ParkerVision’s attempt at service was effective (which it was not),
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`Plaintiff cannot show that Realtek did not “otherwise defend,” as required under Fed. R. Civ.
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`P. 55(a). Accordingly, Plaintiff’s Motion has no basis, and should be denied.
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`I.
`
`INTRODUCTION
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`ParkerVision’s Motion is just the latest among the ever-changing and improper tactics
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`it has pursued in litigating its infringement case. In connection with separate complaints
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`brought three years ago against Hisense, TCL, and LG, ParkerVision knew it would need
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`discovery of Realtek as a third party. But failing to follow the Court’s procedures and deadlines
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`to obtain that discovery, ParkerVision sought stay of those actions to file this action against
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`Realtek instead. Now, ParkerVision again willfully disregards this Court’s rules and seeks to
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`circumvent the law as to Realtek’s due process rights by filing this Motion—a motion that is
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`plainly without merit.
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`First, Realtek is not in default because ParkerVision has not effected service. By
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`ParkerVision’s own admission: “In Taiwan, service of the summons and complaint must be
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`administered by the clerk of a Taiwanese court with jurisdiction over Realtek.” Dkt. 10 at 9.
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`Consequently, ParkerVision has never effected service because it has never sought the
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`1 By filing this Opposition, Realtek does not concede jurisdiction over it nor does it waive
`service. Nothing in this Response should be interpreted as a general appearance or waiver or
`relinquishment of Realtek’s rights to assert defenses or objections including, without
`limitation, the defenses of: (1) lack of personal jurisdiction; (2) improper venue and/or forum
`non conveniens; (3) insufficient process; (4) insufficient service of process; (5) failure to state
`a claim upon which relief can be granted; (6) failure to join a party under Rule 19; (7) improper
`joinder of claims and/or parties; and (8) any other procedural or substantive defense available
`under state or federal law.
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`1
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`Case 6:22-cv-01162-ADA Document 18 Filed 03/03/23 Page 6 of 15
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`assistance of the Taiwanese court to serve through Letters Rogatory. ParkerVision’s late
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`attempt to invoke guidance from the U.S. Department of State cannot change its admission.
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`Moreover, ParkerVision’s change of heart is based on information that the U.S. Department of
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`State expressly admonishes is not reliable because the guidance “may not be totally accurate.”2
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`Dkt. 12 at 1-2.
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`Second, entry of default is nonsensical given that ParkerVision’s Motion for
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`Alternative Service (Dkt. 10, “Alternative Service Motion”) is still pending before this Court.
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`On January 10, 2023, more than a week before Realtek’s alleged deadline to respond to
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`ParkerVision’s complaint, ParkerVision represented that it would file its Alternative Service
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`Motion “to avoid unnecessary motion practice regarding service and/or default.” Dkt. 10-3 at
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`2. Relying on that representation, Realtek did not file a motion to dismiss for ineffective service
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`of process. ParkerVision’s decision to now file this Motion is troubling—ParkerVision either
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`purposefully misled Realtek so that ParkerVision could argue default or moved for default to
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`cloak its admission of ineffective service. Either way, this Motion is facially inappropriate
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`given the pending Alternative Service Motion.
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`Third, even if ParkerVision effected proper service, ParkerVision cannot show that
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`Realtek did not “otherwise defend” itself in this action as required to enter default under Fed.
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`R. Civ. P. 55(a). Realtek expressly informed ParkerVision that service was improper and
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`specially appeared to submit a Response to the Alternative Service Motion. Importantly,
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`ParkerVision almost certainly knew that had it not filed an Alternative Service Motion, Realtek
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`would have filed a motion to dismiss for ineffective service. As such, ParkerVision’s statement
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`in this Motion that “Defendant has failed to … otherwise defend this action” (Dkt. 12 at 2) is
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`plainly false. This is even more evident by the fact that ParkerVision’s supporting affidavit
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`(Dkt. 12-1) notably omits any statement that Realtek failed to defend this action.
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`2 TRAVEL.STATE.GOV,
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`Case 6:22-cv-01162-ADA Document 18 Filed 03/03/23 Page 7 of 15
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`The impropriety of ParkerVision’s conduct in this case is yet another part of a pattern
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`of misconduct. ParkerVision is not exempt from this Court’s orders, the Federal Rules, or the
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`basic principles of the Constitution. Years ago, ParkerVision identified the accused products
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`in its complaints against Hisense, TCL, and LG, but failed to timely seek discovery from
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`Realtek in accordance with this Court’s scheduling orders for those cases. ParkerVision cannot
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`now evade the consequences of its dilatory actions by filing this suit. It is not and cannot be
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`easier to obtain discovery from a foreign party by seeking default based on a deficient
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`complaint than through Letters Rogatory. Due process does not allow it. ParkerVision’s
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`Motion is inaccurate and improper, and should be denied.
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`II.
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`BACKGROUND
`
`A.
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`Related Cases
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`In the complaint in this case, ParkerVision alleges that Hisense, TCL, and LG
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`televisions incorporating a Realtek RTL8812BU chip purportedly infringe its patents. These
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`are the very same allegations that appeared years ago in ParkerVision’s complaints in
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`ParkerVision, Inc. v. Hisense Co., Ltd. et al., 6:20-CV-00870-ADA (filed on September 24,
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`2020), ParkerVision, Inc. v. TCL Industries Holdings Co. Ltd. et al., 6:20-CV-00945 (filed on
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`October 12, 2020), ParkerVision, Inc. v. LG Electronics, Inc., 6:21-CV-00520 (filed on May
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`22, 2021). Rather than timely seeking Letters Rogatory in each of these cases, ParkerVision
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`waited until just before close of fact discovery.
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`Unable to obtain the necessary discovery in accordance with the scheduling orders in
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`the cases against Hisense, TCL, and LG, ParkerVision then sought a stay of those cases while
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`it filed the complaint in this action on November 10, 2022 (Dkt. 1). But yet again, ParkerVision
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`failed to immediately seek Letters Rogatory. Instead, ParkerVision sent a letter to the Clerk of
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`the Court requesting FedEx delivery of the complaint, summons, and civil coversheet to
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`Realtek on December 13, 2022, contrary to proper service under Taiwanese law. Dkt. 8.
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`Case 6:22-cv-01162-ADA Document 18 Filed 03/03/23 Page 8 of 15
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`ParkerVision did so even as the U.S. Department of State has recognized “Taiwan may not
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`consider service by registered mail or by agent acceptable and may require that service be
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`effected pursuant to letters rogatory.”3
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`B.
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`Failed Attempt at Service and Misrepresentation to this Court
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`Under Realtek’s longstanding health and safety policy reinforced during the COVID
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`pandemic, the company does not accept packages from unknown senders. Consistent with that
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`policy, FedEx made several attempts to deliver the service package, but shipment was refused
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`each time and eventually returned on December 28, 2022. Dkt. 11-1, 11-2.
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`The same day that FedEx returned the service package to ParkerVision’s counsel,
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`ParkerVision filed an Acknowledgment of Service with the Court. Dkt. 9. Turning a blind eye
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`to its receipt of the service package, ParkerVision submitted an incomplete FedEx record with
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`its Acknowledgement. Notable was ParkerVision’s omission of the FedEx information
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`confirming that the package was “[a]t [a] local FedEx facility” hours after it was allegedly
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`“Delivered” and that the “[s]hipment [was] refused by recipient” again and again in the
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`subsequent days. Id.
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`C.
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`Communications with ParkerVision Counsel
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`Realtek engaged Theodore Angelis of K&L Gates on a limited basis to request that
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`ParkerVision correct the record. On January 4, 2023, Mr. Angelis wrote to ParkerVision’s
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`counsel explaining “[t]he actual tracking information shows that delivery did not occur because
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`(pursuant to Taiwanese law) Realtek was not able to accept the documents tendered.” Dkt. 10-
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`2 at 1. Mr. Angelis further requested that ParkerVision “immediately bring these facts to the
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`attention of the Court and refrain from representing to the Court that service has been effected
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`pursuant to Federal Rule of Civil Procedure 4(h)(2) and 4(f)(2)(C)(ii).” Id. at 3.
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`3 TRAVEL.STATE.GOV, https://travel.state.gov/content/travel/en/legal/Judicial-Assistance-
`Country-Information/Taiwan.html
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`Case 6:22-cv-01162-ADA Document 18 Filed 03/03/23 Page 9 of 15
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`On January 10, 2023, ParkerVision responded to Mr. Angelis, arguing that Realtek
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`must have “returned” the package on December 19, disregarding FedEx’s record showing that
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`it made multiple attempts to deliver the package—clear evidence that Realtek did not “return”
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`the package, as FedEx would not make multiple attempts to deliver a “return” package.
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`ParkerVision further requested Realtek waive service, promising if Realtek did not do so,
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`“ParkerVision will file a motion for alternative service.” Dkt. 10-3 at 2. Mr. Angelis promptly
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`reminded ParkerVision that he and K&L Gates “are not authorized to accept or waive service.”
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`Id. at 1.
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`Subsequently, ParkerVision filed its Alternative Service Motion on January 23, 2023.
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`Dkt. 10. Realtek filed a timely Response in Opposition to the Alternative Service Motion on
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`February 6, 2023. Breaking the Court’s rules again, ParkerVision filed a late Reply (Dkt. 13)4
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`as well as the present Motion on February 17, 2023 (Dkt. 12).
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`III. LEGAL STANDARD
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`1.
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`Requirements of Fed. R. Civ. P. 55(a)
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`Federal Rule of Civil Procedure 55(a) provides that the clerk of the court shall enter a
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`default against a party if that party fails to plead or otherwise defend, and the movant
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`demonstrates that failure by affidavit or otherwise. Fed. R. Civ. P. 55(a).
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`The plaintiff is responsible for properly serving the defendant with a summons and a
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`copy of the complaint. Fed. R. Civ. P. 4(c)(1). Once served, a defendant must file an answer
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`to the complaint within 21 days of service. Fed. R. Civ. P. 12(a) (1)(A)(i). Until the plaintiff
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`serves the defendant, the defendant has no duty to answer or otherwise defend against the
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`complaint. Rogers v. Hartford Life & Accident Ins. Co., 167 F.3d 933, 937 (5th Cir. 1999).
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`4 Local Rule CV-7.E.2. requires that “[a] reply in support of a motion shall be filed not later
`than 7 days after the filing of the response to the motion.” Realtek’s Response was filed on
`February 6, 2023. ParkerVision’s Reply was due February 13, 2023. ParkerVision filed its
`Reply on February 17, 2023.
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`Case 6:22-cv-01162-ADA Document 18 Filed 03/03/23 Page 10 of 15
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`Under Fed. R. Civ. P. 55(a), “[t]he words ‘otherwise defend’ refer to attacks on the
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`service, or motions to dismiss, or for better particulars, and the like, which may prevent
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`default without presently pleading to the merits.” Bass v. Hoagland, 172 F.2d 205, 210 (5th
`
`Cir. 1949).
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`2.
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`Proper Service on a Taiwanese Entity
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`Federal Rule of Civil Procedure 4(h)(2) states that a foreign entity served outside the
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`United States must be served “in any manner prescribed by Rule 4(f) for serving an individual,
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`except personal delivery under (f)(2)(C)(i).” Rule 4(f) provides that service on the foreign
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`defendant can be accomplished: (1) “by any internationally agreed means of service that is
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`reasonably calculated to give notice, such as those authorized by the Hague Convention”; (2)
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`“if there is no internationally agreed means . . . by a method that is reasonably calculated to
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`give notice”; or (3) “by other means not prohibited by international agreement, as the court
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`orders.” Fed. R. Civ. P. 4(f)(1)-(3); In re OnePlus Tech., 2021 WL 4130643, at *4. This Court
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`has consistently required a plaintiff to attempt to comply with the laws of the foreign
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`jurisdiction in which it seeks to serve the defendant.
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` Trs. of Purdue Univ. v.
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`STMicroelectronics N.V., No. 6:21-CV00727-ADA, 2021 WL 5393711, at *1 (W.D. Tex. Nov.
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`18, 2021) (“[T]his Court has time-and-again recognized that ‘principles of comity encourage
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`the court to insist, as a matter of discretion, that a plaintiff attempt to follow foreign law in its
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`efforts to secure service of process upon defendant.’”)
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`The laws of Taiwan do not provide for service on a defendant by anyone other than
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`the court clerk of Taiwan. Taiwan Code of Civil Procedure, Part I, Chapter IV, Section 2,
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`Article 123 (“Except as otherwise provided, service of process will be administered by the
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`court clerk on his/her own authority.”); see also MDJ Industries, LC v. Kytsa Enter., Co. Ltd.,
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`Case No. C20-0069-JCC, 2021 WL 409961, at *3 (W.D. Wash. Feb. 5, 2021) (“[M]ultiple
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`district courts faced with this question have concluded that the Code does not permit an
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`Case 6:22-cv-01162-ADA Document 18 Filed 03/03/23 Page 11 of 15
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`individual other than the court clerk to properly effectuate service on Taiwanese
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`corporations.”); Blue Spike, LLC v. ASUS Computer Int’l, Case No. 6:15-cv-1384-RWS-
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`KNM, 2018 WL 3301705, at *3, 4 (E.D. Tex. Feb. 20, 2018); Fujitsu Ltd. v. Beklin Int’l, Inc.,
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`782 F.Supp.2d 868, 874-78 (N.D. Cal. 2011).
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`3.
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`Default is Disfavored
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`The Fifth Circuit favors resolving cases on their merits and generally disfavors default.
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`Rogers v. Hartford Life & Accident Ins. Co., 167 F.3d 933, 936 (5th Cir. 1999); Sun Bank of
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`Ocala v. Pelican Homestead & Sav. Ass’n, 874 F.2d 274, 276 (5th Cir. 1989) (“Default
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`judgments are a drastic remedy, not favored by the federal rules and resorted to by the courts
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`only in extreme situations.”). Any doubt regarding default judgment should be resolved in
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`favor of the alleged defaulting party. Lindsey v. Prive Corp., 161 F.3d 886, 893 (5th Cir. 1998).
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`IV. ARGUMENTS
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`1.
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`ParkerVision Failed to Effect Proper Service
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`ParkerVision argues that it effected proper service on Realtek under Fed. R. Civ. P.
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`4(f)(2)(C)(ii). Dkt. 12 at 1. It did not. Service is improper pursuant to Fed. R. Civ. P.
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`4(f)(2)(C)(ii) if it is “prohibited by the foreign country’s law.” Here, there is no legitimate
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`dispute that under Taiwanese law, all means of service are prohibited except through Letters
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`Rogatory. ParkerVision admits that:
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`In Taiwan, service of the summons and complaint must be administered by the clerk of
`a Taiwanese court with jurisdiction over Realtek. … Taiwanese law also allows a
`foreign party to request, by letters rogatory, the assistance of the courts of Taiwan in
`serving civil litigation documents.
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`Dkt. 10 at 9. Thus, by its own admission, ParkerVision was aware that its service attempt was
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`improper and could not be effected through FedEx delivery.
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`ParkerVision now, however, changes its position and argues that service was proper
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`because the U.S. Department of State website suggests, “Service of process in Taiwan can be
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`effected by international registered mail/return receipt requested.” Dkt. 12 at 2. However, the
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`Case 6:22-cv-01162-ADA Document 18 Filed 03/03/23 Page 12 of 15
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`website has no authority on the subject. Indeed, ParkerVision’s representations to the Court
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`omit yet another key piece of information—the website that ParkerVision relies upon includes
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`a prominent disclaimer:
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`IS PROVIDED FOR GENERAL
`INFORMATION
`DISCLAIMER: THE
`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.5
`
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`The U.S. Department of State further recognizes that “Taiwan may not consider service by
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`registered mail or by agent acceptable and may require that service be effected pursuant to
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`letters rogatory.” Id.
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`2.
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`Default is Inappropriate Given the Pending Alternative Service Motion
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`This Motion is an unnecessary waste of party and judicial resources. To the extent that
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`the parties dispute service, this issue could have been resolved by briefing a motion to dismiss
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`for ineffective service of process. Instead, ParkerVision represented that it would file an
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`Alternative Service Motion “to avoid unnecessary motion practice regarding service and/or
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`default.” Dkt. 10-3 at 2. And it did so file, thereby admitting that service is, at minimum,
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`disputed, and foregoing any legitimate motion for entry of default.
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`ParkerVision’s decision to file this Motion now despite its pending Alternative Service
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`Motion is premature and improper. Indeed, district courts have recognized that motions for
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`default judgment are potentially made in bad faith when service issues remain. See, e.g., Green
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`v. Trinh Dang La, No. CIV. A. H-05-2097, 2006 WL 6569946, at *1 (S.D. Tex. Jan. 30, 2006)
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`(holding a motion for default to be in bad faith where plaintiff failed to cure service issues).
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`This Motion cannot rescind ParkerVision’s admission that it has failed to properly serve
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`TRAVEL.STATE.GOV,
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`Information/Taiwan.html.
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`https://travel.state.gov/content/travel/en/legal/Judicial-Assistance-Country-
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`Case 6:22-cv-01162-ADA Document 18 Filed 03/03/23 Page 13 of 15
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`Realtek under Taiwanese law. Rather, the Motion underscores ParkerVision’s gross disregard
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`for the law and the representations it makes to opposing counsel and the Court.
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`3.
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`Realtek Has Defended Itself in this Action
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`Entry of default is improper in view of Realtek’s active defense against service in this
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`matter. There are a variety of actions sufficient to show defendant’s intention to dispute a
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`lawsuit, including letters and telephone conversations between counsel. Sun Bank of Ocala v.
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`Pelican Homestead & Sav. Ass'n, 874 F.2d 274, 277 (5th Cir. 1989). Here, Realtek engaged
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`Mr. Angelis for the specific purpose of discussing ParkerVision’s service failure and its
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`submission of the incomplete FedEx record to the Court. Dkt. 10-1. While Mr. Angelis does
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`not represent Realtek in this matter generally, his discussions with ParkerVision challenging
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`the validity of service plainly shows that Realtek has defended itself in this action.
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`Significantly, Realtek acted in reliance upon ParkerVision’s representation that it
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`would seek to resolve its service failure through a motion for alternative service. Had
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`ParkerVision not made such a commitment, Realtek would have filed a motion to dismiss for
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`ineffective service of process (another well-recognized example of otherwise defending, see
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`Bass, 172 F.2d at 210). Realtek properly relied upon ParkerVision’s communication with
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`counsel and its corresponding Alternative Service Motion.
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`Regardless, Realtek’s Response in Opposition to the Alternative Service Motion
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`definitively establishes that it defended itself in this matter. “The words ‘otherwise defend’
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`refer to attacks on the service.” Bass, 172 F.2d at 210. Realtek plainly attacks service in its
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`Response. Not only does Realtek argue that alternative service is premature under this Court’s
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`guidance based on the Federal Circuit decision in In re OnePlus, Realtek’s Response
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`established that service was never effected. See generally Dkt. 11.
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`There is no legitimate question that Realtek has defended itself in this action by
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`specially appearing to attack service through both correspondence and motion practice.
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`Case 6:22-cv-01162-ADA Document 18 Filed 03/03/23 Page 14 of 15
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`Furthermore, ParkerVision is well aware that Realtek would have filed a motion to dismiss for
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`ineffective service of process had ParkerVision not committed to file its Alternative Service
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`Motion. ParkerVision’s willingness to ignore this record and represent that Realtek “has failed
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`to … otherwise defend this action” in a filing with the Court compounds Realtek’s deeply
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`troubling disregard for its representations to this Court and the rule of law. This conduct must
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`be stopped.
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`V.
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`CONCLUSION
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`For the foregoing reasons, Realtek respectfully requests the Court deny ParkerVision’s
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`motion for clerk’s entry of default.
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`DATED: March 3, 2023
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`Respectfully submitted,
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`CHERRY JOHNSON SIEGMUND JAMES, PLLC
`400 Austin Ave., 9th Floor
`Waco, Texas 76701
`Telephone: (254) 732-2242
`Facsimile: (866) 627-3509
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`BY: /s/ Mark D. Siegmund
`MARK D. SIEGMUND
`State Bar No. 24117055
`Email: msiegmund@cjsjlaw.com
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`Counsel For Realtek Semiconductor Corp.
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`CERTIFICATE OF SERVICE
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`A true and correct copy of the foregoing instrument was served or delivered
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`electronically via U.S. District Court [LIVE] – Document Filing System, to all counsel of
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`record, on this the 3rd day of March 2023.
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`/s/ Mark D. Siegmund
`MARK D. SIEGMUND
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`10
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`Case 6:22-cv-01162-ADA Document18 Filed 03/03/23 Page 15 of 15
`Case 6:22-cv-01162-ADA Document 18 Filed 03/03/23 Page 15 of 15
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