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`Case 6:22-cv-01162-ADA Document 92-1 Filed 03/15/24 Page 1 of 24
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`Case 6:22-cv-01162-ADA Document 70 Filed 09/01/23 Page 1 of 23Case 6:22-cv-01162-ADA Document 92-1 Filed 03/15/24 Page 2 of 24
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`1
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`IN THE UNITED STATES DISTRICT COURT
`FOR THE WESTERN DISTRICT OF TEXAS
`WACO DIVISION
`*
`PARKERVISION, INC.
`August 30, 2023
`*
`
`*
`VS.
` * CIVIL ACTION NO. 6:22-CV-1162
`REALTEK SEMICONDUCTOR
`*
` CORP.
`*
`
`BEFORE THE HONORABLE ALAN D ALBRIGHT
`DISCOVERY HEARING (via Zoom)
`
`
`APPEARANCES:
`For the Plaintiff:
`
`For the Defendant:
`
`Court Reporter:
`
`Jason S. Charkow, Esq.
`Ronald M. Daignault, Esq.
`Daignault Iyer LLP
`8618 Westwood Center Drive, Ste 150
`Vienna, VA 22182
`Zachary H. Ellis, Esq.
`The Mort Law Firm, PLLC
`100 Congress Ave, Ste 2000
`Austin, TX 78701
`Grace I. Wang, Esq.
`Allen & Overy LLP
`1221 Avenue Of The Americas
`New York, NY 10020
`Mark Siegmund, Esq.
`Cherry Johnson Siegmund James, PLLC
`The Roosevelt Tower
`400 Austin Avenue, 9th Floor
`Waco, Texas 76701
`Kristie M. Davis, CRR, RMR
`PO Box 20994
`Waco, Texas 76702-0994
`(254) 340-6114
`
`Proceedings recorded by mechanical stenography,
`transcript produced by computer-aided transcription.
`
`KRISTIE M. DAVIS, OFFICIAL COURT REPORTER
`U.S. DISTRICT COURT, WESTERN DISTRICT OF TEXAS (WACO)
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`2
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`(Hearing begins.)
`DEPUTY CLERK: A civil action in Case
`6:22-CV-1162, ParkerVision, Inc. versus Realtek
`Semiconductor Corp. Case called for a discovery
`hearing.
`
`THE COURT: Announcements from counsel,
`
`please.
`
`MR. CHARKOW: Good afternoon, Your Honor.
`This is Jason Charkow with the Daignault Iyer firm on
`behalf of ParkerVision. With me today, I have Zak
`Ellis and Ron Daignault, also the same firm.
`THE COURT: Are you going to be doing the
`
`arguing?
`
`well.
`
`MR. CHARKOW: I am.
`THE COURT: Because I can't hear you very
`
`MR. CHARKOW: Uh-oh. That's not good.
`Can you hear me now? I put the
`microphone closer to my mouth.
`THE COURT: Yeah. That's much better.
`
`Thank you.
`
`MR. CHARKOW: Okay. Sorry about that.
`THE COURT: No problem.
`Mr. Siegmund?
`MR. SIEGMUND: Good afternoon, Your
`
`KRISTIE M. DAVIS, OFFICIAL COURT REPORTER
`U.S. DISTRICT COURT, WESTERN DISTRICT OF TEXAS (WACO)
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`3
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`Honor. Mark Siegmund on behalf of defendant Realtek.
`With me this afternoon is Grace Wang with Allen &
`Overy, and she's going to be arguing this matter on
`behalf of defendant.
`We're ready to proceed.
`THE COURT: Okay. And the issue is
`whether or not we should grant ParkerVision's relief.
`I'll hear from them.
`MR. CHARKOW: Thank you, Your Honor.
`So where we are right now, Your Honor, as
`you're aware, is we're in preliminary infringement
`contention stages and defendants are about to produce
`their preliminary invalidity contentions.
`As Your Honor's also aware, part of that
`is the -- we produced technical documents with your
`preliminary -- they're supposed to produce preliminary
`documents with -- technical documents with the
`preliminary invalidity contentions. And so we sent
`them an e-mail clarifying, you know, what we're
`seeking.
`
`That's what resulted in the dispute
`that's before Your Honor right now. Basically, Realtek
`has -- is refusing to produce any technical documents
`other than the one, I guess, schematics or technical
`documents for one Realtek chip.
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`KRISTIE M. DAVIS, OFFICIAL COURT REPORTER
`U.S. DISTRICT COURT, WESTERN DISTRICT OF TEXAS (WACO)
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`4
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`So this case is about wireless chips,
`Your Honor. These are those -- you know, these very
`small chips that, you know, where they're highly
`confidential schematics. These are not publicly
`available information.
`You know, to get to this point,
`ParkerVision had to perform expensive and
`time-consuming circuit extractions to chart the -- the
`product that ParkerVision charted.
`With regards to other products, Your
`Honor, we identified, I think, 22 other chips. We
`believe those chips are the same or similar
`configuration to the chip that we charted. We provided
`Realtek with the basis why we believed that was the
`case. We provided a declaration of Dr. Ricketts.
`Dr. Ricketts has over 25 years'
`experience in the industry, in the integrated circuit
`industry for chips of this type. He explains very
`clearly in his declaration that he believes that, based
`on his knowledge of how companies reuse circuit
`architecture, reviewing Realtek patents as well as a
`paper that was sponsored by Realtek, given all that
`information, he concluded that it is reasonable to
`assume that the additional chips are reasonably similar
`to the chips that we charted.
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`KRISTIE M. DAVIS, OFFICIAL COURT REPORTER
`U.S. DISTRICT COURT, WESTERN DISTRICT OF TEXAS (WACO)
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`
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`Case 6:22-cv-01162-ADA Document 70 Filed 09/01/23 Page 5 of 23Case 6:22-cv-01162-ADA Document 92-1 Filed 03/15/24 Page 6 of 24
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`5
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`And so we did not chart -- we did not
`chart every, you know, 22 chips. Again, these circuit
`extractions, as you may be aware, cost, you know,
`upwards of $100,000. And we believe that we have a
`basis -- a very reasonable basis, based on expert
`statements, as to why these chips are similar.
`Now, you know, Realtek disagrees.
`Realtek says, well, no. You have to -- you know, you
`have to really go into -- you know, you basically have
`to go to all the circuit extractions, you've got to do,
`you know, extensive circuit extractions for all 22
`products. And then based on that, you have to tell us
`why they're similar. And we think that's unreasonable.
`That is, you know, do 22 circuit
`extractions, Your Honor, is probably over $2 million
`and my guess is years of extractions. And of course
`Realtek is saying that because they don't want to
`produce information. And they -- it's -- it would be
`very chilling on plaintiffs, if a plaintiff had to go
`and spend millions of dollars before they could bring a
`lawsuit and literally spend years of doing extractions.
`And that's why there's on information and
`belief. And we believe that we have good information
`and belief because we rely on an expert who has 25
`years' experience, have looked at Realtek patents,
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`KRISTIE M. DAVIS, OFFICIAL COURT REPORTER
`U.S. DISTRICT COURT, WESTERN DISTRICT OF TEXAS (WACO)
`
`
`
`
`
`Case 6:22-cv-01162-ADA Document 70 Filed 09/01/23 Page 6 of 23Case 6:22-cv-01162-ADA Document 92-1 Filed 03/15/24 Page 7 of 24
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`6
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`knows how these companies work, including Realtek --
`you know, companies like Realtek.
`And this case falls directly within a
`case that Your Honor has previously addressed, which
`was this IGT case that we cited in our e-mail, Your
`Honor.
`
`In IGT, basically similar situation.
`There were preliminary infringement contentions. In
`that case, I think there were 100 uncharted products.
`And the Court ordered the other side, the defendants,
`to produce documents regarding these uncharted
`products.
`
`And the Court, you know, noted that --
`I'm going to read this because I think it's important
`because it's relevant here. The Court said: It finds
`it appropriate to order discovery and rejected reliance
`on, defendants in that case, Zynga's unilateral
`arguments that products are not fairly represented,
`which is the same argument that Realtek is making here.
`And this Court rejected, and they said:
`The Court notes that the plaintiffs should exhaust
`publicly available information in providing preliminary
`infringement contentions.
`Which is what we did. Realtek has very
`little information about the products out there.
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`KRISTIE M. DAVIS, OFFICIAL COURT REPORTER
`U.S. DISTRICT COURT, WESTERN DISTRICT OF TEXAS (WACO)
`
`
`
`
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`Case 6:22-cv-01162-ADA Document 70 Filed 09/01/23 Page 7 of 23Case 6:22-cv-01162-ADA Document 92-1 Filed 03/15/24 Page 8 of 24
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`7
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`And then the Court said: But even if
`Zynga, the defendant, is correct that products are not
`fairly represented, plaintiff is still entitled to
`discovery to verify it when such information is not
`publicly available.
`That's exactly the case here. The
`information's not publicly available. As much as
`Realtek wants to say it's publicly available because
`there's chips out there, that doesn't make the
`information publicly available.
`The, you know, Realtek schematics are
`some of the most prized and highly confidential things
`they have. That information's not available. The fact
`that we can do extractions doesn't make the information
`publicly available.
`Like I said, it's extremely expensive,
`time-consuming process. And, you know, if we wound up
`trying to chart -- let me put it this way. If we
`charted our final infringement contentions to include
`just the schematics that we developed ourselves, I am
`sure Realtek would argue that those are insufficient
`because we didn't use actual schematics.
`So at this point, Your Honor -- and then
`the other case that they cite is -- from Your Honor is
`this -- they cite this WSOU case, Your Honor.
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`KRISTIE M. DAVIS, OFFICIAL COURT REPORTER
`U.S. DISTRICT COURT, WESTERN DISTRICT OF TEXAS (WACO)
`
`
`
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`Case 6:22-cv-01162-ADA Document 70 Filed 09/01/23 Page 8 of 23Case 6:22-cv-01162-ADA Document 92-1 Filed 03/15/24 Page 9 of 24
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`8
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`And that was a case that dealt with --
`it's distinguishable from this case, Your Honor, and
`that dealt with a situation where a defendant was --
`sorry -- there was preliminary infringement
`contentions, and then it was at the eve of final
`infringement contentions and the Court, from what I
`understand, merged the two requirements and said that,
`of course, at a final infringement contention stage,
`you have to provide, you know, detailed information.
`But that's not where we're at, Your
`Honor, in this case.
`So what we seek, Your Honor, is that
`Realtek should have to, you know, we have that their
`products are reasonably similar. We support that with
`expert declaration. We said that upon -- we gave --
`that's the basis for our information and belief.
`That's how, you know, cases work where you provide
`information and belief. And we have very good basis
`for information and belief and that there's reasonable
`similarity. And that's the standard that the Court has
`set out in the IGT case.
`So for those reasons, we think that
`Realtek should have to produce the schematics.
`Certainly way less burdensome on Realtek to have to
`produce schematics than us to spend millions of dollars
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`KRISTIE M. DAVIS, OFFICIAL COURT REPORTER
`U.S. DISTRICT COURT, WESTERN DISTRICT OF TEXAS (WACO)
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`Case 6:22-cv-01162-ADA Document 70 Filed 09/01/23 Page 9 of 23Case 6:22-cv-01162-ADA Document 92-1 Filed 03/15/24 Page 10 of 24
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`and years to reverse engineer these chips.
`THE COURT: Understood.
`A response?
`MS. WANG: Good afternoon, Your Honor.
`Grace Wang representing Realtek.
`This is a simple issue of whether
`ParkerVision has met its burden in explaining how
`uncharted products are reasonably similar to the
`charted product. And they have not met that burden.
`So here ParkerVision has charted only a
`single WiFi chip, but now they want to sweep in 22
`groups of other chips. They're sweeping in Bluetooth
`chips. They're sweeping in WiFi chips that operate
`under different WiFi standards from the charted chip.
`They're sweeping in Internet of Things, IoT, chips,
`Access Point, AP, router chips. They're even trying to
`sweep in global satellite navigation chips.
`The problem with all of this is that
`ParkerVision has not explained how any of these chips
`are actually reasonably similar to the one that they've
`charted. And, in fact, there are fundamental
`differences across the chips. We have explained these
`differences to ParkerVision. They said nothing to
`rebut the differences nor have they explained their
`apparent position that the differences don't matter.
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`KRISTIE M. DAVIS, OFFICIAL COURT REPORTER
`U.S. DISTRICT COURT, WESTERN DISTRICT OF TEXAS (WACO)
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`
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`Case 6:22-cv-01162-ADA Document 70 Filed 09/01/23 Page 10 of 23Case 6:22-cv-01162-ADA Document 92-1 Filed 03/15/24 Page 11 of 24
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`So I'll just give you one example. The
`chips operate in different frequency ranges. So the
`charted chip operates at 5-gigahertz, and most of the
`uncharted chips, this is including most of the other
`WiFi chips and all of the Bluetooth chips, they all
`operate at less than half of that. They operate at
`2.4-gigahertz.
`And this difference in frequency is very
`relevant here because the patents are talking about
`frequency down-conversion and sampling.
`So the upshot to all of this is that the
`accused functionality, the accused circuits are
`necessarily different across the different groups that
`ParkerVision has listed.
`As its sole support for similarity across
`the different groups of chips, ParkerVision and its
`expert Dr. Ricketts, they point to three different
`documents. But none of them explain how the
`differences amongst the chips, such as the frequency
`differences between Bluetooth and WiFi, none of them
`explain how those differences are supposed to have no
`impact on how the chips perform frequency
`down-conversion.
`Dr. Ricketts also admits in his
`declaration that he has no actual knowledge of the
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`KRISTIE M. DAVIS, OFFICIAL COURT REPORTER
`U.S. DISTRICT COURT, WESTERN DISTRICT OF TEXAS (WACO)
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`Case 6:22-cv-01162-ADA Document 70 Filed 09/01/23 Page 11 of 23Case 6:22-cv-01162-ADA Document 92-1 Filed 03/15/24 Page 12 of 24
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`11
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`Realtek products. And his belief that the chips are
`the same across all of these groups, across all of
`these different standards, that's a mere assumption.
`As for ParkerVision's argument that what
`they're requesting isn't publicly available, that's
`just not true. ParkerVision's own actions prove the
`opposite. So there are product descriptions for all of
`these chips that are publicly available. None of them
`are relied on by ParkerVision.
`These product descriptions describe the
`frequency ranges, the power requirements for these
`chips. ParkerVision's own contentions have relied on
`the public product description for the chip that they
`chose to chart but not for any of the uncharted chips.
`The chips are, of course, publicly
`available for purchase. ParkerVision has already
`bought at least one of them and reverse engineered it.
`Based on that, they've generated dozens of schematics
`of that chip. All of this is based on public
`information.
`
`ParkerVision should be required to do
`that again for the different chips, especially in light
`of the relevant differences across them.
`This case is different from IGT. There,
`the requested documentation for the products was not
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`KRISTIE M. DAVIS, OFFICIAL COURT REPORTER
`U.S. DISTRICT COURT, WESTERN DISTRICT OF TEXAS (WACO)
`
`
`
`
`
`Case 6:22-cv-01162-ADA Document 70 Filed 09/01/23 Page 12 of 23Case 6:22-cv-01162-ADA Document 92-1 Filed 03/15/24 Page 13 of 24
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`publicly available, but here it is. The chips are
`publicly available. The public specs are publicly
`available. And ParkerVision has not exhausted that
`publicly available information.
`So Realtek requests that the Court deny
`ParkerVision's requested relief.
`And as it has done under similar
`circumstances, in the WSOU case, where the Court
`actually made clear that the ruling was applicable to
`the stage of preliminary contentions, we request that
`the Court order ParkerVision to either provide a full
`explanation as to why the charted chip is
`representative of each uncharted chip, addressing the
`differences that we've raised, or ParkerVision should
`separately chart out each chip individually.
`And if ParkerVision continues to refuse
`either option, then it should remove the uncharted
`chips from this case.
`Thank you.
`MR. SIEGMUND: And, Your Honor, I know
`the Court is one riot, one ranger. But if you would
`like to hear more about the IGT versus Zynga case and
`why that's different, I argued that before the Court
`and lost it, unfortunately, for Zynga.
`But if you need to hear more about that
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`KRISTIE M. DAVIS, OFFICIAL COURT REPORTER
`U.S. DISTRICT COURT, WESTERN DISTRICT OF TEXAS (WACO)
`
`
`
`
`
`Case 6:22-cv-01162-ADA Document 70 Filed 09/01/23 Page 13 of 23Case 6:22-cv-01162-ADA Document 92-1 Filed 03/15/24 Page 14 of 24
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`case, I'm happy to address it, Your Honor. But that's
`all I have.
`
`THE COURT: I'm good.
`Any rebuttal?
`MR. CHARKOW: Yes, Your Honor.
`So, first of all, let me go backward.
`We're talking about preliminary infringement
`contentions. Counsel's arguing very substantively
`about this case and how we have to prove things and
`what we have to put in there. And this is just not the
`stage of this case, right. We're very early on in this
`case.
`
`Counsel also talked about Bluetooth and
`frequencies. That's irrelevant to -- that's
`irrelevant. It's the fact that it's the structure that
`dictates, the fact that different frequencies can use
`the same structures.
`So quite frankly, Your Honor, that's just
`a red herring. Frequencies and power requirements,
`that has nothing to do with the specifics of how the
`structure of these chips operate.
`And again, you don't hear them saying
`that the structures are different or they're the same.
`They don't say that. They're talking about something
`that has nothing to do with anything.
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`KRISTIE M. DAVIS, OFFICIAL COURT REPORTER
`U.S. DISTRICT COURT, WESTERN DISTRICT OF TEXAS (WACO)
`
`
`
`
`
`Case 6:22-cv-01162-ADA Document 70 Filed 09/01/23 Page 14 of 23Case 6:22-cv-01162-ADA Document 92-1 Filed 03/15/24 Page 15 of 24
`
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`And again, our expert, Dr. Ricketts, they
`haven't provided -- I think we went above and beyond by
`providing declarations from an expert. They have
`provided nothing. They have provided no internal
`declarations, no information from any of their
`employees to say we got it wrong.
`Dr. Ricketts specifically talked about
`across standards and Bluetooth and WiFi. And he said
`that it's very common for companies to reuse the same
`architecture regardless of the -- of the specification,
`whether it's Bluetooth or WiFi, that's being used.
`The other thing that I want to point out
`is that the -- let's see -- the public availability.
`Counsel talked about that this information was all
`publicly available and there's specs.
`Those specs, Your Honor, don't talk about
`the details that we're talking about. They don't talk
`about the capacitors and the switches and the
`transistors that you need in order to -- in order to
`allege infringement.
`The specs that she's talking about are --
`talks about frequency ranges and high-level stuff.
`There's no specs out there that shows the schematics
`that you need to prove infringement in this case.
`So what counsel is saying is incorrect,
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`KRISTIE M. DAVIS, OFFICIAL COURT REPORTER
`U.S. DISTRICT COURT, WESTERN DISTRICT OF TEXAS (WACO)
`
`
`
`
`
`Case 6:22-cv-01162-ADA Document 70 Filed 09/01/23 Page 15 of 23Case 6:22-cv-01162-ADA Document 92-1 Filed 03/15/24 Page 16 of 24
`
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`and they're avoiding the issue in terms of what truly
`is publicly available.
`And basically, you know, this also goes
`to the issue of discovery in this case and it seems
`like Realtek -- basically what counsel has just said is
`that we're basically essentially required to do -- you
`know, as a plaintiff, to do extractions that cost
`around 100,000 or more dollars per chip and, again,
`will take years before we can get information from them
`at this stage to figure out, you know, how we're going
`to chart things and to get the information that we're
`entitled to, you know, along with the preliminary
`invalidity contentions.
`And if you're talking about the burden
`between the parties, ParkerVision has to spend millions
`and probably years now to go out and to do extractions
`and circuit schematics captures while Realtek, on the
`other side, can just go to people in their organization
`and say, okay. Are there representative products?
`Which one -- there's 20 -- this isn't an infinite
`number of products, Your Honor. There's only 22
`products here.
`They can go to, you know, people inside
`and say, yes. These are representative. There's
`actually -- 22 is actually only three schematics
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`KRISTIE M. DAVIS, OFFICIAL COURT REPORTER
`U.S. DISTRICT COURT, WESTERN DISTRICT OF TEXAS (WACO)
`
`
`
`
`
`Case 6:22-cv-01162-ADA Document 70 Filed 09/01/23 Page 16 of 23Case 6:22-cv-01162-ADA Document 92-1 Filed 03/15/24 Page 17 of 24
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`represent, you know, all the schematics. And we don't
`know that, but they would know that.
`So, Your Honor, for all those reasons, we
`believe given the preliminary stage of this case, given
`the declaration that we provided from our expert, which
`is specifically addressed across various Bluetooth/WiFi
`chips and he specifically stated that it's
`reasonably -- they're reasonably -- those chips are
`going to be reasonably similar, we believe that we're
`entitled to this discovery now and certainly when
`discovery, you know, opens in full so that we can
`properly chart the chips.
`And again, the IGT case is right on
`point. You know, the fact that Realtek doesn't agree
`with us on substantive issues shouldn't -- should have
`no bearing on this. It's not about whether they agree
`with us or not agree with us or, you know, whether
`we've met some high standard that's needed for final
`contentions. We're at preliminary infringement
`contentions.
`
`THE COURT: Any rebuttal?
`MS. WANG: So, Your Honor, it's not our
`position that ParkerVision has to spend millions and
`millions of dollars reverse engineering every single
`chip, but they do at this stage have a burden to
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`KRISTIE M. DAVIS, OFFICIAL COURT REPORTER
`U.S. DISTRICT COURT, WESTERN DISTRICT OF TEXAS (WACO)
`
`
`
`
`
`Case 6:22-cv-01162-ADA Document 70 Filed 09/01/23 Page 17 of 23Case 6:22-cv-01162-ADA Document 92-1 Filed 03/15/24 Page 18 of 24
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`explain. If they're not going to do that, they do have
`the burden to explain how the uncharted chips are
`reasonably similar to the charted chips. And they
`haven't met that burden.
`It would be a different matter if they
`had taken one representative Bluetooth chip, one
`representative WiFi chip for each of the WiFi
`standards, one representative Access Point router chip,
`one representative GPS chip, one representative IoT
`chip. They haven't done that here.
`What they've done is charted a single
`WiFi chip under one WiFi standard, and they're trying
`to lump in and sweep in different chips under different
`standards that are very different from one another.
`And the differences between the charted chip and the
`uncharted chip is not unrelevant. And nothing that
`ParkerVision or Dr. Ricketts have said addresses those
`differences.
`
`THE COURT: I'll be back in a second.
`(Pause in proceedings.)
`THE COURT: Okay. If we could go back on
`
`the record.
`
`I'm going to give the defendant two
`options here. The first is -- the default option is
`that they're going to produce all the technical
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`KRISTIE M. DAVIS, OFFICIAL COURT REPORTER
`U.S. DISTRICT COURT, WESTERN DISTRICT OF TEXAS (WACO)
`
`
`
`
`
`Case 6:22-cv-01162-ADA Document 70 Filed 09/01/23 Page 18 of 23Case 6:22-cv-01162-ADA Document 92-1 Filed 03/15/24 Page 19 of 24
`
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`documents for the 22 uncharted products. But I
`understand your argument about having to produce that
`many.
`
`So if you all want to get together and
`work with the plaintiff and say, your chip -- I'm going
`to pick this number just because it's in front of me --
`the Chip RTL8812BU is representative of other chips for
`purposes of infringement. So we're -- for example, if
`you only want to give the technical documents for one
`Bluetooth product and agree with ParkerVision that for
`purposes of the manner in which they function, they
`function identically, so you can just -- if you get --
`if the plaintiff gets one, they don't need the others.
`You all -- I'm fine with you all working
`something like that out, and I know when I was
`practicing we used to do that.
`But if you can't agree to do that, then
`you can just produce all of them for the 22 products.
`So let me ask counsel: Ms. Wang, how
`long would it -- let me ask you first if you have any
`interest in talking to ParkerVision's counsel about
`doing something like what I just said. If you don't,
`then I'll -- I can move ahead.
`MS. WANG: Yeah. I mean, we -- I'd have
`to confer with my client, but we'd be willing to try to
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`KRISTIE M. DAVIS, OFFICIAL COURT REPORTER
`U.S. DISTRICT COURT, WESTERN DISTRICT OF TEXAS (WACO)
`
`
`
`
`
`Case 6:22-cv-01162-ADA Document 70 Filed 09/01/23 Page 19 of 23Case 6:22-cv-01162-ADA Document 92-1 Filed 03/15/24 Page 20 of 24
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`work something out with the plaintiff and see what's
`possible.
`
`THE COURT: Okay. Then let me hear from
`ParkerVision's counsel. I know you all have not done a
`great job of getting along in this case. Sometimes you
`do, sometimes you don't. That's fine.
`How long would you like to have to try
`and work this out with opposing counsel? How long do
`you think it would take?
`And then I'll hear from Ms. Wang.
`MR. CHARKOW: Yeah. So of course we're
`willing to work together with the defendants to try to
`put something together. My guess, it's going to take
`at least a few weeks because I think we're going to
`have to go back and forth. They're going to have to --
`you know, we don't have the information, right. So we
`can't say what's representative and not as clearly as
`they can say what's representative.
`So, you know, if we can come to some, you
`know, common ground, we can do that. But my guess is
`it's going to take at least a couple of weeks to go
`back and forth with them if we're going to do this
`process right. It's not something that's going to take
`a day because they're going to have to go back to
`engineers, get information, give us some information.
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`KRISTIE M. DAVIS, OFFICIAL COURT REPORTER
`U.S. DISTRICT COURT, WESTERN DISTRICT OF TEXAS (WACO)
`
`
`
`
`
`Case 6:22-cv-01162-ADA Document 70 Filed 09/01/23 Page 20 of 23Case 6:22-cv-01162-ADA Document 92-1 Filed 03/15/24 Page 21 of 24
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`We can certainly do that. And like you said, we've
`done that in other cases.
`So -- but probably my guess, it's going
`to take a couple of weeks for us to work it out with
`them.
`
`THE COURT: Well, and then let me be --
`let me be skeptical here for a moment and assume that
`y'all will not be able to resolve this.
`Ms. Wang, one, I'll give you two weeks to
`try and work this out, unless you all agree to take
`more time and that's fine.
`But assuming that your client would have
`to produce these documents, how long would it take you
`to produce the documents to ParkerVision?
`MS. WANG: That's a good question. I'd
`have to -- I really just have to go back to them and
`see what's possible.
`MR. SIEGMUND: Your Honor, if we could
`get a couple of weeks to do that, I think we could
`probably reach some agreement with them. Obviously
`Realtek is not a United States company. It is in
`Taiwan. And so there is some difficulty in
`communication with the client just time zone wise and
`what's going on in the world -- sorry.
`THE COURT: I'm sorry. I didn't mean to
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`KRISTIE M. DAVIS, OFFICIAL COURT REPORTER
`U.S. DISTRICT COURT, WESTERN DISTRICT OF TEXAS (WACO)
`
`
`
`
`
`Case 6:22-cv-01162-ADA Document 70 Filed 09/01/23 Page 21 of 23Case 6:2
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