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No. 61

Document ParkerVision, Inc. v. Realtek Semiconductor Corp., 6:23-cv-00374, No. 61 (W.D.Tex. Jul. 9, 2024)

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No. 106

Document ParkerVision, Inc. v. Realtek Semiconductor Corp., 6:22-cv-01162, No. 106 (W.D.Tex. Jun. 19, 2024)

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No. 104 DISCOVERY ORDER

Document ParkerVision, Inc. v. Realtek Semiconductor Corp., 6:22-cv-01162, No. 104 (W.D.Tex. Jun. 11, 2024)

“Significantly, once one extends the extraterritoriality principle to confining how damages are calculated, it makes no sense to insist that the action respecting the product being used for measurement itself be an infringing action.” Id.

As the Federal Circuit recently confirmed, ParkerVision must provide a “focused, coherent explanation of the required causal connection to domestic infringement.” Brumfield v. IBG, LLC, 97 F.4th 854, 880 (Fed. Cir. 2024) (affirming district court’s exclusion of worldwide sales under the WesternGeco framework because the damages theory “is legally insufficient ... [since] it does not start from an act of ‘infringement’”).

Realtek’s continuous failure to produce damages-related documents prejudices ParkerVision’s ability to develop its damages case, particularly under the current scheduling order where Realtek is trying to delay and “run out the clock” on discovery.

Indeed, ParkerVision has failed to produce the same marketing, business plans, sales projections, competitor analysis, and other financial documents in response to Realtek’s similar requests for production, and refuses to confirm whether or not it will.

Additionally, Realtek must produce marketing, business plans, sales projections, competitor analysis, and other financial documents in response to Request for Production Nos. 15, 23, 32, and 34.

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Analyze Judge
- Alan Albright
Analyze Party
- Parkervision
Analyze Firm
- Daignault Iyer
- The Mort Law Firm

No. 103 DISCOVERY ORDER

Document ParkerVision, Inc. v. Realtek Semiconductor Corp., 6:22-cv-01162, No. 103 (W.D.Tex. Jun. 11, 2024)

On June 6, 2024, counsel for Plaintiff ParkerVision, Inc. (“ParkerVision”) and Defendant Realtek Semiconductor Corp.’s (“Realtek”) submitted to the Court a chart summarizing a discovery dispute.

It has produced almost nothing (and in some cases, nothing) related to research, chip design and development, specifications, testing, presentations, planning, roadmaps, marketing, competitive analyses, etc.—documents a sophisticated company like Realtek should have plenty of.

Realtek’s counsel should have collected all documents falling within the scope of ParkerVision’s RFPs and withheld only those for which it had a reasonable objection in the context of the breadth of discovery allowed under Rule 26.

Indeed, in response to every specific inquiry from ParkerVision, Realtek searched, collected, and produced documents, including those with no relevance to the accused feature.

Indeed, ParkerVision states in a separate dispute that Realtek’s simple request for draft licenses is “not proportional to the needs of this case and the issues at stake.” Ex. F. Under that standard (indeed, any standard), collecting and reviewing technical documents on unaccused features here (memory, connectivity, peripherals, security, digital processing, bus, etc.) cannot be proportional.

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