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UNITED STATES DISTRICT COURT

WESTERN DISTRICT OF TEXAS

WACO DIVISION

PARKERVISION, INC.,

 Plaintiff, 

 v. 

INTEL CORPORATION,

 Defendant.

Civil Action No. 6:20-cv-00108-ADA

Civil Action No. 6:20-cv-00562-ADA

JOINT MOTION TO AMEND SCHEDULING ORDER

On January 20, 2022, by an email from Mr. Regan Rundio and the agreement of 

the parties, the Court rescheduled trial in these matters to October 24, 2022 and May 29, 

2023. In view of the rescheduled trial dates, Plaintiff ParkerVision Inc. and Defendant 

Intel Corporation jointly move to modify the schedule up to and including the trials of 

these matters as follows:

Proposed 

Deadline

Event

108/562 Cases – First Trial

Event

108/562 Cases – Second Trial1

1 The parties have agreed and hereby stipulate to the following regarding claims and defenses at the Second 

Trial. Subject to the Court’s rulings on claim narrowing, ParkerVision may assert any claims that have been 

preserved in its Final Infringement Contentions and expert reports for the Second Trial, provided that any 

such claim was not invalidated at the First Trial. For any claim that ParkerVision asserted at the First Trial, 

Intel may present any invalidity theory (e.g., a theory that a particular reference anticipates the claim under § 

102, a theory that a particular combination of references renders the claim obvious under § 103, or a theory 

that a claim term is indefinite, not enabled, or lacks written description under § 112) that has been preserved in 

its Final Invalidity Contentions and expert reports for the Second Trial, unless that identical theory was 

presented at the First Trial with respect to that claim and the claim was not determined to be invalid. For any 

claim that ParkerVision did not assert at the First Trial, Intel may present any invalidity theory preserved in its 

Final Invalidity Contentions and expert reports for the Second Trial. For the avoidance of doubt, Intel shall 

not be precluded from offering at the Second Trial any evidence relating to prior independent development 

and/or the background state of the art, even if similar, or identical evidence was presented at the First Trial.

Case 6:20-cv-00108-ADA Document 108 Filed 02/09/22 Page 1 of 9
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Accused cellular products 

(6,580,902; 9,246,736; 

9,118,528; 8,588,725; 

9,444,673; and 7,539,474)

Accused Wi-Fi and Bluetooth products

(Same patents along with 7,050,508 or 

8,190,108, one of which ParkerVision will 

dismiss with prejudice within 2 weeks of

the PTAB’s final written decision 

regarding the ‘108 patent which will be 

issued in or about July 2022)

1/17/2022 Deadline to serve Final 

Infringement Contentions as 

to the 8,588,725 and 

9,444,673 patents. After this 

date, leave of Court is 

required for any 

amendment to Final 

Infringement Contentions. 

2/14/2022 Deadline to serve Preliminary Invalidity 

Contentions in response to ParkerVision’s

Preliminary Infringement Contentions as 

to Intel’s wi-fi/Bluetooth chips for patent 

nos. 7,050,508 and 8,190,108

2/16/2022 Deadline for the first of two 

meet and confers to discuss 

narrowing the number of 

claims asserted and prior art 

references at issue. Unless 

the parties agree to the 

narrowing, they are ordered 

to contact the Court’s Law 

Clerk to arrange a 

teleconference with the 

Court to resolve the 

disputed issues.

2/18/2022 Deadline to serve Final 

Invalidity Contentions. 

After this date, leave of 

Court is required for any 

Case 6:20-cv-00108-ADA Document 108 Filed 02/09/22 Page 2 of 9
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amendment to Final 

Invalidity Contentions. 

3/25/2022 Close of Fact Discovery.

4/21/2022 Opening Expert Reports.

4/27/2022 Deadline to serve Final Infringement 

Contentions. After this date, leave of 

Court is required for any amendment to 

Final Infringement Contentions. 

5/18/2022 Deadline to serve Final Infringement 

Contentions. After this date, leave of 

Court is required for any amendment to 

Final Infringement Contentions. 

5/24/2022 Rebuttal Expert Reports.

6/17/2022 Close of Expert Discovery.

6/21/2022 Deadline for the second of 

two meet and confer to 

discuss narrowing the 

number of claims asserted 

and prior art references at 

issue to triable limits. To the 

extent it helps the parties 

determine these limits, the 

parties are encouraged to 

contact the Court’s Law 

Clerk for an estimate of the 

amount of trial time 

anticipated per side. The 

parties shall file a Joint 

Report within 5 business 

days regarding the results of 

the meet and confer.

Deadline to serve Final Invalidity 

Contentions. After this date, leave of 

Court is required for any amendment to 

Final Invalidity Contentions.

Case 6:20-cv-00108-ADA Document 108 Filed 02/09/22 Page 3 of 9
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7/12/2022

Dispositive motion deadline 

and Daubert motion 

deadline. 

See General Issues Note #9 

regarding providing copies 

of the briefing to the Court 

and the technical adviser (if 

appointed).

8/2/2022

Responses to dispositive 

motions and Daubert 

motions due. (See Rule CV7.D.2.)

8/16/2022

Replies in support of 

dispositive motions and 

Daubert motions due. (See

Rule CV-7.E.2

8/25/2022 Serve Pretrial Disclosures 

(jury instructions, exhibits 

lists, witness lists, discovery 

and deposition 

designations).

9/8/2022 Serve objections to pretrial 

disclosures/rebuttal 

disclosures.

Deadline for the first of two meet and 

confers to discuss narrowing the number 

of claims asserted and prior art references 

at issue. Unless the parties agree to the 

narrowing, they are ordered to contact 

the Court’s Law Clerk to arrange a 

teleconference with the Court to resolve 

the disputed issues.

9/15/2022 Serve objections to rebuttal 

disclosures and File Motions 

in Limine.

9/22/2022 File Joint Pretrial Order and 

Pretrial Submissions (jury 

instructions, exhibits lists, 

witness lists, discovery and 

deposition designations); 

Case 6:20-cv-00108-ADA Document 108 Filed 02/09/22 Page 4 of 9
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file oppositions to motions 

in limine.

9/30/2022 File Notice of Request for 

Daily Transcript or Real 

Time Reporting. If a daily 

transcript or real time 

reporting of court 

proceedings is requested for 

trial, the party or parties 

making said request shall 

file a notice with the Court 

and e mail the Court 

Reporter, Kristie Davis at 

kmdaviscsr@yahoo.com 

Deadline to meet and confer 

regarding remaining 

objections and disputes on 

motions in limine.

10/6/2022 File joint notice identifying 

remaining objections to 

pretrial disclosures and 

disputes on motions in 

limine.

10/14/2022 Final Pretrial Conference.

10/24/2022 Jury Selection/Trial.

12/9/2022 Close of Fact Discovery

12/23/2022 Opening Expert Reports

Case 6:20-cv-00108-ADA Document 108 Filed 02/09/22 Page 5 of 9
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1/27/2023 Rebuttal Expert Reports

2/17/2023 Close of Expert Discovery

2/24/2023 Deadline for the second of two meet and 

confer to discuss narrowing the number 

of claims asserted and prior art references 

at issue to triable limits. To the extent it 

helps the parties determine these limits, 

the parties are encouraged to contact the 

Court’s Law Clerk for an estimate of the 

amount of trial time anticipated per side. 

The parties shall file a Joint Report within 

5 business days regarding the results of 

the meet and confer.

3/3/2023 Dispositive motion deadline and Daubert 

motion deadline. 

See General Issues Note #9 regarding 

providing copies of the briefing to the 

Court and the technical adviser (if 

appointed).

3/17/2023 Responses to dispositive motions and 

Daubert motions due. (See Rule CV7.D.2.)

3/31/2023 Replies in support of dispositive motions 

and Daubert motions due. (See Rule CV7.E.2

4/7/2023 Serve Pretrial Disclosures (jury 

instructions, exhibits lists, witness lists, 

discovery and deposition designations) 

Case 6:20-cv-00108-ADA Document 108 Filed 02/09/22 Page 6 of 9
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4/21/2023 Serve objections to pretrial 

disclosures/rebuttal disclosures.

4/28/2023 Serve objections to rebuttal disclosures 

and File Motions in Limine.

5/5/2023 File Joint Pretrial Order and Pretrial 

Submissions (jury instructions, exhibits 

lists, witness lists, discovery and 

deposition designations); file oppositions 

to motions in limine.

5/10/2023 File Notice of Request for Daily 

Transcript or Real Time Reporting. If a 

daily transcript or real time reporting of 

court proceedings is requested for trial, 

the party or parties making said request 

shall file a notice with the Court and e 

mail the Court Reporter, Kristie Davis at 

kmdaviscsr@yahoo.com 

Deadline to meet and confer regarding 

remaining objections and disputes on 

motions in limine. 

5/12/2023 File joint notice identifying remaining 

objections to pretrial disclosures and 

disputes on motions in limine.

5/19/2023 Final Pretrial Conference

5/29/2023 Jury Selection/Trial 

Case 6:20-cv-00108-ADA Document 108 Filed 02/09/22 Page 7 of 9
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Dated: February 9, 2022 Respectfully submitted,

/s/ J. Stephen Ravel /s/ Raymond W. Mort, III

J. Stephen Ravel

Texas State Bar No. 16584975

steve.ravel@kellyhart.com

KELLY HART & HALLMAN LLP

303 Colorado, Suite 2000

Austin, Texas 78701

Tel: (512) 495-6429

James E. Wren 

Texas State Bar No. 22018200 

One Bear Place, Unit 97288 

Waco, Texas 76798 

Tel: (254) 710-7670 

james.wren@baylor.edu

Michael J. Summersgill (pro hac vice)

Sarah B. Petty (pro hac vice) 

Marissa A. Lalli (pro hac vice) 

Samuel C. Leifer (pro hac vice) 

WILMER CUTLER PICKERING 

HALE AND DORR LLP 

60 State Street 

Boston, Massachusetts 02109 

Tel: (617) 526-6000 

michael.summersgill@wilmerhale.com 

sarah.petty@wilmerhale.com 

marissa.lalli@wilmerhale.com 

samuel.leifer@wilmerhale.com 

Todd Zubler (pro hac vice) 

WILMER CUTLER PICKERING 

HALE AND DORR LLP 

1875 Pennsylvania Avenue NW 

Washington, DC 20006 

Tel: (617) 526-6000 

todd.zubler@wilmerhale.com 

Raymond W. Mort, III

Texas State Bar No. 00791308

raymort@austinlaw.com

THE MORT LAW FIRM, PLLC

100 Congress Avenue, Suite 2000

Austin, Texas 78701

Tel/Fax: 512-865-7950

Of counsel:

Ronald M. Daignault (pro hac vice)*

Chandran B. Iyer (pro hac vice) 

Jason S. Charkow (pro hac vice)*

Stephanie R. Mandir (pro hac vice)

Zachary H. Ellis 

(Texas State Bar No. 24122606)*

Christian E. Samay (pro hac vice)*

DAIGNAULT IYER LLP

8618 Westwood Center Drive – Suite 150

Vienna, VA 22182

rdaignault@daignaultiyer.com

cbiyer@daignaultiyer.com

jcharkow@daignaultiyer.com

smandir@daignaultiyer.com

zellis@daignaultiyer.com

*Not admitted in Virginia

Attorneys for Plaintiff ParkerVision, Inc.

Case 6:20-cv-00108-ADA Document 108 Filed 02/09/22 Page 8 of 9
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Jason F. Choy (pro hac vice)

WILMER CUTLER PICKERING 

HALE AND DORR LLP 

350 South Grand Avenue, Suite 2100 

Los Angeles, California 90071 

Tel: (213) 443-5300 

jason.choy@wilmerhale.com

Attorneys for Defendant Intel Corporation

Case 6:20-cv-00108-ADA Document 108 Filed 02/09/22 Page 9 of 9