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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 

JURY TRIAL DEMANDED 

NOTICE REGARDING AGREED AMENDMENT TO SCHEDULING ORDER 

To facilitate the exchange of pretrial materials in this case, and pursuant to the Court’s 

Amended Standing Order Regarding Joint or Unopposed Request to Change Deadlines dated 

March 7, 2022, Defendant Intel Corporation (“Intel”) hereby provides notice that the parties have 

agreed to amend the August 1, 2022 Amended Scheduling Order DE 150 as follows: 

Dates Event 

108 Case – First Trial1

Accused cellular products 

(6,580,902; 9,246,736; 9,118,528; 8,588,725; 9,444,673; and 7,539,474) 

 

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 assert as part of a § 102 or § 103 invalidity argument any prior art reference disclosed in its Invalidity 

Contentions and expert reports for the Second Trial, that was not used as a § 102 or § 103 reference at the First 

Trial, and present any theory that a claim term is indefinite, not enabled, or lacks written description under § 

112 unless that identical theory was presented at the First Trial with respect to that claim and the claim was 

not determined to be invalid in a final judgment. 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, motivation to combine, 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 188 Filed 11/01/22 Page 1 of 5
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11/15/2022 Responses to dispositive motions and Daubert motions due. (See Rule CV7.D.2.) 

11/22/2022 Replies in support of dispositive motions and Daubert motions due. (See

Rule CV-7.E.2) 

12/7/2022 Defendant serves proposed joint pretrial order, jury instructions, proposed 

voir dire, special verdict form, exhibit list, witness list, affirmative 

discovery and deposition designations.2

Plaintiff serves exhibit list, witness list, affirmative discovery and 

deposition designations. 

12/8/2022 Parties serve copies of exhibits on their respective exhibit lists. 

12/14/2022 Defendant serves objections to Plaintiff’s exhibit list, witness list, and 

affirmative discovery and deposition designations. Defendant also serves 

any counter discovery and deposition designations and any rebuttal 

exhibits. 

Plaintiff serves objections and responses to Defendant’s proposed joint 

pretrial order, jury instructions, proposed voir dire, and proposed verdict 

form, and objections to Plaintiff’s exhibit list, witness list, and affirmative 

discovery and deposition designations. Plaintiff also serves any counter 

discovery and deposition designations and any rebuttal exhibits. 

12/22/2022 Defendant serves objections and responses to Plaintiff’s proposed revisions 

to the proposed joint pretrial order, jury instructions, proposed voir dire, 

and proposed verdict form. Defendant also serves counter discovery and 

deposition designations and any rebuttal exhibits. 

Plaintiff serves objections to Defendant’s counter discovery and deposition 

designations and any rebuttal exhibits. 

Parties File Motions in Limine.3

1/13/2023 Plaintiff Files Joint Pretrial Order and Pretrial Submissions (jury 

instructions, exhibits lists, witness lists, discovery and deposition 

designations, voir dire4). 

Parties File Oppositions to Motions in Limine. 

 

2 The parties agree that, for all deposition designation exchanges, the parties will serve both charts and 

highlighted transcripts identifying their respective designations. 

3 The parties agree that they will not serve discovery or deposition counter-counter designations. 

4 See Amended Standing Order on Pretrial Procedures and Requirements in Civil Cases, ¶ C.3.a (Sept. 16, 

2022). 

Case 6:20-cv-00108-ADA Document 188 Filed 11/01/22 Page 2 of 5
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1/17/2023 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. 

1/20/2023 File joint notice identifying remaining objections to pretrial disclosures and 

disputes on motions in limine. 

1/27/2023 Final Pretrial Conference. 

2/6/2023 Jury Selection/Trial. 

 

Case 6:20-cv-00108-ADA Document 188 Filed 11/01/22 Page 3 of 5
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Dated: November 1, 2022 Respectfully submitted, 

s/ J. Stephen Ravel 

Michael J. Summersgill (admitted Pro Hac Vice) 

Sarah B. Petty (admitted Pro Hac Vice) 

Harry Hanson (admitted Pro Hac Vice) 

Samuel C. Leifer (admitted Pro Hac Vice) 

Alicia Coneys (admitted Pro Hac Vice) 

Wilmer Cutler Pickering Hale and Dorr LLP 

60 State Street 

Boston, Massachusetts 02109 

T (617) 526-6000 

michael.summersgill@wilmerhale.com 

sarah.petty@wilmerhale.com 

harry.hanson@wilmerhale.com 

samuel.leifer@wilmerhale.com 

alicia.coneys@wilmerhale.com 

Todd Zubler (admitted Pro Hac Vice) 

Isley M. Gostin (admitted Pro Hac Vice) 

Wilmer Cutler Pickering Hale and Dorr LLP 

1875 Pennsylvania Avenue NW 

Washington, DC 20006 

T (202) 663-6636 

todd.zubler@wilmerhale.com 

isley.gostin@wilmerhale.com 

Mary (Mindy) V. Sooter 

Wilmer Cutler Pickering Hale and Dorr LLP 

1225 17th Street, Suite 2600 

Denver, CO 80202 

T (720) 274-3135 

mindy.sooter@wilmerhale.com 

Jason F. Choy (admitted Pro Hac Vice) 

Wilmer Cutler Pickering Hale and Dorr LLP 

350 South Grand Avenue, Suite 2100 

Los Angeles, California 90071 

T (213) 443-5300 

jason.choy@wilmerhale.com 

J. Steven Ravel 

KELLY HART & HALLMAN LLP 

303 Colorado, Suite 2000 

Austin, Texas 78701 

T (512) 495-6429 

steve.ravel@kellyhart.com 

James E. Wren 

Texas State Bar No. 22018200 

1 Bear Place, Unit 97288 

Waco, Texas 76798 

T (254) 710-7670 

james.wren@baylor.edu 

ATTORNEYS FOR DEFENDANT 

INTEL CORPORATION 

Case 6:20-cv-00108-ADA Document 188 Filed 11/01/22 Page 4 of 5
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CERTIFICATE OF SERVICE 

 The undersigned hereby certifies that a true and correct copy of the above and foregoing 

document has been served on November 1, 2022, to all counsel of record who are deemed to have 

consented to electronic service via the Court’s CM/ECF system. 

 

 /s/ J. Stephen Ravel 

 J. Stephen Ravel 

Case 6:20-cv-00108-ADA Document 188 Filed 11/01/22 Page 5 of 5