UNITED STATES DISTRICT COURT

FOR THE WESTERN DISTRICT OF TEXAS

WACO DIVISION 

PARKERVISION, INC., 

Plaintiff

 v.

INTEL CORPORATION, 

 Defendant 

Case No. 6:20-cv-00108-ADA 

PLAINTIFF PARKERVISION, INC.'S RESPONSE IN OPPOSITION TO 

DEFENDANT INTEL CORPORATION'S MOTION TO EXCLUDE OPINIONS 

AND TESTIMONY FROM PLAINTIFF'S TECHNICAL EXPERT DR. 

MICHAEL STEER

Case 6:20-cv-00108-ADA Document 228 Filed 11/22/22 Page 1 of 20
TABLE OF CONTENTS

Page

I. INTRODUCTION .............................................................................................. 1

II. LEGAL STANDARD.......................................................................................... 2

III. ARGUMENT...................................................................................................... 3

A. Dr. Steer’s C/RTP Opinions Should Not Be Excluded............................ 3

1. Intel has notice of ParkerVision’s C/RTP theories....................... 3

2. Dr. Steer’s C/RTP opinions are admissible .................................. 6

B. Dr. Steer’s Infringement Opinions Based On His CircuitLevel Simulations Should Not Be Excluded......................................... 11

IV. CONCLUSION................................................................................................. 15

Case 6:20-cv-00108-ADA Document 228 Filed 11/22/22 Page 2 of 20
TABLE OF AUTHORITIES

Page(s)

Cases

CloudofChange, LLC v. NCR Corp., 

Case No. 6:19-cv-00513-ADA, ECF No. 205 (W.D. Tex. Nov. 9, 2021)....................... 15

Daubert v. Merrell Dow Pharms., Inc., 

509 U.S. 579 (1993)................................................................................................passim

Moore v. Ashland Chem. Inc., 

151 F.3d 269 (5th Cir. 1998)......................................................................................... 10

Perdiemco v. Industrack LLC, 

Case No. 2:15-cv-00727-JRG-RSP, 2016 U.S. Dist. LEXIS 183636 (E.D. 

Tex. Nov. 3, 2016) ........................................................................................................... 6

Watkins v. Telesmith, Inc., 

121 F.3d 984 (5th Cir. 1997)........................................................................................... 3

Other Authorities

FED. R. EVID. 702(a)....................................................................................................... 2, 3

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PAGE |1 

I. INTRODUCTION 

First, in the context of a Daubert motion, Intel seeks to exclude testimony of 

ParkerVision’s expert based on a purported lack of notice to Intel. This is not the 

proper subject of a Daubert motion and, thus, Intel’s argument should be rejected. 

Nevertheless, there was no lack of notice. The testimony Intel complains about 

relates to Dr. Steer’s opinions on conception and reduction to practice (“C/RTP”). But 

Intel has known for more than two years that ParkerVision alleged earlier C/RTP 

dates (as well as the specific dates) for claim 5 of the ’902 Patent, claim 6 of the ’725 

Patent, and claims 5 and 17 of the ’673 Patent. Moreover, ParkerVision produced 

C/RTP documents at this time and supplemented its production during discovery. At 

bottom, Intel is now complaining that ParkerVision did not include what is 

tantamount of an expert report regarding C/RTP in its interrogatories. But if Intel 

wanted additional details in ParkerVision’s interrogatory disclosures related to 

C/RTP, it should have raised it with ParkerVision and, if necessary, the Court during 

discovery (and before expert reports), rather than lie in wait and raise it in the context 

of a Daubert motion less than four months before trial. 

Second, Intel asserts that Dr. Steer’s methodology for evaluating C/RTP is 

unsound. As discussed below, there is nothing unsound about his methodology. Intel 

simply disagrees with how Dr. Steer got to his conclusions. This is the subject of crossexamination at trial; not Daubert. Intel is effectively asking the Court to weigh Dr. 

Steer’s opinions supporting an early C/RTP date and determine whether 

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ParkerVision’s Eddie-1 chip embodies the asserted claims. That, however, is an issue 

for the jury.

Finally, Intel asserts that Dr. Steer’s simulations analysis was flawed because 

he modeled transistors in the accused SMARTi chips as switches. Intel ignores that

when Dr. Steer modeled the accused chips using switches, he had a sound basis for 

doing so: he relied on the testimony of Intel’s engineers, Intel’s documents, and his 

independent testing which all demonstrated that it was appropriate to model a 

transistor as a switch. Once again, this is the subject of cross-examination at trial; 

not Daubert. 

Intel fails to show that Dr. Steer’s opinions are unreliable and, thus, the Court 

should deny Intel’s motion.

II. LEGAL STANDARD

An expert witness must be “qualified as an expert by knowledge, skill, 

experience, training, or education,” and the testimony must “help the trier of fact to 

understand the evidence or to determine a fact in issue[.]” FED. R. EVID. 702(a). The 

trial judge, in the role of gatekeeper, has the authority to screen expert testimony for 

compliance with Rule 702 and to regulate and exclude subjects and theories about 

which an expert may testify. Daubert v. Merrell Dow Pharms., Inc., 509 U.S. 579, 589 

(1993). Rule 702 requires judges to “ensure that any and all scientific testimony or 

evidence admitted is not only relevant, but reliable.” Id. Under Daubert, expert 

testimony is admissible only if the proponent demonstrates that: (1) the expert is 

qualified; (2) the evidence is relevant to the suit; and (3) the evidence is reliable. See 

Case 6:20-cv-00108-ADA Document 228 Filed 11/22/22 Page 5 of 20
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Watkins v. Telesmith, Inc., 121 F.3d 984, 988-90 (5th Cir. 1997). Rule 702’s 

requirement that expert testimony “assist the trier of fact to understand the evidence 

or to determine a fact in issue” is primarily a relevance consideration. Daubert, 509 

U.S. at 591.

III. ARGUMENT 

A. Dr. Steer’s C/RTP Opinions Should Not Be Excluded

1. Intel has notice of ParkerVision’s C/RTP theories

Intel complains that it was not provided with notice of ParkerVision’s theory. 

Not only is Intel wrong, but lack of notice is not the proper subject of a Daubert 

motion. 

Contrary to Intel’s assertions, this is not a case like Elbit Sys. Land & C41 Ltd. 

v. Hughes Network Sys., LLC, where an earlier priority date was asserted nine days

before fact discovery closed. See 2017 U.S. Dist. LEXIS 94495, at *28 (E.D. Tex. Jun. 

20, 2017). On August 27, 2020, ParkerVision disclosed to Intel a priority date of 

August 21, 1997 for claim 5 of the ’902 Patent, claim 6 of the ’725 Patent, and claims 

5 and 17 of the ’673 Patent. Ex. 1 at 7-10 (ParkerVision, Inc.’s Amended Disclosure 

of Preliminary Infringement Contentions). At the same time, ParkerVision produced 

documents bearing production numbers PV_011928–PV_011996—documents which 

Dr. Steer relies on in his rebuttal report—and identified them as evidence of C/RTP

for the claimed inventions. Id. at 11. Thus, ParkerVision put Intel on notice of its

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early C/RTP theory prior to Intel serving its Preliminary Invalidity Contentions and 

prior to fact discovery opening.1 

Moreover, contrary to Intel’s assertion, Dr. Steer’s C/RTP charts did not 

“disclose[] for the first time, a new ParkerVision theory that a circuit board schematic 

allegedly from August 1997 . . . supports an August 21, 1997 invention date . . . .” Mot. 

at 5-6 (citing CONF-PV00175452-453). Intel appears to misunderstand what is being 

shown in the circuit board schematics. 

The Eddie-1 chip is mounted on an Eddie-1 circuit board. As Dr. Steer 

explained in his conception charts, the Eddie-1 circuit board is configurable so that 

some or all components on the board can be used in different configurations. See, e.g., 

Ex. 3 at 5 (Steer ’902 C/RTP Chart). CONF-PV00175452-453 illustrates the

configurable components (resistors/capacitors) on the Eddie-1 circuit board. See 

generally Ex. 4. For his C/RTP analysis, Dr. Steer relies on a single ended capacitor 

and a 50 ohm load found on the Eddie-1 board for the energy storage element and 

load, respectively. The single ended capacitor is shown in PV_011982 and load on the 

Eddie-1 board is discussed at PV_011982–944 at p. 11 (discussing the RF port being 

terminated in 50 ohms). See Ex. 5. These documents were produced with 

ParkerVision’s August 27, 2020 Amended Preliminary Infringement Contentions as 

supporting C/RTP. The schematic shown in PV_011982 is one configuration of the 

configurable components on the Eddie-1 board of CONF-PV00175452-453, which also 

1 In its Preliminary Invalidity Contentions, Intel acknowledged that it had reviewed 

ParkerVision’s August 27, 2020 Amended Disclosure of Preliminary Infringement 

Contentions. See Ex. 2 at 1.

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illustrates the single-ended capacitor and 50 ohm load. Thus, Intel’s assertion that 

Dr. Steer disclosed a new theory is wrong.

After the August 27, 2020 disclosures, ParkerVision maintained that the

claims were entitled to a priority date of August 21, 1997 throughout this case. Intel’s 

expert, Dr. Vivek Subramanian, acknowledged that ParkerVision disclosed an 

invention date of August 21, 1997 well-before the close of fact discovery. Ex. 6 at ¶ 

201 (citing Plaintiff ParkerVision, Inc’s Supplemental Responses and Objections to 

Defendant Intel Corporation’s First Set of Interrogatories Nos. 1-6, 9, 11-14, Case No. 

6:20-cv-00108-ADA (W.D. Tex. Feb. 2, 2022) at 4-7). Moreover, Intel admits that 

documents relied on by Dr. Steer evidencing early C/RTP were produced during fact 

discovery. Mot. at n. 5. 

If Intel wanted additional details of C/RTP in ParkerVision’s interrogatory 

responses, Intel should have raised it with ParkerVision and, if necessary, the Court. 

Intel chose not to do so. Any problems Intel has were strategic decisions of its own 

making.

Further, Intel tested ParkerVision’s early C/RTP theory during fact discovery.

Jeff Parker affirmatively represented to Intel that ParkerVision came up with the 

ideas that resulted in the asserted patents between 1995 and 1999. Ex. 7 at 35:20–25

(“Q. And so to best of your recollection, ParkerVision came up with the ideas that 

resulted in the asserted patent sometime between 1995 and 1999. Is that fair? Yes. 

I[t] would be somewhere in that time frame, correct.”) Mr. Parker, as ParkerVision’s 

corporate witness, also informed Intel that ParkerVision had produced documents 

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indicating that ParkerVision had reduced the inventions to practice as early as 

August 21, 1997. Ex. 8 at 599:18-23. Mr. Parker never refused to answer Intel’s 

questions regarding C/RTP, and Intel never claimed that Mr. Parker was 

inadequately prepared for his deposition. 

Finally, when the opportunity arose for Intel to question Dr. Steer directly 

about his C/RTP opinions, Intel did not ask Dr. Steer a single question about them—

even after knowing for more than two years that ParkerVision was asserting an early 

C/RTP theory. The reason for this is now clear. Rather than trying to get the 

information from ParkerVision, Intel chose to remain silent in order to claim a 

meritless discovery deficiency so that it could attempt to preclude ParkerVision’s

expert from testifying. This objectively unreasonable position cannot support 

precluding Dr. Steer from presenting his C/RTP opinions to the jury. Accordingly, the 

Court should deny Intel’s request. 

2. Dr. Steer’s C/RTP opinions are admissible

Intel’s arguments appear to be directed to a purported lack of evidence to 

support an August 21, 1997 priority date, and not the reliability of Dr. Steer’s C/RTP 

opinions. Intel had the opportunity to move for summary judgment on this issue,2 but 

instead chose to advance its lack of evidence arguments under the guise of a Daubert 

motion. Nevertheless, Intel’s arguments fail here because Dr. Steer’s opinions are 

reliable.

2 Perdiemco v. Industrack LLC, Case No. 2:15-cv-00727-JRG-RSP, 2016 U.S. Dist. 

LEXIS 183636, at *6 (E.D. Tex. Nov. 3, 2016).

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Intel asserts that Dr. Steer’s methodology is unsound because Dr. Steer

allegedly (1) failed to provide evidence of use of the claimed technology in a physical 

product, (2) failed to apply the Court’s claim construction for the “storage element” 

and (3) has not applied a methodology to show the “storage element” claim 

limitations. Intel is wrong.

First, Dr. Steer presented evidence that the Eddie-1 circuit board schematic 

(PV_011983) was implemented in an actual physical embodiment. In particular, Dr. 

Steer states: 

As discussed in my Opening Report, ParkerVision’s engineering team 

realized that they could increase a receiver’s sensitivity by sampling an 

RF carrier signal and transferring energy to form a down-converted 

baseband signal. See Steer Report, ¶ 373. After creating prototypes and 

conducting tests, ParkerVision soon realized that its technology led to 

improved RF receiver performance, lower power consumption, reduced 

size and integration benefits. . . . ParkerVision named its novel RF 

direct down-conversion technology “Direct-to-Data” or “D2D.”

ParkerVision incorporated its energy transfer circuitry into an 

integrated circuit (“IC”), which was named the Eddie-1. The Eddie-1 

is a Gallium Arsenide (GaAs) chip fabricated using Triquint’s 

GaAS FET technology. A layout of the Eddie-1 IC is shown below.

Ex. 3 at 1-2 (citing PV_011983) (emphasis added). Dr. Steer also pointed to a 

ParkerVision press release discussing actual testing of the Eddie-1 chip. See, e.g., Ex. 

3 at 9 (Steer ’902 C/RTP Chart) (“ParkerVision announced the testing and high-level 

performance of its Eddie-1 IC in a press release dated December 10, 1997. See, e.g., 

PVII00114707-09; PV00290561.”). Thus, it is clear that Dr. Steer’s opinions are based 

on the fabricated Eddie-1 chip—an actual physical embodiment. Accordingly, the 

Court should disregard Intel’s incorrect assertion.

Case 6:20-cv-00108-ADA Document 228 Filed 11/22/22 Page 10 of 20
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Second, Dr. Steer applied the Court’s claim construction for the “storage 

element” terms and provided his reasoning as to why this claim element is met. As 

Dr. Steer acknowledge in his rebuttal report, “I have reviewed the constructions of 

the U.S. District Court for the Western District of Texas as well as the constructions 

agreed to by the parties. I have relied on these constructions in forming my opinions 

in this case.” Ex. 9 at ¶ 104. Thus, Dr. Steer applied the Court’s construction when 

identifying single-ended capacitor C8 of the Eddie-1 as an “energy storage 

device/module” / “storage module” (collectively, “energy storage elements”). Further, 

Dr. Steer’s opinions provide reliable analysis. 

In order to determine whether the single-ended capacitor is a “storage” 

element, Dr. Steer analyzes frequencies and component values of the Eddie-1 chip: 

See, e.g., Ex. 3 at 17; see also id. at 6 (“The circuit board includes capacitors and 

resistors having the following component values: C3 = C4 = 27 pF, C5 = C6 = 100 pF, 

C7 = C8 = 220 pF, and R24 = R25 = 200 Ω.”);3 Ex. 10 at 20, 27 (Steer ’673 C/RTP 

3 While Dr. Steer relies on the Boeing Report from April 1998 for frequency values, this 

report uses the Eddie-1 chip/circuit board—the version of the Eddie chip that was 

available in August 1997. Intel raises an issue with this but it can cross-examine Dr. 

Steer at trial. 

Case 6:20-cv-00108-ADA Document 228 Filed 11/22/22 Page 11 of 20
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Chart) (referring to “‘Eddie Test Results’ in the Secondary Consideration Section of 

the Report,” which relate to cellular performance parameters). Intel takes issue with 

this methodology for numerous reasons, all of which are the subject of crossexamination at trial. None of these reasons, however, demonstrate that Dr. Steer’s 

analysis is facially unreliable.

Moreover, in his rebuttal report, Dr. Steer incorporated his discussion of 

background technologies from his opening report. Ex. 9 at ¶ 28. In his opening report, 

Dr. Steer explained that “a capacitor is one type of circuit element used to store 

(accumulate) energy.” Ex. 11 at ¶ 90. Dr. Steer thoroughly explained the manner in 

which capacitors store energy. Id. at ¶¶ 91-101. These technological explanations

support his conclusions that the Eddie-1 includes the recited energy storage elements 

in the form of a single-ended capacitor. Further, Dr. Steer explicitly opines that the 

Eddie-1’s capacitor functions as part of an energy transfer system, which transfers 

non-negligible amounts of energy from an input electromagnetic signal to a low 

impedance load to form a down-converted signal. See Exs. 12–17. 

Dr. Steer further identifies the Eddie-1’s capacitor acquiring energy during 

apertures of an energy transfer signal (Ex. 12); discharging stored energy to form a 

remaining portion of a down-converted signal (Ex. 14); providing a place where 

significant energy can be stored when the switch is closed (Ex. 14); having energy 

from a modulated carrier signal directed to it (Ex. 17); discharging a portion of 

previously accumulated energy to a low impedance load (Ex. 17); and acquiring 

energy during apertures of a control signal (Ex. 17). These activities are clearly 

Case 6:20-cv-00108-ADA Document 228 Filed 11/22/22 Page 12 of 20
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consistent with “a [element/device/module] of an energy transfer system that stores 

non-negligible amounts of energy from an input electromagnetic signal.” See ECF No. 

75.

The party offering expert testimony bears the burden of proving by “a 

preponderance of the evidence that the testimony is reliable.” Moore v. Ashland 

Chem. Inc., 151 F.3d 269, 276 (5th Cir. 1998).” As described, Dr. Steer’s opinions 

clearly rise above this threshold. Further, “whether Daubert’s specific factors are, or 

are not, reasonable measures of reliability in a particular case is a matter that the 

law grants the trial judge broad latitude to determine.” Kumho Tire, 526 U.S. 137, 

147 (1999). However, the trial court’s role as gatekeeper under Daubert “is not 

intended to serve as a replacement for the adversary system. . . . Thus, while 

exercising its role as a gate-keeper, a trial court must take care not to transform a 

Daubert hearing into a trial on the merits.” Dr. Steer’s opinions follow the Court’s 

constructions and reliably explain how the Eddie-1 embodies every element of the 

asserted claims—including the energy storage elements. 

The Court’s analysis need not extend further to determine whether Dr. Steer 

sufficiently or credibly makes this showing—as Intel seems to request. The credibility 

and persuasiveness of expert testimony are matters to be resolved by a jury. 

Accordingly, the Court should deny Intel’s request to exclude Dr. Steer’s C/RTP 

opinions. 

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B. Dr. Steer’s Infringement Opinions Based On His Circuit-Level 

Simulations Should Not Be Excluded

The asserted claims of the patents-in-suit recite a “switch” / “switching device” 

/ “switching module.” The Court construed this term to have its plain-and-ordinary 

meaning, wherein the plain-and-ordinary meaning is “an electronic device for 

opening and closing a circuit as dictated by an independent control input.” ECF No. 

75 at 6. Applying this construction, Dr. Steer analyzed the Accused Products to 

determine whether they contained “an electronic device for opening and closing a 

circuit as dictated by an independent control unit.” Ultimately, Dr. Steer determined 

that Ex. 11 at ¶ 329. 

Id. at ¶ 624.4

Regarding modeling, generally, Dr. Steer explained: 

In order to understand the operation of a circuit, one must view the 

circuit as a whole and also look at the electrical signals in the circuit. 

One cannot simply look at individual components of the circuit. This is 

because the same components (e.g., transistor) used in different 

4 “A FET is a type of transistor. A FET can amplify, oscillate, or switch the flow of 

current between two terminals by varying the voltage at a third terminal. In other 

words, a FET can perform different functions depending on how it is set up.” Ex. 11

at ¶ 255. “That FETs have many modes of operation depending on circuit topology 

and signals is well known.” Id. at ¶ 275. When a FET is used as a switch, the FET 

opens and closes. When the FET is ON (closed), current can pass through the FET; 

when the FET is OFF (opened), current does not pass through the FET. Said another 

way, a FET used as a switch has two states—either ON (closed) or OFF (opened); 

allowing all current through or preventing current from flowing.” Id. at ¶ 276. 

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circuits can be used in different ways depending on a number of 

characteristics or parameters that can be varied, such as dimensions 

and materials, which can affect the operation.

Ex. 11 at ¶ 274. Thus, “[i]t is undisputed that every circuit simulation involves some 

level of simplification.” Mot. at 19. In this case, “[it was] not possible to simulate an 

entire chip at the transistor level so models with the essential characteristics being 

investigate[d were] used.” Ex. 18 at 4. But, “[i]t should be noted that the switch used 

in [Dr. Steer’s] models i[s] a practical switch with finite on-resistance and off 

resistance.” Id. at ¶ 22. 

; and (2) Dr. Steer’s independent testing 

of the Accused Products’ transistors.

Ex. 19 at 138:13-

19. 

Ex. 20 at 105:5-13. 

Ex. 21 at 157:12-19. Intel’s own 

technical expert, Dr. Subramanian, admits that “

.” Ex. 6 at ¶ 78. 

Further, Intel’s documents and the statements of its engineers confirm that 

. Dr. Klepser testified, 

for example, “

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PAGE |13

Ex. 20 at 70:8-18; see 

also, e.g., id. at 68:16-70:18, 70:19-76:14 

, 133:2-134:19; Ex. 19. at 248:12-249:6; Ex. 21 at 147:24-149:19 

( ). As 

shown in one example below, 

:

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PAGE |14

Ex. 11 at 101 (citing 96102DOC00050662-96102DOC00050679 at 50663); see also id.

at ¶¶ 363-365 (identifying Intel documents).

Dr. Steer could simply have reasonably relied Intel’s engineers and documents. 

Instead, Dr. Steer also chose 

Ex. 11 at ¶ 626; see also Ex. 

22 at 171:14-17 

.

Ex. 18 at pp. 686-783 (“Part X”); see also id. at 

Figure X.C.1(a), Figure X.C.1(b), Figure X.D.1(a), Figure X.D.1(b), Figure X.E.1(a), 

Figure X.E.1(b), Figure X.F.1(a), Figure X.F.1(b), Figure X.G.1(a), Figure X.G.1(b) 

. 

Ex. 11 at ¶ 345; 

see also Ex. 18 at Figure X.C.4(a), Figure X.C.8(a), X.C.4(b), X.C.8(b), X.D.4(a), Figure 

X.D.8(a), X.D.4(b), X.D.8(b), X.E.4(a), Figure X.E.8(a), X.E.4(b), X.E.8(b), X.F.4(a), 

Figure X.F.8(a), X.F.4(b), X.F.8(b), X.G.4(a), Figure X.G.3(a), X.G.3(b) (

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.5 Based on the foregoing, Dr. Steer had sufficient basis to 

.

Intel may disagree with Dr. Steer’s methodology and reasoning, but that does 

not make Dr. Steer’s opinion unreliable. “[T]his is not an inadmissibility issue but an 

issue for the jury to weigh the competing expert opinions.” CloudofChange, LLC v. 

NCR Corp., Case No. 6:19-cv-00513-ADA, ECF No. 205 at 6 (W.D. Tex. Nov. 9, 2021). 

“Vigorous cross-examination, presentation of contrary evidence, and careful 

instruction on the burden of proof are the traditional and appropriate means of 

attacking shaky but admissible evidence.” Daubert, 509 U.S. at 596. Thus, Intel may 

cross-examine Dr. Steer at trial about any alleged inconsistencies in his circuit-level 

simulations, but Intel’s request to exclude Dr. Steer’s infringement opinions should 

be denied.

IV. CONCLUSION 

For the foregoing reasons, the Court should deny Intel’s motion.

5 See also Ex. 11 at ¶ 628 (“The time period for which the transistors open/close is 

determined by the LO signal, which is applied at the gate of the transistors. The gate 

is separate from the input/output (source/drain) of the switch and, thus, the LO signal 

is an independent control input. Specifically, the LO signal closes transistors during 

an aperture, which is the pulse width of the control signal (i.e., the length of activation 

of the switch).”); id. at ¶ 629 (“During a sampling aperture of an LO signal, for 

example, transistors close (the switch is “ON”), and the transistors conduct current 

comprised of the RF signal (energy from the RF signal is transferred from an input 

to an output of the switch). Outside the sampling aperture of the LO signal, 

transistors open (the switch is “OFF”), blocking the flow of current (blocking energy 

from the RF signal from passing through the switch).”)

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Dated: November 15, 2022 Respectfully submitted,

 

Raymond W. Mort, III

Texas State Bar No. 00791308

raymort@austinlaw.com

THE MORT LAW FIRM, PLLC

501 Congress Ave, Suite 150

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)* 

Scott R. Samay (pro hac vice)* 

Stephanie Mandir (pro hac vice) 

Zachary H. Ellis (Texas Bar No. 

24122606)

rdaignault@daignaultiyer.com 

cbiyer@daignaultiyer.com 

jcharkow@daignaultiyer.com 

ssamay@daignaultiyer.com

smandir@daignaultiyer.com

zellis@daignaultiyer.com 

DAIGNAULT IYER LLP 

8618 Westwood Center Drive

Suite 150 

Vienna, VA 22182

*Not admitted in Virginia

ATTORNEYS FOR PLAINTIFF

Case 6:20-cv-00108-ADA Document 228 Filed 11/22/22 Page 19 of 20
PAGE |17

CERTIFICATE OF SERVICE

I hereby certify that on November 15, 2022, a true and correct copy of the foregoing 

document was forwarded by electronic mail to all counsel of record for Defendant Intel 

Corporation. 

Dated: November 15, 2022 Respectfully submitted,

/s/ Raymond W. Mort, III 

Raymond W. Mort, III

Case 6:20-cv-00108-ADA Document 228 Filed 11/22/22 Page 20 of 20