UNITED STATES DISTRICT COURT 

WESTERN DISTRICT OF TEXAS

WACO DIVISION

PARKERVISION, INC., 

Plaintiff,

vs.

INTEL CORPORATION,

Defendant.

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

 JURY TRIAL DEMANDED

ANSWER AND AFFIRMATIVE DEFENSES TO FIRST AMENDED 

COMPLAINT FOR PATENT INFRINGEMENT 

Plaintiff ParkerVision, Inc.’s (“ParkerVision”) patent infringement claims against 

Defendant Intel Corporation (“Intel”) have no merit and Intel’s products do not use 

ParkerVision’s purported inventions in the patents asserted in this case, as evidenced by 

findings by courts in Germany that the same accused chips in this case do not infringe 

ParkerVision’s closely related European Patent No. 1 135 853 (the “EP ’853 patent”), and 

that the EP ’853 patent is invalid. See Munich Regional Court, Apr. 25, 2019, 7 O 2141/17, 

Final Judgment (trans.) (Ger.) at 19; Bundespatentgericht [BPatG] [Federal Patent Court], 

Dec. 16, 2019, 5 Ni 19/17 (EP), Decision on Costs and Determination of the Value in Dispute 

(trans.) (Ger.) at 10, 15. 

Accordingly, and as alleged herein, Intel hereby answers ParkerVision’s First 

Amended Complaint for Patent Infringement (D.I. 14) as follows. 

NATURE OF THE ACTION1

1. This paragraph states legal conclusions to which no response is required. To 

the extent a further response is required, Intel denies that it has infringed any asserted patent, 

directly or indirectly. Intel denies any remaining allegations in this paragraph. 

 1 For ease of reference, Intel uses the headings used in ParkerVision’s First Amended Complaint. In so doing, 

Intel does not admit any of the allegations contained in those headings.

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PARTIES

2. Intel lacks knowledge or information sufficient to form a belief as to the truth 

of the allegations in paragraph 2, and therefore denies the same. 

3. Intel admits that it is a corporation organized and existing under the laws of 

Delaware with a place of business at 2200 Mission College Boulevard, Santa Clara, 

California 95054. 

4. Intel admits that it has facilities at 1300 S. Mopac Expressway, Austin, Texas 

78746; 6500 River Place Blvd, Bldg. 7, Austin, Texas 78730; and 5113 Southwest Parkway, 

Austin, Texas 78735. To the extent a further response is required, Intel denies any remaining 

allegations in this paragraph.

5. Intel admits that it has a Texas registered agent located at CT Corporation 

System, 1999 Bryan Street, Suite 900, Dallas, Texas 75201. To the extent a further response 

is required, Intel denies any remaining allegations in this paragraph. 

6. Intel admits that since 1989, it has been registered to do business in the State 

of Texas under Texas Taxpayer Number 19416727436. To the extent a further response is 

required, Intel denies any remaining allegations in this paragraph. 

JURISDICTION AND VENUE

7. This paragraph states legal conclusions to which no response is required. To 

the extent a further response is required, Intel admits that this Court has subject matter 

jurisdiction over ParkerVision’s allegations of patent infringement. Intel denies any 

remaining allegations in this paragraph.

8. This paragraph states legal conclusions to which no response is required. To 

the extent a further response is required, Intel admits that Intel Corporation is a named party 

in this action and that it has a place of business in this District, specifically, 1300 S. Mopac 

Expressway, Austin, Texas 78746. Intel specifically denies that it has committed acts of 

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infringement in this District or anywhere else. Intel further denies that venue is convenient in 

this District, and denies that venue will be proper or convenient in this District for all matters 

where Intel is a named party; given the extent of Intel’s operations in other states, transfer out 

of this District and/or Division will presumably be appropriate in other cases and nothing 

herein should be read as a waiver of Intel’s right to request transfer out of this Division 

and/or District in future cases as may be appropriate. Except as so expressly admitted, Intel 

denies the remaining allegations in this paragraph. 

9. This paragraph states legal conclusions to which no response is required. To 

the extent a further response is required, Intel admits that it has recruited and employs some 

Texas residents. Intel denies any remaining allegations in this paragraph.

10. This paragraph states legal conclusions to which no response is required. To 

the extent a further response is required, Intel admits that it conducts business within this 

judicial district; that it has facilities in this judicial district; that it receives income from its 

operations in this judicial district; and that it employs Texas residents within this judicial 

district. Intel denies any remaining allegations in this paragraph.

11. This paragraph states legal conclusions to which no response is required. To 

the extent a further response is required, Intel denies any remaining allegations in this 

paragraph. 

12. Intel denies that it has infringed any asserted patent, directly or indirectly. 

Moreover, this paragraph states legal conclusions to which no response is required. To the 

extent a further response is required, Intel denies any remaining allegations in this paragraph. 

13. This paragraph states legal conclusions to which no response is required. To 

the extent a further response is required, Intel denies any remaining allegations in this 

paragraph.

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14. Intel admits that it has facilities in Austin and that it has employees at those 

facilities but none of those employees have any material connection to this case. The 

remaining statements in this paragraph are legal conclusions to which no response is required. 

To the extent a further response is required, Intel denies any remaining allegations in this 

paragraph.

15. Intel admits that its website describes its operations in Austin as follows: 

“Located in the capitol city of Texas, Intel Austin is an important research and development 

center for the Intel technology that is changing the way we live, work, and play. Among the 

innovations developed in Austin are core technologies for next-generation microprocessors, 

platforms and base software; groundbreaking silicon solutions for computing and 

communications devices, which includes handheld computing and cellular communications; 

and cutting-edge network storage products.” To the extent a further response is required, 

Intel denies any remaining allegations in this paragraph. 

16. Intel admits that the third-party website cited in paragraph 16 of the First 

Amended Complaint purports to list H-1B labor condition applications for “Employer Name” 

“Intel Corporation” at “Worksite City” “Austin, TX.” Intel lacks knowledge and information 

sufficient to form a belief as to the truth of the statements on the cited third-party website at 

this time, and therefore denies the same. The remaining statements in this paragraph are legal 

conclusions to which no response is required. To the extent any other response to the 

allegations in this paragraph is required, Intel denies such allegations.

17. Intel admits that its website lists job openings for positions in Austin, Texas. 

To the extent any other response to the allegations in this paragraph is required, Intel denies 

such allegations. 

18. Intel admits that it is a party to Flash-Control, LLC v. Intel Corp., Case No. 

1:19-cv-01107 (W.D. Tex.) and VLSI Tech. LLC v. Intel Corp., Case No. 1:19-cv-00977 

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(W.D. Tex.). To the extent any other response to the allegations in this paragraph is required, 

Intel denies such allegations. 

BACKGROUND

19. Intel lacks knowledge or information sufficient to respond to ParkerVision’s 

allegations in this paragraph, and therefore denies such allegations on that basis. 

20. Intel lacks knowledge or information sufficient to respond to ParkerVision’s 

allegations in this paragraph, and therefore denies such allegations on that basis.

21. Intel lacks knowledge or information sufficient to respond to ParkerVision’s 

allegations in this paragraph, and therefore denies such allegations on that basis.

22. Intel denies the allegations of paragraph 22, including, without limitation, the 

assertion that ParkerVision allegedly “developed an innovative method of RF direct 

conversion by a process of sampling a RF carrier signal and transferring energy to create a 

down-converted baseband signal.” Intel lacks knowledge or information sufficient to respond 

to ParkerVision’s assertions regarding the time frame in which ParkerVision was allegedly 

working on this technology, and therefore denies such allegations on that basis. Intel denies 

any remaining allegations in this paragraph.

23. Intel lacks knowledge or information sufficient to respond to ParkerVision’s 

assertions regarding the creation of prototype chips or conduction of tests, and therefore 

denies such allegations on that basis. Intel denies that ParkerVision’s “technology led to 

improved RF receiver performance, lower power consumption, reduced size and integration 

benefits” and further denies that ParkerVision’s technology allowed “RF transceivers [to] be 

built smaller, cheaper and with greater improved performance.” Intel denies any remaining 

allegations in this paragraph.

24. Intel denies that ParkerVision’s technology represented “innovation[]” and 

further denies that ParkerVision developed technologies novel or useful in the areas of 

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“additional RF down-conversion technologies, RF up-conversion technologies and other 

related direct-conversion technologies,” or “complementary wireless communications 

technologies that involved interactions, processes, and controls between the baseband 

processor and the transceiver.” Intel denies that ParkerVision’s technology “improved” or 

“enhanced the operation of transceivers that incorporate ParkerVision’s down-converter and 

up-converter technologies.” Intel lacks knowledge or information sufficient to respond to 

ParkerVision’s assertions regarding the size of its patent portfolio, and therefore denies such 

allegations on that basis. Intel denies any remaining allegations in this paragraph.

25. Intel denies that ParkerVision’s technology constituted “innovations.” 

Qualcomm is not a party to this lawsuit, and Intel denies that Qualcomm’s alleged conduct 

has any bearing on this litigation. Intel denies any remaining allegations in this paragraph. 

26. Intel denies that ParkerVision’s “technology” is “significant,” “revolutionary,” 

“critical,” a “holy grail,” or that it offered performance benefits, as evidenced by 

ParkerVision’s history of failed claims of patent infringement. For example, the Federal 

Patent Court in Germany rejected ParkerVision’s contention that it invented a “fundamentally 

different approach to energy transmission down-conversion,” and instead found that 

ParkerVision’s EP ’853 patent would have been found invalid, had it not already expired. 

See Bundespatentgericht [BPatG] [Federal Patent Court], 5 Ni 19/17 (EP), Decision on Costs 

and Determination of the Value in Dispute (Ger.) (trans.) at 10, 15, Dec. 16, 2019. Intel also 

denies the remaining characterizations of ParkerVision’s technology in this paragraph. These 

purported statements by individuals at Qualcomm are not relevant to this litigation and do not 

support ParkerVision’s allegations of infringement here, particularly in light of 

ParkerVision’s losses on its claims of patent infringement against Qualcomm in the Middle 

District of Florida and at the Federal Circuit. See Parkervision, Inc. v. Qualcomm Inc., 27 F. 

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Supp. 3d 1266, 1269 (M.D. Fla. 2014), aff’d in part, rev’d in part, 621 F. App’x. 1009 (Fed. 

Cir. 2015). Intel denies any remaining allegations in this paragraph. 

27. Intel lacks knowledge or information sufficient to respond to ParkerVision’s 

allegations in this paragraph, and therefore denies such allegations on that basis.

28. Intel denies that ParkerVision’s purported technology addressed “a critical 

need for smaller, more efficient receivers capable of supporting multiple frequency bands,” 

and denies any remaining allegations in this paragraph. 

29. Intel lacks knowledge or information sufficient to respond to ParkerVision’s 

allegations in this paragraph, and therefore denies such allegations on that basis. 

30. Intel denies that it uses or has ever used ParkerVision’s technology. Intel 

further denies that ParkerVision has been damaged by Intel’s conduct. Intel lacks knowledge 

or information sufficient to respond to ParkerVision’s remaining allegations in this 

paragraph, and therefore denies such remaining allegations on that basis. 

31. Denied.

INTEL CHIPS

32. Intel admits that Intel and/or its affiliates have manufactured and sold RF 

transceiver chips and/or modems, including the Intel PMB 5750, PMB 5757 and PMB 5762 

(collectively, the “RF Transceiver Chips”), outside the United States in Asia, and that those 

same chips may be incorporated by third parties into smartphones. To the extent any other 

response to the allegations in this paragraph is required, Intel denies such allegations. 

33. Intel admits that its RF Transceiver Chips have been incorporated by third 

parties into devices such as Apple iPhones. Intel further admits that its RF Transceiver Chips 

offer, among other things, the ability to connect to a cellular network. To the extent any other 

response to the allegations in this paragraph is required, Intel denies such allegations. 

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34. Intel admits that the PMB 5750 has been incorporated by third parties into the 

Apple iPhone 7 and 7 Plus. Intel admits that the PMB 5757 has been incorporated by third 

parties into the Apple iPhone 8, 8 Plus, and X. Intel admits that the PMB 5762 has been 

incorporated by third parties into the Apple iPhone XR, XS, and XS Max. To the extent any 

other response to the allegations in this paragraph is required, Intel denies such allegations. 

35. Intel states that Apple acquired assets related to Intel’s RF Transceiver Chips 

in December 2019. To the extent any other response to the allegations in this paragraph is 

required, Intel denies such allegations. 

THE ASSERTED PATENTS

United States Patent No. 6,049,706

36. No response to the allegations in this paragraph is required because 

ParkerVision voluntarily dismissed Count I of its First Amended Complaint, and thereby 

dismissed its allegations of infringement of U.S. Patent No. 6,049,706 (the “’706 patent”) in 

this case. D.I. 20. To the extent any other response to the allegations in this paragraph is 

required, Intel denies such allegations. 

37. No response to the allegations in this paragraph is required because 

ParkerVision voluntarily dismissed Count I of its First Amended Complaint, and thereby 

dismissed its allegations of infringement of the ’706 patent in this case. D.I. 20. To the 

extent any other response to the allegations in this paragraph is required, Intel denies such 

allegations. 

38. No response to the allegations in this paragraph is required because 

ParkerVision voluntarily dismissed Count I of its First Amended Complaint, and thereby 

dismissed its allegations of infringement of the ’706 patent in this case. D.I. 20. To the 

extent any other response to the allegations in this paragraph is required, Intel denies such 

allegations. 

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United States Patent No. 6,266,518 

39. Intel admits that U.S. Patent No. 6,266,518 (the “’518 patent”) is entitled 

“Method and System for Down-Converting Electromagnetic Signals by Sampling and 

Integrating Over Apertures” and was issued on July 24, 2001 but denies that it is a valid or 

duly and legally issued patent. Intel admits that Exhibit 2 purports to be a copy of the ’518 

patent. To the extent any other response to the allegations in this paragraph is required, Intel 

denies such allegations

40. This paragraph states legal conclusions to which no response is required. To 

the extent a further response is required, Intel denies that the ’518 patent is valid and 

enforceable, and further denies all remaining allegations in this paragraph. 

41. Intel lacks knowledge or information sufficient to respond to ParkerVision’s 

allegations in this paragraph, and therefore denies such allegations on that basis.

United States Patent No. 6,580,902

42. Intel admits that U.S. Patent No. 6,580,902 (the “’902 patent”) is entitled 

“Frequency Translation Using Optimized Switch Structures” and was issued on June 17, 

2003, but denies that it is a valid or duly and legally issued patent. Intel admits that Exhibit 3 

purports to be a copy of the ’902 patent. To the extent any other response to the allegations 

in this paragraph is required, Intel denies such allegations. 

43. This paragraph states legal conclusions to which no response is required. To 

the extent a further response is required, Intel denies that the ’902 patent is valid and 

enforceable, and further denies all remaining allegations in this paragraph. 

44. Intel lacks knowledge or information sufficient to respond to ParkerVision’s 

allegations in this paragraph, and therefore denies such allegations on that basis. 

United States Patent No. 7,110,444

45. Intel admits that U.S. Patent No. 7,110,444 (the “’444 patent”) is entitled 

“Wireless Local Area Network (WLAN) Using Universal Frequency Translation Technology

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Including Multi-Phase Embodiments and Circuit Implementations” and was issued on 

September 19, 2006, but denies that it is a valid or duly and legally issued patent. Intel 

admits that Exhibit 4 purports to be a copy of the ’444 patent. To the extent any other 

response to the allegations in this paragraph is required, Intel denies such allegations. 

46. This paragraph states legal conclusions to which no response is required. To 

the extent a further response is required, Intel denies that the ’444 patent is valid and 

enforceable, and further denies all remaining allegations in this paragraph.

47. Intel lacks knowledge or information sufficient to respond to ParkerVision’s 

allegations in this paragraph, and therefore denies such allegations on that basis. 

United States Patent No. 7,539,474

48. Intel admits that U.S. Patent No. 7,539,474 (the “’474 patent”) is entitled “DC 

Offset, Re-Radiation, and I/Q Solutions Using Universal Frequency Translation Technology” 

and was issued on May 26, 2009, but denies that it is a valid or duly and legally issued patent. 

Intel admits that Exhibit 5 purports to be a copy of the ’474 patent. To the extent any other 

response to the allegations in this paragraph is required, Intel denies such allegations. 

49. This paragraph states legal conclusions to which no response is required. To 

the extent a further response is required, Intel denies that the ’474 patent is valid and 

enforceable, and further denies all remaining allegations in this paragraph. 

50. Intel lacks knowledge or information sufficient to respond to ParkerVision’s 

allegations in this paragraph, and therefore denies such allegations on that basis. 

United States Patent No. 8,588,725

51. Intel admits that U.S. Patent No. 8,588,725 (the “’725 patent”) is entitled 

“Apparatus, System, and Method for Down Converting and Up-Converting Electromagnetic 

Signals” and was issued on November 19, 2013, but denies that it is a valid or duly and 

legally issued patent. Intel admits that Exhibit 6 purports to be a copy of the ’725 patent. To 

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the extent any other response to the allegations in this paragraph is required, Intel denies such 

allegations. 

52. This paragraph states legal conclusions to which no response is required. To 

the extent a further response is required, Intel denies that the ’725 patent is valid and 

enforceable, and further denies all remaining allegations in this paragraph. 

53. Intel lacks knowledge or information sufficient to respond to ParkerVision’s 

allegations in this paragraph, and therefore denies such allegations on that basis. 

United States Patent No. 8,660,513

54. Intel admits that U.S. Patent No. 8,660,513 (the “’513 patent”) is entitled 

“Method and System for Down-Converting an Electromagnetic Signal, and Transforms for 

Same, and Aperture Relationships” and was issued on February 25, 2014, but denies that it is 

a valid or duly and legally issued patent. Intel admits that Exhibit 7 purports to be a copy of 

the ’513 patent. To the extent any other response to the allegations in this paragraph is 

required, Intel denies such allegations. 

55. This paragraph states legal conclusions to which no response is required. To 

the extent a further response is required, Intel denies that the ’513 patent is valid and 

enforceable, and further denies all remaining allegations in this paragraph. 

56. Intel lacks knowledge or information sufficient to respond to ParkerVision’s 

allegations in this paragraph, and therefore denies such allegations on that basis. 

United States Patent No. 9,118,528

57. Intel admits that U.S. Patent No. 9,118,528 (the “’528 patent”) is entitled 

“Method and System for Down-Converting an Electromagnetic Signal, and Transforms for 

Same, and Aperture Relationships” and was issued on August 25, 2015, but denies that it is a 

valid or or duly and legally issued patent. Intel admits that Exhibit 8 purports to be a copy of 

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the ’528 patent. To the extent any other response to the allegations in this paragraph is 

required, Intel denies such allegations. 

58. This paragraph states legal conclusions to which no response is required. To 

the extent a further response is required, Intel denies that the ’528 patent is valid and 

enforceable, and further denies all remaining allegations in this paragraph. 

59. Intel lacks knowledge or information sufficient to respond to ParkerVision’s 

allegations in this paragraph, and therefore denies such allegations on that basis.

United States Patent No. 9,246,736

60. Intel admits that U.S. Patent No. 9,246,736 (the “’736 patent”) is entitled 

“Method and System for Down-Converting an Electromagnetic Signal” and was issued on 

January 26, 2016, but denies that it is a valid or duly and legally issued patent. Intel admits

that Exhibit 9 purports to be a copy of the ’736 patent. To the extent any other response to 

the allegations in this paragraph is required, Intel denies such allegations. 

61. This paragraph states legal conclusions to which no response is required. To 

the extent a further response is required, Intel denies that the ’736 patent is valid and 

enforceable, and further denies all remaining allegations in this paragraph. 

62. Intel lacks knowledge or information sufficient to respond to ParkerVision’s 

allegations in this paragraph, and therefore denies such allegations on that basis. 

United States Patent No. 9,444,673

63. Intel admits that U.S. Patent No. 9,444,673 (the “’673 patent”) is entitled 

“Methods and Systems for Down-Converting a Signal Using a Complementary Transistor 

Structure” and was issued on September 13, 2016, but denies that it is a valid or duly and 

legally issued patent. Intel admits that Exhibit 10 purports to be a copy of the ’673 patent. 

To the extent any other response to the allegations in this paragraph is required, Intel denies 

such allegations. 

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64. This paragraph states legal conclusions to which no response is required. To 

the extent a further response is required, Intel denies that the ’673 patent is valid and 

enforceable, and further denies all remaining allegations in this paragraph. 

65. Intel lacks knowledge or information sufficient to respond to ParkerVision’s 

allegations in this paragraph, and therefore denies such allegations on that basis. 

CLAIMS FOR RELIEF

COUNT I – Alleged Infringement of United States Patent No. 6,049,706

66. No response to the allegations in this paragraph is required because 

ParkerVision voluntarily dismissed Count I of its First Amended Complaint, and thereby 

dismissed its allegations of infringement of the ’706 patent in this case. D.I. 20. To the 

extent any other response to the allegations in this paragraph is required, Intel denies such 

allegations. 

67. No response to the allegations in this paragraph is required because 

ParkerVision voluntarily dismissed Count I of its First Amended Complaint, and thereby 

dismissed its allegations of infringement of the ’706 patent in this case. D.I. 20. To the 

extent any other response to the allegations in this paragraph is required, Intel denies such 

allegations. 

68. No response to the allegations in this paragraph is required because 

ParkerVision voluntarily dismissed Count I of its First Amended Complaint, and thereby 

dismissed its allegations of infringement of the ’706 patent in this case. D.I. 20. To the 

extent any other response to the allegations in this paragraph is required, Intel denies such 

allegations. 

69. No response to the allegations in this paragraph is required because 

ParkerVision voluntarily dismissed Count I of its First Amended Complaint, and thereby 

dismissed its allegations of infringement of the ’706 patent in this case. D.I. 20. To the 

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extent any other response to the allegations in this paragraph is required, Intel denies such 

allegations. 

70. No response to the allegations in this paragraph is required because 

ParkerVision voluntarily dismissed Count I of its First Amended Complaint, and thereby 

dismissed its allegations of infringement of the ’706 patent in this case. D.I. 20. To the 

extent any other response to the allegations in this paragraph is required, Intel denies such 

allegations. 

71. No response to the allegations in this paragraph is required because 

ParkerVision voluntarily dismissed Count I of its First Amended Complaint, and thereby 

dismissed its allegations of infringement of the ’706 patent in this case. D.I. 20. To the 

extent any other response to the allegations in this paragraph is required, Intel denies such 

allegations. 

COUNT II – Alleged Infringement of United States Patent No. 6,266,518 

72. Intel repeats and incorporates its Answers to paragraphs 1 to 71 as though 

fully set forth herein. 

73. Intel denies each and every allegation in paragraph 73.

74. Intel denies each and every allegation in paragraph 74. 

75. This paragraph, which merely parrots language directly from the claims and 

specification of the ’518 patent and makes no effort to address the actual functioning of 

Intel’s products, states legal conclusions to which no response is required. Intel denies that it 

infringes any valid and enforceable claim of the ’518 patent. To the extent a further response 

is required to any allegations in this paragraph, Intel denies such allegations. 

76. This paragraph, which merely parrots language directly from the claims and 

specification of the ’518 patent and makes no effort to address the actual functioning of 

Intel’s products, states legal conclusions to which no response is required. Intel denies that it 

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infringes any valid and enforceable claim of the ’518 patent. To the extent a further response 

is required to any allegations in this paragraph, Intel denies such allegations. 

77. This paragraph, which merely parrots language directly from the claims and 

specification of the ’518 patent and makes no effort to address the actual functioning of 

Intel’s products, states legal conclusions to which no response is required. Intel denies that it 

infringes any valid and enforceable claim of the ’518 patent. To the extent a further response 

is required to any allegations in this paragraph, Intel denies such allegations. 

78. This paragraph, which merely parrots language directly from the claims and 

specification of the ’518 patent and makes no effort to address the actual functioning of 

Intel’s products, states legal conclusions to which no response is required. Intel denies that it 

infringes any valid and enforceable claim of the ’518 patent. To the extent a further response 

is required to any allegations in this paragraph, Intel denies such allegations. 

79. Intel denies each and every allegation in paragraph 79.

COUNT III – Alleged Infringement of United States Patent No. 6,580,902

80. Intel repeats and incorporates its Answers to paragraphs 1 to 79 as though 

fully set forth herein. 

81. Intel denies each and every allegation in paragraph 81.

82. Intel denies each and every allegation in paragraph 82. 

83. This paragraph, which merely parrots language directly from the claims and 

specification of the ’902 patent and makes no effort to address the actual functioning of 

Intel’s products, states legal conclusions to which no response is required. Intel denies that it

infringes any valid and enforceable claim of the ’902 patent. To the extent a further response 

is required to any allegations in this paragraph, Intel denies such allegations. 

84. This paragraph, which merely parrots language directly from the claims and 

specification of the ’902 patent and makes no effort to address the actual functioning of 

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Intel’s products, states legal conclusions to which no response is required. Intel denies that it 

infringes any valid and enforceable claim of the ’902 patent. To the extent a further response 

is required to any allegations in this paragraph, Intel denies such allegations. 

85. This paragraph, which merely parrots language directly from the claims and 

specification of the ’902 patent and makes no effort to address the actual functioning of 

Intel’s products, states legal conclusions to which no response is required. Intel denies that it 

infringes any valid and enforceable claim of the ’902 patent. To the extent a further response 

is required to any allegations in this paragraph, Intel denies such allegations. 

86. This paragraph, which merely parrots language directly from the claims and 

specification of the ’902 patent and makes no effort to address the actual functioning of 

Intel’s products, states legal conclusions to which no response is required. Intel denies that it 

infringes any valid and enforceable claim of the ’902 patent. To the extent a further response 

is required to any allegations in this paragraph, Intel denies such allegations. 

87. Intel denies each and every allegation in paragraph 87.

COUNT IV – Alleged Infringement of United States Patent No. 7,110,444

88. Intel repeats and incorporates its Answers to paragraphs 1 to 87 as though 

fully set forth herein. 

89. Intel denies each and every allegation in paragraph 89.

90. Intel denies each and every allegation in paragraph 90.

91. This paragraph, which merely parrots language directly from the claims and 

specification of the ’444 patent and makes no effort to address the actual functioning of 

Intel’s products, states legal conclusions to which no response is required. Intel denies that it 

infringes any valid and enforceable claim of the ’444 patent. To the extent a further response 

is required to any allegations in this paragraph, Intel denies such allegations. 

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92. This paragraph, which merely parrots language directly from the claims and 

specification of the ’444 patent and makes no effort to address the actual functioning of 

Intel’s products, states legal conclusions to which no response is required. Intel denies that it 

infringes any valid and enforceable claim of the ’444 patent. To the extent a further response 

is required to any allegations in this paragraph, Intel denies such allegations. 

93. Intel denies each and every allegation in paragraph 93.

COUNT V – Alleged Infringement of United States Patent No. 7,539,474

94. Intel repeats and incorporates its Answers to paragraphs 1 to 93 as though 

fully set forth herein. 

95. Intel denies each and every allegation in paragraph 95.

96. Intel denies each and every allegation in paragraph 96.

97. This paragraph, which merely parrots language directly from the claims and 

specification of the ’474 patent and makes no effort to address the actual functioning of 

Intel’s products, states legal conclusions to which no response is required. Intel denies that it 

infringes any valid and enforceable claim of the ’474 patent. To the extent a further response 

is required to any allegations in this paragraph, Intel denies such allegations. 

98. This paragraph, which merely parrots language directly from the claims and 

specification of the ’474 patent and makes no effort to address the actual functioning of 

Intel’s products, states legal conclusions to which no response is required. Intel denies that it 

infringes any valid and enforceable claim of the ’474 patent. To the extent a further response 

is required to any allegations in this paragraph, Intel denies such allegations. 

99. This paragraph, which merely parrots language directly from the claims and 

specification of the ’474 patent and makes no effort to address the actual functioning of 

Intel’s products, states legal conclusions to which no response is required. Intel denies that it 

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infringes any valid and enforceable claim of the ’474 patent. To the extent a further response 

is required to any allegations in this paragraph, Intel denies such allegations. 

100. Intel denies each and every allegation in paragraph 100.

COUNT VI – Alleged Infringement of United States Patent No. 8,588,725

101. Intel repeats and incorporates its Answers to paragraphs 1 to 100 as though 

fully set forth herein. 

102. Intel denies each and every allegation in paragraph 102. 

103. Intel denies each and every allegation in paragraph 103.

104. This paragraph, which merely parrots language directly from the claims and 

specification of the ’725 patent and makes no effort to address the actual functioning of 

Intel’s products, states legal conclusions to which no response is required. Intel denies that it 

infringes any valid and enforceable claim of the ’725 patent. To the extent a further response 

is required to any allegations in this paragraph, Intel denies such allegations. 

105. This paragraph, which merely parrots language directly from the claims and 

specification of the ’725 patent and makes no effort to address the actual functioning of 

Intel’s products, states legal conclusions to which no response is required. Intel denies that it 

infringes any valid and enforceable claim of the ’725 patent. To the extent a further response 

is required to any allegations in this paragraph, Intel denies such allegations. 

106. Intel denies each and every allegation in paragraph 106.

COUNT VII – Alleged Infringement of United States Patent No. 8,660,513

107. Intel repeats and incorporates its Answers to paragraphs 1 to 106 as though 

fully set forth herein. 

108. Intel denies each and every allegation in paragraph 108.

109. Intel denies each and every allegation in paragraph 109.

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110. This paragraph, which merely parrots language directly from the claims and 

specification of the ’513 patent and makes no effort to address the actual functioning of 

Intel’s products, states legal conclusions to which no response is required. Intel denies that it 

infringes any valid and enforceable claim of the ’513 patent. To the extent a further response 

is required to any allegations in this paragraph, Intel denies such allegations. 

111. This paragraph, which merely parrots language directly from the claims and 

specification of the ’513 patent and makes no effort to address the actual functioning of 

Intel’s products, states legal conclusions to which no response is required. Intel denies that it 

infringes any valid and enforceable claim of the ’513 patent. To the extent a further response 

is required to any allegations in this paragraph, Intel denies such allegations. 

112. This paragraph, which merely parrots language directly from the claims and 

specification of the ’513 patent and makes no effort to address the actual functioning of 

Intel’s products, states legal conclusions to which no response is required. Intel denies that it 

infringes any valid and enforceable claim of the ’513 patent. To the extent a further response 

is required to any allegations in this paragraph, Intel denies such allegations. 

113. This paragraph, which merely parrots language directly from the claims and 

specification of the ’513 patent and makes no effort to address the actual functioning of 

Intel’s products, states legal conclusions to which no response is required. Intel denies that it 

infringes any valid and enforceable claim of the ’513 patent. To the extent a further response 

is required to any allegations in this paragraph, Intel denies such allegations. 

114. This paragraph, which merely parrots language directly from the claims and 

specification of the ’513 patent and makes no effort to address the actual functioning of 

Intel’s products, states legal conclusions to which no response is required. Intel denies that it 

infringes any valid and enforceable claim of the ’513 patent. To the extent a further response 

is required to any allegations in this paragraph, Intel denies such allegations. 

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115. This paragraph, which merely parrots language directly from the claims and 

specification of the ’513 patent and makes no effort to address the actual functioning of 

Intel’s products, states legal conclusions to which no response is required. Intel denies that it 

infringes any valid and enforceable claim of the ’513 patent. To the extent a further response 

is required to any allegations in this paragraph, Intel denies such allegations. 

116. Intel denies each and every allegation in paragraph 116.

COUNT VIII – Alleged Infringement of United States Patent No. 9,118,528

117. Intel repeats and incorporates its Answers to paragraphs 1 to 116 as though 

fully set forth herein. 

118. Intel denies each and every allegation in paragraph 118.

119. Intel denies each and every allegation in paragraph 119.

120. This paragraph, which merely parrots language directly from the claims and 

specification of the ’528 patent and makes no effort to address the actual functioning of

Intel’s products, states legal conclusions to which no response is required. Intel denies that it 

infringes any valid and enforceable claim of the ’528 patent. To the extent a further response 

is required to any allegations in this paragraph, Intel denies such allegations. 

121. This paragraph, which merely parrots language directly from the claims and 

specification of the ’528 patent and makes no effort to address the actual functioning of 

Intel’s products, states legal conclusions to which no response is required. Intel denies that it 

infringes any valid and enforceable claim of the ’528 patent. To the extent a further response 

is required to any allegations in this paragraph, Intel denies such allegations. 

122. This paragraph, which merely parrots language directly from the claims and 

specification of the ’528 patent and makes no effort to address the actual functioning of 

Intel’s products, states legal conclusions to which no response is required. Intel denies that it 

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infringes any valid and enforceable claim of the ’528 patent. To the extent a further response 

is required to any allegations in this paragraph, Intel denies such allegations.

123. This paragraph, which merely parrots language directly from the claims and 

specification of the ’528 patent and makes no effort to address the actual functioning of 

Intel’s products, states legal conclusions to which no response is required. Intel denies that it 

infringes any valid and enforceable claim of the ’528 patent. To the extent a further response 

is required to any allegations in this paragraph, Intel denies such allegations.

124. This paragraph, which merely parrots language directly from the claims and 

specification of the ’528 patent and makes no effort to address the actual functioning of 

Intel’s products, states legal conclusions to which no response is required. Intel denies that it 

infringes any valid and enforceable claim of the ’528 patent. To the extent a further response 

is required to any allegations in this paragraph, Intel denies such allegations.

125. This paragraph, which merely parrots language directly from the claims and 

specification of the ’528 patent and makes no effort to address the actual functioning of 

Intel’s products, states legal conclusions to which no response is required. Intel denies that it 

infringes any valid and enforceable claim of the ’528 patent. To the extent a further response 

is required to any allegations in this paragraph, Intel denies such allegations.

126. Intel denies each and every allegation in paragraph 126. 

COUNT IX – Alleged Infringement of United States Patent No. 9,246,736

127. Intel repeats and incorporates its Answers to paragraphs 1 to 126 as though 

fully set forth herein. 

128. Intel denies each and every allegation in paragraph 128.

129. Intel denies each and every allegation in paragraph 129.

130. This paragraph, which merely parrots language directly from the claims and 

specification of the ’736 patent and makes no effort to address the actual functioning of 

Case 6:20-cv-00108-ADA Document 26 Filed 06/26/20 Page 21 of 29
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Intel’s products, states legal conclusions to which no response is required. Intel denies that it 

infringes any valid and enforceable claim of the ’736 patent. To the extent a further response 

is required to any allegations in this paragraph, Intel denies such allegations. 

131. This paragraph, which merely parrots language directly from the claims and 

specification of the ’736 patent and makes no effort to address the actual functioning of 

Intel’s products, states legal conclusions to which no response is required. Intel denies that it 

infringes any valid and enforceable claim of the ’736 patent. To the extent a further response 

is required to any allegations in this paragraph, Intel denies such allegations. 

132. This paragraph, which merely parrots language directly from the claims and 

specification of the ’736 patent and makes no effort to address the actual functioning of 

Intel’s products, states legal conclusions to which no response is required. Intel denies that it 

infringes any valid and enforceable claim of the ’736 patent. To the extent a further response 

is required to any allegations in this paragraph, Intel denies such allegations.

133. This paragraph, which merely parrots language directly from the claims and 

specification of the ’736 patent and makes no effort to address the actual functioning of 

Intel’s products, states legal conclusions to which no response is required. Intel denies that it 

infringes any valid and enforceable claim of the ’736 patent. To the extent a further response 

is required to any allegations in this paragraph, Intel denies such allegations.

134. This paragraph, which merely parrots language directly from the claims and 

specification of the ’736 patent and makes no effort to address the actual functioning of 

Intel’s products, states legal conclusions to which no response is required. Intel denies that it 

infringes any valid and enforceable claim of the ’736 patent. To the extent a further response 

is required to any allegations in this paragraph, Intel denies such allegations.

135. This paragraph, which merely parrots language directly from the claims and 

specification of the ’736 patent and makes no effort to address the actual functioning of 

Case 6:20-cv-00108-ADA Document 26 Filed 06/26/20 Page 22 of 29
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Intel’s products, states legal conclusions to which no response is required. Intel denies that it 

infringes any valid and enforceable claim of the ’736 patent. To the extent a further response 

is required to any allegations in this paragraph, Intel denies such allegations.

136. This paragraph, which merely parrots language directly from the claims and 

specification of the ’736 patent and makes no effort to address the actual functioning of 

Intel’s products, states legal conclusions to which no response is required. Intel denies that it 

infringes any valid and enforceable claim of the ’736 patent. To the extent a further response 

is required to any allegations in this paragraph, Intel denies such allegations.

137. This paragraph, which merely parrots language directly from the claims and 

specification of the ’736 patent and makes no effort to address the actual functioning of 

Intel’s products, states legal conclusions to which no response is required. Intel denies that it 

infringes any valid and enforceable claim of the ’736 patent. To the extent a further response 

is required to any allegations in this paragraph, Intel denies such allegations.

138. Intel denies each and every allegation in paragraph 138.

COUNT X – Alleged Infringement of United States Patent No. 9,444,673

139. Intel repeats and incorporates its Answers to paragraphs 1 to 138 as though 

fully set forth herein. 

140. Intel denies each and every allegation in paragraph 140.

141. Intel denies each and every allegation in paragraph 141.

142. This paragraph, which merely parrots language directly from the claims and 

specification of the ’673 patent and makes no effort to address the actual functioning of 

Intel’s products, states legal conclusions to which no response is required. Intel denies that it 

infringes any valid and enforceable claim of the ’673 patent. To the extent a further response 

is required to any allegations in this paragraph, Intel denies such allegations.

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143. This paragraph, which merely parrots language directly from the claims and 

specification of the ’673 patent and makes no effort to address the actual functioning of 

Intel’s products, states legal conclusions to which no response is required. Intel denies that it 

infringes any valid and enforceable claim of the ’673 patent. To the extent a further response 

is required to any allegations in this paragraph, Intel denies such allegations.

144. This paragraph, which merely parrots language directly from the claims and 

specification of the ’673 patent and makes no effort to address the actual functioning of 

Intel’s products, states legal conclusions to which no response is required. Intel denies that it 

infringes any valid and enforceable claim of the ’673 patent. To the extent a further response 

is required to any allegations in this paragraph, Intel denies such allegations. 

145. This paragraph, which merely parrots language directly from the claims and 

specification of the ’673 patent and makes no effort to address the actual functioning of 

Intel’s products, states legal conclusions to which no response is required. Intel denies that it 

infringes any valid and enforceable claim of the ’673 patent. To the extent a further response 

is required to any allegations in this paragraph, Intel denies such allegations.

146. Intel denies each and every allegation in paragraph 146.

JURY DEMANDED

Intel demands a trial by jury on all issues so triable. 

RESPONSE TO PRAYER FOR RELIEF

Intel denies that it has infringed any asserted patent, directly or indirectly. Intel 

denies that ParkerVision is entitled to any of the grounds for relief enumerated in the First 

Amended Complaint or any other relief, and respectfully requests that the Court enter 

judgment against ParkerVision on each of ParkerVision’s claims. To the extent the Prayer 

for Relief includes any factual allegations, Intel denies those allegations. 

Case 6:20-cv-00108-ADA Document 26 Filed 06/26/20 Page 24 of 29
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AFFIRMATIVE AND OTHER DEFENSES

WHEREFORE, having answered ParkerVision’s First Amended Complaint, Intel 

asserts the following defenses set forth below. By pleading these defenses, Intel does not 

concede that it has the burden of proof as to any of them. 

Intel reserves the right to allege additional affirmative defenses that become known 

through the course of discovery. 

FIRST DEFENSE: FAILURE TO STATE A CLAIM

147. The First Amended Complaint, and each purported claim for relief asserted 

therein, fails to state a claim upon which relief can be granted.

SECOND DEFENSE: NON-INFRINGEMENT

148. Intel does not make, use, test, sell, offer for sale, or import into the United 

States, and has not made, used, tested, sold, offered for sale or imported into the United 

States, any products or methods that infringe any valid and enforceable claim of the ’518, 

’902, ’444, ’474, ’725, ’513, ’528, ’736, and ’673 patents, either directly or indirectly, 

literally or through the doctrine of equivalents, or otherwise. 

THIRD DEFENSE: INVALIDITY

149. One or more claims of the ’518, ’902, ’444, ’474, ’725, ’513, ’528, ’736, and 

’673 patents are invalid for failure to meet the conditions of patentability and/or otherwise 

comply with one or more provisions of 35 U.S.C. §§ 101, 102, 103, 112, and/or 116. 

FOURTH DEFENSE: UNENFORCEABILITY

150. The ’518, ’902, ’444, ’474, ’725, ’513, ’528, ’736, and ’673 patents, and the 

claims therein, are unenforceable against Intel. 

FIFTH DEFENSE: EQUITABLE ESTOPPEL, WAIVER, ACQUIESCENCE, 

UNCLEAN HANDS 

Case 6:20-cv-00108-ADA Document 26 Filed 06/26/20 Page 25 of 29
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151. ParkerVision’s claims for relief are barred, in whole or in part, under 

principles of equity, including but not limited to estoppel, waiver, acquiescence, and/or 

unclean hands. For example, ParkerVision has engaged in serial litigation in which it has 

unsuccessfully asserted these and related patents against multiple parties, including against 

Intel’s SMARTi chip products that ParkerVision has also accused of infringement in this 

case. In Germany, courts have found the accused Intel chips at issue here to have not 

infringed the EP ’853 patent, which is a closely related patent to the patents asserted in this 

litigation, and also determined that the EP ’853 patent would likely have been found invalid. 

See Munich Regional Court, 7 O 241/17, Final Judgement (trans.) (Ger.) at 19, Apr. 25, 2019; 

see also Bundespatentgericht [BPatG] [Federal Patent Court], 5 Ni 19/17 (EP), Decision on 

Costs and Determination of the Value in Dispute (Ger.) (trans.) at 10, 15, Dec. 16, 2019. In 

light of ParkerVision’s serial and unsuccessful patent litigation campaign, ParkerVision’s 

claims should therefore be barred, in whole or in part, under the principles of equity, 

including the doctrine of unclean hands. 

152. As a further example, in 2011, MaxTak Capital Advisors, LLC, MaxTak 

Partners LP, and David Greenbaum sued ParkerVision for fraud, alleging that ParkerVision 

“made numerous public statements omitting material facts and deliberately misrepresenting: 

(a) d2p’s [i.e., ParkerVision’s “direct-to-power” technology] effectiveness and value; (b) the 

interest expressed by OEMs and other manufacturers in developing and commercializing 

products integrating d2p technology; (c) ParkerVision’s financial results; and (d) the 

Company’s prospects for developing profitable sales of its d2p technology.” See MaxTak 

Capital Advisors, et al. v. ParkerVision, Inc., et al., Case No. 2:11-cv-07549, D.I. 1 ¶ 33 

(D.N.J. Dec. 28, 2011). On information and belief, the ParkerVision d2p technology at issue 

in MaxTak relates to the same RF technology that ParkerVision claims to have invented in its 

Complaint and First Amended Complaint in this case. See, e.g., D.I. 1 ¶¶ 20-31 (Complaint); 

Case 6:20-cv-00108-ADA Document 26 Filed 06/26/20 Page 26 of 29
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D.I. 14 ¶¶ 20-31 (First Amended Complaint). On information and belief, ParkerVision has 

likewise misrepresented its RF technology in its Complaint and First Amended Complaint in 

this case, and ParkerVision’s claims should therefore be barred, in whole or in part, under the 

principles of equity, including the doctrine of unclean hands. 

SIXTH DEFENSE: PROSECUTION HISTORY ESTOPPEL AND DISCLAIMER

153. ParkerVision is estopped, based on statements, representations, and 

admissions made during prosecution of the patent applications that led to the ’518, ’902, 

’444, ’474, ’725, ’513, ’528, ’736, and ’673 patents from asserting that the claims of the 

aforementioned patents are infringed by Intel or Intel’s products, services, including the 

doctrine of equivalents. 

SEVENTH DEFENSE: LIMITATION ON DAMAGES

154. ParkerVision’s claims for monetary damages are limited by the statute of 

limitations and/or limited to acts of infringement occurring within six years of the date of 

initiating this suit under 35 U.S.C. § 286. 

EIGHTH DEFENSE: FAILURE TO MARK

155. To the extent ParkerVision, its predecessors, or licensees of any asserted 

patent failed to comply with the marking requirements set forth in 35 U.S.C. § 287, the relief 

sought by ParkerVision is barred, in whole or in part. 

Case 6:20-cv-00108-ADA Document 26 Filed 06/26/20 Page 27 of 29
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Dated: June 26, 2020 Respectfully submitted,

By: /s/ J. Stephen Ravel

J. Stephen Ravel

Texas State Bar No. 16584975

KELLY HART & HALLMAN LLP

303 Colorado Street, Suite 2000

Austin, TX 78701

Telephone: (512) 495-6429

Facsimile: (512) 495-6401

steve.ravel@kellyhart.com

James E. Wren

Texas State Bar No. 22018200

1 Bear Place, Unit 97288

Waco, Texas 76798

Telephone: (254) 710-7670

james.wren@baylor.edu

Michael J. Summersgill (pro hac vice) 

Massachusetts State Bar No. 632816

Sarah B. Petty (pro hac vice)

Massachusetts State Bar No. 666485

WILMER CUTLER PICKERING

 HALE & DORR LLP

60 State Street

Boston, MA 02109

Telephone: (617) 526-6000

Facsimile: (617) 526-5000

michael.summersgill@wilmerhale.com

sarah.petty@wilmerhale.com

Jason Choy (pro hac vice) 

California State Bar No. 277583

WILMER CUTLER PICKERING

 HALE & DORR LLP

350 South Grand Avenue, Suite 2100

Los Angeles, CA 90071

Telephone: (213) 443-5300

Facsimile: (213) 443-5400

jason.choy@wilmerhale.com

Case 6:20-cv-00108-ADA Document 26 Filed 06/26/20 Page 28 of 29
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CERTIFICATE OF SERVICE

The undersigned certifies that on June 26, 2020 all counsel of record who are deemed 

to have consented to electronic service are being served with a copy of this document via the 

Court’s CM/ECF system pursuant to Local Rule CV-5(b)(1).

/s/ J. Stephen Ravel

J. Stephen Ravel

Case 6:20-cv-00108-ADA Document 26 Filed 06/26/20 Page 29 of 29