One Financial Ceater
+ MINTZ LEVIN sone
617.542.2241 fax
Michael T, Renaud | 617 348 1870 | mtcennud@mintz.com
December 15, 2015
VIA HAND DELIVERY & EDIS
Office of the
‘The Honorable Lisa R. Barton Secretary
Secretary to the Commission Int Trade Commission
USS. International Trade Commission
500 E Street, S.W.
Washington, D.C. 20436
Re: Certain RF Capable Integrated Circuits and Products Containing the Same;
Inv, No 337-TA-_
Dear Secretary Barton:
T enclose for filing on behalf ParkerVision, Inc. (“ParkerVision”) the following documents in
support of ParkerVision’s request that the Commission commence an investigation pursuant to
the provisions of Section 337 of the Tariff Act of 1930, as amended,19 U.S.C. §1337. Please
note that Confidential Exhibits 1A-1B, 2, 2A-2E, 2G, 21-2GG, 11-44 and 61-68 to the Complaint
contain Confidential Business Information and pursuant to the Commission's Rules of Practice
and Procedure, a request for confidential treatment of the information in those exhibits
accompanies this filing Accordingly, ParkerVision submits the following:
1. One (1) original and eight (8) paper copies of Complainant’s Verified Complaint and the
Public Interest Statement (originals unbound); one (1) CD of the Non-Confidential
Exhibits and one (1) CD of the Confidential Exhibits (Commission Rules
19 CFR §§ 201.6(c), 210.4(f(2), 210.8 (a)(1)(i)) and 210.8(b));
2. Nine (9) additional copies of the Complaint, the Public Interest Statement and nine (9)
CDs of the non-confidential and confidential exhibits (each set of exhibits on separate
CDs), for service upon the following proposed Respondents: Apple, Inc.; LG Electronics,
Inc; LG Electronics U.S.A., Inc.; LG Electronics MobileComm U.S.A, Inc.; Samsung
Electronics Co., Ltd.; Samsung Electronics America, Inc.; Samsung Telecommunications
America, LLC; Samsung Semiconductor, Inc.; and Qualcomm, Inc. (Commission Rules
19 CER §§ 201.6(c), 210.4(1(2), 210.8(a)(1)(i) and 201.8(6));
3. One (1) additional copy of the Complaint for service upon the embassy of South Korea
(Commission Rules 19 CFR §§ 210.8(a)(1)(iii) and 210.11(a));
4, One (1) certified copy of each of the following asserted United States Patents: U.S. Patent
No. 6,879,817; U.S. Patent No. 7,929,638; U.S. Patent No. 8,571,135; and U.S. Patent
No, 9,118,528, included with the Complaint as Exhibits 3, 5, 7, and 9 (Commission Rule
19 CFR § 210.12(a)(9)(i));
Mintz, Levin, Cohn, Ferris, Glovsky and Popeo, P.C.
Boston | Loses | Los ASGria's | New YoRK | SAN BIEGH J Saw FaanenscoMintz, Levin, Cohn, Ferris, Glovsky and Popeo, P.C.
Honorable Lisa R. Barton
December 15, 2015
Page 2
5. One (1) certified copy and four (4) additional copies, on CDs, of the U.S. Patent and
Trademark Office prosecution histories for each of the asserted United States Patents:
USS. Patent No. 6,879,817; U.S, Patent No. 7,929,638, U.S. Patent No. 8,571,135; and
U.S. Patent No. 9,118,528, included with the Complaint as Appendices A, C, E, and G,
respectively (Commission Rule19 CFR § 210.12(6)(1));
6. One (1) certified copy of the Assignment Records for asserted United States Patents: U.S.
Patent No. 6,879,817; U.S. Patent No. 7,929,638; U.S. Patent No. 8,571,135 and U.S.
Patent No, 9,118,528, included with the Complaint as Exhibits 4, 6, 8, and 10
(Commission Rule 19 CFR § 210.12(a)(9)Gi));
7. Four (4) copies, on CD, of each patent and applicable pages of each technical reference
mentioned in the prosecution histories for each of the asserted United States Patents: U.S.
Patent No. 6,879,817; U.S. Patent No. 7,929,638, U.S. Patent No. 8,571,135; and U.S.
Patent No. 9,118,528; included with the Complaint as Appendices B, D, F, and H,
respectively (Rule 19 CFR § 210.12(c)(2)); and
8. A letter and certification pursuant to Commission Rules 19 CFR §§ 201.6(b) and
210.5(a) requesting confidential treatment of information appearing in Confidential
Exhibits 1A-1E, 2, 2A-2E, 2G, 21-2GG, 11-44 and 61-68 to ParkerVision’s verified
Complaint.
Respectfully submitted,
AAT!
Michael T. Renaud
Counsel for Complainant
ParkerVision, Inc.(One Financial Center
i MINTZ LEVIN Bown Ma oat
617.542.2241 fax
Michael T. Renaud | 617 348 1870 | mtzensud@mintz.com ‘www.mintz.com
December 15, 2015
VIA HAND DELIVERY & EDIS
The Honorable Lisa R. Barton
Secretary to the Commission
U.S. International Trade Commission.
500 E Street, S.W.
Washington, D.C. 20436
Re: Certain RF Capable Integrated Circuits and Products Containing the Same
Dear Secretary Barton:
Mintz, Levin, Cohn, Ferris, Glovsky and Popeo, P.C. represents Complainant ParkerVision, Inc.
(“ParkerVision”) in the matter of the above referenced Complaint, which is being filed pursuant
to Section 337 of the Tariff Act of 1930, as amended, 19 U. S. C. § 1337.
Pursuant to Commission Rules 201.6(b) and 210.5(d), ParkerVision respectfully requests
confidential treatment of the information contained in Confidential Exhibits 1A-1E, 2, 2A-2E,
2G, 2I-2GG, 11-44 and 61-68. The information contained in these exhibits qualifies as
confidential information pursuant to 19 C.F.R. § 201.6 in that it discloses proprietary commercial
information, proprietary commercial relationships, and/or proprietary business information that
is not otherwise publicly available, and because the disclosure of such information would cause
substantial harm to ParkerVision, and would also impair the Commission’s ability in the future
to obtain such types of information in performance of its statutory function.
| certify that the proprietary confidential commercial information, proprietary commercial
relationships, and/ or proprietary business information present in these exhibits is not reasonably
available to the public, and thus warrants confidential treatment.
Respectfully submitted,
Michael T. Renaud
Counsel for Complainant
ParkerVision, Inc.
Subscribed and sworn before me
Mintz, Levin, Cohn, Ferris, Glovsky and Popeo, P.C.
Boston | LONDON | Los ANGHIS | New YORK | SAN DIEGO | SAN FRANCISCO | STANFORD | WasttNcirons
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