UNITED STATES DISTRICT COURT MIDDLE DISTRICT · PDF fileMIDDLE DISTRICT OF FLORIDA JACKSONVILLE DIVISION ... admission of the bulk of the opposing parties’ exhibits ... UNITED

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UNITED STATES DISTRICT COURT MIDDLE DISTRICT OF FLORIDA

JACKSONVILLE DIVISION

PARKERVISION, INC.,

Plaintiff,

v.

Qualcomm INCORPORATED,

Defendant.

Case No. 3:11-cv-719-J-37TEM

JOINT FINAL PRETRIAL STATEMENT

Pursuant to the Case Management and Scheduling Order and Local Rule 3.06(c), Plaintiff

Parkervision, Inc. (“ParkerVision”) and Defendant, Qualcomm Incorporated (“Qualcomm”)

(collectively, “the Parties”) respectfully submit this Joint Final Pretrial Statement.

I. CERTIFICATION OF SETTLEMENT EFFORTS AND PRE-TRIAL COORDINATION EFFORTS AS REQUIRED BY LOCAL RULE 3.06(B)

As required by the Case Management and Scheduling Order and Local Rule 3.06(b),

counsel for each party, including lead trial counsel for each party, met in person in Orlando,

Florida on September 3, 2013. The parties met and conferred on issues identified in Local Rule

3.06(b).

ParkerVision’s Position On The L.R. 3.06(b) Certification:

ParkerVision cannot agree to certify that the parties have properly met and conferred on

objections to all proposed trial exhibits as required by L.R. 3.06(b). The Court specifically

ordered the parties to meet and confer in person on objections to the trial exhibit list, dkt. 84 at 9-

10, and it further stated in that order that “it is anticipated that counsel will agree to the

admission of the bulk of the opposing parties’ exhibits without objection . . .” First, late in the

Case 3:11-cv-00719-RBD-TEM Document 336 Filed 09/13/13 Page 1 of 39 PageID 13346

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evening on which the Joint Final Pretrial Statement was due, Qualcomm sent ParkerVision a

revised exhibit list noting objections to various ParkerVision exhibits it had never previously

included an objection to. Because these exhibits were first objected to well-after the in-person

meet and confer, the parties have not had an opportunity to meet and confer in person on these

exhibits. Qualcomm asserts that because these exhibits fall within the scope of one of their

Motions in Limine, that the meet and confer requirement is satisfied. ParkerVision disagrees: in

none of the parties’ prior exhibit list exchanges did these exhibits have an objection from

Qualcomm. Second, and despite the Court’s instruction, Qualcomm refuses to designate more

than a handful of exhibits as “Joint”—despite the fact that it seeks to affirmatively offer into

evidence many of the exact same exhibits that are on ParkerVision’s proposed trial exhibit list.1

Third, on the day that this Joint Final Pretrial Statement was due, Qualcomm also added 25 new

exhibits to its trial exhibit list (which ParkerVision was forced to superficially to review and

object to at the last minute). Qualcomm’s addition of exhibits after the in-person meet and

confer also violates the Court’s instructions to the parties.2

Qualcomm’s position on the L.R. 3.06(b) Certification:

1 The exhibits to which new objections were received include: PX9, PX44, PX45, PX46, PX49, PX50, PX53, PX54, PX55, PX56, PX62, PX63, PX64, PX65, PX76, PX82, PX86, PX87, PX88, PX99, PX100, PX104, PX105, PX106, PX110, PX114, PX115, PX116, PX117, PX118, PX119, PX120, PX121, PX122, PX123, PX124, PX125, PX127, PX141, PX143, PX144, PX145, PX146, PX150, PX152, PX153, PX155, PX157, PX159, PX161, PX167, PX168, PX174, PX175, PX178, PX179, PX181, PX182, PX183, PX184, PX188, PX189, PX193, PX195, PX196, PX197, PX201, PX202, PX203, PX205, PX206, PX207, PX208, PX209, PX210, PX211, PX212, PX213, PX216, PX217, PX218, PX220, PX221, PX222, PX223, PX224, PX225, PX226, PX227, PX228, PX229, PX232, PX233, PX234, PX235, PX241, PX242, PX244, PX245, PX246, PX247, PX251, PX252, PX253, PX255, PX256, PX258, PX260, PX262, PX263, PX264, PX265, PX266, PX269, PX271, PX272, PX279, PX282, PX296, PX297, PX302, PX307, PX310, PX312, PX313, PX314, PX874, PX875, PX937, PX938, PX940, PX951, PX953 2 The exhibits received today include DX1720 - DX1744.


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ParkerVision does not accurately describe the parties’ meet-and-confer process. First, the parties

met and conferred for many hours both in person and by telephone on objections to specific

exhibits, “buckets” of objections to categories of exhibits, and the parties’ motions in limine. On

the motions in limine, the parties agreed that motion-in-limine-related objections need not be

made for each individual exhibit to which the motion in limine applied. When that agreement

proved unworkable for some documents, Qualcomm added objections to the exhibit list to clarify

how the motions in limine applied to certain specific documents. ParkerVision’s attempt to

characterize those objections as “new” simply has no basis. Second, ParkerVision misstates the

discussions regarding the joint exhibit list. The mere inclusion of an exhibit on one party’s

exhibit list, such as a party admission by the other side, does not waive objections to the other

side introducing the document. The current joint exhibit list includes documents as to which

neither side has any objections but does not include exhibits that happen to be on both parties’

lists but as to which objections remain. Third, both parties have added exhibits since the in-

person meet-and-confer. Qualcomm’s inclusion of 25 additional documents related to topics the

parties had already met-and-conferred on did not prejudice ParkerVision’s ability to make the

same objections to those documents that it had previously made to other, related documents. In

fact, ParkerVision added its objections within hours of the exhibits being noted.

II. STATEMENT OF JURISDICTION

This Court has subject matter jurisdiction over this action pursuant to 28 U.S.C. §§ 1331,

and 1338(a) because this action arises under the patent laws of the United States, including 35

U.S.C. § 1 et seq.

Venue and personal jurisdiction are not disputed in this case. The parties do not contest

that ParkerVision has standing to bring this suit.


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III.CONCISE STATEMENT OF THE NATURE OF THE ACTION

This is a patent infringement lawsuit. ParkerVision alleges that Qualcomm directly and

indirectly infringes U.S. Patent Nos. 6,061,551 (“the ’551 patent”), 6,266,518 (“the ’518

patent”), 6,370,371 (“the ’371 patent”), and 7,496,342 (“the ’342 patent”) (collectively, the

“Patents-in-Suit”).3 ParkerVision alleges that Qualcomm infringes either literally or, in the

alternative, under the doctrine of equivalents. Additionally, ParkerVision contends that

Qualcomm’s infringement was willful. ParkerVision seeks both pre-verdict and post-verdict

damages up to the time of judgment to compensate ParkerVision for Qualcomm’s acts of

infringement, but in no event less than a reasonable royalty, as well as injunctive relief against

future acts of infringement by Qualcomm under 35 U.S.C. § 283. In the alternative, ParkerVision

contends that any denial of a permanent injunction should be conditioned on payment of future

reasonable royalties. ParkerVision also seeks prejudgment and post judgment interests and costs,

pursuant to 35 U.S.C. § 284 and attorneys’ fees pursuant to 35 U.S.C. § 285, as well as treble

damages against Qualcomm.

Qualcomm denies ParkerVision’s allegations and requests for relief. Qualcomm denies

that it has infringed literally, under the doctrine of equivalents, directly, or indirectly. Qualcomm

contends that ParkerVision has failed to preserve any doctrine-of-equivalents or contributory

infringement claims and objects to their inclusion in the joint pre-trial statement. Qualcomm

also contends that all asserted claims of the Patents-in-Suit are invalid under 35 U.S.C. §§ 102,

103, and/or 112, for anticipation, obviousness, non-enablement, and indefiniteness. Qualcomm

contends that ParkerVision’s claim for pre-suit damages is barred by the equitable doctrine of

laches. Qualcomm denies all allegations of willful infringement. Qualcomm denies that

3 The parties have jointly agreed to dismiss their claims and counterclaims with respect to two previously asserted patents. The parties will file a joint motion to this effect shortly.


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ParkerVision is entitled to any past or future damages, enhanced damages, an injunction, or an

ongoing royalty. Qualcomm seeks its costs and, pursuant to 35 U.S.C. § 285, its attorneys’ fees.

IV. BRIEF, GENERAL STATEMENT OF EACH PARTY’S CASE

A. ParkerVision’s Case

1. Background of the Dispute

This case involves ParkerVision’s patented down-conversion technology, sometimes

referred to as energy transfer sampling, energy sampling, or direct-to-data (“D2D”), which

makes receivers in cell phones and tablets smaller, more power efficient, and able to be used on

different mobile phone networks. Prior technologies, including superheterodyne and direct

conversion analog-mixer, used methods that require numerous parts and supporting components

to work properly, were large and expensive, had high power consumption and limited flexibility

to meet cell phone standards and frequencies, and/or had reduced dynamic range. Other

approaches that the industry had tried to develop for decades, such as voltage samplers and track-

and-hold samplers, were never able to achieve the performance required for high-performance

products such as cell phones and tablets. ParkerVision’s technology, on the other hand, achieves

performance in ways that previous methods never could. Specifically, it simultaneously achieves

power efficiency, size and integration benefits, greater range, better noise and interference

rejection, higher quality signal, better dynamic range, and overall reduced cost.

The breakthrough occurred in 1996 when a group of ParkerVision engineers, including

David Sorrells, discovered that receiver sensitivity could be increased by transferring power

during the sampling down-conversion process. In energy transfer sampling, a signal’s energy is

transferred and accumulated in a storage device, where controlled charge and discharge cycles

create the down-converted baseband signal—which is the information sent on the carrier.


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Thereafter, ParkerVision developed prototype chips, and conducted various tests and

measurements over a period of approximately one year, concluding that their unique sampling

technique provided an optimal solution for direct conversion receivers and many types of RF

carrier waveforms. The Patents-in-Suit resulted from ParkerVision’s research and development

efforts.

From 1998 through 1999, ParkerVision and Qualcomm conducted negotiations over

whether Qualcomm would license ParkerVision’s energy transfer sampling technology.

Qualcomm was enthusiastic about ParkerVision’s technology. However, fundamentally

believing in the value of its technology and being of the opinion that Qualcomm was not

negotiating reasonably, ParkerVision was unwilling to agree to the financial terms Qualcomm

offered, and ParkerVision broke off licensing discussions in mid- to late 1999. The parties went

their separate ways. However, as the need for smaller, more efficient receivers able to support

multiple frequency bands came to the forefront in the mid-2000s, Qualcomm—unbeknownst to

ParkerVision—began designing and selling infringing receivers. Despite introducing infringing

receivers, Qualcomm never returned to ParkerVision for a license. Instead, ParkerVision

independently discovered Qualcomm’s infringement in 2011. In mid-2011, after confirming

Qualcomm’s infringement, ParkerVision filed suit against Qualcomm.

2. The Patents-in-Suit

ParkerVision is the sole and exclusive owner of all rights, title and interest to the

following valid and enforceable Patents-in-Suit:

U.S.PATENT NO.

DATEISSUED TITLE

6,061,551 May 9, 2000 Method and System for Down-ConvertingElectromagnetic Signals


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U.S.PATENT NO.

DATEISSUED TITLE

6,266,518 July 24, 2001 Method and System for Down-ConvertingElectromagnetic Signals by Sampling andIntegrating Over Apertures

6,370,371 April 9, 2002 Applications of Universal Frequency Translation7,496,342 February 24,

2009Down-Converting Electromagnetic Signals, Including Controlled Discharge of Capacitors

The Patents-in-Suit generally relate to methods, systems, and apparatuses used to convert

electromagnetic signals from higher frequencies to lower frequencies. Such down-conversion is

used, for instance, in the operation of cellular telephones.

ParkerVision owned the Patents-in-Suit throughout the period of Qualcomm’s

infringement and still owns the Patents-in-Suit. ParkerVision has not granted Qualcomm a

license to practice the Patents-in-Suit.

The invention date for the ’551, ’518, and ’371 patents is March 6, 1997, rather than each

patent’s effective filing date of October 21, 1998. For the ’342 patent, the invention date is the

effective date of filing, April 14, 2000.

3. ParkerVision’s Infringement Contentions

Qualcomm’s infringing products are receivers, transceivers, and integrated

transceivers and basebands that Qualcomm’s customers incorporate into cell phones and

other devices. Qualcomm’s infringing products (the “Accused Products”) include the

following Qualcomm receiver design architectures: Astra, Bahama, Eagleray, GZIF3,

GZIF4, Halley, Hercules, Iceman, Iris, Libra/Gemini, Magellan, Merlin (QCT),

Napoleon, Odyssey, Ramsis, Solo, Volans, Voltron, and Ywing. These design

architectures correspond to the following individual integrated circuits: RGR6240,

WCN2243, FTR8700, RTR6275, RTR6237, RTR6280, RTR6285, RTR6285A,

MXU6219, QTR9215, RTR8700, RTR9605, WCN3660, WCN1312, MDM6200,


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MDM6600, QSC6155, QSC6175, QSC6185, QSC6295, QSC6695, QTR8200,

QTR8600, QTR8600L, QTR8601, QTR8615, QTR8615L, RTR8600, RTR8601,

RTR8605, QSC1105, QSC1100, QSC1110, WTR1605, WTR1605L, QSC6055,

QSC6065, QSC6075, QSC6085, MDM6085, QSC6270, QSC6240, MDM6270,

ESC6270, ESC6240, WCN1314, RTR6500, and WCN1320.

Each of the Accused Products directly infringes claims 23, 25, 161, 193, and 202 of the

’551 patent; claims 1, 27, 82, 90, and 91 of the ’518 patent; claim 2 of the ’371 patent; and claim

18 of the ’342 patent (the “Asserted Claims”)4 under 35 U.S.C. §§ 271 and 281-285, literally

and/or under the doctrine of equivalents. Qualcomm is directly liable for the infringement of the

Accused Products because it makes, uses, offers to sell, sells, and/or imports each of the Accused

Products into the United States, without authority or license from ParkerVision.

Qualcomm indirectly infringes the Asserted Claims of each of the Patents-in-Suit by

active inducement under 35 U.S.C. § 271(b). Qualcomm has induced and continues to induce its

customers and/or users of the Accused Products to directly infringe the Asserted Claims of each

of the Patents-in-Suit. Qualcomm specifically intends for its customers and/or users of the

Accused Products to directly infringe the Asserted Claims of each of the Patents-in-Suit in the

United States. Qualcomm knew of or was willfully blind to each of the Patents-in-Suit before

the July 20, 2011 filing of the original complaint by ParkerVision. Qualcomm designed the

Accused Products such that they would each infringe the Asserted Claims of each of the Patents-

in-Suit if made, used, sold, offered for sale or imported into the United States. Qualcomm knows

that the customers and/or users of the Accused Products will directly infringe the Asserted

4 The parties have jointly agreed to dismiss their claims and counterclaims with respect to many of the previously asserted claims of the patents-in-suit. The parties will file a joint motion to this effect shortly.


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Claims of each of the Patents-in-Suit when those customers and/or users make, use, sell, offer to

sell, and/or import into the United States the Accused Products and/or cellular telephones and

mobile devices that include the Accused Products.

Qualcomm indirectly infringes the Asserted Claims of each of the Patents-in-Suit by

contributory infringement under 35 U.S.C. § 271(c). Qualcomm has contributed to and continues

to contribute to the direct infringement of the Asserted Claims of each of the Patents-in-Suit by

customers and/or users of the Accused Products. Qualcomm knew of or was willfully blind to

each of the Patents-in-Suit before ParkerVision filed the original complaint on July 20, 2011.

Since then, Qualcomm has sold, offered to sell, and/or imported into the United States the

Accused Products, which Qualcomm knows to be especially made or adapted for use in

infringing the Asserted Claims of each of the Patents-in-Suit such that they would infringe the

Asserted Claims of each of the Patents-in-Suit if made, used, sold, offered for sale or imported

into the United States. The direct conversion receiver technology within the Accused Products

has no substantial use that does not infringe the Asserted Claims of each of the Patents-in-Suit.

Qualcomm lacks justifiable belief that there is no infringement, or that the infringed

claims are invalid, and has acted with objective recklessness in its infringing activity.

Moreover, Qualcomm has long known about each of the Patents-in-Suit, or was willfully blind to

the existence of the Patents-in-Suit. Therefore, Qualcomm’s infringement is and has been willful.

4. ParkerVision Has Suffered Harm as a Result of Qualcomm’s Infringement

Qualcomm’s acts of direct, contributory, and induced infringement have caused damage

to ParkerVision, and ParkerVision is entitled to recover compensatory damages sustained as a

result of Qualcomm’s wrongful acts in the form of a reasonable royalty. Unless enjoined by this

Court, Qualcomm will continue to infringe the Patents-in-Suit, continuing to damage


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ParkerVision and causing irreparable harm. ParkerVision therefore requests that this Court

enter a permanent injunction enjoining Qualcomm from continuing to infringe each of the

Patents-in-Suit. In the alternative, ParkerVision contends that any denial of an injunction should

be conditioned on payment of reasonable royalties for future infringement, including during any

stay of an injunction pending appeal. Qualcomm’s infringement is willful, and ParkerVision is

therefore entitled to an award of exemplary damages, attorneys’ fees, and costs in bringing

this action.

B. Qualcomm’s Case

In 1998 and 1999, Qualcomm was using a superheterodyne (multistage) downconversion

architecture. At that time, ParkerVision and Qualcomm discussed a potential business

relationship involving ParkerVision’s direct downconversion technology, “D2D.” Based on

ParkerVision’s bold claims about its technology, Qualcomm was intrigued and assigned some

engineers to evaluate the ParkerVision technology. Although the engineering analysis had raised

serious questions about the value of ParkerVision’s technology, Qualcomm engaged in financial

discussions regarding a potential technology transfer and license if ParkerVision’s technology

could be made to work and was better than other available technologies. The parties never

reached agreement.

ParkerVision had significant difficulty demonstrating the viability of its proposed

technology. By the time the financial discussions ended in mid-1999, the RF engineering

specialists within Qualcomm had concluded that the ParkerVision technology was not

particularly novel, would require substantial effort by Qualcomm to incorporate into any cell

phone product—if it even could—and that Qualcomm could independently develop its own

direct downconversion technology using a different and reliable approach. That is exactly what

Qualcomm did. Qualcomm’s initial ZIF direct downconversion products—which ParkerVision


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has not accused of infringement—were sold by the millions for many years starting in the early

2000’s.

Then in approximately 2005, Qualcomm saw an opportunity to purchase a company

called Berkana Wireless. Berkana had a number of interesting technologies, including

technologies that Qualcomm could immediately incorporate into its next generation of

receivers—thereby quickening the time to market. Qualcomm paid over $50 million for

Berkana, and then proceeded to combine Berkana’s various receiver technologies, which

included a direct downconverter, into the existing Qualcomm designs. That is when

ParkerVision alleges that Qualcomm’s infringement began.

But Qualcomm’s ZIF and Berkana-based designs are fundamentally different from

ParkerVision’s D2D “energy sampler” in many important respects. Qualcomm went a

completely different direct downconversion route and Qualcomm’s technology does not infringe

ParkerVision’s very different “energy sampling” technology. Qualcomm is not aware that any

ParkerVision “energy sampling” or D2D technology is in use in any cell phone device and, based

on the description of the latest product ParkerVision has promoted on its website, ParkerVision

itself has not been able to create a viable receiver product for use in cellular devices.

Qualcomm’s products are different, do not use energy sampling or D2D, do not infringe the

patents, and have been used successfully in millions of devices around the world. In addition,

ParkerVision’s patents are invalid for multiple reasons, including anticipation, obviousness, non-

enablement, and indefiniteness.

Indirect infringement and willful infringement require additional elements of proof

beyond whether Qualcomm’s products meet the limitations of the asserted claims. For example,

to prove indirect or willful infringement, ParkerVision must establish that Qualcomm acted with


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a culpable state of mind. For example, inducement requires that ParkerVision prove Qualcomm

knew of the patents-in-suit and knew that the patents were valid and infringed by third parties.

Qualcomm did not believe and does not believe that it infringes any of the Patents-in-Suit or that

they are valid. Qualcomm does not believe that D2D could be used in a working, commercially

viable receiver – the kind of product Qualcomm must design and produce to satisfy its

customers. Qualcomm never intended to induce any customer to infringe the patents-in-suit.

Thus, ParkerVision cannot prevail on its indirect infringement claim—which is the basis for

virtually all of the alleged damages in this case.

Finally, with respect to damages, Qualcomm contends that ParkerVision’s outsized

request has no relationship to these patents or any reasonable assessment of their contribution to

technology, even assuming they are valid. Further, ParkerVision’s damages theory is based on

improper assumptions and factors that have clearly been prohibited by law. By way of

background, ParkerVision has entered into scores of NDAs so companies could evaluate its

technology. Not a single one has ever produced a product using the technology. The market’s

decision not to use ParkerVision’s technology is strong evidence that it does not provide any real

value over other technology.

Thus, even if

liability is assumed, a proper damages calculation would result in a small fraction of the damages

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sought by ParkerVision. ParkerVision’s damages theory—that Qualcomm would have agreed to

pay hundreds of millions of dollars in 2006 for technology that has generated a total of

from the entire industry—simply has no support in the objective market evidence.

V. LIST OF ALL EXHIBITS AND RULE 5.04 EXHIBIT SUBSTITUTES TO BE OFFERED AT TRIAL WITH NOTATION OF ALL OBJECTIONS THERETO

See Attachments A-1 (ParkerVision’s Exhibit Lists); A-2 (Qualcomm’s Exhibit List);

and A-3 (Joint Exhibit List) to this Statement.

The parties are working together on a procedure for maintaining at trial the

confidentiality of a limited number of highly confidential technical and business documents

designated pursuant to the parties’ Confidentiality Agreement (see Attachment A).

The parties each reserve the right to omit or withdraw any exhibit that party has

designated for use at trial. The parties agree that a party’s listing of a document on its own

exhibit list is not an admission that the document is admissible as evidence if introduced by the

other party. Any exhibit, once admitted, may be used equally by either party subject to any

limitations as to its admission into evidence. The parties reserve the right to use any

demonstrative used by the other party at any time during the trial (including electronic display).

The parties reserve the right to present electronic copies of demonstratives furnished in paper

form in connection with the pretrial process and to modify such demonstratives.

The parties agree that any description of a document on an exhibit list is provided for

convenience only and shall not be used as an admission or otherwise as evidence regarding that

exhibit.

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VI. LIST OF ALL WITNESSES WHO MAY BE CALLED AT TRIAL

See Attachments B-1 (ParkerVision’s Witness List) and B-2 (Qualcomm’s Witness List)

to this Statement.

VII. LIST OF ALL EXPERT WITNESSES INCLUDING, AS TO EACH WITNESS, A STATEMENT OF THE SUBJECT MATTER AND A SUMMARY OF HIS OR HER TESTIMONY

A. Retained Experts to be Offered by ParkerVision

1. Paul Prucnal

Dr. Prucnal is an expert witness for ParkerVision who is expected to offer opinions about

the topics identified in his expert reports, previously testified to in his deposition, or based on

updated information subsequently provided by Qualcomm or its experts. Dr. Prucnal will testify

as to issues of infringement and invalidity. Dr. Prucnal’s expertise relates to RF receiver design

and functionality, RF communication systems, optical communications, electrical engineering,

the state of the art, the level of skill of one of ordinary skill in the art, and the existence,

relevancy, meaning, and significance of art in the field.

2. Paul Benoit

Mr. Benoit is an expert witness for ParkerVision who is expected to offer opinions about


updated information subsequently provided by Qualcomm. Mr. Benoit’s will testify as to the

amount of damages that ParkerVision is entitled to as a result of Qualcomm’s infringement. Mr.

Benoit’s expertise relates to accounting, economics, and finance.


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B. Fact Witnesses Who Will Offer Expert Testimony5

1. Jeffrey Parker

Mr. Parker is the President and Chief Executive Officer of ParkerVision. He is expected

to offer opinions regarding the topics identified in his Rule 26(a)(2)(C) disclosure, previously

testified to in his deposition, or based on updated or non-confidential information provided by

Qualcomm. In addition to testifying as a fact witness, Mr. Parker will provide expert testimony

as to the amount of damages that Qualcomm should be required to pay ParkerVision to

compensate it for infringement and the amount of a royalty that ParkerVision would have

reasonably accepted in any actual or contemplated negotiation between ParkerVision and

Qualcomm. Mr. Parker’s expertise relates to the wireless communications industry, business

negotiations, and licensing agreements.

2. David Sorrells

Mr. Sorrells is the Chief Technology Officer of ParkerVision and one of the inventors of

each of the Patents-in-Suit. He is expected to offer opinions regarding the topics identified in his

Rule 26(a)(2)(C) disclosure, previously testified to in his deposition, or based on updated or non-

confidential information provided by Qualcomm. Mr. Sorrells’s expertise relates to receiver

design and functionality, the state of the art, the level of skill of one or ordinary skill in the art,

and the existence, relevancy, meaning, and significance of art in the field. In addition to

testifying as a fact witness, Mr. Sorrells will testify regarding Qualcomm’s infringement of the

Patents-in-Suit and validity of the Patents-in-Suit.

5 As detailed in Qualcomm’s pending motions in limine, Qualcomm objects to ParkerVision’s proffer of expert testimony from Mr. Parker and Mr. Sorrells. (Dkt. 325.) As ParkerVision will detail and set out in its response to Qualcomm’s motions in limine, Mr. Parker and Mr. Sorrells each filed expert disclosures pursuant to FED. R. CIV. P. 26(a)(2)(C). In addition, both Mr. Parker and Mr. Sorrells are qualified to provide the disclosed expert testimony.


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C. Retained Experts to be Offered by Qualcomm

1. Dr. Behzad Razavi

Dr. Razavi is an expert witness for Qualcomm who is expected to offer opinions about


updated information subsequently provided by ParkerVision or its experts (if allowed). Dr.

Razavi will testify as to issues of invalidity, including the state of the art before the filing of

ParkerVision’s asserted claims. Dr. Razavi’s expertise includes RF receiver/transceiver design

and functionality, RF communication systems, electrical engineering, the state of the art, the

level of skill of one of ordinary skill in the art, and the existence, relevancy, meaning, and

significance of art in the field.

2. Dr. Robert Fox

Dr. Fox is an expert witness for Qualcomm who is expected to offer opinions about the

topics identified in his expert reports, previously testified to in his deposition, or based on

updated information subsequently provided by ParkerVision or its experts (if allowed). Dr. Fox

will testify as to issues of non-infringement. Dr. Fox’s expertise includes RF

receiver/transceiver design and functionality, RF communication systems, electrical engineering,

the state of the art, the level of skill of one of ordinary skill in the art, and the existence,

relevancy, meaning, and significance of art in the field.

3. Dr. Tim Williams

Dr. Williams is an expert witness for Qualcomm who is expected to offer opinions about


updated information subsequently provided by ParkerVision or its experts (if allowed). Dr.

Williams will testify as to issues relevant to invalidity and damages. Dr. William’s expertise

includes RF receiver/transceiver design and functionality, RF communication systems, electrical


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engineering, the state of the art, the level of skill of one of ordinary skill in the art, the existence,

relevancy, meaning, and significance of art in the field, the value of any alleged inventions in the

Patents-in-Suit, cellular communication systems, and commercial aspects of the wireless

communications industry.

4. Dr. Gregory Leonard

Dr. Leonard is an expert witness for Qualcomm who is expected to offer opinions about


updated information subsequently provided by ParkerVision (if allowed). Dr. Leonard will

testify as to issues of damages. Dr. Leonard’s expertise includes economics.

5. Joseph Hanna

In any proceedings related to any request for an injunction, Qualcomm also expects to

offer the opinion of Mr. Hanna. He will testify regarding opinions about the topics identified in

his expert reports and previously testified to in his deposition. His expertise includes emergency

communications systems and the importance of certain communications technology to

emergency communication networks.6

6 Qualcomm notes that ParkerVision has not preserved the ability to present any expert testimony regarding the eBay factors for any request for injunctive relief. To the extent that the testimony of ParkerVision’s experts is relevant to the eBay factors, ParkerVision has adequately preserved the ability to present such testimony in its request for injunctive relieve. Furthermore, in its response to a Qualcomm interrogatory on the eBay factors, ParkerVision identified Mr. Parker as the person most knowledgeable on the related evidence. ParkerVision’s Resp. to Qualcomm Interr. No. 14 (Nov. 16, 2012). ParkerVision notes that expert testimony is not required for testimony regarding the eBay factors of a request for injunctive relief.


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VIII. IN CASES IN WHICH ANY PARTY CLAIMS MONEY DAMAGES, A STATEMENT OF THE ELEMENTS OF EACH SUCH CLAIM AND THE AMOUNT BEING SOUGHT WITH RESPECT TO EACH SUCH ELEMENT

ParkerVision is entitled to damages under 35 U.S.C. § 284 for Qualcomm’s past acts of

infringement. ParkerVision alleges it is entitled to a reasonable royalty for Qualcomm’s past

direct infringement, totaling at least for the period from January 2006 through

October 2013. ParkerVision alleges it is entitled to a reasonable royalty for Qualcomm’s past

indirect infringement (induced and contributory infringement), totaling at least for

the period from January 2006 through October 2013. ParkerVision seeks an updated accounting

from Qualcomm for use in updating the foregoing totals. ParkerVision has requested updated

financial information from Qualcomm and expects to provide testimony on this updated

information (if timely obtained from Qualcomm).

In addition to the foregoing actual damages and accounting sought at trial, ParkerVision

intends to seek, by way of post-trial motion in the event of a finding of liability, an enhancement

of actual damages due to willful infringement, prejudgment interest, postjudgment interest, costs,

and an award of attorneys’ fees under 35 U.S.C. § 285 upon an “exceptional case” finding by the

Court.

Qualcomm denies liability and that ParkerVision is entitled to any remedy. Following a

verdict, Qualcomm intends to seek costs and an award of attorneys fees.

IX. LIST OF ALL DEPOSITIONS TO BE OFFERED IN EVIDENCE AT TRIAL (AS DISTINGUISHED FROM POSSIBLE USE FOR IMPEACHMENT), INCLUDING A DESIGNATION OF THE PAGES AND LINES TO BE OFFERED FROM EACH DEPOSITION

See Attachments C-1 (ParkerVision’s designations) and C-2 (Qualcomm’s designations)

to this Statement.

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The parties are working together on a procedure for maintaining at trial the

confidentiality of a limited number of highly confidential deposition testimony designated

pursuant to the parties’ Confidentiality Agreement (see Attachment A).

The parties each reserve the right to omit or withdraw deposition selections before or

during trial.

IX. CONCISE STATEMENT OF STIPULATED FACTS AND WILL REQUIRE NO PROOF AT TRIAL, TOGETHER WITH ANY RESERVATIONS DIRECTED TO SUCH STIPULATIONS

Litigation

1. ParkerVision filed its Original Complaint on July 20, 2011.

2. Qualcomm filed its Answer, Defenses, and Counterclaims in response to ParkerVision’s original Complaint on September 16, 2011.

3. ParkerVision filed its First Amended Complaint on February 28, 2012.

4. Qualcomm filed its Answer, Defenses, and Counterclaims in response to ParkerVision’s First Amended Complaint on March 16, 2012.

5. ParkerVision filed its Second Amended Complaint on August 30, 2012.

6. ParkerVision filed its Third Amended Complaint on August 30, 2012.

7. Qualcomm filed its Answer, Defenses, and Counterclaims in response to ParkerVision’s Third Amended Complaint on April 11, 2013.

8. ParkerVision filed its Answer to Qualcomm’s Counterclaims on May 6, 2013.

Corporate Information

9. ParkerVision is a Florida corporation with its principal place of business at 7915 Baymeadows Way, Jacksonville, Florida 32256.

10. ParkerVision was founded in 1989.

11. Qualcomm is a Delaware corporation with its principal place of business at 5775 Morehouse Drive, San Diego, California, 92121.

12. Qualcomm was founded in 1985.


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Accused Products

13. Electromagnetic waves are characterized by frequency (or “period” or “cycle”) and amplitude.

14. Electromagnetic waves are also characterized by phase.

15. The Accused Products fall into three categories: (a) receivers; (b) transceivers, which contain both a receiver and a transmitter; and (c) integrated transceivers/basebands, which combine a transceiver with a baseband processor on a single chip or package.

16. A transmitter is a device that converts a signal into a form that can be sent over the air, and then sends the converted signal over the air.

17. A receiver is a device that receives radio frequency signals from the air, and converts those signals into a form that can be used in later processing to convert back into the original signal.

18. A transceiver combines a receiver with a transmitter on a single chip or in a single package.

19. Each of the Accused Products is a single unitary product, meaning that it is an individual chip or package that is sold as an indivisible unit.

20. The Qualcomm dies at issue in this litigation are: Astra, Bahama, Eagleray, GZIF3, GZIF4, Halley, Hercules, Iceman, Iris, Libra/Gemini, Magellan, Merlin (QCT), Napoleon, Odyssey, Ramsis, Solo, Volans, Voltron, and Ywing. For purposes of infringement or noninfringement, the design, circuitry, and operation of the accused products created from a particular die is the same. A showing that an accused product created from a particular die infringes an asserted claim is also a showing that the other accused products created from that die also infringe the same claim. Likewise, a finding that a particular die does not infringe one or more asserted claims of the patents-in-suit also requires a finding that the accused products associated with that die do not infringe the same claims.

The table below categorizes the products accused of infringement by product name and die. These products are referred to as the “Accused Products”:

Die Name Products

Astra RGR6240

Bahama WC2243

Eagleray FTR8700


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Die Name Products

GZIF3 RTR6275

GZIF4 RTR6237, RTR6280, RTR6285, RTR6285A, MXU6219

Halley QTR9215

Hercules RTR8700

Iceman RTR9605

Iris WCN3660

Libra/Gemini WCN1312

Magellan MDM6200, MDM6600, QSC6155, QSC6175, QSC6185, QSC6295, QSC6695, QTR8200, QTR8600, QTR8600L, QTR8601, QTR8615, QTR8615L, RTR8600, RTR8601,

RTR8605

Merlin (QCT) QSC1105

Napoleon QSC1100, QSC1110

Odyssey WTR1605, WTR1605L

Ramsis QSC6055, QSC6065, QSC6075, QSC6085, MDM6085

Solo QSC6240, ESC6240, MDM6270, ESC6270, QSC6270

Volans WCN1314

Voltron RTR6500

Ywing WCN1320

21. A commercial sample of the RGR6240 was first produced on November 12, 2008.

22. A commercial sample of the WCN2243 was first produced on December 31, 2010.

23. A commercial sample of the FTR8700 was first produced on April 14, 2011.

24. A commercial sample of the RTR6275 was first produced in 2006.

25. A commercial sample of the RTR6237 was first produced on June 29, 2007.


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26. Commercial samples of the RTR6280 and RTR6285 were first produced on June 30, 2007.

27. A commercial sample of the RTR6285A was first produced on August 15, 2011.

28. A commercial sample of the MXU6219 was first produced on February 28, 2007.

29. A commercial sample of the QTR9215 was first produced on June 30, 2011.

30. A commercial sample of the WCN3660 was first produced on December 19, 2011.

31. A commercial sample of theWCN1312 was first produced on April 28, 2010.

32. Commercial samples of the MDM6200 and MDM6600 were first produced on January 31, 2011.

33. Commercial samples of the QSC6155, QSC6185, and QSC6695 were first produced on September 30, 2010.

34. Commercial samples of the QSC6175, QSC6295, QTR8601, RTR8600, and RTR8601 were first produced on June 30, 2010.

35. A commercial sample of the QTR8200 was first produced on March 30, 2010.

36. Commercial samples of the QTR8600, QTR8600L, and RTR8605 were first produced on March 31, 2010.

37. A commercial sample of the QTR8615 was first produced on December 23, 2010.

38. A commercial sample of the QTR8615L was first produced on March 24, 2011.

39. A commercial sample of the QSC1105 was first produced on December 30, 2011.

40. A commercial sample of the QSC1100 was first produced on February 27, 2009.

41. A commercial sample of the QSC1110 was first produced on December 17, 2008.

42. A commercial sample of the WTR1605 was first produced on April 30, 2012.

43. A commercial sample of the QSC6055 was first produced on June 30, 2007.

44. Commercial samples of the QSC6065 and QSC6075 were first produced on December 21, 2007.

45. A commercial sample of the QSC6085 was first produced on April 21, 2008.

46. A commercial sample of the MDM6085 was first produced on February 15, 2010.


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47. Commercial samples of the QSC6270, QSC6240, ESC6270, and ESC6240 were first produced on December 5, 2008.

48. A commercial sample of the MDM6270 was first produced on June 30, 2010.

49. A commercial sample of the WCN1314 was first produced on October 31, 2011.

50. A commercial sample of the RTR6500 was first produced on November 15, 2007.

51. A commercial sample of the WCN1320 was first produced on October 15, 2009.

Qualcomm’s Baseband Technology

52. Qualcomm receivers/transceivers are designed to function in conjunction with a Qualcomm baseband processor.

Patents-in-Suit

53. U.S. Patent No. 6,061,551 (“the ’551 patent”) issued on May 9, 2000 and is entitled “Method and System for Down-Converting Electromagnetic Signals.”

54. The application for the ’551 patent was filed on October 21, 1998.

55. The prosecution history of the ’551 Patent includes a reference to U.S. Patent Application Serial No. 09/376,359, now U.S. Patent No. 6,266,518 (“the ’518 Patent”).

56. The named inventors of the ’551 patent are David F. Sorrells, Michael J. Bultman, Robert W. Cook, Richard C. Looke, and Charley D. Moses, Jr.

57. The ’518 patent issued on July 24, 2001 and is entitled “Method and System for Down-Converting Electromagnetic Signals by Sampling and Integrating Over Apertures.”

58. The application for the ’518 patent was filed on August 18, 1999.

59. The ’518 Patent is a continuation of the ’551 patent.


61. U.S. Patent No. 6,370,371 (“the ’371 patent”) issued on April 9, 2002 and is entitled “Applications of Universal Frequency Translation.”

62. The ’371 patent is a continuation-in-part of U.S. Patent Application Serial No. 09/176,027.



McKool 905908v8 24

64. The application for the ’371 patent was filed on March 3, 1999.

65. U.S. Patent No. 7,496,342 (“the ’342 patent”) issued on February 24, 2009 and is entitled “Down-Converting Electromagnetic Signals, Including Controlled Discharge of Capacitors.”

66. The ’342 patent is a divisional of U.S. Patent No. 7,010,286, filed May 16, 2001, which is a continuation-in-part of U.S. Patent Application Serial No. 09/550,644, filed on April 14, 2000, which is a continuation-in-part of U.S. Patent Application Serial No. 09/293,342, filed on April 16, 1999, which is a continuation-in-part of U.S. Patent Application Serial No. 09/176,022, now the ’551 Patent.

67. The named inventors of the ’342 patent are David F. Sorrells, Michael J. Bultman, Robert W. Cook, Richard C. Looke, Charley D. Moses, Jr., Gregory S. Rawlins, and Michael W. Rawlins.

68. ParkerVision is the assignee of the ’551 patent, the ’518 patent, the ’371 patent, and the ’342 patent.

69. ParkerVision is the sole and exclusive owner of all rights, title, and interest to the ’551 patent, the ’518 patent, the ’371 patent, and the ’342 patent.

Claim Terms

70. The parties agree as to the meanings of the following claim terms

References Identified as Prior Art by Qualcomm

Claim Term Agreed Meaning

“carrier signal” “an electromagnetic wave that is capable of carrying information via modulation”

“aliasing rate” “sampling rate that is less than or equal to twice the frequency of the carrier signal”

“aperture periods” “the durations of time over which energy is transferred from the carrier signal”

“electrically coupling” “indirectly or directly connecting such that an electric signal can flow between the coupled points”

“baseband signal” “any generic information signal desired for transmission and/or reception”


McKool 905908v8 25

71. The following references identified by Qualcomm as prior art appear on the face of Patents-in-Suit. Additionally, the file histories for the Patents-in-Suit includes disclosure documents on which the Patent Examiner marked his initials next to each of the following references identified by Qualcomm as prior art:

U.S. Patent No. 4,346,477, “Phase Locked Sampling Radio Receivers,” to R. Gordy (“Gordy”) is listed on the face of the ’551 patent.

U.S. Patent No. 5,140,705, “Center-Tapped Coil-Based Tank Circuit for a Balanced Mixer Circuit,” to T. Kosuga (“Kosuga”) is listed on the face of the ’342 patent.

Rudell, J.C. et al., “A 1.9-Ghz Wide-Band IF Double Conversion CMOS Receiver for Cordless Telephone Applications,” IEEE Journal of Solid-State Circuits, IEEE, vol. 32, No. 12, pp. 2071-2088 (Dec. 1997) (“Rudell”) is listed on the face of the ’342 patent.

U.S. Patent No. 6,121,819, “Switching Down Conversion Mixer for Use in Multi-Stage Receiver Architectures,” to K. Traylor (“Traylor”) is listed on the face of the ’342 patent.

The ’551 patent is listed on the face of the ’342 patent.

72. The article “Subharmonic Sampling of Microwave Signal Processing Requirements,” Microwave Journal (1992), by Peter Weisskopf, was published in May 1992. The Weisskopf article predates the asserted claims of the patents-in-suit.

73. The article “A Mixer Computer-Aided Design Tool Based in the Time Domain,” 1988 IEEE MTT-S Digest, pp. 1107-1110, by Polly Estabrook and Bruce Lusignan, (“Estabrook I”) was published in 1989. The Estabrook I article predates the asserted claims of the patents-in-suit.

74. The article “The Design of a Mobile Radio Receiver Using a Direct Conversion Architecture,”1988 IEEE Vehicular Technology Conference, IEEE 38th 06/1989 (1989), by Polly Estabrook and Bruce Lusignan, (“Estabrook II”) was published in 1989. The Estabrook II article predates the asserted claims of the patents-in-suit.

75. The article “The Merigo Method: SSB Generator/Producing A Demodulator,” Ham Journal, July/August 1993 Issue, pp. 20-31, by Yasuo Nozawa, was published in August 1993. The Nozawa article predates the asserted claims of the patents-in-suit.

76. The article “The Fourth Method: Generating and Detecting SSB Signals,” QEX, Sept. 1990, pp. 7-11, by D. H. van Graas, was published in September 1990. The van Graas article predates the asserted claims of the patents-in-suit.


McKool 905908v8 26

77. ParkerVision’s Cameraman MDS-2000 product was a videocamera system that used wireless technology to permit the video user to appear in the video while at the same time being able to control the camera action.

78. ParkerVision’s Cameraman MDS-2000 product was made publicly available no later than August 29, 1995. The Cameraman product predates the asserted claims of the patents-in-suit.

79. The article “A 1.5 GHz Highly Linear CMOS Downconversion Mixer, “IEEE Journal of Solid-State Circuits, Vol. 30, No. 7, July 1995, pp. 736-742, by Jan Crols and Michel Steyaert, was published in July 1995. The Crols article predates the asserted claims of the patents-in-suit.

80. U.S. Patent No. 4,346,477, “Phase Locked Sampling Radio Receiver,” to R. Gordy, was issued on August 24, 1982. The Gordy patent predates the asserted claims of the patents-in-suit.

81. U.S. Patent No. 5,339,459, “High Speed Sample and Hold Circuit and Radio Constructed Therewith,” to T. Schiltz, was issued on August 16, 1994. The Schiltz patent predates the asserted claims of the patents-in-suit.

82. U.S. Patent No. 5,140,705, “Center-Tapped Coil-Based RF Tank Circuit for a Balanced Mixer Circuit,” to T. Kosuga, was issued on August 18, 1992. The Kosuga patent predates the asserted claims of the patents-in-suit.

83. The reference “Practical RF Design Manual,” by Doug DeMaw, was published in 1982. The DeMaw reference predates the asserted claims of the patents-in-suit.

84. U.S. Patent No. 5,379,457, “Low Noise Active Mixer,” to N. Nguyen, was issued on January 3, 1995. The Nguyen patent predates the asserted claims of the patents-in-suit.

Qualcomm’s Sales and Financial Information7

85. Qualcomm does not dispute that, in 2006, approximately 29.3% of Qualcomm’s revenues from its worldwide sales of Accused Products resulted from sales of Accused Products that were eventually incorporated into devices that were imported into the United States.


7 For purposes of this case only, Qualcomm does not dispute the percentage of revenues associated with Accused Products that were incorporated into devices ultimately imported into the United States, as detailed in the body of the joint pre-trial statement.


McKool 905908v8 27






Authenticity

92. To the best of Qualcomm’s knowledge, each document produced by Qualcomm in this case with a “QCPV” prefix is authentic.

93. To the best of ParkerVision’s knowledge, each document produced by ParkerVision in this case with a “PV” or “CONF-PV” prefix is authentic.

X. CONCISE STATEMENT OF APPLICABLE PRINCIPLES OF LAW ON WHICH THERE IS AGREEMENT

1. ParkerVision is the exclusive owner of all rights under the Patents-in-Suit, and is the party entitled to bring suit for infringement of the Patents-in-Suit and sue for past infringement of the Patents-in-Suit.

2. Jurisdiction and venue are proper in this Court.

3. Subject to any modifications made by a party before the Court presents the instructions to the jury, the parties submit the proposed jury instructions and agree that the agreed upon principles of law expressed therein apply. See Attachment D to this Statement.


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XI. CONCISE STATEMENT OF ISSUES OF FACT WHICH REMAIN TO BE LITIGATED

A. Infringement Issues

1. Whether Qualcomm directly infringes the Asserted Claims of the ’551 patent, the ’518 patent, the ’371 patent, and the ’342 patent.8

2. Whether Qualcomm indirectly infringes the Asserted Claims of the’551 patent, the ’518 patent, the ’371 patent, and the ’342 patent under either induced or contributory infringement.9

3. If Qualcomm is found liable for infringement of any Asserted Claim of the Patents-in-Suit, whether the infringement was willful (See below for antecedent question of law).

B. Invalidity Issues

4. Whether any of the Asserted Claims of the Patents-in-Suit are invalid for anticipation under 35 U.S.C. § 102.

5. Whether the underlying factual elements of the obviousness and non-enablement theories have been proven.

C. Remedies

6. If Qualcomm is found liable for infringement of a valid claim, whether and what amount of pre-verdict damages ParkerVision has proved.

XII. CONCISE STATEMENT OF ISSUES OF LAW WHICH REMAIN FOR DETERMINATION

A. Questions of Validity

1. Whether any of the Asserted Claims of the ’551 patent, the ’518, or the ’371 patent are invalid for failure to meet the enablement requirement of 35 U.S.C.

8 As described in Qualcomm’s motions in limine, the parties dispute whether ParkerVision has preserved the issue of infringement under the doctrine of equivalents. As ParkerVision will detail and set out in its response to Qualcomm’s motions in limine, ParkerVision’s doctrine of equivalents evidence is adequate and Qualcomm’s vehicle for challenging such evidence is inappropriate.9 As described in Qualcomm’s motions in limine, the parties dispute whether ParkerVision has preserved the issue of contributory infringement. As ParkerVision will detail and set out in its response to Qualcomm’s motions in limine, ParkerVision’s contributory infringement evidence is adequate and Qualcomm’s vehicle for challenging such evidence is inappropriate.


McKool 905908v8 29

§ 112. Enablement is a legal determination of whether a patent enables one skilled in the art to make and use the claimed invention. Dkt. 318 at 7.

2. Whether any of the Asserted Claims of the ’551 patent or the ’518 patent are invalid under 35 U.S.C. § 112 as indefinite.

3. Whether any of the Asserted Claims of the Patents-in-Suit are invalid under 35 U.S.C. §103(a) as obvious? Obviousness is a question of law based on underlying findings of fact. In re Kubin, 561 F.3d 1351, 1355 (Fed. Cir. 2009).

B. Remedies

4. If Qualcomm is found liable for willfully infringing any Asserted Claim, whether an award of enhanced damages is appropriate pursuant to 35 U.S.C. § 284. In addition, both the judge and the jury play a role in determining the issue of willful infringement. When the underlying defense to willful infringement is predicated on underlying mixed questions of law and fact, as in this case, the Court must address the threshold determination of objective recklessness as a matter of law. Bard Peripheral Vascular, Inc. v. W.L. Gore & Assocs., Inc., 682 F.3d 1003, 1007 (Fed. Cir. 2012).

5. Whether this case is an exceptional case pursuant to 35 U.S.C. § 285 and whether ParkerVision or Qualcomm is entitled to an award of attorneys’ fees.

6. Whether ParkerVision and/or Qualcomm is entitled to costs, and, if so, the dollar amount of its costs.

7. If ParkerVision is awarded any damages, whether ParkerVision is entitled to post- and pre-trial interest and post-trial damages.

8. Whether ParkerVision is entitled to pre-judgment and post-judgment interest, and, if so, the dollar amount of pre-judgment and post-judgment interest.

C. Injunction

9. If Qualcomm is found liable for infringing any Asserted Claim, whether ParkerVision is entitled to an injunction against Qualcomm pursuant to 35 U.S.C. § 283 and the extent of any such injunction.

10. ParkerVision proposes as an issue whether any denial of an injunction should be conditioned on payment of reasonable royalties for future infringement, and if so, the royalty amount set for future infringement and a means or mechanism to account for future royalty payments, including during any stay of an injunction pending appeal.


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D. Claim Construction

11. ParkerVision respectfully submits that O2 Micro Int’l Ltd. v. Beyond Innovation Tech. Co., 521 F.3d 1351, 1361 (Fed. Cir. 2008) requires the Court to construe the meaning of the “generating” limitation in light of the parties’ disagreement regarding its plain and ordinary meaning. Qualcomm objects to ParkerVision’s submission on the grounds that the Court has already determined both that the claims do not include ParkerVision’s “discharge” requirement and that ParkerVision did not preserve the claim construction position it now advances. (Dkt. 318 at 5-6.)

XIII. CONCISE STATEMENT OF ANY DISAGREEMENT AS TO THE APPLICATION OF THE FEDERAL RULES OF EVIDENCE OR THE FEDERAL RULES OF CIVIL PROCEDURE

The parties have presented a number of evidentiary disputes in their respective motions in

limine. The parties’ additional disputes regarding the admissibility of exhibits and deposition

designations are documents and testimony are provided in the attached exhibits to this Pretrial

Statement. The parties have been working to further limit the number of disputes and will

continue to do so up to and throughout the trial.

The parties jointly request that in advance of trial, the Court allow each party an equal

amount of time (between 30 minutes to an hour) to make arguments regarding the admissibility

of certain exhibits that remain in dispute.

XIV. JOINTLY-PROPOSED SET OF JURY INSTRUCTIONS IN ORDER OF PRESENTATION TO THE JURY

See Attachment D to this Statement.

Each party reserves the right to modify its requested jury instructions in light of the

evidence introduced at trial and any rulings the Court may enter before the conclusion of the

trial.


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XV. PROPOSED JURY VERDICT FORMS

See Attachment E-1 (ParkerVision’s proposed verdict form) and E-2 (Qualcomm’s

proposed verdict form) to this Statement.

Each party reserves the right to modify its requested verdict form in light of the evidence

introduced at trial and any rulings the Court may enter before the conclusion of the trial.

XVI. JOINTLY-PROPOSED JUROR QUESTIONNAIRE AND LIST OF VOIR DIRE QUESTIONS

See Attachment F to this Statement for the parties’ Jointly Proposed List of Voir Dire

Questions.

The parties additionally jointly request that the Court ask that the potential jurors in the

panel respond to this Court’s Juror Questionnaire for Civil Cases. The Juror Questionnaire for

Civil Cases from the Court’s website is attached to this Statement as Attachment F.

XVII. AGREED MOTIONS IN LIMINE

1. Any argument, evidence, testimony, or reference to ParkerVision in a derogatory manner (such as a “patent troll” or “patent pirate”), to economic detriment suffered generally by businesses as a result of patent litigation, or to suggest that ParkerVision has less right to enforce its patents than others, including larger companies. This agreed motion in limine is not intended to limit in any way Qualcomm’s ability to argue that the Asserted Claims are invalid.

2. Any argument, evidence, testimony, or reference to alleged issues between either party and the SEC, or any investigations into either party’s compliance with SEC regulations.

3. Any argument, evidence, testimony, or reference that ParkerVision had an obligation to call or otherwise contact Qualcomm about its allegations of infringement prior to the filing of this lawsuit. This agreed motion in limine is not intended to limit in any way Qualcomm’s ability to support its laches defense before the Court or argue that it did not have sufficient knowledge of potential infringement of the Patents-in-Suit prior to the suit under the state-of-mind elements for indirect and willful infringement.


McKool 905908v8 32

4. Any argument, evidence, testimony, or reference regarding rejected claim construction positions, except as made to the Court to show a reasonable, good faith claim construction position regarding state-of-mind elements for indirect and willful infringement.

5. Any argument, evidence, testimony, or reference regarding the Nozawa board. This agreed motion in limine is not intended to limit Qualcomm’s ability to rely on the Nozawa article as a prior art reference.

6. Any argument, evidence, testimony, or reference that the Patents-in-Suit issued under an incorrect obviousness standard.

7. Any argument, evidence, testimony, or reference to valuations of or the book value of ParkerVision’s patents or intellectual property.

8. Any argument, evidence, testimony, or reference to issues to be decided by the Court, such as laches, equitable estoppel, double patenting, inequitable conduct, unclean hands, injunction, etc., except as to facts relevant to other issues properly before the jury.

9. Any argument, evidence, testimony, or reference regarding patents or patent claims that have never been asserted in this case or were previously asserted and willingly withdrawn (including the fact that ParkerVision voluntarily withdrew asserted patents or asserted claims), except as argued to the Court in addressing exceptional case and prevailing party findings.

10. Any argument, evidence, testimony, or reference to motions in limine, motions to strike, and motions to exclude filed by the parties and the outcomes of such motions.

11. Any argument, evidence, testimony, or reference regarding Sterne Kessler’s alleged breach of fiduciary duty to Qualcomm, or other abated claims against Sterne Kessler.

12. Any argument, evidence, testimony, or reference regarding the workload of the PTO (or its examiners) or any attempt to disparage the PTO (or its examiners). This agreed motion in limine is not intended to limit Qualcomm’s ability to argue that the PTO incorrectly issued the Patents-in-Suit or did not have all the information needed to assess the validity of the Patents-in-Suit.

13. Any argument, evidence, testimony, or references to the possible consequences of a verdict in ParkerVision’s or Qualcomm’s favor, including the possible issuance of an injunction, an award of enhanced damages, an award of attorney’s fees, or arguments that a verdict would result in (1) consumers paying more for products; (2) the economy being negatively impacted; (3) an injunction or the accused products no longer being available for use, or (4) firings or layoffs.

14. Any argument, evidence, testimony, or reference to settlement discussions between ParkerVision and Qualcomm covered by Federal Rule of Evidence 408 that have taken place since the filing of this lawsuit, or any related documents.


McKool 905908v8 33

15. Any argument, evidence, testimony, or reference to the office location of the parties’ lawyers.

16. Any argument, evidence, testimony or reference to the retention agreements or nature of the agreements (including any contingency fee arrangement) between the parties and their counsel or any argument, evidence, testimony or reference to either parties’ change of counsel during the litigation.

17. Any argument, evidence, testimony, or reference to (1) any jury study or focus groups that have been conducted by either party or (2) the use by either party of a shadow jury during trial.

18. Any argument, evidence, testimony, or reference, regarding any witness relating to criminal charges, tax liens, divorce proceedings, alleged drug use, size of a person’s residence or water consumption.

19. Any argument, evidence, testimony, or reference referring to a prior retention or relationship between any expert with counsel or any party in this case, including whether a party has attempted to retain another party’s expert.

20. Any argument, evidence, testimony, or reference to the “win/loss” record of the parties’ expert witnesses or what percentage of the time the juries agreed with the parties’ experts in other cases.

21. Any argument, evidence, testimony, or reference to legal and expert fees and expenses incurred by the parties in prosecuting and defending this litigation and/or incurred in a typical patent litigation. This motion in limine is not intended to preclude either party from inquiring as to the rate and amounts an expert has charged.

22. Any cross examination of a witness using documents the witness was previously precluded from seeing, including, but not limited to, due to the Confidentiality Agreement in this case.

23. Any argument, evidence, testimony, or reference to online postings, letters, or documents, or statements by Mike Farmwald or opinions of Mike Farmwald.

24. Any argument, evidence, testimony, or reference to postings, statements, documents, or content located only on the website www.pvnotes.com.

25. Any evidence, reference to or argument to expert’s earnings in other matters or general financial success.

26. Any evidence, reference to or argument regarding other cases in which ParkerVision or Qualcomm has been a party or any case or any instance where either party was accused of misappropriating another’s technology or infringed another’s patents.


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XVIII. LIST OF ALL MOTIONS OR OTHER MATTERS WHICH REQUIRE ACTION BY THE COURT

A. Pending Motions

1. ParkerVision’s Daubert Motion to Exclude Portions of the Expert Reports and Proposed Testimony of Gregory Leonard and Behzad Razavi (Dkt. 285).

2. Qualcomm’s Daubert Motion to Preclude Paul Benoit’s Damages Testimony (Dkt. 288).

3. Qualcomm’s Motion to Phase Trial Proceedings (Dkt. 322).

4. ParkerVision’s Motions in Limine (Dkt. 323).

5. Qualcomm’s Motions in Limine (Dkt. 325).

B. Issues to be Tried to the Bench

The parties agree that the equitable issues of laches and equitable estoppel are issues that

should be tried before the judge and not the jury. The parties propose trying these issues before

the bench at the Court’s convenience during the trial.

In addition, any request for any post-trial remedies, such as an injunction, would be heard

by the Court.

C. Access to Schematic Review Computer During Trial

As provided for in the parties Confidentiality Agreement, ParkerVision requests that the

Court order Qualcomm to provide access to the Source Code Computer for review of

Qualcomm’s schematics under the same conditions and with the same limitations and restrictions

as provided in this section at a site in or near Orlando, Florida beginning one week prior to the

start of trial and continuing through the end of trial.

D. Length of Trial

ParkerVision estimates that the necessary time for trial will be 6 days. ParkerVision

requests 15 hours per side for direct, cross, and rebuttal examination. ParkerVision further


McKool 905908v8 35

requests 45 minutes per side for an opening statement and 45 minutes per side for closing

arguments.

Qualcomm estimates that the necessary time for trial will be 12 days. Qualcomm

requests 25 hours per side for direct, cross, and rebuttal examination.

E. Juror Notebooks

ParkerVision requests that the Court provide the jury notebooks or binders that include a

blank pad for taking notes, a copy of the patents in this case, and a copy of the Court’s claim

constructions. Qualcomm objects to the inclusion of certain exhibits and not others in items

provided to the jurors.

XIX. STIPULATIONS REGARDING TRIAL PROCEDURES

1. The parties will exchange copies of all documentary, graphic, slide, animation, and any other form of Demonstratives they plan to use at trial for use during direct examination or opening—but not for cross-examination—by 7:00 p.m. the night before their intended use. In other words, if a demonstrative will be used on a Wednesday, it must be exchanged or made available by 7:00 p.m. on the previous Tuesday. The parties shall exchange objections to these demonstratives by 9:00 p.m. on the day the exhibits are received. Demonstratives exchanged will not be used by the opposing party prior to being used by the disclosing party.

“Demonstratives” subject to this ¶ 1 do not include (1) exhibits created in the courtroom during testimony or opening at trial, (2) the enlargement, highlighting, ballooning, etc. of trial exhibits or transcripts of testimony, (3) composites of admitted exhibits and/or testimony, so long as the demonstrative includes only portions of the underlying exhibit or testimony, or (4) demonstratives previously displayed in the course of the trial. Reasonable nonsubstantive edits or corrections of typographical and similar errors to demonstrative exhibits may be made to such exhibits prior to use.

Demonstratives subject to this ¶ 1 must be cleared of outstanding objections before being shown to the jury.

Additionally, any transcripts of testimony (excluding testimony given during this trial) that has been previously designated by the parties and cleared of outstanding objections can be shown to the jury during opening, closing or on direct examination. On cross-examination, transcripts of testimony may be used so long as it is not in violation of a motion in limine or other exclusionary order, regardless of whether it was previously designated by the parties.


McKool 905908v8 36

In reaching the agreements contained within this document, the parties are not agreeing to waive any evidentiary objection and expressly reserve the right to make said objections as appropriate.

2. The parties will make available for inspection all non-documentary demonstratives or live product demonstrations, such as physical exhibits, physical prior art or physicalproducts, they plan to use at trial for use during direct examination or opening—but not for cross-examination—by 7:00 p.m. two nights before their intended use. In other words, if a demonstrative will be used on a Wednesday, it must be exchanged or made available by 7:00 p.m. on the previous Monday. The parties shall exchange objections to these non-documentary demonstratives or live product demonstrations by 7:00 p.m. the night before their intended use. Demonstratives and demonstrations exchanged pursuant to this ¶ 2 will not be used by the opposing party prior to being used by the disclosingparty.

3. The parties will exchange lists of exhibits they intend to use during direct examination by 7:00 p.m. the night before their intended use. The parties shall exchange any objections and confidentiality designations to the exhibits by 9:00 pm on the date the lists of exhibits are exchanged.

4. The parties agree to continue to meet and confer to resolve their objections to the other party’s deposition designations and exhibits. The parties agree to endeavor to enter intofurther stipulations and resolve any remaining objections as to the authenticity and use of produced documents following the exchange of exhibit lists and objections.

5. The parties will identify witnesses to be called live (in the order of call) and by deposition at 7:00 p.m., two days in advance of the day of trial during which the witnesses will testify. In other words, if a witness will testify on a Wednesday, the witness must beidentified by 7:00 p.m. on. the previous Monday.

6. For deposition video testimony, the parties will provide a list of any depositiondesignations to be played by 6:00 pm two days before the designation is to be played. Counters and objections to the 6:00 pm designations are due by 9:30 pm the same evening, and any unresolved objections will be raised with the Court the next morning.

7. The parties agree that any exhibit listed on a party’s own exhibit list as to which no objection remains pending at the time of opening statements may be shown to the jury bythat party during opening statements if the exhibit will be the subject of testimony by a witness at trial.

8. The parties will meet and confer regarding demonstratives, exhibits, and deposition objections, as well as any confidentiality designations, by 9:30 pm the night before the objected materials are to be used in Court.


McKool 905908v8 37

9. The parties will work to jointly stipulate on exhibits that may be pre-admitted into evidence by the Court on the first day of trial.

10. All exhibits that are not pre-admitted by the Court must be admitted into evidence before the sponsoring party shows the exhibit to the jury.

11. Each party will provide access to the Source Code Computer under the same conditions and with the same limitations and restrictions as provided in the Confidentiality Agreement at a site in or near Orlando, Florida beginning one week prior to the start of trial and continuing through the end of trial.

12. Provided the Court consents, parties will agree to split the costs of bringing in lunch for the jury each day.

13. Consistent with the Confidentiality Agreement, the party asserting confidentiality with respect to any exhibit, deposition, or demonstrative must notify the Court on the morning that the exhibit, deposition, or demonstrative will be shown to the jury.

14. During the parties’ meet and confer process regarding exhibits and continuing through the end of trial, each party will make a good faith effort to de-designate those exhibits, depositions, and demonstratives that may be shown to the jury without clearing the courtroom.


McKool 905908v8

September 12, 2013

Respectfully submitted,

McKOOL SMITH, P.C.

/s/ Douglas A. Cawley Douglas A. Cawley, Lead Attorney Texas State Bar No. 04035500 E-mail: [email protected] Richard A. Kamprath Texas State Bar No.: 24078767 [email protected] Ivan Wang Texas State Bar No.: 24042679 E-mail: [email protected] McKool Smith P.C. 300 Crescent Court, Suite 1500 Dallas, Texas 75201 Telephone: (214) 978-4000 Telecopier: (214) 978-4044

Kevin L. Burgess Texas State Bar No. 24006927 [email protected] Josh W. Budwin Texas State Bar No. 24050347 [email protected] Leah Buratti Texas State Bar No. 24064897 [email protected] Mario A. Apreotesi Texas State Bar No. 24080772 [email protected] Kevin Kneupper Texas State Bar No. 24050885 [email protected] James Quigley Texas State Bar No. 24075810 [email protected]

McKool Smith P.C. 300 West Sixth Street, Suite 1700 Austin, Texas 78701 Telephone: (512) 692-8700 Telecopier: (512) 692-8744

SMITH HULSEY & BUSEY

/s/ James A. BollingStephen D. Busey James A. Bolling Florida Bar Number 117790 Florida Bar Number 901253 225 Water Street, Suite 1800 Jacksonville, Florida 32202 (904) 359-7700 (904) 359-7708 (facsimile) [email protected]

ATTORNEYS FOR PLAINTIFF PARKERVISION, INC.


McKool 905908v8

CERTIFICATE OF SERVICE

I HEREBY CERTIFY that on this day, September 12, 2013, I served the foregoing on all

counsel of record via ECF.

/s/ Leah Buratti Leah Buratti

LOCAL RULE 3.06 CERTIFICATION

On September 3, 2013 lead counsel for ParkerVision and lead counsel for Qualcomm met

and conferred in person as required by Dkt. 84 and Local Rule 3.06 regarding the issues

addressed in this Pre-Trial Statement, except as the parties have described above.

/s/ Leah Buratti Leah Buratti


ATTACHMENT A-1

(Plaintiff’s Exhibit List)

Case 3:11-cv-00719-RBD-TEM Document 336-1 Filed 09/13/13 Page 1 of 116 PageID 13385

McKool 922227v1


JACKSONVILLE DIVISION PARKERVISION, INC., )

Plaintiff, ) v. Case No. 3:11-cv-719-J-37TEM ) QUALCOMM INCORPORATED, ) Defendant. )

PLAINTIFF’S EXHIBIT LIST

EXHIBIT NO.1

DATE IDENTIFIED

DATE ADMITTED

SPONSORING WITNESSES

OBJECTIONS / STIPULATED ADMISSIONS2

DESCRIPTION OF EXHIBIT

PX 1 Blue Ribbon copy of U.S. Patent 6,061,551, dated 5/9/2000 (PHYSICAL EXHIBIT)




PX 5 Blue Ribbon copy of U.S. Patent 6,963,734 dated 11/08/2005 (PHYSICAL EXHIBIT)

1 Certain exhibit numbers have been intentionally omitted where the Plaintiff agreed to remove an exhibit from its list or converted an exhibit to JX. 2 “A” indicates Stipulated Admission


2 McKool 922227v1

EXHIBIT NO.1

DATE IDENTIFIED

DATE ADMITTED





PX 8 Certified Copy of File History of U.S. Patent 6,266,518, dated 8/18/1999 (PV00008586 – PV00010418)

PX 9 Not Relevant; Prejudicial

Email chain from R. Gilmore to M. Blecker re ParkerVision Update, dated 10/4/1999 (QCPV001389395 – QCPV001389396)



PX 15 Certified Copy of U.S. Patent 6,370,371, dated 4/9/2002 (PV00010419 – PV00010509)

PX 18 Certified Copy of U.S. Patent 7,724,845, dated 05/25/2010 (PV00013567 - PV00013965)

PX 19 Hearsay Alvin E. Roth, Axiomatic Models of Bargaining, SPRINGER-VERLAG, dated 1979 (PV00467732 - PV00467807)

PX 20 Hearsay Amitava Krishna Dutt and Anindya Sen, Union Bargaining Power, Employment, and Output in a Model of Monopolistic Competition with Wage Bargaining, JOURNAL OF ECONOMICS, Vol. 65, No. 1, dated 1997 (PV00468114 - PV00468131)


3 McKool 922227v1

EXHIBIT NO.1

DATE IDENTIFIED

DATE ADMITTED




PX 21 Hearsay Chester C. McGuire, Simulation Modeling in Forensic Economics: The Example of Reasonable Royalty Negotiations, LITIGATION ECONOMICS DIGEST, dated 1999 (PV00468016 - PV00468030)

PX 22 Hearsay Ali M. Niknejad, Lecture 9: Intercept Point, Gain Compression, and Blocking, University of California Notes, available at http://rfic.eecs.berkeley.edu/~niknejad/ee142_fa05lects/pdf/lect9.pdf, dated 2005 (PV00366335 - PV00366366) Learned Treatise - Not For Admission

PX 23 Hearsay A. Frank Adams, III, Peter T. Calcagno, and Budina Naydenova, Patent Royalty Rates: A Look at Recent Court Decisions, dated 2008 (PV00467937 - PV00467952)

PX 24 TriQuint Semiconductor Development Agreement between ParkerVision and TriQuint, dated 3/4/1997 (PV00028394 - PV00028416)

PX 25 Letter from M. Samuelson, Boeing, to J. Parker re Proprietary Information Agreement No. 9-1150-MNS-97-037, dated 11/5/1997 (PV00028381)

PX 26 Proprietary Information Agreement between The Boeing Company and ParkerVision, No. 9-1150-MNS-97-037, dated 11/6/1997 (PV00028382 - PV00028386)

PX 27 Hearsay Press Release - ParkerVision Announces Breakthrough in Wireless Radio Frequency


4 McKool 922227v1

EXHIBIT NO.1

DATE IDENTIFIED

DATE ADMITTED




Technology, dated 12/10/1997 (PV00028373 - PV00028375)

PX 28 Universal Direct Conversion Receiver Evaluation ASIC Contract between ParkerVision and The Boeing Company, dated 1/29/1998 (PV00028417 - PV00028427)

PX 29 Hearsay J. Parker letter to Jeff Jacobs, dated 2/5/1998 (PV00184626 - PV00184629)

PX 30 Hearsay Press Release - Laboratory Tests Verify ParkerVision Wireless Technology, dated 3/3/1998 (PV00028379 - PV00028380)

PX 31 Hearsay; Lack of authenticity; Multiple Documents

Boeing Tests, dated 4/29/1998 (5/10/2013 Sorrells Deposition Ex. 59, (PV00375264 - PV00375280)

PX 32 Hearsay Performance Evaluation Report for the Parker Vision Universal Direct Conversion Receiver, dated 5/1/1998 (5/10/2013 Sorrells Deposition Ex. 58, QSTR00000049 - QSTR00000089)

PX 33 Mutual Non-Disclosure Agreement between Qualcomm and ParkerVision (fully executed), dated 6/9/1998 (PV00184630 - PV00184635)

PX 35 Not relevant; Hearsay

Custom Solutions Business Unit Development and Production Agreement for Custom Silicon Systems (CSS) between ParkerVision and National Semiconductor Corporation, dated 7/16/1998 (PV00028387 - PV00028393)


5 McKool 922227v1

EXHIBIT NO.1

DATE IDENTIFIED

DATE ADMITTED




PX 36 Hearsay Fax from J. Parker to J. Jacobs attaching letter, dated 8/10/1998 (10/25/2012 Jacobs Deposition Ex. 3, PV00184636 - PV00184644)

PX 37 Not relevant; Prejudicial

Email from P. Kantak to J. Jacobs re ParkerVision, dated 8/11/1998 (10/25/2012 Jacobs Deposition Ex. 4, QCPV001389535)

PX 38 Not Relevant; Prejudicial; Hearsay

Letter from S. Silverman to I. Jacobs (QC), dated 8/13/1998 (PV00184645 - PV00184646)


Email chain from V. Gyton to J. Parker re Jeff Jacobs, dated 8/14/1998 (10/25/2012 Jacobs Deposition Ex. 5, PV00184647)


Email chain from P. Kantak to J. Parker re Next Steps in Qualcomm / ParkerVision discussion, dated 8/18/1998 (PV00184648)


Email chain from P. Kantak to J. Parker re ParkerVision Visit, dated 8/19/1998 (PV00184651)


Email from P. Kantak to C. Wheatley re ParkerVision, dated 8/22/1998 (QCPV00138567)


Email to C. Wheatley re ParkerVision, dated 8/22/1998 (11/7/2012 Wheatley Deposition Ex. 1, QCPV001412691)

PX 47 Not relevant; Prejudicial; Hearsay

Email chain from J. Jacobs to J. Parker re Follow-up from Friday, dated 8/25/1998 (10/25/2012 Jacobs Deposition Ex. 7, PV00184652)


Email from P. Kantak to J. Parker re Direct2Data Follow-up, dated 8/25/1998 (QCPV001389572 -


6 McKool 922227v1

EXHIBIT NO.1

DATE IDENTIFIED

DATE ADMITTED




QCPV001389573)


Email from P. Kantak to K. Montalvo, et al. re ParkerVision, dated 8/27/1998 (QCPV001389577)


Email chain from P. Kantak to S. Younis re ParkerVision, dated 8/28/1998 (QCPV001389578)


Email chain from J. Hamilla to J. Parker re Qualcomm phone, dated 9/1/1998 (PV00184659)


Email chain from P. Kantak to J. Parker re ParkerVision visit, dated 9/8/1998 (PV00184660 - PV00184661)


Email from P. Kantak to K. Montalvo, et al. re ParkerVision, dated 9/8/1998 (12/6/2012 Younis Deposition Ex. 1, QCPV001389583 QCAPV001549401)


Email from P. Kantak to J. Parker re Information, dated 9/9/1998 (QCPV001389583)


Email chain from S. Ciccarelli to C. Wheatley, et al. re ParkerVision, dated 9/9/1998 (11/7/2012 Wheatley Deposition Ex. 2, QCPV00157578 - QCPV001575760)


Email chain from C. Wheatley to S. Ciccarelli, et al. re ParkerVision, dated 9/10/1998 (11/7/2012 Wheatley Deposition Ex. 5, QCPV001575749 - QCPV001575751)


Email chain from P. Kantak to J. Parker re Visit Thursday 9/17, dated 9/11/1998 (PV00184662)


7 McKool 922227v1

EXHIBIT NO.1

DATE IDENTIFIED

DATE ADMITTED





Email chain from J. Parker to S. Ciccarelli, et al. re 802.11 Technical Paper, and attachment entitled Technical Overview of an IEEE Hearsay.11 WLAN Receiver Using ParkerVision Direct2Data Architecture, dated 9/12/1998 (QCPV001389587 - QCPV001389601)


Email chain from J. Jacobs to J. Parker re Visit to Qualcomm, dated 9/14/1998 (PV00184663)


Email chain from P. Kantak to J. Parker re Visit Thursday 9/17, dated 9/14/1998 (PV00184664 - PV00184665)


Email chain from P. Kantak to J. Parker re Recap, dated 10/06/1998 (PV00184666)


Email from P. Kantak to S. Younis, et al. re ParkerVision, dated 10/6/1998 (QCPV001389615)


Email chain from P. Kantak to L. Wen, et al. re Resending…ParkerVision, dated 10/7/1998 (QCPV001389618 - QCPV001389619)


Email chain from P. Kantak to L. Wen, et al. re Resending..ParkerVision, dated 10/7/1998 (12/6/2012 Younis Deposition Ex. 3, QCPV001390593 - QCPV00139054)


Email chain between J. Parker and P. Kantak re Update, dated 10/9/1998 (PV00184667)

PX 67 Not relevant; Email from D. Sorrells to S. Younis


8 McKool 922227v1

EXHIBIT NO.1

DATE IDENTIFIED

DATE ADMITTED




Prejudicial; Hearsay

re ParkerVision Visit, dated 10/27/1998 (11/30/2012 Sorrells Deposition Ex. 25, QCPV001549410)


Email chain between J. Parker and P. Kantak re Venture with Microsoft, dated 11/6/1998 (PV00184678)


Email chain from P. Kantak to J. Parker re Phone conversation, dated 11/20/1998 (PV00184681)


Email chain from P. Kantak to I. Jacobs re ParkerVision, dated 11/21/1998 (QCPV001390126 - QCPV001390130)


Email chain between J. Parker and P. Kantak re Further to our conversation yesterday, dated 11/24/1998 (PV00184682 - PV00184683)


Email chain from P. Kantak to S. Younis re D2D Update, dated 12/1/1998 (QCPV001389663)


Email from D. Sorrells to S. Younis re D2D Update, dated 12/1/1998 (12/1/2012 Sorrells Deposition Ex. 27, QCPV001390138)


Email chain from P. Kantak to S. Younis re D2D Update, dated 12/2/1998 (QCPV001413300)


Email chain between J. Parker and P. Kantak re Update on Waiver Request, dated 12/3/1998 (PV00184693 - PV00184694)


Email from P. Kantak to J. Lodenius re ParkerVision update (progress is impressive), dated 12/10/1998


9 McKool 922227v1

EXHIBIT NO.1

DATE IDENTIFIED

DATE ADMITTED




(QCPV001389678)

PX 77 Hearsay Email from D. Sorrells to S. Younis re CMOS D2D IC's, dated 1/11/1999 (12/1/2012 Sorrells Deposition Ex. 28, QCPV001390154 - QCPV001390155)


Email chain from S. Younis to sciccarelli re CMOS D2D IC’s, dated 1/11/1999 (12/6/2012 Younis Deposition Ex. 4, QCPV001549439 - QCPV001549440)


Letter from R. Sterne to R. Miller and J. Parker re Waiver of Conflict, dated 1/12/1999 (PV00184696 - PV00184698)


Email chain from S. Younis to D. Sorrells re CMOS D2D IC’s, dated 1/14/1999 (QCPV001547622 - QCPV001547623)


Email from S. Bazarjani to dschrock, sjha, pkantak, et al. re ParkerVision (from Saed Younis), dated 2/2/1999 (12/6/2012 Younis Deposition Ex. 5)


Email chain between P. Kantaka and jlodenius, et al. re ParkerVision, dated 2/2/1999 (QCPV001389716 - QCPV001389717)


Email chain from P. Kantak to D. Schrock and P. Kantak re ParkerVision, dated 2/2/1999 (QCPV001415313 - QCPV001415315)


Email from D. Schrock to S. Bazarjani re ParkerVision (From Saed Younis), dated 2/2/1999 (QCPV001623209 -


10 McKool 922227v1

EXHIBIT NO.1

DATE IDENTIFIED

DATE ADMITTED




QCPV001623210)


Email from P. Kantak to J. Parker re Next meeting time dated 2/6/1999, with attached Qualcomm CDMA Technologies Strategic Outlook, dated 1/31/1999 (PV00184699 - PV00184727)


Email from P. Kantak to J. Parker, et al. re Qualcomm and ParkerVision, dated 2/4/199 (QCPV001389723)


Email (delete: chain) from S. Younis to F. Antonio re how you are going to accomplish that?, dated 2/3/1999, (12/6/2012 Younis Deposition Ex. 10, QCPV001549446)


Email from D. Schrock to P. Kantak re ParkerVision, dated 2/4/1999 (QCPV001390206)


Email chain from S. Jha to S. Younis re ParkerVision?, dated 2/4/1999 (12/6/2012 Younis Deposition Ex. 6, QCPV001568156)


Email chain from D. Schrock email to I. Jacobs, et al. re Qualcomm and ParkerVision, dated 2/4/1999 (QCPV005526982 - QCPV005526984)


Email from P. Kantak to A. Oberst re Market Research Reports, dated 2/5/1999 (QCPV001389731)


Fax from J. Parker to P. Kantak re extended NDA, dated 2/9/1999 (PV00184736)


Fax from J. Parker to P. Kantak re extended NDA, dated 2/11/999 (PV00184737)


11 McKool 922227v1

EXHIBIT NO.1

DATE IDENTIFIED

DATE ADMITTED





Email chain from R. Sterne to J. Parker, et al. re ParkerVision/Qualcomm NDA, dated 2/12/1999 with attached undated Non-Dislcosure Agreement (PV00184738 - PV00184747)

PX 96 Not relevant; Prejudicial; Hearsay; Illegible

Handwritten notes from Q-Comm meeting, dated 2/16/1999 (12/13/2012 Parker Deposition Ex. 12, PV00184748)


Email chain from P. Kantak to S. Jha, et al. re ParkerVision’s D2D Technology, dated 2/16/1999 (QCPV00138737 - QCPV001389738)


Email chain from S. Jha to P. Kantak, et al. re ParkerVision’s D2D Technology, dated 2/16/1999 (QCPV001390222 - QCPV001390223)


Email chain from P. Kantak to J. Lodenius, et al. re PV, dated 2/22/1999 (QCPV001389742)


Email chain from J. Lodenius to Andy Oberst, et al. re PV, dated 2/22/1999 (QCPV001390226)


Email from P. Kantak to D. Schrock, et al. re Premeeting to ParkerVision Florida Visit, dated 2/23/1999 (QCPV001413370)


Email from A. Oberst to P. Kantak re PV modeling, with attached spreadsheet - WW Digital Terminal Sales Forecast, dated 2/23/1999 (QCPV001564900 - QCPV001564909)

PX 103 Not relevant; Email from P. Kantak to S. Younis,


12 McKool 922227v1

EXHIBIT NO.1

DATE IDENTIFIED

DATE ADMITTED




Prejudicial et al. re PV Meeting, dated 2/25/1999 (QCPV001389753)


Email from S. Ciccarelli to P. Kantak, et al. re Parker Vision report, and attachment entitled D2D_report.doc, dated 2/26/1999 (QCPV001547652 - QCPV001547659)


Email from S. Ciccarelli to C. Wheatley delete the following:, and attachment entitled D2D_report.doc, dated 2/26/1999 (QCPV001570467)


Email from S. Ciccarelli to P. Kantak, et al. re Parker Vision report, and attachment entitled D2D_report.doc, dated 2/26/1999 (QCPV001576040 - QCPV001576047)


ParkerVision Market Analysis from 1999-2003 (QCPV05574533 - QCPV005574534)


ParkerVision Licensing Business Model - P&L from 1999-2003 (QCPV005574535)

PX 109 Hearsay Strategic Alliance with ParkerVision, dated 2/26/1999 (QCPV005574536 - QCPV005574539)


Email chain from C. Wheatley to S. Ciccarelli re ParkerVision report, dated 3/1/1999 (QCPV001555074 - QCPV001555075)

PX 111 Not Relevant; Prejudicial; Hearsay; Illegible

Handwritten notes re Meeting with Johann and Prashant in Jax, dated 3/2/1999 (12/13/2012 Parker Deposition Ex. 13, PV00184771 - PV00184782)


13 McKool 922227v1

EXHIBIT NO.1

DATE IDENTIFIED

DATE ADMITTED




PX 112 Certified Copy of File History of U.S. Patent 6,370,371, dated 3/3/1999 (PV00010510 - PV00012433)

PX 113 Lack of authenticity; Illegible

Handwritten notes re Board Meeting with Qualcomm, dated 3/5/1999 (PV00184795 - PV00184803)


Email from P. Kantak delete: email to J. Lodenius re Meeting Tomorrow, dated 3/5/1999 (QCPV001389759)


Email from S. Jha to C. Wheatley, et al. re pistachio, dated 3/6/1999 (QCPV001564691)


Email chain from S. Bazarjani to steveno re ParkerVision, dated 3/8/1999 (QCPV001568154)


Email from S. Younis to S. Ciccarelli, et al. re ParkerVision, dated 08/21/2001 (QCPV001568166)


Email from S. Jha to C. Wheatley, et al. re pistachio, dated 3/6/1999 (11/7/2012 Wheatley Deposition Ex. 6, QCPV001575767)


Email chain from D. Schrock to S. Jha re pistachio, dated 3/6/1999 (10/25/2012 Jacobs Deposition Ex. 8, QCPV001621654)


Email chain from D. Schrock to S. Jha re pistachio, dated 3/6/1999 (QCPV001623213)


Email from S. Jha to D. Schrock, et al. re pistachio, dated 3/6/1999 (QCPV001623280)


14 McKool 922227v1

EXHIBIT NO.1

DATE IDENTIFIED

DATE ADMITTED





Email from S. Ciccarelli to S. Bazarjani, et al. re ParkerVision, dated 3/8/1999 (QCPV001568155)


Email chain from P. Kantak to S. Jha, et al. re PV, dated 3/10/1999 (QCPV001389773 - QCPV001389775)


Email chain from J. Jacobs to P. Kantak re PV, dated 3/10/1999 (10/25/2012 Jacobs Deposition Ex. 9, QCPV001390255 - QCPV001390256)


Email from P. Kantak to S. Younis re PV WLAN, dated 3/11/1999 (QCPV001389779)


Email from A. Oberst to P. Kantak re PV modeling, and attachment entitled PV modeling2.xls, dated 02/27/1999 (QCPV001564920 - QCPV001564930)


Email from P. Kantak to J. Parker re Names and Titles, dated 3/12/1999 (QCPV001413400)


Email chain from P. Kantak to W. Sailer, et al. re Mutual NDA Q/PV, dated 3/12/1999 (QCPV005443566A – QCPV005443572A)

PX 129 Hearsay Mutual Non-Disclosure Agreement between Qualcomm and ParkerVision, dated 3/15/1999 (12/13/2012 Parker Deposition Ex. 14, PV00184804 - PV00184847)


Appendix B, Individual Confidentiality Agreement between ParkerVision and C. Persico, dated 3/15/1999 (10/23/2012 Persico


15 McKool 922227v1

EXHIBIT NO.1

DATE IDENTIFIED

DATE ADMITTED




Deposition Ex. 9, QCPV005420548 – QCPV005420549)


Handwritten notes re Disclosure meeting, notes by J. Parker, dated 3/16/1999 (12/13/2012 Parker Deposition Ex. 15, PV00184848 – PV00184856)


Memo from J. Parker re March 16, 1999 meeting in Del Mar, California at the L'Auberge Del Mar Hotel with Qualcomm, dated 3/16/1999 (PV00184862 – PV00184863)

PX 133 Not relevant; Prejudicial Hearsay; Multiple Documents; Illegible

Memo from J. Parker re March 16, 1999 meeting in Del Mar, California at the L'Auberge Del Mar Hotel with Qualcomm, dated 3/16/1999, delete: dated 3/16/1999 (12/13/2012 Parker Deposition Ex. 16, PV00184864 – PV00184867)

PX 134 Hearsay; Multiple Documents; Illegible

Who Are We and Why are We Here?, ParvkerVision presentation, dated 3/16/1999 (11/30/2012 Sorrells Deposition Ex. 14, PV00274773)


System Integration Theory and Practice, Direct2Data Architecture, ParkerVision presentation, dated 3/16/1999 (11/7/2012 Wheatley Deposition Ex. 7 and 10/23/2012 Persico Deposition Ex. 4, QCPV005420560 – QCPV005420572)


Utilizing and Configuring D2D - Advantages Made Practical, ParkerVision presentation, dated 3/16/1999 (10/23/2012 Persico Deposition, Ex. 5, QCPV005420628 – QCPV005420644)


16 McKool 922227v1

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DATE IDENTIFIED

DATE ADMITTED





CMOS D2D Circuit Design, ParkerVision presentation, dated 3/16/1999 (10/23/12 Persico Deposition Ex. 6, QCPV005420645 – QCPV005420661)


ParkerVision CMOS D2D Layout, ParkerVision presentation, dated 3/16/1999 (10/23/2012 Persico Deposition Ex. 7, QCPV005420662 – QCPV005420669)

PX 139 Not relevant; Hearsay; Multiple Documents; Illegible

Who Are We and Why are We Here?, ParkerVision presentation, dated 3/16/1999 (10/23/2012 Persico Deposition Ex. 8 and 11/7/2012 Wheatley Deposition Ex. 8, QCPV005420676 – QCPV005420722)

PX 140 Hearsay Utilizing and Configuring D2D - Advantages Made Practical, ParkerVision presentation, dated 3/16/1999 (5/1/2013 Razavi Deposition, Ex. 23, QCPV005529969 – QCPV005529985)


Email cfrom J. Lodenius to D. Schrock re ParkerVision, dated 3/17/1999 (QCPV001623409)


ParkerVision Valuation Analysis document, dated 3/17/1999 (QCPV005574621 – QCPV005574632)


Email chain from P. Kantak to S. Ciccarelli, et al. re D2D Technical evaluation plan, dated 3/18/1999 (QCPV001547436 delete: – QCPV001547436)


Email chain from C. Wheatley to P. Kantakdelete: , sciccarelli, syounis,


17 McKool 922227v1

EXHIBIT NO.1

DATE IDENTIFIED

DATE ADMITTED




et al. re D2D Technical evaluation plan, dated 3/18/1999 (11/7/2012 Wheatley Deposition Ex. 9, QCPV001555076)


Email chain from C. Wheatley to P. Kantak, et al. re D2D Technical evaluation plan, and attachment entitled D2D Evaluation Plan CW1.doc, dated 3/18/1999 (QCPV001620199 – QCPV001620202)


Email from P. Kantak to J. Lodenius re Parker, dated 3/19/1999 (QCPV001547438)


Draft of ParkerVision Valuation Analysis, dated 3/19/1999 (QCPV005574605 – QCPV005574620)


Faxed letter from R. Sterne to P. Kantak re Mutual Non-Disclosure Agreement, dated 3/24/1999 (PV00184875 – PV00184878)


Email from P. Kantak to S. Younis, et al. re PV Information package, dated 3/25/1999 (QCPV001389801)


Email from C. Wheatley to R. Gilmore, et al. re PV, dated 3/26/1999 (11/7/2012 Wheatley Deposition Ex. 15, QCPV001391526)


Email from C. Wheatley to R. Gilmore, et al. re PV, dated 3/26/1999 (11/7/2012 Wheatley Deposition Ex. 11, QCPV001392438)


Email from R. Gilmore to C. Wheatley, et al. re PV, dated


18 McKool 922227v1

EXHIBIT NO.1

DATE IDENTIFIED

DATE ADMITTED




3/26/1999 (QCPV001547709)


Email from C. Wheatley to P. Kantak, et al. re PV, dated 3/26/1999 (QCPV001564972)


Email from S. Younis to C. Wheatley re Oops! Re: PV, dated 3/27/1999 (12/6/2012 Younis Deposition Ex. 9, QCPV005518496)


Email chain from P. Kantak to C. Wheatley re PV, dated 3/29/1999 (11/7/2012 Wheatley Deposition Ex. 17, QCPV001389803)


Email from P. Kantak to R. Gilmore, et al. re D2D Technical Meeting with PV folks postponed, dated 3/29/1999 (QCPV001389804)


Email from S. Jha to R. Gilmore, et al. re PV, dated 3/29/1999 (QCPV001620207)


Email from R. Gilmore to S. Jha re PV, dated 3/29/1999 (QCPV001620206)


D2D Technology Fundamentals, ParkerVision presentation, dated 4/6/1999 (QCPV005529759 – QCPV005529784)


Email from P. Kantak to C. Wheatley, et al. re PV noise averaging, dated 4/9/1999 (QCPV001413427)


Email chain from P. Kantak to J. Parker re Next meeting, dated 4/12/1999 (QCPV001389812 – QCPV001389813)

PX 163 Not relevant; Prejudicial;

Letter from R. Sterne to P. Kantak re Mutual Non-Disclosure Agreement,


19 McKool 922227v1

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DATE IDENTIFIED

DATE ADMITTED




Hearsay dated 4/13/1999 (12/1/2012 Sorrells Deposition Ex. 31, PV00267777 – PV00267779)


Email chain from J. Lodenius to A. Oberst, et al. re PV, dated 4/13/1999 (QCPV001547718)

PX 165 Email from A. Oberst to S. Jha, et al. re PV, dated 4/13/1999 (QCPV001558790)


ParkerVision Valuation Analysis, dated 03/26/1999 (QCPV001564974 – QCPV001564995)


Email from C. Wheatley to R. Gilmore re D2D, dated 4/16/1999 (11/7/2012 Wheatley Deposition Ex. 20, QCPV001555082)


Email from P. Kantak to B. Miller re ParkerVision, dated 4/17/1999 (QCPV001389824)


Email chain from P. Kantak to J. Parker re D2D Information, dated 4/26/1999 (PV00184900 - PV00184901)


Email chain from C. Wheatley to D. Sorrells re D2D Information, dated 4/22/1999 (11/7/2012 Wheatley Deposition Ex. 19, QCPV001412690)


Email from A. Oberst to P. Kantak, et al. re PV model attachment entitled PV modeling4.xls, dated 4/22/1999 (QCPV001564996 – QCPV001565006)


Email from A. Oberst to P. Kantak re PV model and attachment entitled Spreadsheet, dated 4/22/1999 (QCPV001565024 –


20 McKool 922227v1

EXHIBIT NO.1

DATE IDENTIFIED

DATE ADMITTED




QCPV001565040)


Email chain from C. Wheatley to D. Sorrells re D2D information, dated 4/23/1999 (12/1/2012 Sorrells Deposition Ex. 33, QCPV001392442)


Email from P. Kantak to A. Oberst re PV royalty model, dated 4/26/1999 (QCPV001389835)


Email from P. Kantak to J. Parker re Term Sheet, dated 4/30/1999 (QCPV001413450)


Email chain from D. Sorrells to J. Parker re QC and Term Sheet for Qualcomm/ParkerVision Agreement, dated 5/10/1999 (PV00184905 – PV00184908)


Term Sheet regarding proposed agreement between QC and PV, dated 5/3/1999 (PV00184931 – PV00184933)


Email from K. Prashant to dcianflone re template, and attachment entitled PV/QC Terms of Agreement, Strategic Alliance (QCPV001575987 – QCPV001576003)


PV/QC Terms of Agreement Strategic Alliance, dated 5/4/1999 (QCPV00544431A – QCPV00544446A, REDACTED)

PX 180 Not relevant; Prejudicial; Multiple Documents

ParkerVision Info., Qualcomm presentation, dated 5/4/1999 (QCPV005445206A – QCPV005445214A, REDACTED)

PX 181 Not relevant; PV/QC Terms of Agreement Strategic Alliance, dated 5/4/1999


21 McKool 922227v1

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DATE IDENTIFIED

DATE ADMITTED




Prejudicial (QCPV005530079A – QCPV005530103A, REDACTED)




Document/Table “ParkerVision Summary Market Analysis”, dated 5/4/1999 (QCPV005530183 – QCPV005530192)



PX 185 Not relevant; Prejudicial; Illegible


PX 186 Not relevant; Prejudicial; Illegible



Email from P. Kantak to A. Oberst re PV attachment, and attachment entitled PV royaltymodeling.xls, dated 5/5/1999 (QCPV001576086 - QCPV001576155)


Email from P. Kantak to vbeaton re ParkerVision Approval Meeting, dated 5/12/1999 (10/25/2012 Jacobs Deposition Ex. 10, QCPV001389847)


Email chain from J. Jacobs and P. Kantak re ParkerVision Approval Meeting, dated 5/14/1999 (QCPV001547448 – QCPV001547449)


22 McKool 922227v1

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DATE IDENTIFIED

DATE ADMITTED





Email from J. Jacobs to P. Kantak re ParkerVision Approval Meeting, dated 5/14/1999 (QCPV001547725 – QCPV001547726)


Email from P. Kantak to J. Jacobs, et al. re PV -- Royalty, dated 5/15/1999 (QCPV001547450 – QCPV001547451)


Email from P. Kantak to D. Cianfone re FYI RF/IF consolidation article, dated 5/27/1999 (QCPV005443601 – QCPV005443603)


Email from P. Kantak to jjacobs re PV meeting with Tony, dated 5/18/1999 (10/25/2012 Jacobs Deposition Ex. 11, QCPV001389850)


Email from P. Kantak to J. Parker re More Information?, dated 5/18/1999 (QCPV001547452)


Email chain from P. Kantak to jjacobs, et al. re meeting with J. Parker to negotiate royalty issue, dated 5/21/1999 (10/25/2012 Jacobs Deposition Ex. 12, QCPV001389860)


Email from P. Kantak to J. Lodenius re PV, dated 5/21/1999 (QCPV001547459)


Email from P. Kantak to J. Lodenius re Spreadsheet, dated 5/21/1999 (QCPV001547460)


Email from P. Kantak to J. Parker re Docs, and attachment entitled PV Excel 5.xls, dated 5/21/1999 (QCPV001556329 -


23 McKool 922227v1

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DATE IDENTIFIED

DATE ADMITTED




QCPV001556337)


Email chain from J. Jacobs to P. Kantak re “Symbol announcement”, dated 5/22/1999 (10/25/2012 Jacobs Deposition Ex. 13, QCPV001390341)


Email chain from P. Kantak to L. Lupin, et al. re PV Unit Forecast, dated 5/22/1999 (QCPV001547463 – QCPV001547464)


Email chain between P. Kantak and L. Lupin, dated 5/22/1999 (QCPV001556349 – QCPV001556350)


ParkerVision, Excess D2D Value Add Market Analysis, dated 5/24/1999 (5/8/2013 Benoit Deposition Ex. 3, PV00184917 – PV00184923)


Email from J. Lodenius to P. Kantak re Spreadsheet, dated 5/25/1999 (QCPV001547741)


Email from P. Kantak to J. Parker re Meeting Tuesday, dated 5/26/1999, with attached Term Sheet for Qualcomm/ParkVision Agreement (12/13/2012 Parker Deposition Ex. 21, PV00184912 – PV00184916)


Email from P. Kantak to A. Oberst re pistachio: where do we go from here?, dated 5/26/1999 (QCPV001389865)


Email chain from P. Kantak to C. Wheatley, et al. re pistachio: where do we go from here?, dated 5/26/1999 (QCPV005526985A – QCPV005526986A)


24 McKool 922227v1

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DATE IDENTIFIED

DATE ADMITTED





Email chain from P. Kantak to A. Oberst re pistachio: where do we go from here?, dated 5/26/1999 (QCPV010430997A – QCPV010430998A)


Email chain from P. Kantak to A. Oberst re pistachio: where do we go from here?, dated 5/26/1999 (QCPV010430999A)


Email chain from P. Kantak to C. Wheatley, et al. re pistachio: where do we go from here?, dated 5/26/1999 (QCPV010431103A)


Email chain from C. Wheatley to S. Jha, et al. re pistachio: where do we go from here?, dated 5/26/1999 (QCPV011466419)


Email from P. Kantak to J. Jacobs, et al. re ParkerVision update, dated 5/28/1999 (QCPV001389867 – QCPV001389868)


Email from P. Kantak to C. Wheatley re D2D, dated 5/28/1999 (QCPV005443604A – QCPV005443605A, REDACTED)


Email from P. Kantak to C. Wheatley, et al. re D2D, dated 5/28/1999 (QCPV005443939A – QCPV005443940A)


Email from S. Jha to C. Wheatley, et al. re D2D, dated 5/28/1999 (QCPV005443941A – QCPV005443942A)


Email from P. Kantak to W. Sailer re D2D, dated 5/28/1999 (QCPV010431000A)


25 McKool 922227v1

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DATE IDENTIFIED

DATE ADMITTED





Email chain from P. Kantak to J. Lodenius re D2D, dated 5/28/1999 (QCPV010431001A – QCPV010431002A, REDACTED)


Email chain from J. Lodenius to S. Jha, et al. re D2D, dated 5/28/1999 (QCPV010431006A)


Email chain from C. Pieronek to T. Lingren re New Lesson from Packaging Engineering, dated 5/28/1999 (QCPV010431008A – QCPV010431009A)


Email from C. Pieronek to T. Lingren re Lessons Learned Contributors Chosen for Reward & Recognition, dated 5/28/1999 (QCPV010431010A – QCPV010431012A)


Email from C. Wheatley to P. Kantak, et al. re D2D, dated 5/28/1999 (QCPV010431096A)


Email chain from P. Kantak to C. Wheatley, et al. re D2D, dated 5/28/1999 (QCPV010431097A – QCPV010431098A)


Email chain from C. Wheatley to S. Jha, et al. re D2D, dated 5/29/1999 (QCPV01564657A – QCPV01564658A)


Email chain from B. Butler to W. Gardner, et al. re FIR Text, dated 5/29/1999 (QCPV001570458A – QCPV001570460A)


Email from C. Wheatley to S. Jha, et al. re D2D, dated 5/29/1999 (QCPV005443943A – QCPV005443944A)


26 McKool 922227v1

EXHIBIT NO.1

DATE IDENTIFIED

DATE ADMITTED





Email chain from S. Jha to C. Wheatley, et al. re D2D, dated 5/29/1999 (QCPV005620571A – QCPV005620572A)


Email chain from S. Jha to C. Wheatley, et al. re D2D, dated 5/29/1999 (QCPV010430995A – QCPV010430996A)


Email chain from P. Kantak to J. Parker re Meetings for next week, dated 6/2/1999 (QCPV001547479)


Email from P. Kantak to L. Lupin, et al. re PV meeting, Friday 11am, dated 6/4/1999 (QCPV001389869)


Draft letter from J. Parker to P. Kantak re term sheet, dated 6/5/1999 (QCPV001389872 – QCPV001389876)


Draft Term Sheet for Qualcomm/ParkerVision Agreement, dated 6/7/1999 (PV00184934 – PV00184937)


Email chain from C. Wheatley to R. Gilmore, et al. re Direct Conversion, dated 6/16/1999 (QCPV001547782 – QCPV001547783)


Email chain from P. Kantak to J. Burke, et al. re NDA for ParkerVision, dated 6/7/1999 (QCPV001547484)


QC’s ParkerVision Meeting Agenda, dated 6/7/1999 (QCPV005444425)


ParkerVision Meeting Notes, dated 6/8/1999 (QCPV00544426)

PX 237 Not relevant; Qualcomm Table Analyzing Royalty


27 McKool 922227v1

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DATE IDENTIFIED

DATE ADMITTED




Prejudicial to ParkerVision, dated 6/9/1999 (QCPV005530166 – QCPV005530167)


Qualcomm Nonexclusive License Outline, dated 6/10/1999 (PV00184938)


Letter from P. Kantak to J. Parker (with handwritten notes), dated 6/10/1999 (PV00184948 – PV00184963)


Letter from P. Kantak to J. Parker (with handwritten notes), dated 6/10/1999 (12/13/2012 Parker Deposition Ex. 23, PV00184964 – PV00184975)


Email from P. Kantak to J. Parker re PV/QC Proposed Agreement, dated 6/10/1999 (QCPV001389880 – QCPV001389881)


Letter from P. Kantak to J. Parker, dated 6/10/1999 (QCPV001389883 – QCPV001389894)


Email chain from C. Wheatley to R. Gilmore, et al. re Direct Conversion, dated 6/16/1999 (QCPV001558801 – QCPV001558802)


Email chain from S. Jha to B. Judson, et al. re Direct Conversion, dated 6/17/1999 (11/7/2012 Wheatley Deposition Ex. 21, QCPV001555036 – QCPV001555038)


Email chain from B. Judson to C. Wheatley, et al. re Direct Conversion, dated 6/17/1999 (QCPV001558803 – QCPV001558804)


28 McKool 922227v1

EXHIBIT NO.1

DATE IDENTIFIED

DATE ADMITTED





Email chain from D. Schrock to S. Jha re Direct Conversion, dated 6/17/1999 (QCPV001558808 – QCPV001558810)


Email from P. Kantak to B. Judson re PV, dated 6/21/1999 (QCPV005443607)


Email chain from P. Kantak to J. Parker, et al. re Latest Licensing T&C’s and Discussion, dated 6/22/1999 (QCPV011507720)


Email from P. Kantak to pak re PV Technology, dated 6/23/1999 (QCPV001389909)


Email chain from P. Kantak to J. Lodenius, et al. re ParkerVision -- Current Status and New Developments, dated 6/23/1999 (QCPV001391396 – QCPV001391397)


Email chain from P. Kantak to T. Thornley re ParkerVision -- Current Status and New Developments, dated 6/23/1999 (QCPV001413516 – QCPV001413517)


Email chain from T. Thornley to J. Lodenius re UK’s ARM (ISEL:ARM) gets push by Lucent (NYSE:LU) deal, dated 6/23/1999 (QCPV001562125)


Email chain from S. Jha to P. Kantak, et al. re D2D test, dated 6/24/1999 (QCPV001415241)


Email chain from R. Gilmore to T. Lingren, et al. re GSM phones and TTP visit, dated 6/25/1999 (QCPV001554914 –


29 McKool 922227v1

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DATE IDENTIFIED

DATE ADMITTED




QCPV001554915)


Email chain from R. Gilmore to D. Schrock and P. Jacobs re GSM phones and TTP visit, dated 6/25/1999 (QCPV001562168 – QCPV001562169)


Email chain between J. Parker and P. Kantak re D2D, dated 6/29/1999 (PV00184989 – PV00184990)


Email from P. Kantak to seyfi, et al. re ParkerVision Meeting, dated 6/29/1999 (QCPV001389923)


Email chain from C. Wheatley to P. Kantak, et al. re ParkerVision meeting, dated 6/29/1999 (11/7/2012 Wheatley Deposition Ex. 26, QCPV001392432 – QCPV001392433)


Email chain from P. Kantak to B. Judson, et al. re ParkerVision Meeting, dated 6/29/1999 (QCPV001413524)


Email from P. Kantak to S. Jah re ParkerVision Meeting, dated 6/29/1999 (QCPV001413526 – QCPV001413527)


Email chain from P. Kantak to C. Wheatley, et al.re ParkerVision meeting, dated 6/30/1999 (QCPV001547493)


Email chain between J. Parker and P. Kantak re D2D, dated 7/7/1999 (PV00184991 - PV00184992)


Email chain from P. Kantak to T. Thornley re ParkerVision -- Current Status and New Developments, dated 6/30/1999 (QCPV001390431


30 McKool 922227v1

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DATE IDENTIFIED

DATE ADMITTED




– QCPV001390433)

PX 268 Not relevant; Prejudicial; Multiple Documents; Illegible

Parkervision Valuation Analysis, dated 6/30/1999 (QCPV005530128A – QCPV005530144A)


Email chain from P. Kantak to C. Wheatley, et al. re ParkerVision NDA, dated 7/14/1999 (QCPV001547495)


Email chain from S. Jha to P. Kantak, et al. re ParkerVision Update, dated 7/14/1999 (QCPV001391406)


Email chain from S. Bazarjani to P. Kantak, et al. re ParkerVision NDA, dated 7/15/1999 (QCPV001559155 – QCPV001559156)


Email chain from P. Kantak to S. Bazarjani re Test Chip (MIST), dated 7/30/1999 (QCPV001547499)


Email chain from M. Blecker to P. Kantak re unanswered phone calls and stock price interest, dated 8/10/1999 (QCPV001415334 – QCPV001415336)


Email chain from M. Blecker to J. Parker re ParkerVision Update, dated 8/12/1999 (PV00184993 – PV00184996)


Email from P. Kantak to D. Schrock, et al. re ParkerVision Update, dated 7/14/1999 (QCPV001389941)

PX 277 Hearsay; Multiple Documents

ParkerVision Board Meeting, dated 8/16/1999 (PV00430770 – PV00430857)


31 McKool 922227v1

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DATE IDENTIFIED

DATE ADMITTED





Email chain from P. Kantak to S. Altman re Direct Conversion, dated 8/16/1999 (QCPV001547504 – QCPV001547506)


Email chain from P. Kantak to C. Persico re ParkerVision, dated 8/24/1999 (QCPV001389571)


Email from C. Wheatley to M. Blecker, D. Schrock, Lodenius, Gilmore, Lupin, Altman, Jha, and Paul Jacobs re “ParkerVision Possesses No Valuable Technology,” says Asensio, dated 9/28/1999 (QCPV011507722 – QCPV011507723)


Email chain from C. Wheatley to R. Gilmore, et al. re ParkerVision Update, dated 10/5/1999 (QCPV001547810 – QCPV001547812)


Email chain from P. Kantak to sjha, et al. re ParkerVision Update, dated 10/6/1999 (QCPV001415270 – QCPV001415271)


Email chain from D. Schrock to M. Blecker re ParkerVision Update, dated 10/11/1999 (QCPV001390500 – QCPV001390502)


Wireless Technology Pool License Agreement between ParkerVision and Symbol Technologies, dated 10/12/1999 (5/8/2013 Benoit Deposition Ex. 5, PV00185210 – PV00185283)


Email chain from J. Parker to P. Kantak re ParkerVision Update, dated 10/22/1999 (QCPV001390521 – QCPV001390522)


32 McKool 922227v1

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DATE IDENTIFIED

DATE ADMITTED





Email chain from J. Parker to P. Kantak re D2D CDMA Transmitter Demonstration, dated 11/2/1999 (QCPV001390530 – QCPV001390531)


Email chain from C. Wheatley to A. Viterbi re 11/12/99 - Wireless ASIC News, dated 11/13/1999 (QCPV001555069)


Test Report - Direct Conversion CDMA Modulator Based on D2D Technology by G. Rawlins, dated 11/12/1999 (QCPV001558715 – QCPV001558744)


Memorandum from J. Parker to P. Kantak re Preliminary Test Report re Use of ParkerVision's D2D Technology, dated 11/12/1999 and attachment entitled Test Report (QCPV001558851 – QCPV001558883)


Email chain from P. Kantak to C. Wheatley, et al. re ParkerVision Update re: CDMA Zero IF Modulator/Xmitr, dated 12/15/1999 (QCPV001547541 – QCPV001547542)

PX 293 Email from P. Peterzell to C. Persico, et al. re Status of Direct Conversion Prototype Project (12/3/99), dated 12/3/1999 (QCPV005770267)


Memo from J. Parker to P. Kantak attaching Test Report, dated 11/19/1999 (QCPV001389397 – QCPV001389429)

PX 295 Not relevant; Email chain from P. Kantak to C.


33 McKool 922227v1

EXHIBIT NO.1

DATE IDENTIFIED

DATE ADMITTED




Prejudicial; Hearsay

Wheatley, et al. re ParkerVision Update re: ParkerVision Update re: CDMA Zero IF Modulator/Xmitr, dated 11/19/1999 with attached 11/19/1999 memo from J. Parker to P. Kantak and Test Report dated 11/12/1999 (QCPV001547507


Email from P. Kantak to A. Magoffin of QC re ParkerVision, dated 12/30/1999 (QCPV001556272)


Email from P. Kantak to A. Oberst, et al. re Direct down, dated 2/18/2000 (QCPV001414678)


Email chain from A. Oberst to P. Kantak, et al. re Direct down, dated 2/23/2000 (QCPV001390540 – QCPV001390541)


Email chain from J. Lodenius to A. Oberst, et al. re Direct down, dated 2/23/2000 (QCPV001390542 – QCPV001390543)

PX 300 Hearsay Email chain from J. Tran to C. Persico, et al. re ParkerVision Confirms Compatibility of D2D(TM)-Based CDMA Transmitter with PrairieComm’s Baseband Processor, dated 2/28/2000 (QCPV001558920 – QCPV001558922)


Eric Nee, Qualcomm Hits The Big Time Pushing a little-known digital cellular technology from surf's-up San Diego, this $4-billion-a-year hotshot wants to be THE NEXT INTEL, Fortune available athttp://money.cnn.com/magazines/fortune/fortune_archive/2000/05


34 McKool 922227v1

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DATE IDENTIFIED

DATE ADMITTED





Email chain from C. Wheatley to P. Heidmann re ParkerVision, dated 6/6/2000 (QCPV001555070)

PX 303 Not relevant Email chain from P. Peterzell to C. Persico re Agenda for Friday's Meeting with IMJ, dated 6/20/2000 (QCPV005748384)

PX 304 Not relevant Email from P. Peterzell to C. Persico and K. Sahota re Direct Conversion, attaching presentation, Direct Down Conversion using a Gated Switch, dated 6/23/2000 (QCPV001392390 - QCPV001392402)


Email chain from P, Kantak to A. Obsert, et al. re ParkerVision patent award (QC patent knowledge), dated 7/21/2000 (QCPV001389982 – QCPV001389983)


Email from J. Parker to D. Sorrells re: Zac Renner at Nokia, dated 8/6/2000 (PV00229923)


Email chain from S. Bazarjani to D. Schrock, et al. re ParkerVision, dated 2/2/1999 (QCPV001564855 – QCPV001564856)

PX 308 Hearsay Email from P. Heidmann to C. Wheatley re ParkerVision (Direct2Data Presentation Nov. 14), dated 11/18/2000 (QCPV001392444 – QCPV001392445)


Memo from J. Parker to P. Kantak re preliminary test report, dated 11/30/2000 (PV00184997 – PV00184998)


Email from D. Schrock to J. Cunningham re ParkerVision Patent on Direct Conversion, dated


35 McKool 922227v1

EXHIBIT NO.1

DATE IDENTIFIED

DATE ADMITTED




12/19/2000 (QCPV001551285)

PX 311 Hearsay Email from C. Wheatley to R. Blakeney, P. Peterzell, S. Ciccarelli re Qualcomm Bids For Recognition in Direct-Conversion Chip Field, dated 12/21/2000 (QCPV0011507724 – QCPV0011507726)


Email from S. Younis to T. Lingren re ParkerVision meeting, dated 8/21/2001 (QCPV001549437)


Email from S. Younis to S. Ciccarelli re Call to Chuck Wheatley, dated 8/21/2001 (QCPV001568165)


Email from S. Younis to S. Jha re ParkerVision?, dated 8/21/2001 (QCPV001619421)

PX 315 Email chain from S. Younis to P. Peterzell re Status of Direct Conversion Prototype Project (12/3/1999), dated 8/21/2001 (QCPV005589276)

PX 316 Email from R. Padovani to [email protected] forwarding email from W. Xiong to 802.11 group re ParkerVision, dated 10/19/2001 (QCPV001555058)


Janine Sullivan, Direct Conversion Receivers: A Buyer’s Guide, EE Times, http://www.eetimes.com/design/communications-design/4140958/Direct-Conversion-Receivers-A-Buyer-s-Guide/, dated 11/1/2001


Jon Strange & Doug Grant, Direct Conversion: No Pain, No Gain, EE Times,


36 McKool 922227v1

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DATE ADMITTED




http://eetimes.com/electronics-news/4142146/Direct-Conversion-No-Pain-No-Gain, dated 4/2/2002

PX 319 Hearsay Email chain from C. Wheatley to F. Antonio, et al. re Parkervision patent, dated 5/18/2002 (11/7/2012 Wheatley Deposition Ex. 29, QCPV001575706 – QCPV001575707)

PX 320 Qualcomm Announces RTR6250 Multiband UMTS/GSM RF Chip to Enable Worldwide Roaming for UMTS Terminals; http://www.qualcomm.com/media/releases/2002/12/17/qualcomm-announces-rtr6250-multiband-umtsgsm-rf-chip-enable-worldwide, dated 12/17/2002

PX 321 Mutual Non-Disclosure Agreement between ParkerVision and Qualcomm dated 12/19/2002 (PV00184999 – PV00185003)

PX 322 Email chain from S. Bazarjani to S. Cicarelli re RF A/D, dated 5/12/2004 (QCPV001547362)

PX 323 Presentation: “Berkana Analysis”, dated 5/00/2004 (QCPV001626959 – QCPV001626990)


Broadband Business Forecast - Wi-Fi to the Max: ParkerVision Claims One-Mile Wireless Broadband, dated 5/18/2004 (PV00028430 – PV00028431)

PX 325 Test report for Berkana Multi-Band GSM/GPRS Transceiver (Test by T. Chung, T. Huang, D. Chen 6/28/2013), dated 5/23/2004???? (QCPV010718660-1 –


37 McKool 922227v1

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DATE ADMITTED




QCPV010718660-21)

PX 326 Not relevant Email chain from D. Tahmassebi to B. Kim re RF System - Weekly meeting summary, dated 3/12/2004 (QCPV010823325)

PX 327 LNA and mixer design for Firebird quad-band receiver (i.e., Chip-N), dated 8/17/2004 (QCPV005484244 – QCPV005484251)


Putting Oomph into Network Storage, dated 11/15/2004 (PV00028434 – PV00028437)


Just 'crazy enough' Direct2Data Seeks New Efficiencies in Radio Hardware, by Peter Coffee, dated 1/31/2005 (PV00028433)

PX 330 Email chain from P. Kantak to K. Grajski re Public Venture Capital, dated 2/11/2005 (QCPV001549131 – QCPV001549132)

PX 331 Hearsay; Lack of authenticity

Jim Stiles, Noise Figure of Passive Devices, University of Kansas Presentation available at http://www.ittc.ku.edu/~jstiles/622/handouts/Noise%20Figure%20of%20Passive%20Devices.pdf, dated 4/17/2005

PX 332 Email chain from A. Hadjichristos to C. Conroy re 6285 specs -> emailing second HLDR document, dated 1/7/2006, with attached RTR6285 (gzif4) TSMC18RF, Delta-HDLR and packaging review, 80-V4341-12 (QCPV006419875 – QCPV006420015)

PX 333 Meeting appt re: RTR6285 development, includes list of participants, dated 11/03/2005


38 McKool 922227v1

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DATE ADMITTED




(QCPV005690882 - QCPV005690883)

PX 334 Email from K. Sahota to A. Hadjichristos, et al. re rtr6285 1x support, dated 11/11/2005 (QCPV006420221)

PX 336 Not relevant Email chain from A. Hadjichristos to K. Sahota, et al. re Brainstorm on RTR6285 GSM/UMTS RX architecture, and attachment entitled RTR6285 new proposed RX architecture, dated 11/30/2005 (QCPV006429047 - QCPV006429057)

PX 337 Not relevant Email from A. Hadjichristos to C. Persico re Brainstorm on RTR6285 GSM/UMTS RX architecture, and attachment entitled RTR6285 new proposed RX architecture, dated 11/29/2005 (QCPV006429145 - QCPV006429155)

PX 338 Email chain from B. Abdi to B. Keitel, et al. re Bears company discussion 12-15, dated 12/16/2005 (QCPV001623737A - QCPV001623740A)

PX 339 Email from A. Hadjichristos to gzif4_design.mail re paper on passive mixer IM and SP, and attachment entitled RF Distortion Analysis with Compact MOSFET Models, dated 12/23/2005 (QCPV006429132-QCPV006429136)

PX 341 Email from A. See to A. Hadjichristos, et al. re Quad Band UMTS + Diversity/Quad GSM + GPS Ideas, and attachment entitled Quad Band UMTS 1.pdf, dated 01/06/2006 (QCPV011380204 -


39 McKool 922227v1

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DATE ADMITTED




QCPV011380208)

PX 343 Email chain from A. Hadjichristos to S. Lee, et al. re 1-X VCO Questions, dated 01/10/2006 (QCPV011274235 - QCPV011274236)

PX 344 Email from C. Park to J. Yang, et al. re 2G FE presentation material, and attachment entitled 2G Rx Front-end Review, dated 01/12/2006 (QCPV006750194 - QCPV006750219)

PX 345 RTR6285 Design Kickoff Meeting With Berkana 80-V4341-55 Rev. A, dated 01/00/2006 (QCPV006473942 - QCPV006473969)

PX 346 RTR6285 Design Kickoff Meeting With Berkana 80-V4341-55 Rev. A (Annotated), dated 01/00/2006 (QCPV009387399 - QCPV009387563)

PX 347 Email chain from A. Hadjichristos to V. Aparin, et al. re RTR6285 two day Kick off meeting with Campbell team for next Monday/Tuesday, dated 01/10/2006 (QCPV011274345)

PX 348 Not relevant Email from S. Vora to P. Yang, et al. re Alpina VCO Questions, and attachment entitled LO_partition.pdf, dated 01/19/2006 (QCPV011273480 - QCPV011273482)

PX 350 Not relevant Email chain from C. Conroy to A. Hadjichristos re RTR6285 Weekly status and actions, dated 02/02/2006 (QCPV011274935 - QCPV011274936)


40 McKool 922227v1

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DATE ADMITTED




PX 351 Email chain from S. Vora to J. Ko, et al. re floor plan of alpina tx LO path and tuned buffer path, dated 02/03/2006 (QCPV011273441)

PX 352 Email chain from J. Ko to S. Vora, et al. re floor plan for alpina tx LO path and tuned buffer path, dated 02/03/2006 (QCPV011273507 - QCPV011273508)

PX 353 Not relevant Email from C. Conroy to gzif4_design.mail re follow-up from RTR6285 weekly meeting - "automatic" power saving method without incurring extra programming overhead, and attachment entitled automatic_RX_linearity_control.ppt, dated 02/03/2006 (QCPV011273531

PX 354 Not relevant Qualcomm Presentation, "Automatic" RX Bias Control, Depending on TX Output Power, in RF Transceiver That Uses Digital TX AGC, dated 01/2006 (QCPV011273532 - QCPV011273536)

PX 355 Not relevant Email chain from J. Dunworth to A. Krishnaswami re firebird schematics, dated 02/14/2006 (QCPV011273368)

PX 356 Not relevant Email from C. Conroy to A. Hadjichristos, et al. re notes from meeting - you can incorporate into your master summary, dated 02/23/2006 (QCPV011274915)

PX 357 Email chain from A. Hadjichristos to T. Nacita, et al. re Alpina Porting, dated 03/10/2006 (QCPV011274811)


41 McKool 922227v1

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DATE ADMITTED




PX 358 Not relevant Email chain from A. Hadjichristos to S. Weng re Some more RTR6275 mode control info, dated 03/21/2006 (QCPV011277171 - QCPV011277174)

PX 359 Not relevant Email chain from Y. Xu to A. Hadjichristos, et al. re Diversity LO path buffer mixer loading [ESD for RF inputs], dated 03/31/2006 (QCPV011273726 - QCPV011273728)

PX 361 Qualcomm Announces Industry’s First Single-Chip, RF CMOS Transceiver with Integrated Receive Diversity and GPS for CDMA2000 Networks, dated 4/5/2006 (http://www.qualcomm.com/media/releases/2006/04/05/qualcomm-announces-industry-s-first-single-chip-rf-cmos

PX 362 Email chain from C. Conroy to J. Martin-Hutchison re Please Review 4/12/06 RTR6285 Design Weekly Mtg Minutes, and attachment entitled RTR6285_status.xls, dated 04/14/2006 (QCPV011274916 - QCPV011274924)

PX 363 Kevin Wang, RTR 6285 GPS/DRx Baseband Part-I GPS Mode MLDR (Draft), dated 05/09/2006 (QCPV009383385 - QCPV009383545)


Nokia backs away from CDMA: And steps us battle of wills with Qualcomm, The Register, available at http://www.theregister.co.uk/2006/06/30/nokia_qualcomm_battle/, dated 06/30/2006


42 McKool 922227v1

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DATE ADMITTED




PX 366 Not relevant Qualcomm Targets Mass-Market 3G Handsets with Multi-Band, Single-Chip CMOS UMTS Transceiver (http://www.qualcomm.com/media/releases/2007/02/13/qualcomm-targets-mass-market-3g-handsets-multi-band-single-chip-cmos-umts), dated 02/13/2007

PX 367 Qualcomm CDMA Technologies RTR6285 GZIF4 Commercial Sample Readiness Review, dated 06/27/2007 (QCPV009385536 - QCPV009385603)

PX 368 Hearsay ParkerVision d2d Receiver Introduction Presentation, dated 0829/2007 (CONF-PV00204276)

PX 369 Incomplete Kevin Wang design notebook for the RTR6500 (cover only), dated 11/15/2007 (QCPV011119014)


Brand Finance 500 – The Annual Report of the World’s Most Valuable Brands, May 2008 (http://www.brandfinance.com/knowledge_centre/reports/brand-finance-global-500-2008), dated 05/01/2008 (PV00467637 - PV00467676)


General Ledger Report 1/31/1998-12/31/1998, dated 02/10/2009 (05/10/2013 Sorrells Deposition Ex. 48, PV00469397)


Email chain from A. Grant to J. Parker, et al. re ParkerVision IP Comp Group, and attachment entitled MD PatentVest IP Comp Group, dated 03/11/2010 (CONF-PV00265295-CONF-PV00265296)


Email from R. Williams to J. Parker re Luke Research dated 7/21/2010,


43 McKool 922227v1

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DATE ADMITTED




and attachment entitled Barclays Capital, Semiconductors RF Semis: Sustaining Growth, dated 05/24/2010 (CONF-PV00192079-CONV-PV00192080)

PX 376 Qualcomm presentation, The 3G & 4G and Chipset Evolution, dated 10/24/2011 (CONF_PV00254408)

PX 377 Qualcomm presentation, New York Analyst Day, dated 11/16/2011 (CONF_PV00254397)


Qualcomm Chips Fuel Apple's Push Into LTE In 2012, Forbes (http://www.forbes.com/sites/greatspeculations/2011/11/23/qualcomm-chips-fuel-apples-push-into-lte-in-2012/), dated 11/23/2011


Top 50 - Telecom & Communications, dated 03/16/2012 (CONF-PV00254666)

PX 385 Qualcomm's First Supplemental Objections and Responses to ParkerVision's First Set of Interrogatories (Nos. 1-9), dated 06/21/2012

PX 386 Supplemental Exhibit A to Qualcomm's First Supplemental Objections and Responses to ParkerVision's First Set of Interrogatories (Nos. 1-9), dated 06/21/2012

PX 387 Second Supplemental Exhibit B to Qualcomm's First Supplemental Objections and Responses to ParkerVision's First Set of Interrogatories (Nos. 1-9), dated 06/21/2012


44 McKool 922227v1

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DATE ADMITTED




PX 392 Qualcomm, Inc.’s Form 10-K for the year ended September 30, 2012

PX 402 Hearsay Email from K. Shull to J. Canning re ParkerVision v Qualcomm, and attached spreadsheet of products/average price, dated 12/04/2012 (HUAWEI-000001 - HUAWEI-000002)


Joanna Brenner, Pew Internet: Mobile, Highlights of the Pew Internet Project’s Research Related to Mobile Technology (Dec. 4, 2012) dated 6/6/2013 available at http://pewinternet.org/Commentary/2012/February/Pew-Internet-Mobile.aspx, dated 12/04/2012

PX 408 Exhibit E to Qualcomm's Fourth Supplemental Objections and Responses to ParkerVision's First Set of Interrogatories (Nos. 1-9), dated 12/14/2012

PX 409 Hearsay Transcript of December 17, 2012 Motions Hearing, dated 12/17/2012

PX 415 Qualcomm’s Form 10-Q dated 1/30/2013

PX 417 Rule 26 Preliminary PVDC1000 Frequency Downconverter using a d2d™ Technology, dated 05/06/2013 (05/10/2013 Sorrells Deposition Ex. 43, PV00469398 - PV00469408)

PX 418 Rule 26 PVDC1000 D2D™ Frequency Downconverter Test Overview, 05/07/2013 (05/10/2013 Sorrells Deposition Ex. 42, PV00469409 - PV00469431)


Letter from R. Sterne to P. Kantak re Mutual Non-Disclosure Agreement


45 McKool 922227v1

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DATE IDENTIFIED

DATE ADMITTED




dated 4/13/1999, and attachment entitled D2D Technology Fundamentals, ParkerVision Confidential and Proprietary (12/01/2012 Sorrells Deposition Ex. 30, PV00267777 - PV00267836)

PX 421 Hearsay Presentation: Controlled Aperture Sub Harmonic Matched Filter Principles, ParkerVision Confidential and Proprietary (12/01/2012 Sorrells Deposition Ex. 32, PV00267806 - PV00267836)

PX 423 Results of D2D Testing, Technology Group Qualcomm Proprietary (12/06/2012 Younis Deposition Ex. 8, QCPV001547653 - QCPV001547659)

PX 424 Hearsay Dr. Prucnal's Updated Simulations in Response to Dr. Fox's April 5, 2013 Report, dated 05/07/2013 (05/09/2013 Prucnal Deposition Ex. 7)


ParkerVision Product User Testimonials (PV00028438 - PV00028445)

PX 428 Hearsay Gregory Leonard, Economic Approaches to Intellectual Property Damages, dated 00/00/2005 Learned Treatise - Not For Admission

PX 429 Hearsay Email from J. Stuckey to J. Parker re ParkerVision Investor Slides for Discussion, and attachments entitled Grenoble Strategic Investment Slide 2009-01-25-0345.pptx, ParkerVision Investor Presentation 2009-01-26.pptx, dated 01/00/2009 (CONF-PV00192742-CONF-PV00192744)


46 McKool 922227v1

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DATE ADMITTED




PX 430 Qualcomm CDMA Technologies RF Business Review Presentation, dated 02/00/2006 (QCPV006832029 - QCPV006832130)


Long-Distance Wi-Fi 802.11b adapters make dead zones disappear, dated 04/00/2004 (PV00028432)


Ultimate Mobility Wi-Fi Add-Ons - Join the wireless revolution, dated 04/00/2004 (PV00028446)

PX 434 RTR6500 RF Chipset Product Council 2 presentation, dated 04/00/2005 (QCPV011277076 - QCPV011277117)

PX 435 LCU Wedge Chipset Level HLDR, 80-VC067-1 Rev. A, dated 06/30/2006 (QCPV005777828 - QCPV005778083)

PX 437 Qualcomm CDMA Technologies Presentation, dated 06/00/2004 (QCPV005779752 - QCPV005779763)

PX 438 Hearsay Memo from J. Parker to P. Kantak, dated 06/00/1999 (12/13/2012 Parker Deposition Ex. 20, PV00184939 - PV00184943)

PX 439 Qualcomm CDMA Technologies RF Acquisition, dated 09/00/2005 (QCPV001624335 - QCPV001624369)


John Brandon, ParkerVision WR 1500 - The WR1500 can go the distance, if you have time to wait, Laptop Magazine, dated 11/00/2004 (PV00028428 - PV00028429)

PX 441 Spreadsheet - RTR6285 (GZIF4)


47 McKool 922227v1

EXHIBIT NO.1

DATE IDENTIFIED

DATE ADMITTED




Core Team Action Meeting Minutes, dated 06/21/06 (QCPV000614924 - QCPV000614953)


Matt Richtel, Timeline: The Selling of the Cellphone — and Warnings Unheeded, N.Y. Times, Dec. 7, 2009, available at http://www.nytimes.com/interactive/2009/12/07/technology/07distracted-timeline.html

PX 443 Hearsay Spreadsheets - Units, Date, Prod Variant, Revenue (KCI-PRKR_00001 - KCI-PRKR_00006)

PX 444 Hearsay Material or Methods Specification for IC, DSP, QSC6085, BGA, dated 03/31/2009 (MMLLC-ParkerVision000001 - MMLLC-ParkerVision000015)

PX 445 Hearsay Spreadsheet (MMLLC-ParkerVision000016)

PX 446 Hearsay Spreadsheet (MMLLC-ParkerVision000017)

PX 447 Hearsay FY2012 C781 C771 Sales Unit (whole unit), Ex. P, NECAM 000001)

PX 448 Hearsay; Lack of authenticity; Illegible

Handwritten Notes (PV00184857 - PV00184861)

PX 449 Hearsay; Lack of authenticity; Illegible

Handwritten Notes (PV00184868 - PV00184874)

PX 450 Hearsay direct2data, CDMA Rx Chain Prototype Technical Overview, dated 08/08/2013 (PV00266513)


Reviews, ParkerVision SignalMAX WRI500


48 McKool 922227v1

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DATE IDENTIFIED

DATE ADMITTED




Hearsay (http://reviews.cnet.com/routers/parkervision-signalmax-wrl500-wireless/4505-3319 7-31260064.html), dated 01/21/2011 (PV00268234 - PV00268238)


CompUSA Video (PV00268239)

PX 453 Hearsay Apple iPhone 4S A1387 (16 GB) Quad-band GSM + Edge W-CDMA 850/900/1900/2100 MHz + HSDPA/HSUPA CDMA 850/1900 MHz + 1xEvDO Rev. A Report #11000-111024-CDd, dated 2011 (PV00275396)


ParkerVision Receives Prestigious "Provectus" Award at MDB Capital's Bright Lights Conference, dated 05/17/2010 (PV00289612)

PX 455 Hearsay Rolando Menendez, direct2data, CDMA/AMPS Tx/Rx D2D RF/BB Quadrature Converter (PV00359630 - PV00359705)


Confidential Private Placement Document re: ParkerVision, Inc., dated 01/00/2006 (PV00363582)


ParkerVision Press Release - RCS Experience to Sell ParkerVision Signal MAX Wireless Products, dated 11/15/2004 (PV00363704)


Carter Horney, 3LP Cellular Handset & Tablet Core Chip Trends '12 Market Analysis of Baseband, Application Processor, RF & Powre Management Chips, by Forward Concepts, dated 02/00/2012 (PV00367269 - PV00367600)


49 McKool 922227v1

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DATE IDENTIFIED

DATE ADMITTED





Signal Technologies ParkerVision D2D Test Report Document: ST8500-640-002, dated 09/24/1998 (PV00375436 - PV00375466)


ParkerVision Press Release - ParkerVision SignalMax Selected to Provide Wireless Access to St. Augustine Airport Ahead of Superbowl XXXIX Preparation, dated 11/30/2004 (PV00377047 - PV00377049)

PX 461 Not relevant Qualcomm ASIC Products CDMA ASIC Products Data Book, dated 08/00/1998 (PV00398219-PV00398413)


ParkerVision Confirms Compatibility of D2D-Based CDMA Transmitter with PrairieComm's Baseband Processor, dated 02/18/2000 (PV00421016)

PX 463 Not relevant; Hearsay; Lack of authenticity

STA and SEA US Sales of Accused Smartphones, Case 5:11-cv-01846-LHK, Document 1637-6, dated 08/09/2012 (PV00454655)

PX 464 Not relevant; Rule 26

D2D Down Converter Test Report Document: 8500-640-004, dated 12/10/2012 (PV00456818 - PV00456907)


D2D Cell Band Down Converter Document: 8500-640-005, dated 12/18/2012 (PV00456908 - PV00456984)


ParkerVision PatentVest IP Analysis, dated 09/07/2012 (PV00463913 - PV00463943)

PX 467 Hearsay Samsung SGH-F700V GSM/Edge 900/1800/1900 MHz;


50 McKool 922227v1

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DATE IDENTIFIED

DATE ADMITTED




WCDMA/HSDPA 2100 MHz Report #11820-070102-DCf, dated 00/00/2008 (PV00466106 - PV00466262) Learned Treatise - Not For Admission

PX 468 Hearsay Level 3 Chipography Samsung Ultra Edition II SGH-U700 GSM 900, 1800 1900 MHz/WCDMA 2100 MHz + Edge/HSDPA Report #11820-070906-Swe, dated 2007 (PV00466629 - PV00466706)

PX 469 Hearsay Sanyo PM-8200 Dual Band/Tri-Mode CDMA2000 Camera Phone Report #117.03 040628-1c, dated 2004 (PV00466707 - PV00466789)

PX 470 Hearsay LG-TM510 Tri-Mode Phone Report #117-010813-1f, dated 2001 (PV00466790 - PV00466849)


D2D Cell Band Down Converter Document: 8500-640-006, dated 02/01/2013 (PV00466850 - PV00466869)


Addendum to Report, D2D Cell Band Down Converter Test Report, Document: 8500-116-001, version 00.02, dated 01/30/2013 (PV00466870 - PV00466877)

PX 473 Hearsay Sathwant Dosanjh and Abdellatif Bellaouar, Receive diversity helps maximizing throughput in HSDPA networks, dated 07/10/2006 (PV00466911 - PV00466916) Learned Treatise - Not For Admission


S. Ovide, Qualcomm-Atheros: A Shallow History of Deal Making, Wall Street Journal, dated 01/04/2011 (PV00466917 -


51 McKool 922227v1

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DATE IDENTIFIED

DATE ADMITTED




PV00466918)


Citi - Integration & consolidation - The Roadmap for wireless semiconductors, dated 11/29/2007 (PV00466919 - PV00466990)


ParkerVision Request for Quote for IBM 7WL Dual Band cdma2000/1xEv-DO Receiver, dated 02/08/2013 (PV00466991 - PV00467007)


IDC Estimated Mobile Phone Baseband Units (Discrete/Integrated) - USA ONLY, dated 00/00/2013 (PV00467611 - PV00467613)

PX 478 Not relevant; Hearsay; Incomplete; Lack of authenticity

ParkerVision Source Code SOURCE CODE (PVSC0000125)

PX 479 Not relevant; Hearsay; Incomplete; Lack of authenticity; Illegible

ParkerVision Source Code SOURCE CODE (PVSC0000141, PVSC0000143, PVSC0000146, PVSC0000147, PVSC0000148, PVSC0000149, PVSC0000152)

PX 480 Not relevant; Hearsay; Incomplete; Lack of authenticity; Illegible

ParkerVision Source Code SOURCE CODE (PVSC0000155)

PX 483 RTR6285 (gzif4) TSMC18RF Delta-HDLR and Packaging Review 80-V4341-12 Rev. B, dated 04/00/2007 (03/25/2013 Suppl Ex. D.6, QCPV000002693 - QCPV000002832)

PX 487 QSC6240/QSC6270 Qualcomm Single Chip Device Specification 80-VF846-1 Rev. M, dated


52 McKool 922227v1

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DATE IDENTIFIED

DATE ADMITTED




10/18/2011 (Ex. 6 to PV's Resp to QC's MPSJ, QCPV000033179 - QCPV000033425)

PX 494 WCN2243 System on Chip (SoC) User Guide 80-WL024-3 Rev. B, dated 02/07/2011 (QCPV000148837 - QCPV000148894)

PX 496 WCN1312 Single Chip WLAN Solution User Guide 80-WL100-3 Rev. B dated 3/12/2010 (QCPV000149188 - QCPV000149240)

PX 499 QTR8600L Qualcomm Transceiver Device Specification 80-N0086-1 Rev. F dated 11/02/2011 (QCPV000162777 - QCPV000162887)

PX 504 RTR6237/RTR6236 RF Transceiver IC User Guide 80-VF879-3 Rev. B dated 07/11/2008 (QCPV000189375 - QCPV000189415)

PX 505 RGR6240 GPS RF Receiver IC Device Specification 80-VH703-1 Rev. E dated 02/18/2011 (QCPV000190181 - QCPV000190211)

PX 506 RGR6240 GPS RF Receiver IC User Guide 80-VH703-3 Rev. C dated 5/26/2009 (QCPV000190225 - QCPV000190249)

PX 507 MSM7x30 Chipset Training QTR8x0x Wireless Connectivity and Analog (BT/FM/Audio/TSADC) dated 03/00/2010 (QCPV000190446 - QCPV000190538)

PX 511 RTR8600/RTR8601 Device Specification 80-VP147-1 Rev. N


53 McKool 922227v1

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DATE IDENTIFIED

DATE ADMITTED




dated 03/19/2012 (QCPV000197483 - QCPV000197590)

PX 513 QTR8600/QTR8200 QCT Development Gate (PC-2)/Plan of Record (PoR) Review PC80-VK454-12 Rev. A dated 10/13/2008 (QCPV000215622 - QCPV000215664)

PX 514 RTR8600/RTR8700 QCT Planning Gate (PC-1) Review PC80-VN380-11 Rev. A dated 12/19/2008 (QCPV000215718 - QCPV000215794)

PX 516 Final Transcript - Thomson StreetEvents - QCOM-Q2 2004 Qualcomm Earnings Conference Call dated 04/21/2004 (QCPV000241412 - QCPV000241428)

PX 517 Final Transcript - Thomson StreetEvents - QCOM-Q2 2005 Qualcomm Earnings Conference Call dated 04/20/2005 (QCPV000241475 - QCPV000241492)

PX 518 Final Transcript - Thomson StreetEvents QCOM-Q3 2010 Qualcomm Earnings Conference Call dated 07/21/2010 (QCPV000241872 - QCPV000241491)

PX 519 Final Transcript - Thomson StreetEvents QCOM-Q4 2010 Qualcomm Inc. Earnings Conference Call dated 11/03/2010 (QCPV000241892 - QCPV000241910)

PX 520 Final Transcript - Thomson StreetEvents QCOM-Q1 2011


54 McKool 922227v1

EXHIBIT NO.1

DATE IDENTIFIED

DATE ADMITTED




Qualcomm Earnings Conference Call dated 01/26/2011 (QCPV000241911 - QCPV000241930)

PX 521 File History of US Patent 6,061,551 - Information Disclosure Statement Gordy initialed and considered by Examiner S. Bhattacharya on 08/01/1999 dated 10/21/1998 (QCPV000249992 - QCPV000251133)

PX 522 Not relevant 13289 v4.6 Delta Compliance for MDM6200 ASIC 80-N1086-7 A dated 10/27/2011 (QCPV000350571 - QCPV000350583)

PX 523 MDM6270 Mobile Data Modem Device Specification 80-N1636-1 Rev. C dated 02/25/2010 (QCPV000350890 - QCPV000351086)

PX 526 MBP1610 Mobile Broadcast Platform Device Specification 80-VE044-1 Rev. E dated 09/26/2008 (QCPV000368831 - QCPV000368883)

PX 528 MXC6369 Transceiver Multichip Module Device Specification 80-VF871-1 Rev. C dated 08/25/2008 (QCPV000377259 - QCPV000377314)

PX 530 MBP2600 Mobile Broadcast Platform User Guide 80-VJ231-3 Rev. D dated 12/22/2009 (QCPV000379286 - QCPV000379328)

PX 533 Not relevant MDM6085 Qualcomm Mobile Data Modem Device Specification 80-VL174-1 Rev. F dated 02/25/2011 (QCPV000382017 -


55 McKool 922227v1

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DATE IDENTIFIED

DATE ADMITTED




QCPV000382209)

PX 534 Not relevant MDM6200 and MDM660 Mobile Data Modem Device Specification 80-VR001-1 Rev. J dated 8/4/2011 (QCPV000403262 - QCPV000403416)

PX 536 Not relevant Bond Pad Coordinates and Pin Map, RFR6525/Firebird, 8x8, 56QFN, FSL dated 2004-2005 (QCPV000415836 - QCPV000415841)

PX 542 QSC61x5, QSC6295, and QSC6695 Qualcomm Single Chip User Guide 80-VP447-3 Rev. F dated 04/06/2011 (QCPV000495031 - QCPV000495299)

PX 543 T-Mobile Mobile Terminal Requirements (MTR) for QSC6270 (Q4 2008) dated 09/17/2009 (QCPV000499619 - QCPV000502608)

PX 544 Hearsay RF Filters, PAs, Antenna Switches and Tunability for Cellular Handsets dated 2012 (QCPV000567667 - QCPV000567992) Learned Treatise - Not For Admission

PX 545 RAMSIS HLDR dated 02/03/2006 (QCPV000613577 - QCPV000613824)

PX 546 RTR6285 (GZIF4) Core Team Meeting Minutes dated 07/12/2006 (QCPV000615075 - QCPV000615105)

PX 547 RTR6285 (GZIF4) Core Team Meeting Minutes dated 07/12/2006 (QCPV000615106 -


56 McKool 922227v1

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DATE IDENTIFIED

DATE ADMITTED




QCPV000615138)

PX 548 RTR6285 (gzif4) TSMC18RF Delta-HDLR and packaging review 80-V4341-12 dated 11/03/2005 (QCPV000616642 - QCPV000616780)

PX 549 Hearsay Handset RF Front Ends MMPAs, Antenna Tuning, Envelope Tracking, FEMs dated May 2012 (QCPV001323065 - QCPV001323214) Learned Treatise - Not For Admission

PX 552 BTS4050 System-in-Package (SiP) Device Specification 80-VE403-1 Rev. G dated 08/17/2009 (QCPV001382430 - QCPV001382476)

PX 553 BTS4020BD Device Specification 80-VF681-1 Rev. E dated 09/17/2009 (QCPV001383102 - QCPV001383160)

PX 554 BTS4052 System-in-Package (SiP) Device Specification 80-VF138-1 Rev. F dated 09/11/2009 (QCPV001384868 - QCPV001384910)

PX 556 BTS4054 System-in-Package (SiP) User Guide 80-VG139-3 Rev. A dated 06/03/2009 (QCPV001385034 - QCPV001385089)

PX 558 BTS4025 Bluetooth System-on-Chip (SoC) User Guide 80-VH397-3 Rev. B dated 06/29/2010 (QCPV001386650 - QCPV001386700)

PX 559 BTS4051 System-in-Package (SiP) Device Specification 80-VH451-1


57 McKool 922227v1

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DATE IDENTIFIED

DATE ADMITTED




Rev. F dated 08/18/2009 (QCPV001386988 - QCPV001387028)

PX 561 BTS5045 System-in-Package (SiP) User Guide 80-VJ120-3 Rev. B dated 04/15/2009 (QCPV001387631 - QCPV001387677)

PX 562 Email from P. Kantak to Seyfi, et al. re ParkerVision Meeting dated 06/29/1999 (04/05/2013 Prucnal Reb. Rpt. FN 157, QCPV001392371)

PX 563 Email chain from C. Wheatley to P. Kantak, et al. re ParkerVision Meeting dated 06/29/1999 (QCPV001392374 - QCPV001392375)

PX 564 Regulatory Configuration for Qualcomm Atheros WLAN Station Reference 9.x Software Support Bulletin dated 07/23/2012 (QCPV001438432 - QCPV001438458)

PX 565 Prejudicial Email from G. McCall to S. Ciccarelli, et al. re RF A/D dated 05/12/2004 (QCPV001547361)

PX 566 Email chain between D. Schrock and J. Lodenius re ParkerVision update dated 12/10/1998 (QCPV001547620 - QCPV001547621)

PX 568 Hearsay IDC Market Analysis Worldwide Mobile Phone Semiconductor 2004-2008 Forecast and Analysis by A. Leibovitch dated 03/00/2004 (QCPV001553531 - QCPV001553567) Learned Treatise - Not For Admission


58 McKool 922227v1

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DATE IDENTIFIED

DATE ADMITTED




PX 569 Hearsay Technology Assessment - Direct Conversion Architectures Speed the March to Single-Chip Radio by A. Leibovitch and K. Furer dated 01/00/2003 (QCPV001554180 - QCPV001554199)

PX 570 Email chain from R. Gilmore to P. Peterzell re Direct Conversion dated 06/16/1999 (QCPV001554916 - QCPV001554917)

PX 571 Email chain from P. Kantak to J. Parker re Term Sheet dated 04/30/1999 (QCPV001556316)

PX 572 Draft Term Sheet for Qualcomm/ParkerVision Agreement (QCPV001556317 - QCPV001556320)

PX 573 Email chain between L. Lupin and P. Kantak, et al. re ParkerVision Royalty dated 05/21/1999 (QCPV001562166 - QCPV001562167)


Email from D. Cianfione to A. Oberst attaching the Latest PV Model dated 03/19/1999 (QCPV001563556 - QCPV001563598)

PX 575 Email from P. Kantak to G. Lombardi requesting help dated 08/26/1998 (QCPV001564745)

PX 576 Email chain from P. Kantak to S. Degraw re help dated 08/26/1998 (QCPV001564746)

PX 577 Spreadsheet: Top 50 Material Cost for Q4, QCP-820 PN 65-56088-X undated (QCPV001564776 - QCPV001564799)


59 McKool 922227v1

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DATE IDENTIFIED

DATE ADMITTED




PX 578 Spreadsheet: Top 50 Material Cost for QCP-1920 MCN 65-66014-2 undated (QCPV001564800 - QCPV001564853)


Email from A. Oberst to pkantak regarding PV model and attaching spreadsheet entitled ParkerVision WW Digital Terminal Sales Forecast dated 02/24/1999 (QCPV001564910 - QCPV001564919)

PX 580 ParkerVision WW Digital Terminal Sales Forecast dated 1999-2002 (QCPV001565008 - QCPV001565023)

PX 582 Not relevant; Prejudicial; Multiple Documents

Email from A.Oberst to jking and pkantak regarding PV modeling 6 and attachment entitled ParkerVision WW Digital Terminal Sales Forecast dated 04/23/1999 (Exhibit N, QCPV001565041 - QCPV001565057)

PX 583 Email chain from C. Wheatley to S. Ciccarelli, et al. re ParkerVision dated 09/10/1998 (QCPV001568142 - QCPV001568149)

PX 584 Hearsay Email chain from F. Antonio to K. Leing, et al. re ParkerVision Patent dated 05/17/2002 (QCPV001575708 - QCPV001575709)


Email from P. Kantak to aoberst attaching ParkerVision Summary Control Variables/Assumption dated 05/05/1999 (QCPV001576086 - QCPV001576155)

PX 587 Hearsay Verizon Wireless Device Requirements for Global Devices dated 09/00/2010 (QCPV001577981 - QCPV001578149)


60 McKool 922227v1

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DATE IDENTIFIED

DATE ADMITTED




PX 588 Email from K. Montalvo to S. Younis and S. Ciccarelli re D2D dated 09/10/1998 (QCPV001619406)

PX 589 D2D Technical Evaluation Plan (Redlined Version) undated (QCPV001620196 - QCPV001620198)

PX 590 D2D Technical Evaluation Plan (Redlined Version) undated (QCPV001620200 - QCPV001620202)

PX 591 Hearsay Forward Concepts report entitled Cellular Handset Chip Markets '10 dated 11/00/2010 (QCPV001625614 - QCPV001626179) Learned Treatise - Not For Admission

PX 592 Hearsay Techinsights Report #11000-111024-CDd entitled Apple iPhone 4S A1387 (16 GB) dated 2011 (QCPV001627526 - QCPV001627718) Learned Treatise - Not For Admission

PX 593 Hearsay Techinsights Apple iPhone 4S A1387: Quick Turn Teardown Version 1 dated 10/14/2011 (QCPV001628184 - QCPV001628230) Learned Treatise - Not For Admission

PX 594 Hearsay ResearchInChina Global Mobile Phone Platform (Baseband) Industry Report, 2007-2008 dated 03/2008 (QCPV001631583 - QCPV001631768) Learned Treatise - Not For Admission


61 McKool 922227v1

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DATE IDENTIFIED

DATE ADMITTED




PX 595 Hearsay ABI Research Report entitled Mobile Devices Annual Market Overview (QCPV001635672 - QCPV001635759) Learned Treatise - Not For Admission

PX 596 Qualcomm RGR 1000/RGR1100 RF Transceiver IC Device Specification 80-VG519-1 Rev. A dated 10/18/2007 (QCPV001658528 - QCPV001658582)


Presentation: Qualcomm CDMA Technologies LG/MOT PRC Meeting dated 04/25/2006 (QCPV001850898 - QCPV001850921)


Presentation: 7600 Chipset Proposal to RIM (Verizon/Vodafone) undated (QCPV002162091 - QCPV002162099)

PX 599 Presentation: Investigation of Passive Mixer Performance with Degeneration by A. Tasic, J. Deng, undated (QCPV003107308 - QCPV003107349)

PX 601 Presentation: Atheros Bluetooth RF basic, undated (QCPV005324525 - QCPV005324565)

PX 602 Hearsay IDC Market Analysis Worldwide Moble Phone Connectivity Chipset 2008-2012 Forecast and Analysis dated 02/00/2008 (QCPV005360640 - QCPV005360676) Learned Treatise - Not For Admission

PX 603 Qualcomm Presentation: RFR6135/6250 High-Band Receiver ASIC High Level Design Review


62 McKool 922227v1

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DATE IDENTIFIED

DATE ADMITTED




dated 03/25/2003 (QCPV005416600 - QCPV005416733)

PX 605 Qualcomm CDMA Technologies Dr. Zoidberg (RFR 6125) dated 03/13/2002 (QCPV005439403 - QCPV005439481)

PX 606 Spreadsheet: ParkerVision Summary Control Variables/Assumptions (QCPV005444464 - QCPV005444539)

PX 607 ASP Tables undated (QCPV005444540 - QCPV005444621)

PX 608 Spreadsheet: QC Revenue Forecast with PV Content 2001-2005 undated (QCPV005444905-QCPV005444971)

PX 609 Not relevant Email chain from P. Gudem to S. Ciccarelli, et al. re jammer detector in Napoleon and beyond dated 02/07/2007 (QCPV005449213 - QCPV005449214)

PX 610 Email chain from T. Pals to P. Gaal, et al. re FCC Part 15 Requirement dated 11/28/2005 (QCPV005519295 - QCPV005519299)

PX 612 Hearsay Appendix - Summary of Additional ParkerVision Proprietary and Confidential Information Disclosed to Qualcomm During the Meeting on April 6, 1999 (QCPV005529758)

PX 613 Hearsay Direct2Data Architecture - Controlled Aperture Sub Harmonic Matched Filter Principles (QCPV005529785 - QCPV005529810)


63 McKool 922227v1

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DATE IDENTIFIED

DATE ADMITTED




PX 614 Hearsay Time Sifting, Time Sifting for an Impulse Sample, undated (QCPV005529811)

PX 615 Hearsay Diagrams: Samples Obtained from Phase Shifted Input Signals, Obtained by Correlating Over Ta Interval (QCPV005529812 - QCPV005529815)

PX 616 Hearsay R. Sterne Letter P. Kantak re Mutual Non-Disclosure Agreement dated 3/24/1999 (QCPV005529817 - QCPV005529819)


Who Are We and Why are We Here dated 3/16/1999 (QCPV005529823 - QCPV005529869

PX 618 Hearsay Direct2Data Architecture - System Integration Theory and Practice dated 3/16/1999 (QCPV005529870 - QCPV005529937)

PX 621 Hearsay Presentation: Technical Presentation of the ParkerVision Direct2Data Architecture dated 1998 (QCPV005574556-QCPV005574572)

PX 623 Email from S. Ciccarelli to D. Fillipovic re Jammer Detector Summary for SC2x dated 12/15/2005 (QCPV005592731)

PX 624 Email chain from S. Ciccarelli to P. Gudem re Quick note on inductor option and Tx notch filter dated 04/06/2007 (QCPV005593189)

PX 625 Email chain from S. Ciccarelli to S. Verma, et al. re A few questions on LCU RF dated 06/29/2007


64 McKool 922227v1

EXHIBIT NO.1

DATE IDENTIFIED

DATE ADMITTED




(QCPV005593208 - QCPV005593210)

PX 626 Email chain from S. Ciccarelli to S. Kwok re Lightning mixer NF with and without 1/f noise contribution dated 09/12/2006 (QCPV005593651 - QCPV005593652)

PX 627 Hearsay Forward Concepts - Qualcomm Cellular Handset & Chip Markets '07: An In-Depth Analysis of Cellphones and Chips dated 06/00/2007 (QCPV005599889 - QCPV005600307) Learned Treatise - Not For Admission

PX 628 Hearsay Forward Concepts - Qualcomm Cellular Handset & Chip Markets '08: An In-Depth Analysis of Cellphones and Chips dated 05/00/2008 (QCPV005600308 - QCPV005600906)

PX 629 Presentation: Qualcomm CDMA Technologies radioOne Update dated 01/00/2002 (QCPV005630194 - QCPV005630255)

PX 630 Not relevant Email from A. Mimran to A. Wong re Emerald detailed design review and attaching C625Telephone Adapter LLDR December- 2003 dated 12/18/2003 (QCPV005632635-QCPV005632868)

PX 631 Not relevant; Prejudicial; Hearsay; Multiple Documents

Press Release: ParkerVision Receives Patent for its Core D2D Transmitter Technology dated 07/18/2000 (QCPV005736941 - QCPV005736944)

PX 632 Presentation: Direct Downconversion Architectures (9th


65 McKool 922227v1

EXHIBIT NO.1

DATE IDENTIFIED

DATE ADMITTED




Meeting) dated 10/07/1999 (QCPV005748415 - QCPV005748445)


Technical Overview of an IEEE 802.11 WLAN Receiver Using ParkerVision Direct2Data Architecture dated 00/00/1998 (QCPV005772374 - QCPV005772388)

PX 634 Email chain between X. Wang and [email protected] re Suggestions for LNA/Mixer Design and attaching LNA+Mixer PowerPoint, dated 07/08/2005 (QCPV005774243 - QCPV005774245)

PX 635 Presentation: Low Cost 1x MSM Study Update dated 07/00/2004 (QCPV005779725 - QCPV005779751)

PX 636 Presentation: Direct Downconversion Project dated 12/16/1999 (QCPV005781528 - QCPV005781535)

PX 637 Presentation: RFR6500 (RX Diversity/S-GPS) Product Review dated 10/06/2003 (QCPV005823237 - QCPV005823286)

PX 638 Email from S. Jha to K. Sahota, et al. re RTR6275 Update dated 07/15/2005 (QCPV005910109)

PX 639 Email chain from S. Bazarjani and K. Sahota, et al. re Mixed-Signal Design dated 10/11/2006 (QCPV005982855 - QCPV005982856)

PX 640 Not relevant Qualcomm Chipset Architecture Specification dated 10/20/2009 (QCPV006105203 -


66 McKool 922227v1

EXHIBIT NO.1

DATE IDENTIFIED

DATE ADMITTED




QCPV006105426)

PX 641 Hearsay Forward Concepts report "Global Cellular Handset & Chip Markets: An In-Depth Analysis of Cellphones, Chips, ODMs, OEMs, Cellular Operators & Subscribers" dated 04/00/2005 (QCPV006153355 - QCPV006153746) Learned Treatise - Not For Admission

PX 642 Qualcomm presentation: RTR6280 (gzif4) High Level Design Review 80-V4341-11 dated 06/11/2005 (QCPV006214968 - QCPV006215228)

PX 643 Qualcomm presentation: RTR6285 (gzif4) TSMC18RF Delta-HDLR and packing review 80-V4341-12, dated 10/00/2005 (QCPV006419877 - QCPV006420015)

PX 644 Email from J. Martin-Hutchison to gzif4_design.mail re 02/02/2006 RTR6285 Design Weekly Meeting Minutes dated 02/15/2006 (QCPV006499812 - QCPV006499814)


Goldman Sachs article: Handset Market Share Wars: Battle for Chipset Dominance, dated 05/26/2009 (QCPV006563611 - QCPV006563656)

PX 646 Email from S. Bazarjani to L. Mathe, et al. re RAMSIS HLDR Slides dated 01/16/2006 (QCPV007136945 - QCPV007136946)

PX 647 Hearsay; Incomplete

The Linley Group - Excerpts from A Guide to 3G/4G Wireless Chips 5th Edition dated 09/00/2010


67 McKool 922227v1

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DATE IDENTIFIED

DATE ADMITTED




(QCPV000149188, QCPV007398197; QCPV007398253 and QCPV007398312)

PX 648 Qualcomm PRC Executive Summary undated (QCPV007521686 - QCPV007521823)

PX 649 Not relevant Failure Analysis Lab Monthly Status Report, dated 12/00/2004 (QCPV007688789 - QCPV007688802)

PX 650 80-V4341-23 Rev. A - RTR6285 GSM RX BB PGA - LPF Filter, dated 4/11/2006 (QCPV009383962 - QCPV009384036)

PX 651 Presentation: RF Roadmap for Nokia, dated 9/00/2009 (QCPV009533811 - QCPV009533865)

PX 652 Qualcomm Presentation: Astra (RGR6240) Product Council 2, dated 6/28/2007 (QCPV009548561 - QCPV009548604)

PX 653 Qualcomm Presentation: Redefining Mobility, RF Front-End Market Outlook, dated 00/00/2000 (QCPV009561653 - QCPV009561688)

PX 654 Qualcomm Presentation: QCT RF Front End Products Overview, dated 3/00/2012 (QCPV009577358 - QCPV009577400)

PX 655 Qualcomm Presentation: RF Competitive Landscape, dated 01/00/2012 undated (QCPV009582834 -


68 McKool 922227v1

EXHIBIT NO.1

DATE IDENTIFIED

DATE ADMITTED




QCPV009582868)

PX 656 Qualcomm Presentation: QCT RF Multi-Chip Module MXC6369, dated 6/00/2007 (QCPV009593096 - QCPV009593119)

PX 657 Presentation: ASP Pressure, undated (QCPV009593666 - QCPV009593675)

PX 658 Hearsay; Incomplete

Excerpts of Future Mobile Handsets 10th Edition (pgs 1, 360-367), dated 00/00/2008, (QCPV009601598, QCPV009601973-QCPV009601982)

PX 659 Qualcomm CDMA Technologies Presentation: MXC6369 Product Review, dated 02/00/2008 (QCPV009618818 - QCPV009618833)

PX 660 Qualcomm Presentation: Maverick RFP - 2013/2014 Product Proposal, dated 08/08/2011 (QCPV009643978 - QCPV009644063)

PX 661 Qualcomm Presentation: Maverick - Eureka Future MDM - Requirements Discussion, dated 08/00/2009 (QCPV009772420 - QCPV009772491)

PX 662 Qualcomm CDMA Technologies Presentation: Motorola/QCT RF Review NDA Based Customer Only, dated 06/00/2008 (QCPV009993668 - QCPV009993713)

PX 663 Qualcomm CDMA Technologies Presentation: QCT RF Product & Technology Discussion - QCT RF Engineering & Product Marketing, dated 4/00/2006 (QCPV010071027 -


69 McKool 922227v1

EXHIBIT NO.1

DATE IDENTIFIED

DATE ADMITTED




QCPV010071170)

PX 664 QTR/RTR8x00 Overview, dated 3/00/2009 (QCPV010105136 - QCPV010105164)

PX 665 Qualcomm Presentation: Q it up!, undated (QCPV010123097 - QCPV010123260)

PX 666 Qualcomm Presentation: RF Products Operations Metrics Review, dated 11/00/2009 (QCPV010389952 - QCPV010390004)

PX 669 IC, IFR 3000, CDMA Baseband Analog ASIC3 Receive ATMEL, dated 02/04/2004 (QCPV010490176 - QCPV10490214)

PX 670 Hearsay Strategy Analytics Report: Baseband Processor Profile: Qualcomm's Unassailable Lead, dated 8/00/2009 (QCPV010501928 - QCPV010501959) Learned Treatise - Not For Admission

PX 671 Qualcomm CDMA Technologies RTR6500 Transceiver with Rx Diversity, dated 07/00/2006 (QCPV010524673 - QCPV010524700)

PX 672 Qualcomm Marketing Presentation: RTR6500 Transceiver with Rx Diversity, undated (QCPV010524704 - QCPV010524728)

PX 673 RFR6122 CMOS RF Receiver IC Device Specification 80-V7585-1 Rev. G, dated 02/22/2010 (QCPV010552565 -


70 McKool 922227v1

EXHIBIT NO.1

DATE IDENTIFIED

DATE ADMITTED




QCPV010552596)

PX 674 RFR6170 RF Receiver IC Device Specification 80-V8834-1 Rev. F, dated 03/05/2010 (QCPV010558835 - QCPV010558867)

PX 675 radioOne Platform D (Rx Diversity) Chipset Design Guidelines 80-VB321-1 Rev. A, dated 06/07/2006 (QCPV010563787 - QCPV010563894)

PX 676 Incomplete; Not relevant; Hearsay

Cingular Wireless UMTS Terminal Feature by Tier Requirements, dated 04/16/2004 (QCPV010784593)

PX 678 Email from C. Conroy to B. Kim re Current Summary and attaching Alpina current consumption estimates, RTR6250 Device Spec and RFR6250 Device Spec, dated 11/23/2005 (QCPV010804686 - QCPV010804689)

PX 679 Hearsay Gartner Market Analysis: General-Purpose Analog/Mixed-Signal Landscape Still Fragmented, dated 05/21/2002 (QCPV010817443.00001 - QCPV010817443.00018) Learned Treatise - Not For Admission

PX 680 C. Conroy email to R. Gupta, et al. forwarding Competitor Specs for WCDMA: QCOM RTR6200 Chipset, dated 10/21/2004 (QCPV011045333 - QCPV011045339)

PX 682 Qualcomm Redefining Mobility: RF Products Operations Metrics Quarterly Review, dated 05/00/2011 (QCPV011170466 -


71 McKool 922227v1

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DATE IDENTIFIED

DATE ADMITTED




QCPV011170552)

PX 683 QMC Chipset Product Roadmaps (Disclosed Under NDA), dated 01/00/2013 (QCPV011177383 - QCPV011177503)

PX 684 QC-CE Ops Review CE RF, dated 10/00/2012 (QCPV011178123 - QCPV11178150)

PX 685 Not relevant Maverick - Eureka Exec Roadmap Review, dated 11/28/2012 (QCPV011183981 - QCPV011184015)

PX 686 C. Conroy email to J. Paulus re CDM Testing on Firebird, dated 01/21/2006 (QCPV011273384)

PX 687 C. Persico email to C. Conroy, et al. re CDM Testing on Firebird, dated 01/23/2006 (QCPV011273385)

PX 688 Presentation: RTR6285 (GZIF4) TX LO Path Current Mode Strategy, undated (QCPV011273453 - QCPV011273461)

PX 689 Not relevant Email chain between G. Kondapalli and synth.tsmc18rf re Alpina VCO questions and LO_partition.pdf, dated 01/20/2006 (QCPV011273485 - QCPV011273486)

PX 692 Email from G. Hartman to W. Panton, et al. reUMTS RF Roadmap Update Meeting/Actions and attachment UMTS RF Product Roadmap Update,dated 12/21/2005 (QCPV011274049 - QCPV011274077)

PX 693 Spreadsheet - Person Responsible and Task, undated (QCPV011274920 -


72 McKool 922227v1

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DATE IDENTIFIED

DATE ADMITTED




QCPV011274924)

PX 694 QCT Campbell 0.18µ CMOS RF/Mixed-Signal Circuits and Technology Overview, dated 01/16/2006 (QCPV011282973 - QCPV011282982)

PX 695 Email from K. Wang to A. Hadjichristos, et al. attaching SGPS Module Presentation for gzif4_berkana Kickoff Meeting, dated 01/15/2006 (QCPV011379741 - QCPV011379741)

PX 696 Direct Conversion Architecture, dated 08/02/1999 (QCPV011456049 - QCPV011456049)

PX 697 Direct Conversion Backup Material, undated (QCPV011456068 - QCPV011456082)

PX 698 Direct Conversion Overview, undated (QCPV011456083 - QCPV011456128)

PX 699 Email from C. Wheatley to P. Kantak, et al. re D2D, dated 05/28/1999 (QCPV011466420 - QCPV011466420)

PX 700 Email from S. Jha to C. Wheatley, et al. re D2D, dated 05/29/1999 (QCPV011466427 - QCPV011466428)

PX 701 Incomplete; Not relevant

Chipset Spreadsheet, undated (QCPV011507641)

PX 704 Tenth Supplemental Disclosure Statement dated 10/21/1998 (SK00000325 - SK00000328)

PX 705 Hearsay Sony Mobile Communications (USA) - Exhibit A - Name and


73 McKool 922227v1

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DATE IDENTIFIED

DATE ADMITTED




Model of Mobile Devices, Units Sold, Accused Products Contained in Mobile Device undated (Sony-PV0000001 - Sony-PV0000002)

PX 706 http://www.qualcomm.com/about/history last updated 10/01/2012


http://finance.yahoo.com/q/hp?s=PRKR&a=00&b=1&c=2008&d=11&e=31&f=2012&g=m


http://finance.yahoo.com/q/hp?s=PRKR&a=01&b=1&c=2013&d=01&e=31&f=2013&g=m


http://finance.yahoo.com/q/hp?s=QCOM&a=01&b=1&c=2013&d=01&e=12&f=2013&g=m

PX 710 Hearsay http://www.anandtech.com/show/6541/the-state-of-qualcomms-modems-wtr1605-and-mdm9x25/2

PX 711 Hearsay http://www.ctia.org/advocacy/research/index.cfm/AID/10388


http://www.ctia.org/consumer_info/multimedia/


http://www.federalreserve.gov/releases/h15/data.htm

PX 714 Hearsay http://www.gsmarena.com/apple_iphone-1827.php

PX 715 Not relevant http://www.uspto.gov, U.S. Patent Number 7,010,286, March 7, 2006

PX 716 Not relevant http://www.uspto.gov, U.S. Patent Number 7,065,162, dated 06/20/2006

PX 717 Not relevant http://www.uspto.gov, U.S. Patent Number 7,515,896, dated 4/7/2009


74 McKool 922227v1

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DATE ADMITTED




PX 719 Hearsay Chapter 17: Application of Game Theory to Intellectual Property Royalty Negotiations by John C. Jarosz and Michael J. Chapman, LICENSING BEST PRACTICES 241-65 (Robert Goldscheider and Alan H. Gordon, eds. 2006) (PV00467705 - PV00467731) Learned Treatise - Not For Admission


MSNBC, “First cell phone a true ‘brick’,” http://www.msnbc.msn.com/id/7432915/ns/technology_and_science-wireless/t/first-cell-phone-true-brick/#.UOyBI-TAdjs (last visited Jan. 8, 2013)


Nash, John F., “The Bargaining Problem,” Econometrica, Vol. 18, No.2, April 1950, pp. 155-162 (PV00469561 - PV00469569)


Nash, John, “Two-Person Cooperative Games,” Econometrica, Volume 21, No. 1, January 1953, pp. 128-140 (PV00469570 - PV00469582)

PX 723 Hearsay RIM Confidential Purchasing document for the period of 10/16/2007 through 12/04/2012 undated (RIM-PV0000001 - RIM-PV0000008)

PX 724 Qualcomm Form 10-K 2008, dated 09/28/2008 (QCPV000343294 - QCPV000343400)

PX 725 Qualcomm, Inc. 2011 Annual Report Form 10-K, dated 08/25/2011 (QCPV000343814 - QCPV000343913)


75 McKool 922227v1

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PX 726 Hearsay An Analytical Solution to Reasonable Royalty Rate Calculations by W. Choi and R. Weinstein, THE JOURNAL OF LAW AND TECHNOLOGY, Vol. 41, No. 1 (July 2001) (PV00467689 - PV00467704)

PX 727 http://www.qualcomm.com/media/documents/files/qualcomm-rf360-front-end-solution-product-brief.pdf

PX 728 http://www.qualcomm.com/media/releases/2013/02/21/qualcomm-rf360-front-end-solution-enables-single-global-lte-design-next

PX 731 Hearsay Apple, iPhone Technical Specifications, http://support.apple.com/kb/SP2 (last visited Dec. 6, 2012)


Apple, iPhone Delivers Up to Eight Hours of Talk Time, http://www.apple.com/pr/library/2007/06/18iPhone-Delivers-Up-to-Eight-Hours-of-Talk-Time.html (last visited Dec. 5, 2012)


http://www.wired.com/gadgetlab/2013/02/qualcomm-new-lte-chip/

PX 734 Qualcomm, Press Releases, http://www.qualcomm.com/media/releases/1999/12/22/qualcomm-and-kyocera-sign-agreement-terrestrial-cdma-phone-business (last visited, January 24, 2013)


CNET, ParkerVision SIGNALMAX WR1500, http://reviews.cnet.com/routers/parkervision-signalmax-wr1500-wireless/4505-3319_7-31260064.html (last visited Dec. 11,


76 McKool 922227v1

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DATE ADMITTED




2012)


Trefis, “Qualcomm’s Multimode Chips to Help Market Share” (Nov. 15, 2010), http://www.trefis.com/stock/qcom/articles/26964/qualcomms-multimode-chips-to-help-market-share/2010-11-15

PX 737 Not relevant Qualcomm, Executive Officers, http://www.qualcomm.com/about/leadership (last visited 02/06/2013)

PX 738 Not relevant Qualcomm, Find a Smartphone, http://www.qualcomm.com/snapdragon/smartphones/finder (last visited Feb. 6, 2013)


Letter from J. Canning to J. Budwin re testing at Goodwin Procter (Nov. 2, 2012)


http://www.eetimes.com/design/microwave-rf-design/4016178/Receive-diversity-helps-maximizing-throughput-in-HSDPA-networks

PX 741 http://www.qualcomm.com/media/releases/2004/11/15/qualcomm-expands-product-portfolio-new-wcdma-umtsedge-solution

PX 742 Not relevant; Hearsay re packaging

ParkerVision SignalMax WiFi Router (PHYSICAL EXHIBIT)

PX 744 QSC6270 Single-Chip Solution undated (PV00275376)

PX 745 RF Platform F/G(RTR6285/RTR6280) Topics 80-VE976Rev A dated 12/26/2011 (CONF-PV00197472)


77 McKool 922227v1

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PX 746 Not relevant; Hearsay; Lack of authenticity

FCC ID BEJGU295 LG GU295 undated (CONF-PV00413487)

PX 747 Hearsay LGSway Tech Specs undated (PV00413489)

PX 748 Presentation: QCT CDMA2000 Product Roadmaps (QCT Web Published) dated May 2007 (PV00274761)

PX 749 Presentation: QCT UMTS Overview June 2007 (CONF-PV00189656)


ParkerVision's Emmy Award for Cameraman (Picture), dated 10/04/2012

PX 751 Defendant Qualcomm's Answer and Counterclaims dated 09/16/2011

PX 752 Defendant Qualcomm's First Amended Answer, Counterclaims and Demand for Jury Trial dated 12/02/2011

PX 753 Defendant Qualcomm's Answer to ParkerVision's First Amended Complaint and Qualcomm's Counterclaim and Demand for Jury Trial dated 03/16/2012

PX 754 Defendant Qualcomm's Answer to ParkerVision's Third Amended Complaint and Qualcomm's Counterclaim and Demand for Jury Trial dated 04/11/2013

PX 755 Not relevant Press Release: Qualcomm Announces Plans to Implement New Corporate Structure, dated 06/28/2012

PX 756 Not relevant; Email from A. Oberst to D. Cianflo,


78 McKool 922227v1

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Prejudicial P. Kantak re PV Modeling, dated 03/11/1999 (QCPV001564933 - QCPV001564934)


Email from D. Cianflone to P. Kantak re ParkerVision, dated 04/13/1999 (QCPV001564973 - QCPV001564974)


Email from A. Oberst to P. Kantak re PV Model New, dated 04/22/1999 (QCPV001565007 - QCPV001565023)

PX 760 Qualcomm Presentation: ParkerVision Issues in Potential Acquisition, dated 06/30/1999 (QCPV005530153 - QCPV005530160)

PX 766 Hearsay Exhibit C.2 to Supplemental Expert Report of Paul Benoit, dated 3/25/2013

PX 773 Hearsay Exhibit D.6 to Supplemental Expert Report of Paul Benoit, dated 3/25/2013

PX 778 Hearsay Exhibit G.1 to Supplemental Expert Report of Paul Benoit, dated 3/25/2013



PX 781 Hearsay Exhibit H to Supplemental Expert Report of Paul Benoit, dated 3/25/2013

PX 782 Hearsay Exhibit H.1 to Supplemental Expert Report of Paul Benoit, dated


79 McKool 922227v1

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DATE ADMITTED




3/25/2013

PX 783 Hearsay Exhibit H.2 to Supplemental Expert Report of Paul Benoit, dated 3/25/2013

PX 784 Hearsay Exhibit I to Supplemental Expert Report of Paul Benoit, dated 3/25/2013

PX 785 Hearsay Exhibit I.1 to Supplemental Expert Report of Paul Benoit, dated 3/25/2013








PX 804 Hearsay Exhibit K.1 to Supplemental Expert Report of Paul Benoit, dated 3/25/2013


80 McKool 922227v1

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DATE ADMITTED




PX 806 Hearsay Exhibit L.1 to Supplemental Expert Report of Paul Benoit, dated 3/25/201




PX 810 Hearsay Exhibit M to Supplemental Expert Report of Paul Benoit, dated 3/25/2013

PX 814 Hearsay Exhibit N to Supplemental Expert Report of Paul Benoit, dated 3/25/2013

PX 815 Hearsay Exhibit N.1 to Supplemental Expert Report of Paul Benoit, dated 3/25/2013

PX 816 Hearsay Exhibit N.2 to Supplemental Expert Report of Paul Benoit, dated 3/25/2013

PX 817 Hearsay Exhibit O to Supplemental Expert Report of Paul Benoit, dated 3/25/2013

PX 818 Hearsay Exhibit P to Supplemental Expert Report of Paul Benoit, dated 3/25/2013

PX 827 Hearsay Appendix H to Expert Report of Paul Prucnal Expert, dated 3/4/2013

PX 828 Hearsay Appendix I to Expert Report of Paul Prucnal Expert, dated 3/4/2013


81 McKool 922227v1

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PX 829 Hearsay Appendix J to Expert Report of Paul Prucnal Expert, dated 3/4/2013

PX 834 Rule 26 PVD2510R Demodulator (PHYSICAL EXHIBIT)

PX 835 Not relevant Phone Model No. QCP-2035 (PHYSICAL EXHIBIT)



PX 838 Not relevant Phone Model No. M 3897 (PHYSICAL EXHIBIT)

PX 839 Not relevant Phone Model No. Linksys Q87-CIT200H (PHYSICAL EXHIBIT)

PX 840 Not relevant Phone Model No. Nokia 6215i (PHYSICAL EXHIBIT)

PX 841 Not relevant Phone Model No. LG CE110 (PHYSICAL EXHIBIT)

PX 842 Hearsay UBM TechInsights Report for QSC6275 (PHYSICAL EXHIBIT)

PX 843 Not relevant Eddie-1-Chip (PHYSICAL EXHIBIT)

PX 844 Not relevant Eddie-2-Chip (PHYSICAL EXHIBIT)

PX 845 Not relevant ParkerVision Demonstrative Board Given to Qualcomm in February 1999 (PHYSICAL EXHIBIT)

PX 846 Qualcomm Schematic pages, undated (QCS1PV0000001 - QCS1PV0000084)

PX 847 Qualcomm Schematic pages,


82 McKool 922227v1

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DATE ADMITTED




undated (QCS1PV0001995 - QCS1PV0003587)







PX 854 Email from P. Kantak to S. Ciccarelli, et al. re Meeting with ParkerVision dated 08/22/1998 (QCPV001575739)


ParkerVision's National Academy of Television Art & Sciences Announces Recipients of the 64th Annual Technology & Engineering Emmy Awards, dated 10/04/2012 (PV00469442)


ParkerVision's Grass Valley Emmy Awards and Citations, dated 2012 (PV00469439)


Article: RoadStor, Horizons card show where innovations coming from by J. Coates, Chicago Tribune


83 McKool 922227v1

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DATE ADMITTED




Hearsay Business Section, dated 11/23/2003 (PV00469515 - PV00469518)


Article: Putting the focus on distance learning cameras in the classroom revolutionize today's teaching, Curriculum Administrator, dated 1995 (PV00469519)


ParkerVision acquires Signal Technologies, Jacksonville Business Journal Morning Edition, dated 04/06/2000 (PV00469520)


ParkerVision granted new patent, Jacksonville Business Journal Morning Edition, dated 04/11/2000 (PV00469521)


ParkerVision receives patent, Jacksonville Business Journal Morning Edition, dated 04/18/2002 (PV00469522 - PV00469522)


ParkerVision sells automated TV studio system to McGraw-Hill, Jacksonville Business Journal Morning Edition, dated 04/10/2001 (PV00469523)


ABC goes with ParkerVision's automated television system, Jacksonville Business Journal Morning Edition, dated 04/30/2001 (PV00469524 - PV00469525)


ParkerVision completes testing of new transceiver chips, Jacksonville Business Journal Morning Edition, dated 04/05/2002 (PV00469526)


New ParkerVision chip in WLAN breakthrough, Jacksonville Business Journal Morning Edition, dated 04/30/2001 (PV00469527 -


84 McKool 922227v1

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DATE ADMITTED




PV00469528)


St. Augustine airport to use ParkerVision wireless system, Jacksonville Business Journal Morning Edition, dated 12/02/2004 (PV00469529)


ParkerVision product recognized by Laptop Magazine, Jacksonville Business Journal Morning Edition, dated 06/09/2004 (PV00469530)


ParkerVision products honored at industry trade show, Jacksonville Business Journal Morning Edition, dated 09/20/2004 (PV00469531)


Newspaper article: ParkerVision coming into focus, dated 07/00/1994 (PV00469532)

PX 870 Hearsay Email from P. Kantak to cwheatley and others re ParkerVision Update re: CDMA Zero IF Modulator/Xmitr and attaching CDMA Modulator Test Report, dated 11/19/1999 (QVPV001558711 - QCPV001558744)


Exhibit 14 to Docket No. 305, dated 7/25/2013: Excerpts of Nash Equilibruium, undated

PX 872 http://www.prnewswire.com/news-releases/qualcomm-accelerates-availability-of-low-end-umtshsdpa-chipsets-56027972.html QUALCOMM Accelerates Availability of Low-End UMTS/HSDPA Chipsets - 65nm MSM Chipsets with RF CMOS Deliver High Levels of Integration for


85 McKool 922227v1

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DATE ADMITTED




PX 873 Not relevant PowerPoint: Motorola Account Updatedv1 with Price History, dated 2007 (QCPV007397711 - QCPV007397718)


PowerPoint: Measurements and Possible Architecture of ParkerVision's D2D by S. Bazarjani, S. Ciccarelli, R. Stascewski and S. Younis, dated 01/16/1998 (QCPV005589291 - QCPV005589298)


Letter from P. Kantak to J. Parker, Qualcomm Proprietary, re counter proposal dated 06/10/1999 (PV00370156 - PV00370171)

PX 876 Not relevant; Prejudicial; 1002; Multiple Documents

Qualcomm's Privilege Logs, dated 05/29/2013

PX 877 Incomplete Exhibit 44 of Docket No. 276, dated 06/24/2013: Excerpt from US Patent 8,050,649

PX 878 Incomplete Exhibit 45 to Docket No. 276, dated 06/24/2013: Excerpt from prosecution history of US Patent 8,050,649


Exhibit 51 to Docket No. 276, dated 06/24/2013: Letter from Richard Kamprath to Jim Cannning, dated 04/19/13

PX 880 Hearsay Exhibit 19 to Docket No. 285, dated 07/08/2013: Excerpts from Linley Group marketing report purchased by QC [UNDER SEAL] (QCPV007398196 -QCPV007398391) Learned Treatise - Not For Admission


86 McKool 922227v1

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Market Focus: Semiconductors in Mobile Phones, Worldwide 2004-2008, Focus Report, dated 12/24/2004 (QCPV010721197)

PX 883 Hearsay Email from J. Parker to pak@qualcomm; [email protected] re ParkerVision Update dated 10/04/1999 (QCPV001390702)

PX 884 Not relevant BTS 4020 (QCPVSMPL013) PHYSICAL EXHIBIT




PX 888 ESC 6270 (QCPVSMPL017) PHYSICAL EXHIBIT

PX 889 FTR 8700, dated 11/01/12 (QCPVSMPL018)

PX 890 Not relevant MBP 2600, dated 10/23/12 (QCPVSMPL019) PHYSICAL EXHIBIT

PX 891 Not relevant MBP 2700, dated 10/23/12 (QCPVSMPL020) PHYSICAL EXHIBIT

PX 892 MDM 6085, dated 10/23/12 (QCPVSMPL021) PHYSICAL EXHIBIT



87 McKool 922227v1

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DATE ADMITTED






PX 896 MXU 6219, dated 10/23/12 (QCPVSMPL025) PHYSICAL EXHIBIT

PX 897 QSC 1100, dated 10/25/12 (QCPVSMPL026) PHYSICAL EXHIBIT








PX 905 QSC 6165, dated 11/01/12


88 McKool 922227v1

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DATE IDENTIFIED

DATE ADMITTED




(QCPVSMPL034) PHYSICAL EXHIBIT





PX 910 QSC 6270 (QCPVSMPL039) PHYSICAL EXHIBIT


PX 912 QTR 8200, dated 10/23/12 (QCPVSMPL041) PHYSICAL EXHIBIT


PX 914 QTR 8600L, dated 11/01/12 (QCPVSMPL043) PHYSICAL EXHIBIT




89 McKool 922227v1

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DATE ADMITTED




PX 917 QTR 8615L, dated 11/01/12 (QCPVSMPL046) PHYSICAL EXHIBIT


PX 919 RGR 6240, dated 11/01/12 (QCPVSMPL048) PHYSICAL EXHIBIT

PX 920 RTR 6237, dated 10/23/12 (QCPVSMPL049) PHYSICAL EXHIBIT

PX 921 WCN 1314, dated 10/23/12 (QCPVSMPL058) PHYSICAL EXHIBIT


PX 923 RTR 6285 (QCPVSMPL051) PHYSICAL EXHIBIT

PX 924 RTR 6285A, dated 11/01/12 (QCPVSMPL052) PHYSICAL EXHIBIT

PX 925 RTR 6500 (QCPVSMPL053) PHYSICAL EXHIBIT





90 McKool 922227v1

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DATE IDENTIFIED

DATE ADMITTED







PX 932 WTR 1605, dated 11/01/12 (QCPVSMPL061) PHYSICAL EXHIBIT

PX 933 Hearsay Exhibit 54 to Docket No. 276, dated 6/24/2013: Excerpts of Chen, Zheng, Characterization and Modeling of High-Switching-Speed Behavior of SiC Active Devices, dated 12/18/2009 Learned Treatise - Not For Admission


Email from A. Oberst to johanl, et al. re PV, dated 04/13/199 (QCPV001414715)

PX 935 Not relevant; Prejudicial Hearsay

Email from D. Sorrells to [email protected] re Test Equipment, dated 08/20/1998 (11/30/2013 Sorrells Deposition Ex. 24, QCPV001390031)


Email from R. Gilmore to C. Wheatley, P. Kantak, syounis, et al. re PV, dated 03/26/1999 (11/07/2012 Wheatley Deposition Ex. 12, QCPV001555022)


Email from C. Wheatley to P. Kantak, et al. re PV, dated 03/26/1999 (11/07/2012 Wheatley Deposition Ex. 14,


91 McKool 922227v1

EXHIBIT NO.1

DATE IDENTIFIED

DATE ADMITTED




QCPV001575117)

PX 939 Not relevant; Prejudicial Hearsay

Email chain from C. Wheatley to R. Gilmore, M. Blecker re ParkerVision Update, dated 10/5/1999 (11/07/2012 Wheatley Deposition Ex. 27, QCPV001555062 – QCPV001555064)


Email from P. Peterzell to cpersico, ksahoto re Direct Conversion, dated 06/23/2000 and attaching PowerPoint re briefing on ParkerVision (11/07/2012 Wheatley Deposition Ex. 10, QCPV001414205 – QCPV001414217)

PX 943 Hearsay ParkerVision direct2data document (11/30/2012 Sorrells Deposition Ex. 10, CONF-PV00187794)

PX 944 Hearsay Data Sheet: direct2data PV-1000Hb 802.11b RF Transceiver Specifications, dated 00/00/2002 (11/30/2012 Sorrells Deposition Ex. 23, 10/13/2012 Leach Deposition Ex. 42, CONF_PV00195524)

PX 945 Kim, et al., A Resistively Degenerated Wide-Band Passive Mixer with Low Noise Figure and +60dBm IIP2 in 0.18µm CMOS, Abstract, 2008 IEEE Radio Frequency Integrated Circuits Symposium, pp. 185-188, dated 00/00/2008 (10/23/2012 Persico Deposition Ex. 13)

PX 948 Email chain from C. Conroy to S. Jha, et al. re RF Systems Meeting on 03/13/2007 dated 03/14/2007 and attaching presentation entitled GPS RF Power Consumption and Performance (QCPV005452615 -


92 McKool 922227v1

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DATE IDENTIFIED

DATE ADMITTED




QCPV005452636)

PX 949 Presentation: RTR6285 Co-design Strategy, dated 12/12/2005 (QCPV011273986 - QCPV011273990)

PX 950 Email from M. Hartogs to L. Lupin, et al. forwarding Press Release announcing TI, ParkerVision join for advanced-radio push, dated 03/16/2001 (QCPV010491728 - QCPV01041729)


Email from P. Kantak to B. Sailer attaching Soft Copy of PV Agreement, dated 05/27/1999 (QCPV010492372)


Email chain from P. Kantak to J. Parker regarding Where to reach me, dated 04/22/1999 (QCPV00138927)


Email chain from P. Kantak to J. Jacobs regarding Symbol Announcement, dated 05/22/1999 (QCPV001390342 - QCPV001390343)


Email chain from L. Lupin to P. Kantak regarding Royalty Issue Negotiations with Parker, dated 05/21/1999 (QCPV001391522)

PX 955 Prejudicial; Hearsay

Article: ParkerVisions CamerMan allows two Gannet stations to share resources; cameras in Bangor are controlled from Portland, Broadcasting & Cable dated 01/01/2001 (PV00469514)


Email chain from J. Stuckey to J. Parker regarding Qualcomm timeline, dated 02/04/2010 (CONF-PV00187766)


93 McKool 922227v1

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DATE ADMITTED




PX 957 Rule 26, Hearsay PVD9510R Frequency Downconverter Datasheet


Email from P. Kantak to F. Antonio regarding Request to meet, dated 11/24/1998 (QCPV001413290-QCPV001413294)


Email from C. Wheatley to R. Gilmore, P. Kantak, S. Younis regarding PV, dated 03/26/1999 (QCPV001547710-QCPV001547712)


Email chain from P. Kantak to K. Grajski regarding ParkerVision, dated 02/25/2005 (QCPV001549133-QCPV001549134)

PX 962 Email chain from A. See to C. Riddle, S. Ciccarelli, S. Dhandu, S. Ahsan, F. Faheem, W. Panton regarding A 123 battery presentation and data collection, dated 11/07/2006 (QCPV001569999-QCPV001570000)

PX 963 Email from A. Oberst to S. Cicarelli, K. Sahota re Pvision, dated 01/15/2007 (QCPV001570010)

PX 964 Prejudicial Email from S. Bazarjani to M. Sani regarding review, dated 09/19/2001 (QCPV001576335-QCPV001576336)

PX 967 Email from D. Schrock ro J. Lodenius regarding Week update, dated 03/05/1999 (QCPV001623211-QCPV001623212)

PX 968 Email from J. Lodenius to D. Schrock regarding Analog Devices


94 McKool 922227v1

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DATE IDENTIFIED

DATE ADMITTED




Announces First 3G Radio Chip, dated 02/25/2000 (QCPV001623438-QCPV001623439)

PX 969 Email chain from S. Miyazaki to S. Ciccarelli regarding Internal mtg for RF update, dated 11/06/2006 (QCPV005613173-QCPV005613176)

PX 970 Not relevant Email from J. Martin to [email protected] regarding Tinky Winky Media Flow Meeting Minutes - Jan. 7th, 2004, dated 01/09/2004 (QCPV005452461)

PX 971 Email chain from K. Sahota to C. Conroy, RFAtechpub.review regarding GPS paper, dated 02/20/2007 (QCPV005456674-QCPV005456676)

PX 972 Email chain from C. Persico to V. Aparin regarding Adaptive filter, dated 01/12/2005 (QCPV005458629-QCPV005458632)

PX 973 Email from C. Persico to G. Brown, J. Jenkins, [email protected] regarding RFR6185 Update, dated 08/25/2005 (QCPV005459557)

PX 974 Email from [email protected] to [email protected] regarding Reports for the week ending: 06-Sep-2005, dated 09/07/2005 (QCPV005464164-QCPV005464221)

PX 975 http://icenet.qualcomm.com/Groups/RFAnalog/SSR/Reports/index.cfm?f


95 McKool 922227v1

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DATE IDENTIFIED

DATE ADMITTED




useaction=reports&reportaction=actRunEmp

PX 976 Email from V. Chellapa to P. Gudem regarding doubts, dated 03/17/2004 (QCPV005815922)

PX 977 Email from L. Liu to P. Gudem regarding sfmr and mixer noise impact on LNA spec., dated 06/15/2004 (QCPV005816884)

PX 978 Email chain from G. McAllister to D. Keller, G. Brown, K. Sahota regarding SCTicket #: P<2493546 - Access to former employee's Unix home directory, dated 06/11/2004 (QCPV005930375-QCPV005930377)

PX 979 Email chain from A. Hadjichristos to W. Zhuo, R. Apte regarding Passive mixer update, dated 09/10/2005 (QCPV006231897)

PX 980 Email chain from A. Hadjichristos to P. Gazzerro, W. Sampson regarding SOME RTR6275 GSM ISSUES THAT NEED TO BE DOUBLE-CHECKED CAREFULLY ON THE RTR6285, dated 07/16/2007 (QCPV006416665-QCPV006416666)

PX 981 Email chain from S. Peng to A. Hadjichristos regarding Passive mixer, dated 08/30/2005 (QCPV006429164)

PX 982 Email from S. Peng to A. Hadjichristos regarding Mixer with transimpedance output, dated 08/26/2005 (QCPV006442700)

PX 984 Email chain from L. Zhao to C. Conroy, S. Ciccarelli, B. Kim


96 McKool 922227v1

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DATE ADMITTED




regarding Astra GPS, dated 07/11/2007 (QCPV006736778)

PX 986 Email from C. Park to [email protected], E. Lin regarding conclusion to upgrade the tool, dated 05/03/2005 (QCPV010921182)

PX 988 Email chain from Y. Du to E. Lin, T. Nacita, J. Pak, M. Flynn regarding Waivers for TSMC 0.19 RF, dated 06/07/2006 (QCPV011278986-QCPV011278988)


Email chain from J. Shrenger to D. Allen regarding Document production, dated 07/25/2012 (QCPV011507566-QCPV011507570)


Letter from J. Shrenger to D. Allen regarding ParkerVision v. Qualcomm, dated 06/15/2012 (QCPV011567558-QCPV011507560)

PX 991 Qualcomm's Form 10-K for the fiscal year ended September 28, 2003




PX 995 Qualcomm's Form 10-K for the fiscal year ended September 30,


97 McKool 922227v1

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DATE IDENTIFIED

DATE ADMITTED




2007



PX 998 Email chain from J. Leach to R. Harlan regarding latest cut of D2D WiMax example (CONF-PV00193243-CONF-PV00193244)

PX 999 Certified return receipt for letter sent from R. Sterne to R. Miller (SKPV00196726-SKPV00196727)

PX 1000 Letter from R. Sterne to R. Miller re Notice Under Qualcomm/ParkerVision Mutual Non-Disclosure Agreement (SKPV00196728-SKPV00196729)

PX 1001 Qualcomm LCU: GSM RX HB LLDR, 80-VC067-43 Rev. A by C. Narathong dated 09/27/2007 (QCPV000001096-QCPV000001141)

PX 1002 Qualcomm LCU IM2 Calibration, High-Level Design Review, 80-VC067-47 Rev. A dated 09/25/2007 (QCPV000004945-QCPV000005031)

PX 1003 Qualcomm RTR8600 (Magellan) PRX LO Generation, MLDR, 80-VF535-57 Rev. A dated 06/16/2008 (QCPV000185487-QCPV000185613)

PX 1004 Qualcomm Halley (RTR9205) Top-Level, LLDR, 80-VR713-14 Rev. A dated 05/07/2010


98 McKool 922227v1

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DATE ADMITTED




(QCPV000211537-QCPV000212008)

PX 1005 Qualcomm UBM-2M RFIC (Fury) Mixer, High Level Design Review (HLDR), 80-VF450-20 Rev. A dated 10/13/2008 (QCPV000372236-QCPV000372285)

PX 1006 Qualcomm MBP3150 Hardware/Software Interface Fury-RFIC-Rev2.0/Dalton-ADC, 80-VF450-216 Rev A dated 10/19/2010 (QCPV000372899-QCPV000373173)

PX 1007 Eagleray LO Path: ADC Clock Divider, Preliminary Review, 80-VP870-26 Rev. A dated 05/2009 (QCPV000396608-QCPV000396653)

PX 1008 Qualcomm QSC1100 Napoleon Rx Signal-Path Block-Level HLDR, 80-VD543-14 Rev. B dated 04/2007 (QCPV000460501-QCPV000460633)

PX 1009 Qualcomm Ashoka (QSC11x5) HDD, 80-VU207-2 Rev. B dated 08/26/2011 (QCPV000506225-QCPV000506644)

PX 1010 Qualcomm UBM-2M (Fury) 65nm RFIC HLDR, 80-VF450-XX dated 08/23/2007 (QCPV000859541-QCPV000859801)

PX 1011 Qualcomm RTR8600 IM2 Issues (summary of ideas/problem descriptions from LCU, ULC teams, and RF systems engineers) (QCPV001084323-QCPV001084331)


99 McKool 922227v1

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DATE ADMITTED




PX 1012 Qualcomm Kepler LB Signal Path LLDR, 80-VP702-31 Rev. A dated 01/01/2010 (QCPV001367415-QCPV001367508)

PX 1013 Email from P. Kantak to S. Ciccarelli regarding ParkerVision dated 01/25/1999 (QCPV001564854)

PX 1014 Qualcomm Marimba Bench High Level Test Review (HLTR), 80-VJ324-10 Rev. A dated 05/22/2008 (QCPV003483000-QCPV003483106)

PX 1015 Qualcomm Kepler LB Signal Path MLDR, 80-VP702-XX Rev. A, by Y. Xiao dated 07/31/2009 (QCPV004215577-QCPV004215639)

PX 1016 Qualcomm WTR1605 Diversity MidBand RX Signal Path LLDR, by S. Rai dated 02/28/2011 (QCPV004375842-QCPV004375964)

PX 1017 Qualcomm WTR1605 (Odyssey) PLB RX Signal Path by R. Xu dated 02/02/2011 (QCPV004528818-QCPV004528969)

PX 1018 Email chain from J. Caravella and C. Persico regarding Auto Report-RF/Analog with attached Reports for the week ending 06-Mar-2007 03/07/2007 (QCPV005463127-QCPV005463169)

PX 1019 Presentation: ULC (Napoleon) Rx LO Path/IM2 Caliberation LLDR 80-VD543-42 (DRAFT) by V. Panikkath dated 01/29/2008 (QCPV005655576-


100 McKool 922227v1

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DATE IDENTIFIED

DATE ADMITTED




QCPV005655697)

PX 1020 Email chain between A. Cicalini and S. Bazarjani regarding BB filter current LCU (bad news) dated 04/05/2007 (QCPV005707261-QCPV005707262)

PX 1021 Email chain between P. Gudem and S. Sengupta et al. regarding An idea for Envelop Tracking in Odyssey dated 03/08/2010 (QCPV005785876-QCPV005785881)

PX 1022 Email chain between S. Kwok and P. Gudem et al. regarding Jam levels and IIP3 specs for G1-G4 gain stages dated 10/19/2006 (QCPV005787398-QCPV005787400)

PX 1023 Qualcomm Kepler Quick Start Guide, Tutorial for Systems/PTE/ATE/FFA/SURF Teams dated 05/10/2010 (QCPV005849519-QCPV005849701)

PX 1024 Qualcomm Frequency divider with dividing ratio of 1.5 undated (QCPV005926037- QCPV005926069)

PX 1025 Email chain between R. Sridhara and K. Sahota regarding review prasad gudem dated 08/25/2009 (QCPV005945255-QCPV005945256)

PX 1026 Email chain between K. Barnett and K. Sahota et al. regarding process selection for UBM dated 10/27/2005 (QCPV005978136-QCPV005978139)


101 McKool 922227v1

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DATE IDENTIFIED

DATE ADMITTED




PX 1027 Qualcomm PRx LO Path by A. Cicalini undated (QCPV00603325-QCPV00603302)

PX 1028 Qualcomm RTR9205/RTR9215 RX TOP LEVEL LLDR dated 02/01/2009 (QCPV006043720-QCPV006044132)

PX 1029 Email chain between C. Hsu and P. Gazzerro et al. regarding Mixer implementation dated 03/04/2011 (QCPV006226845-QCPV006226848)

PX 1030 Qualcomm RTR8600 Tx: Targets for HLDR by Y. Tang dated 08/06/2007 (QCPV006281697-QCPV006281704)

PX 1031 Email chain between W. Zhuo and A. Hadjichristos regarding More on GSM front-end with diversity dated 04/28/2005 (QCPV006429282-QCPV006429283)

PX 1032 Qualcomm Magellan DRX/SHDR LO Generation by D. Qiao dated 10/01/2008 (QCPV006686933-QCPV006687004)

PX 1033 Qualcomm Incorporated Acknowledgement dated 10/01/2012 (QCPV010541002-QCPV010541127)

PX 1034 Email chain between S. Ciccarelli and J. Zhou regarding VCO specs dated 05/24/2000 (QCPV011458949-QCPV011458950)

PX 1035 Qualcomm Kepler RX LO Generation LLDR, 80-VP702-80 Rev. A, by R. Sridhara dated


102 McKool 922227v1

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DATE ADMITTED




01/11/2010 (QCPV005556153-QCPV005556206)

PX 1036 Qualcomm Europe (GPS RF core for RTR9205, QTR9215) Core Top LLDR 80-VP745-41 Rev. A 05/00/2010 (QCPV000208919-QCPV000209045)

PX 1037 Qualcomm RTR6285 Objective Specification 80-V4341-10 Rev. C dated 08/03/2006 (QCPV000002591-QCPV000002692)

PX 1038 Email chain between S. Jha to F. Antonio et al. regarding TI/Nokia "single chip solution" dated 1/24/2005 (QCPV001619955-QCPV001619956)

PX 1039 Presentation Factors Considered as part of the Investigation dated 08/29/2013

PX 1040 Qualcomm's Launch of Accused products

PX 1041 Not relevant; Prejudicial; Improper Summary and Improper Demonstrative

Qualcomm's Annual Revenue for Fiscal Years 2006-2012

PX 1042 Email from B. Keitel to A. Oberst, et al. re RF companies, dated 09/27/2005 (QCPV001623750-QCPV001623751)

PX 1043 Not relevant; Prejudicial; Improper Summary; Improper

Qualcomm's financial information relating to the Accused Products during the second and third quarters of the 2013 fiscal year (QCPVN0000024)


103 McKool 922227v1

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DATE ADMITTED




Demonstrative

PX 4000 Email from S. Jha to J. Tran, et al. re Notes on Berkana, dated 05/19/2004 (QCPV001619940 – QCPV001619943) IMPEACHMENT ONLY - NOT FOR PREADMISSION

PX 4001 A. Hadjichristos email to J. Tran, et al. re Agenda for visit, dated 10/06/2005 (QCPV011273836 – QCPV011273837) IMPEACHMENT ONLY - NOT FOR PREADMISSION

PX 4002 Email from K. Sahota to C. Persico, et al. re Notes for Berkana Visit, dated 10/10/2005 (QCPV011273843 – QCPV011273845) IMPEACHMENT ONLY - NOT FOR PREADMISSION

PX 4003 Email from W. Zhuo to A. Hadjichristos re Passive Mixer summary, dated 10/17/2005 (QCPV006429347) IMPEACHMENT ONLY - NOT FOR PREADMISSION

PX 4004 Email from A. Oberst to K. Sahota re Agenda for Berkana meeting, dated 10/26/2005 (QCPV001622205 – QCPV001622206) IMPEACHMENT ONLY - NOT FOR PREADMISSION

PX 4005 Email from A. Oberst to K. Sahota re items to discuss, dated 10/31/2005 (QCPV011273860 - QCPV011273862) IMPEACHMENT ONLY - NOT FOR PREADMISSION

PX 4006 Draft Presentation: RTR6285 (gzif4) TSMC18RF Delta-HDLR and


104 McKool 922227v1

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DATE ADMITTED




Packing Review 80-V4341-12, dated 10/00/2005 (QCPV009385930 - QCPV009386068) IMPEACHMENT ONLY - NOT FOR PREADMISSION

PX 4007 Email from A. Hadjichristos to J. Tran re .18um test chip -> RTR6285 update, dated 11/21/2005 (QCPV006419023 - QCPV006419026) IMPEACHMENT ONLY - NOT FOR PREADMISSION

PX 4008 Email from A. Hadjichristos to K. Sahota re follow-up items from meeting -> First comments on current consumption, and attachment entitled Alpina_current_consumption_estimates_for_QCOM.xls, dated 11/28/2005 (QCPV011273888 - QCPV011273896) IMPEACHMENT ONLY - NOT FOR PREADMISSION

PX 4009 Email from K. Sahota to C. Persico re Berkana engineering due diligence summary, dated 12/07/2005 (QCPV011273917) IMPEACHMENT ONLY - NOT FOR PREADMISSION

PX 4011 Email from C. Conroy to B. Kim re design kit sync up + more, dated 01/04/2006 (QCPV005463526) IMPEACHMENT ONLY - NOT FOR PREADMISSION

PX 4012 Email from C. Conroy to B. Kim, K. Sahota re design kit sync up + more, dated 01/04/2006 (QCPV006419872) IMPEACHMENT ONLY - NOT FOR PREADMISSION


105 McKool 922227v1

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PX 4013 Email from A. Hadjichristos to K. Sahota re Actions list summary and status from Jan 05 meeting, dated 01/07/2006 (QCPV011274329 - QCPV011274330) IMPEACHMENT ONLY - NOT FOR PREADMISSION

PX 4014 Email from A. Hadjichristos to C. Conroy (Berkana / Campbell) re RTR6285 RX architecture decision, dated 01/10/2006 (QCPV011163337 - QCPV011163339) IMPEACHMENT ONLY - NOT FOR PREADMISSION

PX 4015 Email from A. Hadjichristos to C. Conroy re RTR6285 RX architecture decision, dated 01/10/2006 (QCPV011163337 - QCPV011163339) IMPEACHMENT ONLY - NOT FOR PREADMISSION

PX 4016 Alpina 2G/3G ZIF RX Front End Review presentation w/r/t RTR6285 – includes passive mixer, dated 01/16/2006 (QCPV011283061 - QCPV011283102) IMPEACHMENT ONLY - NOT FOR PREADMISSION

PX 4017 Email from G. Kondapalli to P. Yang re Alpina VCO question, dated 01/19/2006 (QCPV011273503 - QCPV011273504) IMPEACHMENT ONLY - NOT FOR PREADMISSION

PX 4018 Email from c. Conroy to D. O’Shea re 2G RX - next steps, and attachment entitled GSM_RX_blockdiagram.ppt, dated 01/23/2006 (QCPV011274581 - QCPV011274587)


106 McKool 922227v1

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DATE ADMITTED




IMPEACHMENT ONLY - NOT FOR PREADMISSION

PX 4019 Email from A. Hadjichristos to S. Vora re: Some R6285 task assignment changes, dated 01/23/2006 (QCPV011277118 - QCPV011277119) IMPEACHMENT ONLY - NOT FOR PREADMISSION

PX 4020 Email from J. Jaffee to D. Maldonado re RTR6285 GSM Rx specs and convergence with the ALPINA chip, dated 01/26/2006 (QCPV011273371) IMPEACHMENT ONLY - NOT FOR PREADMISSION

PX 4021 Not relevant Email from G. Kondapalli to J. Ko re floorplan of alpina tx LO path and tuned buffer path, and attachment entitled TXLO-Strategy.ppt, dated 02/01/2006 (QCPV011273442 - QCPV011273451) IMPEACHMENT ONLY - NOT FOR PREADMISSION

PX 4022 Email from W. Zhuo to C. Conroy re WCDMA Rx Meeting [sic] Summary and Action Item, dated 02/01/2006 (QCPV011273530) IMPEACHMENT ONLY - NOT FOR PREADMISSION

PX 4023 Email from C. Conroy to C. Park re IP2 for BKW9088AB/AC vs. Temperature, Vdd and Process skew - limited data, dated 02/10/2006 (QCPV006494058 - QCPV006494059) IMPEACHMENT ONLY - NOT FOR PREADMISSION

PX 4024 Email from W. Zhuo to C. Conroy re wcdma rx issues, and attachment


107 McKool 922227v1

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DATE ADMITTED




entitled lna_gainstep_idea.ppt, dated 02/16/2006 (QCPV011273633 - QCPV011273636) IMPEACHMENT ONLY - NOT FOR PREADMISSION

PX 4025 Email from C. Conroy to A. Hadjichristos re notes for meeting summary, dated 03/16/2006 (QCPV011274926) IMPEACHMENT ONLY - NOT FOR PREADMISSION

PX 4026 Report: Duff & Phelps, LLC to D. Wise re Estimation of the Fair Value of Certain Intangible Assets of Berkana Wireless, Inc. as of December 31, 2005, dated 04/12/2006 (04/26/2013 Leonard Deposition Ex. 5, QCPV005527167 - QCPV005527189) IMPEACHMENT ONLY - NOT FOR PREADMISSION

PX 4027 Dunworth Declaration in Support of Qualcomm’s Motion to Strike/Compel ParkerVision’s Inadequate Infringement Contentions (Dkt. No. 155), dated 08/27/2012 (10/23/2012 Persico Deposition Ex. 1) IMPEACHMENT ONLY - NOT FOR PREADMISSION

PX 4028 Expert Report of Dr. Behzad Razavi, dated 03/04/2013 IMPEACHMENT ONLY - NOT FOR PREADMISSION

PX 4029 Expert Report of Tim A. Williams Concerning Objective Indicia of Nonobviousness, dated 03/04/2013 IMPEACHMENT ONLY - NOT FOR PREADMISSION


108 McKool 922227v1

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DATE ADMITTED




PX 4030 Expert Report of Robert M. Fox, Ph.D., dated 04/05/2013 IMPEACHMENT ONLY - NOT FOR PREADMISSION

PX 4031 Expert Report of Joseph L. Hanna, dated 04/05/2013 IMPEACHMENT ONLY - NOT FOR PREADMISSION

PX 4032 Expert Report of Dr. Gregory K. Leonard, dated 04/05/2013 IMPEACHMENT ONLY - NOT FOR PREADMISSION

PX 4033 Rebuttal Expert Report of Tim A. Williams, dated 04/05/2013 IMPEACHMENT ONLY - NOT FOR PREADMISSION

PX 4034 Thomas R. Varner, An Economic Perspective on Patent Licensing Structure and Provisions, les Nouvelles, dated 03/00/2012 (04/26/2013 Leonard Deposition Ex. 3) IMPEACHMENT ONLY - NOT FOR PREADMISSION

PX 4035 RTR6285 (Passive Mixer) Wei Zhou Presentation, dated 06/00/2005 (QCPV006429348 - QCPV006429361) IMPEACHMENT ONLY - NOT FOR PREADMISSION

PX 4036 RTR6285 Top Level LLDR, dated 09/25/2006 (QCPV01170060 - QCPV01170503) IMPEACHMENT ONLY - NOT FOR PREADMISSION


109 McKool 922227v1

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DATE ADMITTED




PX 4037 Russ O'Haver and Brian Finnegan, Estimating the Effects of Exclusivity and Geographic Market Characteristics on Royalty Rates: Some Preliminary Results, LER, Vol. 4, No. 2, dated 11/00/1993 (04/26/2013 Leonard Deposition Ex. 4, QCPV011508511 - QCPV011508514


PX 4038 RTR6285 co-design Review with team, dated 12/00/2005 (QCPV006232708 - QCPV006232720) IMPEACHMENT ONLY - NOT FOR PREADMISSION

PX 4039 Spreadsheet - RTR6285 Core Team Action Items, dated 02/21/2007 (QCPV000614376 - QCPV000614389) IMPEACHMENT ONLY - NOT FOR PREADMISSION

PX 4040 Spreadsheet - RTR6285 (GZIF4) Core Team Action Meeting Minutes, dated 05/11/06 (QCPV000614789 - QCPV000614804) IMPEACHMENT ONLY - NOT FOR PREADMISSION


PX 4042 Spreadsheet - RTR6285 (GZIF4) Core Team Action Meeting Minutes, dated 05/24/06 (QCPV000614824 - QCPV000614844) IMPEACHMENT ONLY - NOT


110 McKool 922227v1

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DATE IDENTIFIED

DATE ADMITTED




FOR PREADMISSION







PX 4049 Spreadsheet - RTR6285 (GZIF4) Core Team Action Meeting Minutes,


111 McKool 922227v1

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DATE IDENTIFIED

DATE ADMITTED




dated 07/12/06 (QCPV000615044 - QCPV000615074) IMPEACHMENT ONLY - NOT FOR PREADMISSION



PX 4052 Spreadsheet - RTR6285 (GZIF4) Core Team Action Meeting Minutes, dated 07/26/06 (QCPV000615207-QCPV000615240) IMPEACHMENT ONLY - NOT FOR PREADMISSION

PX 4053 Not relevant Email from A. Hadjichristos to G. Kondapalli re Floorplan of Alpina TX LO Path and Tuned Buffer Path, dated 2/1/2006 (QCPV011273462 - QCPV011273462) IMPEACHMENT ONLY - NOT FOR PREADMISSION

PX 4054 Email from A. Hadjichristos to C. Persico, K. Sahota re Berkana Circuit Summary - Second Version of Presentation and Few More Comments and attachment entitled Berkana Circuits and Preliminary Team Evaluation Summary, dated 12/05/2005 (QCPV011273905 - QPV011273912



112 McKool 922227v1

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DATE IDENTIFIED

DATE ADMITTED




PX 4055 Email chain between A. Hadjichristos, K. Sahota and C. Persico re Berkana Circuit Summary - Second Version of Presentation and Few More Comments, dated 12/06/2005 (QCPV011273915 - QCPV011273916) IMPEACHMENT ONLY - NOT FOR PREADMISSION

PX 4056 K. Sahota email to S. Jha, et al. re Berkana Engineering Due Diligence Summary, dated 12/10/2005 (QCPV011273965 - QCPV011273966) IMPEACHMENT ONLY - NOT FOR PREADMISSION

PX 4057 C. Persico email to S. Jha re Berkana Engineering Due Diligence Summary, dated 12/10/2005 (QCPV011273969) IMPEACHMENT ONLY - NOT FOR PREADMISSION

PX 4058 A. Oberst email to S. Jha re Berkana Engineering Due Diligence Summary, dated 12/10/2005 (QCPV011273970 - QCPV011273971) IMPEACHMENT ONLY - NOT FOR PREADMISSION

PX 4059 K. Sahota email to S. Jha, et al. re Berkana Engineering Due Diligence Summary, dated 12/10/2005 (QCPV011273972 - QCPV011273974) IMPEACHMENT ONLY - NOT FOR PREADMISSION

PX 4060 C. Persico email to B. Adi, et al. re Berkana Engineering Due Diligence Summary, dated 12/12/2005 (QCPV011273982 -


113 McKool 922227v1

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DATE IDENTIFIED

DATE ADMITTED




QCPV011273984) IMPEACHMENT ONLY - NOT FOR PREADMISSION

PX 4061 J. Tran email to C. Persico, et al. re Berkana Engineering Due Diligence Summary, dated 12/12/2005 (QCPV011273991 - QCPV011273994) IMPEACHMENT ONLY - NOT FOR PREADMISSION

PX 4062 G. Hartmann email to J. Tran, A. Hadjichristos re RTR6285 with Berkana Plan, dated 12/14/2005 (QCPV011273995) IMPEACHMENT ONLY - NOT FOR PREADMISSION

PX 4063 G. Hartmann email to M. Khan, et al. re RTR6285 Slides for Discussion - 8:30 am Conf Call, dated 12/15/2005 (QCPV011274034) IMPEACHMENT ONLY - NOT FOR PREADMISSION


Apple, Apple Reinvents the Phone with iPhone, http://www.apple.com/pr/library/2007/01/09Apple-Reinvents-the-Phone-with-iPhone.html (last visited Dec. 5, 2012) IMPEACHMENT ONLY - NOT FOR PREADMISSION


Ariel Rubenstein, Zvi Safra, and William Thompson, On the Interpretation of the Nash Bargaining Solution and Its Extension to Non-Expected Utility Preferences, ECONOMETRICA, Vol. 60, No. 5 (September 1992) (PV00467921 - PV00467936) IMPEACHMENT ONLY - NOT FOR PREADMISSION


114 McKool 922227v1

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DATE IDENTIFIED

DATE ADMITTED




PX 4067 Elizabeth M. Bailey, Gregory K. Leonard, Mario A. Lopez, Making Sense of ‘Apportionment’ in Patent Damages, THE COLUMBIA SCIENCE AND TECHNOLOGY LAW REVIEW, Vol. 12 (2011) (PV00467890 - PV00467906) IMPEACHMENT ONLY - NOT FOR PREADMISSION

PX 4068 Eran Hanany, D. Mark Kilgour, and Yigal Gerchak, Final-Offer Arbitration and Risk Aversion Bargaining, MANAGEMENT SCIENCE, Vol. 53, No. 11 (November 2007) (PV00467816 - PV00467824) IMPEACHMENT ONLY - NOT FOR PREADMISSION

PX 4069 Eric Greenleaf, Ambar Rao, and Atanu Sinha, Guarantees in Auctions: The Action House as Negotiator and Managerial Decision Maker, MANAGEMENT SCIENCE, Vol. 39, No. 9 (1993) (PV00467873 - PV00467889) IMPEACHMENT ONLY - NOT FOR PREADMISSION

PX 4070 Kai Chang, RF and Microwave Wireless Systems 165 (Wiley-Interscience 2000) (PV00468144 - PV00468166) IMPEACHMENT ONLY - NOT FOR PREADMISSION

PX 4071 RTR6285 Top Level LLDR 80-V4341-67 Rev A., Prepared by the RTR6285 design team, dated 09/25/2006 (QCPV000003684 - QCPV000004128) IMPEACHMENT ONLY - NOT FOR PREADMISSION


115 McKool 922227v1

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DATE IDENTIFIED

DATE ADMITTED




PX 4072 RTR8700 (Hercules) Objective Specification 80-VN380-11 Rev. , dated 06/05/2009 (QCPV010483980 - QCPV010484051) IMPEACHMENT ONLY - NOT FOR PREADMISSION

PX 4073 Email chain between A. Hadjichristos and W. Sampson et al. regarding RTR6280 receiver dated 04/20/2005 (QCPV005932686) IMPEACHMENT ONLY - NOT FOR PREADMISSION


ATTACHMENT A-2

(Defendant’s Exhibit List)


EXHIBIT LIST ____ PLAINTIFF X DEFENDANT ____ JOINT

____ GOVERNMENT _____ COURT CASE No. 3:11-cv-719-J-37TEM

STYLE:

EXHIBIT

NO. DATE

IDENTIFIED DATE

ADMITTED SPONSORING

WITNESSES OBJECTIONS / STIPULATED

ADMISSIONS1 DESCRIPTION OF EXHIBIT

DX001 For impeachment and/or cross only

Expert Report of Paul C. Benoit


Expert Report of Paul C. Benoit, Exhibits


Opening Expert Report of Dr. Paul Prucnal


Opening Expert Report of Dr. Paul Prucnal, Appendices

DX005 402/403 ParkerVision's Rule 26(a)(2)(C) Disclosure of Testimony by Jeffrey Parker and David Sorrells


Rebuttal Expert Report of Paul Prucnal


Rebuttal Expert Report of Paul Prucnal, Appendix A


Rebuttal Report of Peter Weisskopf

DX009 403/702/801/802 Expert Report of Dr. Behzad Razavi, Appendix A - Razavi CV

DX010 403/702/801/802 Expert Report of Dr. Gregory K. Leonard, Appendix A - Leonard CV

DX011 403/702/801/802 Expert Report of Joseph L. Hanna, Appendix A - Hanna CV

DX012 403/702/801/802 Expert Report of Robert M. Fox, Ph.D., Appendix A - Fox CV

DX013 403/702/801/802 Expert Report of Tim A. Williams, Appendix A - Williams CV

DX014 402/403 ParkerVision, Inc. Q2 2012 Earnings Conference Call Transcript, 8/15/2012

DX015 402/403 Executive Employment Agreement Between ParkerVision and David Sorrells (2008)

DX016 402/403 File History of U.S. Patent No. 6,061,551, Letter from PTO to M. Lee Granting Petition to Make Special

DX017 402/403 ParkerVision Inc., Annual Report (Form 10-K) (filed March 30, 2000)

DX018 402/403 ParkerVision Inc., Annual Report (Form 10-K) (filed April 1, 2002)

1 Use a code (e.g. “A” or “*”) in this column to identify exhibits to be received in evidence by agreement without objection. Otherwise, specifically state each objection to each opposed exhibit. Please note that each date box on the left must be one inch wide to accommodate the clerk’s date stamp.


2.

EXHIBIT

NO. DATE

IDENTIFIED DATE

ADMITTED SPONSORING



DX019 402/403 ParkerVision Inc., Annual Report (Form 10-K) (filed March 15, 2004)

DX020 402/403 ParkerVision’s Objections and Responses to Interrogatories No. 1-12 (3/5/12)

DX021 402/403 ParkerVision’s First Supplemental Objections and Responses to Qualcomm's First Set of Interrogatories (No. 6-8) (9/13/12)

DX022 801/802 Qualcomm Press Release "Qualcomm Announces radioOne ZIF Single-Band Cellular Chipsets" (12/11/02)

DX023 ParkerVision White Paper entitled "direct2data" (2004)

DX024 ParkerVision Memorandum "Design and Test Considerations for the CDMA Transceiver" (10/00)

DX025 ParkerVision Press Release "ParkerVision Announces Successful Development of the Most Integrated High Performance Wireless LAN Transceiver Chips Currently Available" (7/30/02)

DX026 ParkerVision Advertisement for WR3000 Product

DX027 402/403 Email Chain Between J. Parker and J. Leach et al. re Meetings With Motorola re ParkerVision Transceiver (2/21/05)

DX028 402/403 ParkerVision Presentation "Investor Presentation" (1/09)

DX029 Joint Cooperation and Subcontract Agreement Between VIA Telecom and ParkerVision (12/4/09)

DX030 402/403 Email Chain Between R. Harlan and J. Medina re Articles by S. Zhou and A. Parssinen (7/21/11)

DX031 402/403 Email from J. Yarnell to D. Sorrells re ITT (6/24/08)

DX032 402/403 Khatri, H. et al., "A SAW-less CDMA Receiver Front-End with Single-Ended LNA and Single-Balanced Mixer with 25% Duty-Cycle LO in 65nm CMOS," 2009 IEEE Radio Frequency Integrated Circuits Symposium, pp.13-16

DX033 402/403 Email Chain Between D. Sorrells and J. Parker re Visit to Aironet and Cisco (9/5/00)

DX034 402/403/801/802 ParkerVision Internal Q&A Document Discussion Draft v. 3.0 (6/08)

DX035 402/403 ParkerVision Briefing (2/08) DX036 402/403 Email Chain Between J. Stuckey and R. Harlan

et al. re SK Telecom and FCI (4/26/07) DX037 402/403 Email Chain Between D. Sorrells and E.

Cockrell et al. re PrairieComm (11/1/00) DX038 ParkerVision White Paper "direct2data Appendix

A1: Power Signal Representation by Energy Signal Decomposition and Fourier Analysis" (10/03)

DX039 ParkerVision White Paper "direct2data Appendix A2: D2D Correlator and Simple First Order Approximation" (10/03)

DX040 10/31/03 ParkerVision Appendix A3 to "D2D Complex Down Converter"


3.

EXHIBIT

NO. DATE

IDENTIFIED DATE

ADMITTED SPONSORING



DX041 11/28/12 ParkerVision Appendix A4 to "Non Zero Sampling Aperture Derivation"

DX042 ParkerVision White Paper "direct2data Appendix A5: Baseband Power, SNR and Output BW" (10/03)

DX043 2003 ParkerVision White Paper "D2D Fundamental Theory"

DX044 402/403 Email Chain Between J. Leach to SH Kim re Samsung Plan (7/22/11)

DX045 ParkerVision White Paper "ParkerVision d2d Receiver Technology Introduction" (10/27/10)

DX046 402/403 Email Between J. Parker and D. Sorrells et al. re Draft ParkerVision Press Release "ParkerVision, Inc. Signs Licensing Agreement with Cell Phone Chipset Supplier" (12/17/07)

DX047 402/403 Email Chain Between J. Kim and J. Leach et al. re ParkerVision Use of FCI Receiver (1/19/09)

DX048 801/802 Micro-Ant Presentation "Report # CVG-ESA-101909 Micro-Ant Direct Conversion Ku-band ESA, Prepared for CVG" (10/09)

DX049 ParkerVision Presentation "d2d Receiver Technology" (10/17/08)

DX050 ParkerVision Short Form D2D White Paper (2/05)

DX051 402/403 Email Chain Between E. Kovach and J. Parker re Nokia Meeting (10/20/05)

DX052 ParkerVision Press Release "ParkerVision Announces Sample Phones Tested and Accepted by Its Commercial Chipset Customer" (10/26/99)

DX053 ParkerVision Presentation "ParkerVision, Renesas Technology Europe" (9/26/08)

DX054 402/403/PRIVILEGE ParkerVision Spreadsheet "ParkerVision Patents Asserted" (7/2/11)

DX055 402/403 Email Chain Between R. Harlan and J. Stuckey et al. re Lack of Viability of Phones with Many Receive Bands, Diversity Receiver and GPS (6/12/09)

DX056 Email Chain Between J. Yarnell and B. Solada re Engineering Update (4/3/09)

DX057 402/403 Email Chain Between J. Parker and J. Stuckey et al. re Draft ParkerVision Press Release "ParkerVision, Inc. Signs Licensing and Product Development Agreement with Cell Phone Chipset Supplier" (12/17/07)

DX058 402/403 Email Chain Between J. Leach and D. Sorrells re Potential VIA Relationship (12/18/07)

DX059 Email from D. Figueredo to J. Parker et al. re Meeting Between ParkerVision and FCI (5/29/09)

DX060 402/403 Email Chain Between D. Sorrells and J. Parker re Biographies of ParkerVision Personnel (7/21/00)

DX061 402/403 Email Chain Between SH Kim and J. Moon re FCI (12/19/08)

DX062 ParkerVision White Paper re Sampling in D2D (2007)


4.

EXHIBIT

NO. DATE

IDENTIFIED DATE

ADMITTED SPONSORING



DX063 402/403 Email Chain Between R. Harlan and J. Stuckey et al. re D2D (10/20/08)

DX064 402/403 Email Chain Between D. Sorrells and J. Stuckey re Receiver Marketing Materials (11/11/09)

DX065 402/403 Email from J. Yarnell to D. Sorrells re, inter alia, Investigating Qualcomm Products for Infringement (10/5/07)

DX066 402/403 Email Chain Between J. Parker and D. Sorrells re Liu, L., "Tri-band SAW-less High Linearity Low Noise CDMA Receiver in 65nm CMOS," IEEE 2010 (6/22/11)

DX067 402/403 Lie, L., "Tri-band SAW-less High Linearity Low Noise CDMA Receiver in 65nm CMOS," IEEE 2010

DX068 402/403 ParkerVision Meeting Minutes from FCI Meeting (4/6/06)

DX069 402/403 Email From J. Yarnell to D. Sorrells re Qualcomm Chips (11/6/07)

DX070 402/403 Email Chain Between D. Jacobs and D. Sorrells re Qualcomm Product Documents (6/10/08)

DX071 402/403/801/802/901 Portelligent Die Photos of QSC6010 (6/08) DX072 402/403 Email Chain Between J. Parker and F. Jungman

re FCI (9/12/10) DX073 402/403 Email Chain Between D. Figueredo and J.

Parker re Negotiations with FCI (2/27/09) DX074 Email From D. Sorrells to C. Panasik re Meeting

with TI (6/21/99) DX075 Email Chain Between J. Moon and J. Stuckey et

al. re d2p (8/7/07) DX076 402/403 Email Chain Between J. Leach and SH Kim re

Meetings with SK Telecom and FCI (2/2/07) DX077 Email From D. Sorrells to J. Hamilla re Ericsson

and Qualcomm (5/8/98) DX078 Email Chain Between D. Sorrells and F.

Jungman re D2P (12/11/08) DX079 ParkerVision Presentation "ParkerVision

Technology Presentation Presented to Ashok Kumar" (5/11)

DX080 ParkerVision "MOU: Business Proposal, VIA-ParkerVision Technology License: RF Power Transmitter (D2P)" (8/27/07)

DX081 Email from J. Stuckey to M. Davis et al., re List of Open Items Between ParkerVision and VIA (12/18/07)

DX082 Email From J. Stuckey to M. Davis re Royalty Rates Proposed by VIA (12/19/07)

DX083 402/403 Email Chain Between J. Yarnell and J. Parker re Received Qualcomm Chips (10/17/07)

DX084 402/403/801/802 ParkerVision Meeting Minutes from Motorola Meeting (4/21/05)

DX085 Email from J. Moon to J. Leach re VIA Visit to ParkerVision (8/26/07)

DX086 402/403 ParkerVision "Competitive Product Data" (6/15/09)

DX087 402/403 Email Chain Between K. Waters and J. Yarnell et al. re Phillips Direct Conversion Receiver (12/17/08)


5.

EXHIBIT

NO. DATE

IDENTIFIED DATE

ADMITTED SPONSORING



DX088 List of Non-Disclosures and Other ParkerVision Agreements, 1996-2006

DX089 402/403 Email Chain Between G. Rawlins and J. Leach re Samples for Samsung (7/21/11)

DX090 Email Chain Between D. Sorrells and J. Baker re Difficulties in Qualcomm Negotiation (6/29/99)

DX091 ParkerVision Presentation "What is Direct2Data" (2000)

DX092 Email chain between J. Parker and D. Sorrells re D2D White Paper (10/27/10)

DX093 ParkerVision Presentation "d2d Receiver Introduction" (8/07)

DX094 Email from J. Media to All ParkerVision Employees Containing ParkerVision Press Release "ParkerVision, Inc. Signs Licensing Agreement with Chip Supplier for Mobile Handsets" (12/21/07)

DX095 ParkerVision Brochure "PV8212X" (2011) DX096 Email Chain Between M. Rawlins and D.

Figueredo re Use of D2D in WCDMA Receiver DX097 402/403 Email Chain Between J. Moon and J. Leach re

Commercializing D2D DX098 402/403 Email Chain Between J. Leach and J. Stuckey

re SK Telecom and FCI Action Items (3/13/07) DX099 Email Chain Between J. Parker to F. Jungman

re ParkerVision Rx Solution for VIA (1/3/12) DX100 Email From J. Leach to J. Moon re FCI

Partnership (2/7/07) DX101 402/403 Email Chain Between J. Yarnell and J. Neiner re

Awareness of FCI Chipset (1/23/06) DX102 402/403 Qualcomm radioOne Zero-IF Chipset Design

Guidelines (3/29/02) DX103 402/403 Email Chain Between J. Moon and SH Kim re

Partnership with SK Telecom DX104 Email Chain Between A. Mugisha and J. Leach

et al. re Measurements of Boards Containing FCI Module (2/8/12)

DX105 402/403 Memorandum of J. Moon re Ski Telecom and FCI (5/07)

DX106 ParkerVision Press Release "ParkerVision, Inc. and LG Innotek Enter Into Joint Development Agreement" (12/4/08)

DX107 801/802 ParkerVision Memorandum re Grenoble Agreement (2/09)

DX108 Email from D. Figueredo to J. Parker et al. re Update on Development of HR-3 Board (4/6/09)

DX109 Email Chain Between J. Stuckey and D. Figueredo re Development of D2D Universal Radio (6/2/09)

DX110 402/403 Email From D. Sorrells to J. Parker et al. re ParkerVision Rx Program (7/6/09)

DX111 ParkerVision Proposed Analog HEDGE RX RF and Analog Baseband Block Diagram (7/6/09)

DX112 Email from D. Figueredo to J. Parker et al. re Choice of Receiver Technology (7/19/09)

DX113 ParkerVision Presentation "Sales-Marketing: Program Overview" (8/10)


6.

EXHIBIT

NO. DATE

IDENTIFIED DATE

ADMITTED SPONSORING



DX114 402/403 Email Chain Between J. Yarnell and D. Sorrells re Photographs of Qualcomm Chip Dies (10/2/07)

DX115 402/403 ParkerVision Presentation "Die Photo Project" Containing Photographs of Qualcomm Chip Dies (10/2/07)

DX116 Email Chain Between M. Rawlins and D. Figueredo et al. re Size of D2D Components in Receiver (6/25/08)

DX117 Email Chain Between D. Figueredo and J. Leach re Using D2D or FCI Receiver (2/10/09)

DX118 Email Chain Between J. Parker and J. Leach re Using FCI Module (2/10/09)

DX119 402/403 Email from J. Leach to J. Moot et al. re Meeting with SK Telecom and FCI (3/8/07)

DX120 402/403 Email Chain Between D. Figueredo and J. Yarnell re Use of Infineon and FCI Receivers (2/4/09)

DX121 Email Chain Between J. Leach to J. Median et al. re ParkerVision-VIA Relationship (3/15/12)

DX122 Email Chain Between J. Leach and J. Media re ParkerVision-VIA Relationship (3/15/12)

DX123 402/403/801/802 Email Chain Between J. Stuckey and J. Leach re Meetings with LG Innotek and SK Telecom (9/5/08)

DX124 402/403 Email Chain Between J. Stuckey and D. Figueredo re Use of D2D in CDMA 2K Receiver

DX125 402/403 Email Chain Between R. Harlan and J. Stuckey re FCI Meeting (5/6/09)

DX126 402/403 ParkerVision Meeting Minutes from Samsung Meeting (5/19/05)



DX129 402/403 ParkerVision Meeting Minutes from Samsung Meetings (6/15/05 and 6/16/05)

DX130 402/403 ParkerVision Meeting Minutes from Samsung Meeting (5/19/05) (condensed)

DX131 402/403 ParkerVision Draft Memorandum of Understanding with Samsung (7/17/05)

DX132 Email from J. Stuckey to M. Davis et al. re Draft Statement of Work in VIA-ParkerVision Agreement (12/18/07)

DX133 402/403 ParkerVision Press Release "ParkerVision Reports Fourth Quarter 2008 and Year-End Results" (3/16/09)

DX134 402/403 ParkerVision Press Release "ITT Announces Demonstration of Breakthrough D2P(TM) Technology at Recent Gomactech 2009 Conference" (3/26/09)

DX135 402/403 ParkerVision Press Release "ParkerVision, Inc. and LG Innotek Enter Into Joint Development Agreement" (12/4/08)

DX136 ParkerVision Presentation "CDMA Receiver Technology Development" (8/2/05)

DX137 ParkerVision "Original d2d Introduction Draft by Jeff Parker" (12/10)


7.

EXHIBIT

NO. DATE

IDENTIFIED DATE

ADMITTED SPONSORING



DX138 ParkerVision "d2d Receiver Technology Introduction" (10/10)

DX139 ParkerVision White Paper "ParkerVision d2d Receiver Technology Introduction" (10/27/10)

DX140 402/403 Qualcomm RFT6100 RF Transmitter Device Specification (5/12/03)

DX141 Email Chain Between J. Schrenger and J. Stuckey et al. re VIA Negotiations (12/12/07)

DX142 "Corporate History of ParkerVision, Inc. DX143 402/403 ParkerVision Press Release "ParkerVision, Inc.

Reports 2011 Fourth Quarter and Year-End Results" (3/30/12)

DX144 402/403 ParkerVision Meeting Minutes from Samsung Meeting (6/27/06 and 6/28/06)

DX145 ParkerVision Meeting Minutes of Meeting with VIA Telecom (8/27/07)

DX146 402/403 ParkerVision Meeting Minutes from SK Telecom Meeting (3/11/08)

DX147 ParkerVision Presentation "ParkerVision Technology Presentation, Presented to Samsung" (4/21/11)

DX148 402/403/801/802 Qualcomm's Motion to Strike / Compel Regarding ParkerVision's Inadequate Infringement Contentions, and Supporting Memorandum of Law, Dkt. 154 (8/27/12)

DX149 402/403/801/802 Declaration of Jeremy D. Dunworth, Dkt. 155 (8/27/99)

DX150 402/403/801/802 Declaration of James E. Canning, Dkt. 156 (8/27/12)

DX151 402/403/801/802 Exhibit 1 to Declaration of James E. Canning, Dkt. 156-1, Transcript of Markman Hearing

DX152 402/403 Exhibit 2 to Declaration of James E. Canning, Dkt. 156-2, Transcript of ParkerVision Inc. Conference Call of 7/21/11

DX153 402/403/801/802 Exhibit 3 to Declaration of James E. Canning, Dkt. 156-3, Letter from K. Hummel to All Counsel, 12/9/11

DX154 402/403 Exhibit 4 to Declaration of James E. Canning, Dkt. 156-4, Plaintiff ParkerVision Inc.'s Disclosure of Asserted Claims and Infringement Contentions, 1/30/12

DX155 402/403/801/802 Exhibit 5 to Declaration of James E. Canning, Dkt. 156-5, Letter from D. Greenwald to A. Curry, 2/13/12

DX156 402/403 Exhibit 6 to Declaration of James E. Canning, Dkt. 156-6, Letter from A. Curry to D. Greenwald, 2/17/12

DX157 402/403/801/802 Exhibit 7 to Declaration of James E. Canning, Dkt. 156-7, Letter from D. Greenwald to A. Curry, 2/24/12

DX158 402/403 Exhibit 8 to Declaration of James E. Canning, Dkt. 156-8, Plaintiff ParkerVision Inc.'s Disclosure of Asserted Claims and Infringement Contentions, 3/2/12


8.

EXHIBIT

NO. DATE

IDENTIFIED DATE

ADMITTED SPONSORING



DX159 402/403/IC Exhibit 9 to Declaration of James E. Canning, Dkt. 156-9, Plaintiff ParkerVision's First Request for the Production of Documents, ESI, and Things to Defendant Qualcomm Incorporated (excerpt), 3/13/12

DX160 402/403 Exhibit 10 to Declaration of James E. Canning, Dkt. 156-10, Exhibit A.1 of ParkerVision's Infringement Contentions

DX161 402/403 Exhibit 11 to Declaration of James E. Canning, Dkt. 156-11, Letter from J. Budwin to J. Canning, 8/21/12

DX162 402/403/801/802 Exhibit 12 to Declaration of James E. Canning, Dkt. 156-12, Letter from K. Hummel to S. Busey, 10/19/11

DX163 402/403/801/802 Exhibit 13 to Declaration of James E. Canning, Dkt. 156-13, Letter from J. Canning to J. Budwin (8/17/12)

DX164 403/702/801/802 Expert Report of Joseph L. Hanna DX165 403/702/801/802 Expert Report of Dr. Gregory K. Leonard DX166 403/702/801/802 Expert Report of Dr. Gregory K. Leonard,

Exhibits DX167 403/702/801/802 Expert Report of Dr. Behzad Razavi,

Appendices DX168 403/702/801/802 Expert Report of Tim A. Williams DX169 403/702/801/802 Expert Report of Tim A. Williams, Appendices DX170 403/702/801/802 Rebuttal Expert Report of Tim A. Williams DX171 403/702/801/802 Rebuttal Expert Report of Tim A. Williams,

Appendix A DX172 403/702/801/802 Expert Report of Dr. Behzad Razavi, Errata

Sheet (4/29/13) DX173 403/702/801/802 Expert Report of Dr. Behzad Razavi, Correction

(3/18/13) DX174 403/702/801/802 Letter from A. Karp to J. Budwin re Corrections

to Expert Report of Dr. Behzad Razavi (3/18/13) DX175 403/702/801/802 Expert Report of Tim A. Williams and Rebuttal

Expert Report of Tim A. Williams, Corrections DX176 403/702/801/802 Expert Report of Robert M. Fox, Ph.D., Errata

(5/2/13) DX177* 403/801/802 Jackson, W. "Public Safety Network Has Eye-

Opening First Real-World Test," Government Computer News, September 27, 2012

DX178 402/403 Plaintiff ParkerVision Inc.’s Disclosure of Asserted Claims and Infringement Contentions, Exhibit A.1, 3/2/12

DX179 402/403/602/801/802 U.S. Patent No. 7,769,361 (Zhuo et al.) (filed (Sep. 14, 2006)

DX180 402/403/602/801/802 U.S. Patent No. 7,826,816 (Zhuo et al.) (filed Sep. 13, 2006)

DX181 402/403 Email Chain Between J. Stuckey and R. Harlan re Attendance at IEEE RFIC Conference

DX182 402/403 Email from K. Nemecek to D. Figueredo et al. re Analysis of Samsung Handset SGH-U9000 "Soul" (11/11/08)

* Qualcomm does not intend to use this exhibit in front of the jury, but may use it to oppose any motion for an injunction.


9.

EXHIBIT

NO. DATE

IDENTIFIED DATE

ADMITTED SPONSORING



DX183 402/403 Email Chain Between C. Moses and R. Harlan Attaching Qualcomm Presentation "Single-Chip CMOS UMTS/EGSM Transceiver with Integrated Receive Diversity and GPS" (6/12/09)

DX184 402/403 Email from R. Harlan to J. Medina re Qualcomm Article "A SAW-Less CDMA Receiver Front-End with Single-Ended LNA and Single-Balanced Mixer with 25% Duty-Cycle LO in 65nm CMOS" (7/20/09)

DX185 402/403 Email from R. Harlan to D. Sorrells Attaching Khatri et al., ""A SAW-Less CDMA Receiver Front-End with Single-Ended LNA and Single-Balanced Mixer with 25% Duty-Cycle LO in 65nm CMOS," 2009 IEEE Radio Frequency Integrated Circuits Symposium, pp. 13-16 (7/2/99)

DX186 402/403 Khatri et al., ""A SAW-Less CDMA Receiver Front-End with Single-Ended LNA and Single-Balanced Mixer with 25% Duty-Cycle LO in 65nm CMOS," 2009 IEEE Radio Frequency Integrated Circuits Symposium, pp. 13-16

DX187 402/403 Email from J. Medina to R. Harlan Attaching Kim, "A Highly Linear SAW-less CMOS Receiver Using a Mixer with Embedded Tx Filtering for CDMA," IEEE 2008 CICC, pp. 729-732

DX188 Email Chain Between J. Stuckey and R. Harlan re Description of d2d (8/5/09)

DX189 402/403 Email Chain Between R. Harlan and D. Sorrells re Patents Relating to DC Offsets

DX190 402/403 Email From R. Harlan to D. Sorrells re Qualcomm Patent No. 7,826,816

DX191 402/403 ParkerVision Presentation "QCT Low Duty-Cycle Converter" (5/13/11)

DX192 402/403 Email Chain Between D. Sorrells and R. Harlan Attaching Cicalini, A. et al., "A 65nm CMOS SoC with Embedded HSDPA/EDGE Transceiver, Digital Baseband and Multimedia Processor," ISSCC 2011, Session 21, Cellular, 21.3, pp. 9-11, including comments (5/23/11)

DX193 402/403 Email from R. Harlan to J. Parker Attaching Soer, M., "Analysis and Comparison of Switch-Based Frequency Converters," University of Twente, MSc. Thesis, September 2007 (5/27/11)

DX194 402/403 From Files of R. Harlan, Soer, M., "Analysis and Comparison of Switch-Based Frequency Converters," University of Twente, MSc. Thesis, September 2007, with Highlighting

DX195 402/403 Email Chain Between J. Parker and D. Sorrells re Qualcomm Receivers and Attachments(6/22/11)

DX196 402/403 ParkerVision Presentation "QCT RF Chipset Roadmaps" (7/26/11)


10.

EXHIBIT

NO. DATE

IDENTIFIED DATE

ADMITTED SPONSORING



DX197 402/403 Email Chain between J. Medina and R. Harlan Attaching Parssinen, "A 2-GHz Subharmonic Sampler for Signal Downconversion," IEEE Transactions on Microwave Theory and Techniques, Vol. 45, No. 12, December 1997, pp. 2344-51

DX198 402/403 ParkerVision Presentation "QCT RF Forensic Selections" (8/1/11)

DX199 402/403 ParkerVision Presentation "Superhet to Energy Sampling: Board Area & Parts Count" (7/18/12)

DX200 ParkerVision Presentation "d2d Fundamental Principles" (7/11)

DX201 402/403 Email Chain Between R. Harlan and K. Nemecek re Qualcomm Baseband Products and Attachments (3/25/08)

DX202 402/403 Email From J. Leach to R. Harlan re Analysis of Qualcomm Products and Attachments (7/22/08)

DX203 402/403 Email Chain Between R. Harlan and J. Leach et al. re Qualcomm Products (1/16/09)

DX204 402/403 Email Chain Between J. Leach and M. Rawlins et al. re Qualcomm Products (1/16/09)

DX205 402/403 Email from J. Leach to R. Harlan Attaching Qualcomm MSM6275 Specification (10/27/09)

DX206 402/403 Email Chain Between J. Leach and R. Harlan Attaching Qualcomm QSC6240/QSC6270 Enhanced Qualcomm Single Chip Device Specification (8/19/11)

DX207 402/403 Email From R. Harlan to D. Sorrells Attaching Qualcomm Presentation "RF Platform F/G (RTR6285/RTR6280) Topics" (12/8/11)

DX208 402/403 Qualcomm Presentation "RF Platform F/G (RTR6285/RTR6280) Topics" (3/07)

DX209 ParkerVision Presentation "QCT RF Forensic Roadmap" (8/28/11)

DX210 ParkerVision Datasheet "PV4515.4GTPA Multiband Multimode Power Transmitter" (2008)

DX211 402/403 Email from J. Leach to M. Lee re Qualcomm Product (5/4/05)

DX212 402/403 Qualcomm RFT6120 Baseband-to-RF Transmitter Device Specification (8/29/03)

DX213 402/403 Email Chain Between J. Leach and M. Lee re Qualcomm Products

DX214 402/403 Qualcomm radioOne Zero-IF Chipset Design Guidelines (3/29/02)

DX215 402/403 Qualcomm RFT6100 RF Transmitter Device Specification (5/12/03)

DX216 402/403 Email Chain Between J. Leach and J. Parker re Qualcomm Product Documents (5/6/05)

DX217 402/403 Email from J Leach to F. Krupczynski re Qualcomm Product Documents (5/6/05)

DX218 402/403 Email Chain between J. Leach and J. Neiner re Qualcomm Product Documents (8/2/05)

DX219 402/403 Email from J. Leach to D. Sorrells re Qualcomm Product Documents (8/11/06)

DX220 402/403 Email from J. Moon to J. Leach re Qualcomm Product Documents (10/18/07)


11.

EXHIBIT

NO. DATE

IDENTIFIED DATE

ADMITTED SPONSORING



DX221 402/403 Qualcomm MSM6250/MSM6250A/MSM6225 Mobile Station Modem Device Specification (6/14/05)

DX222 402/403 Email from J. Leach to J. Parker re Qualcomm Product Documents (11/7/07)

DX223 402/403 Email From J. Moon to J. Leach re Qualcomm Product Documents

DX224 402/403 Qualcomm RTR6250 RF Transceiver Device Specification (9/28/06)

DX225 402/403 Qualcomm RFR6250 RF Receiver Device Specification (9/28/06)

DX226 402/403 Email Chain Between S. Kim and [email protected] re Qualcomm Product Documents (3/21/06)

DX227 402/403 Qualcomm MSM6800A/MSM6575/MSM6800 MSM Device Specification (12/21/06)

DX228 402/403 Email from J. Moon to J. Leach re Qualcomm Product Documents

DX229 402/403 Qualcomm MSM6275 ASIC and FFA6275 Current Consumption Data (2/23/06)

DX230 402/403 Qualcomm MSM6275 Mobile Station Modem Device Specification (1/18/08)

DX231 402/403 Email from SH Kim to J. Moon re Qualcomm Product Documents (4/8/08)

DX232 402/403 Email from J. Leach to R. Harlan Attaching Qualcomm Product Documents (10/27/09)

DX233 402/403 Email Chain Between J. Leach and J. Parker re Qualcomm Product Documents (3/29/11)

DX234 402/403 Email from J. Leach to F. Jungman re Qualcomm Product Details (2/10/09)

DX235 402/403 ParkerVision Memorandum Analyzing Qualcomm Products (2/10/09)

DX236 402/403 Qualcomm MSM6275 ASIC and FFA6275 Current Consumption Data (2/23/06)

DX237 402/403 Qualcomm MSM6800A/MSM6575/MSM6800 MSM Device Specification (12/21/06)

DX238 402/403 Email from [email protected] to J. Leach et al. re Qualcomm Product Information (8/19/11)

DX239 402/403 Qualcomm QSC6240/QSC6270 Enhanced Qualcomm Single Chip Device Specification (11/5/09)

DX240 ParkerVision PV-1000hb 802.11b RF Transceiver Specifications (2002)

DX241 402/403 Email from J. Budwin to J. Canning, 10/03/2012 DX242 402/403 ParkerVision's First Set of Interrogatories to

Qualcomm (Nos. 1-9) (1/18/12) DX243 Qualcomm's Objections and Responses to

ParkerVision's First Set of Interrogatories (Nos.1-9) (2/21/12)

DX244 Qualcomm's Supplemental Exhibit B to ParkerVision's First Set of Interrogatories (Nos. 1-9) (3/2/12)

DX245 Qualcomm's Exhibit C to ParkerVision's First Set of Interrogatories (Nos. 1-9) (6/21/12)

DX246 Qualcomm's Second Supplemental Objections and Responses to ParkerVision's First Set of Interrogatories (Nos. 1-9) (9/14/12)


12.

EXHIBIT

NO. DATE

IDENTIFIED DATE

ADMITTED SPONSORING



DX247 Qualcomm's Third Supplemental Objections and Responses to ParkerVision's First Set of Interrogatories (Nos. 1-9) (10/3/12)

DX248 Qualcomm's Exhibit D to ParkerVision's First Set of Interrogatories (Nos. 1-9) (10/3/12)

DX249 Qualcomm's Fourth Supplemental Objections and Responses to ParkerVision's First Set of Interrogatories (Nos. 1-9) (12/14/12)

DX250 Qualcomm's Supplemental Exhibit D to ParkerVision's First Set of Interrogatories (Nos. 1-9) (12/14/12)

DX251 Qualcomm's Fifth Supplemental Objection and Responses to ParkerVision's First Set of Interrogatories (Nos. 1-9) (1/18/13)

DX252 Qualcomm's Sixth Supplemental Objections and Responses to ParkerVision's First Set of Interrogatories (Nos. 1-9) (2/5/13)

DX253 402/403 ParkerVision's Second Set of Interrogatories to Qualcomm (10-14) (3/12/12)

DX254 402/403 Qualcomm's First Supplemental Objections and Responses to ParkerVision's Second Set of Interrogatories (Nos. 10-14) (9/14/12)

DX255 Qualcomm's Second Supplemental Objections and Responses to ParkerVision's Second Set of Interrogatories (Nos. 10-14) (10/16/12)

DX256 Qualcomm's Third Supplemental Objections and Responses to ParkerVision's Second Set of Interrogatories (Nos. 10-14) (1/16/13)

DX257 Qualcomm's Fourth Supplemental Objections and Responses to ParkerVision's Second Set of Interrogatories (Nos. 10-14) (6/13/13)

DX258 402/403 ParkerVision's Third Set of Interrogatories to Qualcomm (Nos. 15-18) (8/31/12)

DX259 402/403 Qualcomm's Objections and Responses to ParkerVision's Third Set of Interrogatories (Nos. 15-18) (10/3/12)

DX260 Qualcomm's Supplemental Objections and Responses to ParkerVision's Third Set of Interrogatories (Nos. 15-18) (12/7/12)

DX261 Qualcomm's Second Supplemental Objections and Responses to ParkerVision's Third Set of Interrogatories (Nos. 15-18) (1/24/13)

DX262 402/403 ParkerVision's Fourth Set of Interrogatories to Qualcomm (No. 19) (9/28/12)

DX263 Qualcomm's Objections and Responses to ParkerVision's Fourth Set of Interrogatories (No. 19) (11/1/12)

DX264 Qualcomm's First Supplemental Objections and Responses to ParkerVision's Fourth Set of Interrogatories (No. 19) (1/24/13)

DX265 402/403 ParkerVision's Fifth Set of Interrogatories to Qualcomm (Nos. 20-25) (10/31/12)

DX266 Qualcomm's Objections and Responses to ParkerVision's Fifth Set of Interrogatories (Nos. 20-25) (11/30/12)

DX267 Qualcomm's First Supplemental Objections and Responses to ParkerVision's Fifth Set of Interrogatories (Nos. 20-25) (1/25/13)


13.

EXHIBIT

NO. DATE

IDENTIFIED DATE

ADMITTED SPONSORING



DX268 402/403 Qualcomm's First Set of Interrogatories to ParkerVision (Nos. 1-12) (1/30/12)

DX269 402/403 ParkerVision's Second Supplemental Objections and Responses to Qualcomm's First Set of Interrogatories (No. 6) (11/1/12)

DX270 402/403 Qualcomm's Second Set of Interrogatories to ParkerVision (Nos. 13-19) (10/12/12)

DX271 402/403 Qualcomm's Third Set of Interrogatories to ParkerVision (No. 20) (10/31/12)

DX272 402/403 ParkerVision's Objections and Responses to Qualcomm's Third Set of Interrogatories (No. 20) (12/3/12)

DX273 402/403 ParkerVision's First Set of Requests for Admission to Qualcomm (Nos. 1-52) (10/31/12)

DX274 Qualcomm's Objections and Responses to ParkerVision's First Set of Requests for Admission (Nos. 1-52) (12/4/12)

DX275 402/403 Qualcomm's First Set of Requests for Admission to ParkerVision (Nos. 1-24) (10/12/12)

DX276 402/403 ParkerVision's Objections and Responses to Qualcomm's First Set of Requests for Admission (Nos. 1-24) (11/16/12)

DX277 402/403 Qualcomm's Second Set of Requests for Admission to ParkerVision (Nos. 25-55) (10/31/12)

DX278 402/403 ParkerVision's Objections and Responses to Qualcomm's Second Set of Requests for Admission (Nos. 25-55) (12/7/12)

DX279 402/403 ParkerVision's First Requests for the Production of Documents, ESI, and Things to Qualcomm (Nos. 1-110) (3/13/12)

DX280 402/403 Qualcomm's Objections and Responses to ParkerVision's First Request for the Production of Documents, ESI and Things (Nos. 1-110) (4/30/12)

DX281 402/403 ParkerVision's Second Request for the Production of Documents, ESI, and Things to Qualcomm (Nos. 1-9) (5/3/12)

DX282 402/403 Qualcomm's Objections and Responses to ParkerVision's Second Request for the Production of Documents, ESI and Things (Nos. 1-9) (6/7/12)

DX283 402/403 ParkerVision's Third Requests for the Production of Documents, ESI, and Things to Qualcomm (Nos. 1-12) (8/14/12)

DX284 402/403 Qualcomm's Objections and Responses to ParkerVision's Third Request for the Production of Documents, ESI and Things (Nos. 1-12) (9/17/12)

DX285 402/403 ParkerVision's Fourth Set of Request for the Production of Documents, ESI, and Things to Qualcomm (Nos. 1-38) (9/4/12)

DX286 402/403 Qualcomm's Objections and Responses to ParkerVision's Fourth Request for the Production of Documents, ESI and Things (Nos. 1-38) (10/9/12)

DX287 402/403 ParkerVision's Fifth Request for the Production of Documents, ESI and Things to Qualcomm (Nos. 1-9) (10/31/12)


14.

EXHIBIT

NO. DATE

IDENTIFIED DATE

ADMITTED SPONSORING



DX288 402/403 Qualcomm's Objections and Responses to ParkerVision's Fifth Request for the Production of Documents, ESI and Things (Nos. 1-9) (11/30/12)

DX289 402/403 Qualcomm's First Request to ParkerVision for the Production of Documents, ESI and Things (Nos. 1-91) (10/30/12)

DX290 402/403 ParkerVision's Responses and Objections to Qualcomm's First Request for the Production of Documents, ESI and Things (Nos. 1-91) (3/5/12)

DX291 402/403 Qualcomm's Second Request to ParkerVision for the Production of Documents, ESI and Things (Nos. 1-12) (5/3/12)

DX292 402/403 ParkerVision's Responses and Objections to Qualcomm's Second Request for the Production of Documents, ESI and Things (Nos. 1-12) (6/7/12)

DX293 402/403 Qualcomm's Third Request to ParkerVision for the Production of Documents, ESI and Things (Nos. 1-25) (8/10/12)

DX294 402/403 ParkerVision's Responses and Objections to Qualcomm's Third Request for the Production of Documents, ESI and Things (Nos. 1-25) (9/13/12)

DX295 402/403 Qualcomm's Fourth Request to ParkerVision for the Production of Documents, ESI and Things (Nos. 1-37) (10/12/12)

DX296 402/403 ParkerVision's Responses and Objections to Qualcomm's Fourth Request for the Production of Documents, ESI, and Things (Nos. 1-37) (11/16/12)

DX297 402/403 Qualcomm's Fifth Request to ParkerVision for the Production of Documents, ESI and Things (Nos. 1-64) (10/30/12)

DX298 402/403 ParkerVision's Responses and Objections to Qualcomm's Fifth Request for the Production of Documents, ESI and Things (Nos. 1-64) (12/3/12)

DX299 402/403 Qualcomm's Sixth Request to ParkerVision for the Production of Documents, ESI and Things (No. 1) (10/31/12)

DX300 402/403 ParkerVision's Responses and Objections to Qualcomm's Sixth Request for the Production of Documents, ESI and Things (No. 1) (12/3/12)

DX301 801/802 Lee, T. "The Design of CMOS Radio-Frequency Integrated Circuits," Cambridge University Press, 1998, Chapter 12: Mixers

DX302 801/802 Lee, T. "The Design of CMOS Radio-Frequency Integrated Circuits," Cambridge University Press, 1998, Chapter 14: Feedback Systems

DX303 402/403 Email from L. Buratti to J. Canning re PVD2510R Chip Schematics Available for Inspection (7/23/13)

DX304 801/802 Muhammad, K. et al., "A Discrete-Time Bluetooth Receiver in a 0.13um Digital CMOS Process," 2004 IEEE Solid State Circuits Conference, Session 15, Wireless Consumer ICs, 15.1


15.

EXHIBIT

NO. DATE

IDENTIFIED DATE

ADMITTED SPONSORING



DX305 ParkerVision Press Release, "ParkerVision Expands Product Portfolio With Introduction of Three New RFICs" (7/2/13)

DX306 402/403 United States Patent No. 5,469,115 (Peterzell et al) (filed on 11/21/1995)

DX307 402/403 United States Patent No. 5,617,060 (Wilson et al.) (filed on 4/1/1997)

DX308 402/403 Unites States Patent No. 5,722,063 (Peterzell et al.) (filed on 2/24/1998)

DX309 402/403 United States Patent No. 5,880,631 (Sahota) (filed 3/9/1999)

DX310 402/403 United States Patent No. 5,930,692 (Peterzell et al.) (filed 7/27/1999)

DX311 402/403 United States Patent No. 5,942,929 (Aparin) (filed 8/24/1999)

DX312 402/403 United States Patent No. 7,130,599 (Persico et al.) (filed 10/31/2006)

DX313 402/403 United States Patent No. 7,167,686 (See et al.) (filed 1/23/2007)

DX314 402/403 United States Patent No. 7,915,954 (Raghupathy et al.) (filed 3/29/2011)

DX315 402/403 United States Patent No. 7,949,306 (Shah) (filed on 5/24/2011)

DX316 402/403 ParkerVision Inc., Annual Report (Form 10KSB) (Filed 3/31/1996)

DX317 402/403/602/801/802 United States Patent No. 6,094,084 (Abou-Allam et al.) (Filed 7/25/2000)

DX318 402/403/602/801/802 Erdogen, O. et al., "A Single-Chip Quad-Band GSM/GPRS Transceiver in 0.18µm Standard CMOS," ISSC 2005, Session 17, RF Cellular ICs, 17.6

DX319 402/403/602/801/802 Erdogen, O. et al., "A Single-Chip Quad-Band GSM/GPRS Transceiver in 0.18µm Standard CMOS," PowerPoint Slides

DX320 ParkerVision, Inc. Q2 2004 Earnings Release Transcript, 8/9/2004

DX321 ParkerVision, Inc. Q3 2004 Earnings Conference Call Transcript, 11/11/2004



DX324 ParkerVision, Inc. Special Event Conference Call Transcript, 6/28/2005



DX327 ParkerVision, Inc. Q2 2006 Earnings Call Transcript, 8/8/2006



DX330 402/403/801/802 ParkerVision, Inc. Business Update Call Transcript, 12/3/2007


16.

EXHIBIT

NO. DATE

IDENTIFIED DATE

ADMITTED SPONSORING









DX337 402/403/801/802 ParkerVision, Inc. Q4 2009 Earnings Call Transcript, 3/15/2010

DX338 402/403/801/802 ParkerVision, Inc. Q1 2010 Earnings Conference Call Transcript, 5/10/2010

DX339 ParkerVision, Inc. 3G Mobile Handset Design Win Conference Call Transcript, 7/21/2010


DX341 402/403/801/802 ParkerVision, Inc. Q3 2010 Earnings Conference Call Transcript, 11/9/2010



DX344 402/403 ParkerVision, Inc. Qualcomm Patent Infringement Conference Call Transcript, 7/21/2011






DX350 File History for European Patent EP1125359 DX351 International Preliminary Examination Report for

PCT/US99/24299 DX352 402/403 Email from J. Budwin to J. Canning Attaching

ParkerVision's Markman Tutorial Simulation Files (8/15/12)

DX353 402/403 ParkerVision's Markman Tutorial Simulation Files (8/15/12)

DX354 402/403 ParkerVision Inc.'s Objections to Qualcomm's First Notice of Deposition Pursuant to Fed.R.Civ.P.30(b)(6) (11/26/12)

DX355 402/403 ParkerVision Inc., Annual Report (Form 10-K) (3/30/2012)

DX356 ParkerVision.com: Lowest Power Consumption Longest Battery Life, The PVM2510XP CDMA Complete RF Solution



17.

EXHIBIT

NO. DATE

IDENTIFIED DATE

ADMITTED SPONSORING



DX358 Parssinen, A. et al., "A 2-GHz Subharmonic Sampler for Signal Downconversion," IEEE Transactions on Microwave Theory and Techniques, Vol. 45, No. 12, December 1995, with J. Parker Handwriting

DX359 402/403 ParkerVision Presentation "2006-2008 Business Plan"

DX360 402/403 Plaintiff ParkerVision, Inc's Amended Initial Disclosures (10/5/12)

DX361 402/403/602/801/802 Peluso, V. et al., “A Dual-Channel Direct-Conversion CMOS Receiver for Mobile Multimedia Broadcasting,” ISSCC, 2006

DX362 402/403 Declaration of Paul Prucnal, Ph.D., in Support of Plaintiff ParkerVision, Inc.'s Rebuttal Claim Construction Brief, Dkt. 136

DX363 3LP "ParkerVision Strategic Patent Assets" DX364 U.S. Patent No. 6,061,551 (Sorrells et al.) (filed

Oct. 21, 1998) DX365 402/403 Claim Construction Order, Dkt. 243 DX366 Dr. Prucnal's Updated Simulations in Response

to Dr. Fox's April 5, 2013 Report DX367 403/702/801/802 Expert Report of Robert M. Fox, Ph.D.

(Including Appendices) DX368 U.S. Patent No. 7,724,845 (Sorrells et al.) (filed

Mar. 28, 2006) DX369 Estabrook, P. et al., "A Mixer Computer-Aided

Design Tool Based in the Time Domain," 1988 IEEE MTT-S Digest, pp.1107-10

DX370 List of Qualcomm Dies and Associated Product Numbers

DX371 Certified Copy of File History of U.S. Patent Application 09/176,022 (filed 10/21/98) (Now U.S. Patent No. 6,061,551)

DX372 402/403/602/801/802 Vilar, E. et al., "Scattering and Extinction: Dependence Upon Raindrop Size Distribution in Temperate (Barcelona) and Tropical (Belem) Regions (10th International Conference on Antennas and Propagation, 14-17 April 1997, Conference Publication No. 436

DX373 File History of U.S. Patent No. 6,061,551, Petition to Make Special (3/2/99)

DX374 402/403 IBM/ParkerVision Joint Development Agreement (7/23/97)

DX375 File History of U.S. Patent No. 6,061,551, Information Disclosure Statement (9/21/99)

DX376 ParkerVision Press Release "ParkerVision and IBM Join Forces to Create Wireless Computer Peripherals" (7/23/97)

DX377 ParkerVision Press Release "ParkerVision Announces Breakthrough in Wireless Radio Frequency Technology" (12/10/97)

DX378 ParkerVision Press Release "ParkerVision Announces Existing Agreement with IBM Terminates--Company Continues with Strategic Focus Announced in December" (1/27/98)

DX379 ParkerVision Press Release "Laboratory Tests Verify ParkerVision Wireless Technology" (3/3/98)


18.

EXHIBIT

NO. DATE

IDENTIFIED DATE

ADMITTED SPONSORING



DX380 ParkerVision Press Release "ParkerVision 'Direct2Data" Introduced in Response to Market Demand" (7/9/98)

DX381 ParkerVision Press Release "ParkerVision Announces Second Quarter and Six Month Financial Results" (7/30/98)

DX382 ParkerVision Press Release "Questar Infocomm, Inc. Invests $5 Million in ParkerVision Common Stock" (12/2/98)

DX383 File history of U.S. Patent No. 7,724,745 (Sorrells et al.) (filed 3/28/2006)

DX384 File history of U.S. Patent No. 6,963,734 (Sorrells et al.) (filed 12/12/2002)

DX385 ParkerVision Press Release "Laboratory Tests Verify ParkerVision Wireless Technology" (3/8/98)

DX386 ParkerVision memo re license agreements DX387 Fax from B. Hightower to M. Lee re termination

of ParkerVision-Symbol agreement (1/5/03) DX388 Wireless Technology Pool License Agreement

Between ParkerVision, Inc. and Symbol Technologies, Inc. (10/12/99)

DX389 801/802 Andrews, C. et al., "A <12mW, 0.7-3.2GHz Receiver with Resonant Multi-phase LO and Current Reuse Harmonic Rejection Baseband," 2012 IEEE Radio Frequency Integrated Circuits Symposium

DX390 801/802 Molnar, A., "Impedance and Noise Interactions Through CMOS Passive Mixers," Presentation, International Microwave Symposium, 17-22 June 2012

DX391 801/802 Klumperink, E., "Multi-Path Poly-Phase Passive Mixer Circuits for Flexibly Programmable Harmonic Rejection Mixing and High-Q Filtering," Presentation, International Microwave Symposium, 17-22 June 2012

DX392 801/802 Darabi, H., "Receiver Architectures for Software-Defined & Cognitive Radio Applications"

DX393 ParkerVision Presentation "Direct2Data Architecture: ParkerVision Wireless Technology"

DX394 ParkerVision Presentation "Samsung Update" (8/23/12)

DX395 ParkerVision Presentation "Via Telecom" DX396 ParkerVision Presentation "ParkerVision

Update" (9/4/08) DX397 ParkerVision Memorandum "Account Update"

(7/11) DX398 ParkerVision Proposal in Response to the

Request for Information from Motorola, Inc. for the Maverick 2 RFE (7/21/09)

DX399 ParkerVision Proposal for the Maverick 2 RFI Intended for Motorola, Inc.

DX400 ParkerVision, Inc. Proposal in Response to the Request for Information from Motorola, Inc. for the Maverick 2 RFE (9/24/09)

DX401 ParkerVision, Inc. Proposal In Response to the Request for Information from Motorola, Inc. for the Maverick 2 RFE (7/23/09)


19.

EXHIBIT

NO. DATE

IDENTIFIED DATE

ADMITTED SPONSORING



DX402 ParkerVision Presentation "Motorola Meeting" (11/20/09)

DX403 402/403 Mutual Non-Disclosure Agreement Between ParkerVision and Motorola (5/22/00)

DX404 ParkerVision, Inc. Proposal In Response to the Request for Information from Motorola, Inc. for the Wildcat RFE (9/24/09)

DX405 ParkerVision Memorandum Sales Update" (1/09)

DX406 402/403 ParkerVision Memorandum re Weaver Bridge Meeting (9/14/11)

DX407 402/403 ParkerVision Memorandum "Mobile World Congress 2011 Summary" (2/16/11)

DX408 402/403 ParkerVision Summary of Meeting with Nokia (4/24/06)






DX414 402/403 ParkerVision Minutes from Samsung Meeting (6/15/11)

DX415 402/403 ParkerVision Minutes from Weaver Bridge Meeting (9/14/11)

DX416 ParkerVision Memorandum "ParkerVision Claim Analysis," D. Sorrells (8/11/11)

DX417 Apple iPhone 4S Teardown, TechInsights (2011)

DX418 ParkerVision Presentation "Samsung Proposal" (4/27/12)

DX419 ParkerVision Presentation "Strategic Discussions for Rapid Product Acceptance and Accelerated Business Growth" (6/10)

DX420 402/403 ParkerVision Presentation "Presentation to Qualcomm" (9/6/06)

DX421 ParkerVision Presentation at AeA 2004 Financial Conference (11/9/04-11/10/04)

DX422 ParkerVision Press Release "ParkerVision Announces Breakthrough in Wireless Radio Frequency Technology" (12/10/97)

DX423 402/403 ParkerVision Press Release "ParkerVision Reports First Quarter 2008 Results" (5/7/08)

DX424 402/403 ParkerVision Press Release "ParkerVision to Exit Retail Operations and Focus as an OEM Supplier of Integrated Circuits for Wireless Devices" (6/28/05)

DX425 ParkerVision Press Release "ParkerVision, Inc. Announces first Significant Sale of its Cameraman Three-Chip System" (4/12/1996)

DX426 402/403 ParkerVision Press Release "ParkerVision Reports Fourth Quarter and Year End Results" (3/20/01)


20.

EXHIBIT

NO. DATE

IDENTIFIED DATE

ADMITTED SPONSORING



DX427 402/403 ParkerVision Press Release "ParkerVision Reports Second Quarter 2009 Results" (8/10/09)

DX428 ParkerVision Press Release "ParkerVision, Inc. Signs Licensing Agreement with Chip Supplier for Mobile Handsets" (12/21/07)

DX429 ParkerVision Press Release "ParkerVision, Inc. Licenses d2p RF Power Transmitter Technology to ITT" (5/2/07)

DX430 402/403 ParkerVision Presentation :Engineering Management Assessment" (3/11)

DX431 ParkerVision Draft Press Release "ParkerVision and VIA Telecom Collaborate to Launch Advanced RF Solution for 3G CDMA EV-DO" (3/11)

DX432 ParkerVision 2012 Corporate Presentation DX433 ParkerVision Presentation "D2D Technology"

(8/04) DX434 ParkerVision Press Release "ParkerVision

Begins Retail Marketing of Longest Range Wireless Networking Products Under the SignalMAX Brand Name" (9/2/04)

DX435 801/802 Niknejad, A., "Lecture 21: Balanced and Passive Mixers," University of California, EECS 142, 2008

DX436 402/403 License Agreement Between ParkerVision and ITT (5/2/07)

DX437 License and Engineering Services Agreement Between ParkerVision and VIA Telecom (12/21/07)

DX438 402/403 Product and Market Development Agreement Between ParkerVision and LG Innotek (12/4/08)

DX439 402/403 Sales Representation Agreement Between ParkerVision and Questar InfoComm (9/27/99)

DX440 402/403 Development and Foundry/Resale Agreement Between ParkerVision and Texas Instruments (3/8/01)

DX441 402/403 ParkerVision Conference Call Transcript (8/15/01)

DX442 402/403/801/802 Alpert, B., "The Strange Case of ParkerVision," Barrons, December 3, 2007

DX443 402/403 Joint Product Development Agreement Between ParkerVision and PrairieComm (2/01)

DX444 Draft License and Engineering Services Agreement Between ParkerVision and VIA Telecom (10/26/07)

DX445 ParkerVision D2D Down Converter Test Report(12/10/12)

DX446 ParkerVision D2D Cell Band Down Converter Test Report (12/18/12)

DX447 402/403 3LP "ParkerVision Strategic Patent Assets Appendix A: Evidence of Use and Engineering Comparison" (1/13)

DX448 Samsung Ultra Edition II SGH-U700 Teardown, Portelligent (2007)

DX449 Sanyo PM-8200 Teardown, Portelligent (2004) DX450 LG-TM510 Teardown, Portelligent (2001)


21.

EXHIBIT

NO. DATE

IDENTIFIED DATE

ADMITTED SPONSORING



DX451 ParkerVision D2D Cell Band Down Converter Design Report (2/1/13)

DX452 ParkerVision Data Sheet for PVD2510R (2013) DX453 ParkerVision Data Sheet for PVL2520R (2013) DX454 402/403 Declaration of Paul Prucnal, Ph.D. in Support of

Plaintiff ParkerVision, Inc.'s Rebuttal Claim Construction Brief, Dkt. 136-1 (7/27/12)

DX455 402/403 Declaration of David Sorrells, Dkt. 165-7 (9/13/12)

DX456 402/403 Plaintiff ParkerVision Inc.’s Disclosure of Asserted Claims and Infringement Contentions, Exhibit A.2





DX461 Provisional Application 60/129839 Cited on Face of U.S. Patent No. 7,724,845 (Sorrells et al.) (filed 4/16/1999)

DX462 Provisional Application 60/158047 Cited on Face of U.S. Patent No. 7,724,845 (to be determined) (filed 10/7/1999)

DX463 Provisional Application 60/171349 Cited on Face of U.S. Patent No. 7,724,845 (Sorrells) (filed 12/21/1999)

DX464 Provisional Application 60/171496 Cited on Face of U.S. Patent No. 7,724,845 (Jenson) (filed 12/22/1999)

DX465 Provisional Application 60/171502 Cited on Face of U.S. Patent No. 7,724,845 (Sorrells) (12/22/1999)








22.

EXHIBIT

NO. DATE

IDENTIFIED DATE

ADMITTED SPONSORING



DX472 402/403/602/801/802 Tsividis, Y. "A First Lab in Circuits and Electronics" 2002

DX473 402/403 File History U.S. Patent Application 09/176,027 (filed 10/21/98) (Abandoned)

DX474 402/403 File History U.S. Patent Application 09/521,878 (filed 3/9/00) (Abandoned)

DX475 File History of U.S. Patent Application 09/376,359 (filed 8/18/99) (Now U.S. Patent No. 6,266,518)


DX477 402/403 File History of U.S. Patent Application 09/526,041 (filed 3/14/00) (Now U.S. Patent No. 6,879,817)







DX484 402/403/602/801/802 Svoboda, J. et al., "Introduction to Electric Circuits," John Wiley & Sons, 2014

DX485 Qualcomm LCU Wedge Chipset Level HLDR (5/06)

DX486 Qualcomm LCU RX Front End HLDR (6/06) DX487 Qualcomm LCU WCDMA High Band U1800,

U1900, and U2100 RX Front End MLDR (12/15/06)

DX488 Qualcomm LCU RX Top Level Low-Level Design Review (9/29/07)

DX489 Qualcomm LCU: WCDMA Low Band Front End LLDR (5/9/07)

DX490 Qualcomm LCU: GSM RX HB LLDR (9/27/07) DX491 Qualcomm QSC6240/QSC6270 (Enhanced and

Nonenhanced) Device Specification (2/18/11) DX492 Qualcomm QSC6240/QSC6270 Qualcomm

Single Chip User Guide (11/5/09) DX493 Qualcomm QSC6240/QSC6270 Chipset

Training RF Topics (3/09) DX494 Qualcomm RTR6285 GRAT VCO LLDR (7/06) DX495 Qualcomm RTR6285 SGPS LO Path MLDR

(12/06) DX496 Qualcomm RTR6285 WCDMA DRX FE

(8/14/06, 9/1/06)


23.

EXHIBIT

NO. DATE

IDENTIFIED DATE

ADMITTED SPONSORING



DX497 Qualcomm WCDMA Rx, GSM, SGPS Rx LO Path and 2V Regulator LLDR (7/21/06)

DX498 Qualcomm RTR6285 GRX TOP LLDR (7/6/06) DX499 Qualcomm RTR6285 Top Level LLDR (9/25/06) DX500 Qualcomm RTR6285/RTR6280 RF Transceiver

IC Device Specification (6/4/10) DX501 Qualcomm RTR6285/RTR6280 RF Transceiver

User Guide (10/13/08) DX502 Qualcomm RTR6285 Design Kick-Off Meeting

(4/07) DX503 Qualcomm RTR6285A RF Transceiver IC

Device Specification (12/22/11) DX504 Qualcomm RTR6285 Objective Specification

(8/3/06) DX505 Qualcomm RTR 6285 WCDMA Wideband Mixer

MLDR (4/20/06) DX506 Qualcomm RTR6285, Voltron R&C-Tuners:

LLDR (7/17/06) DX507 Qualcomm RTR 6285 WCDMA HB LNA (2)

LLDR (4/11/07) DX508 Qualcomm LCU RX GSM Low-Band Front-End

LLDR (4/1/09) DX509 Qualcomm LCU RX LO Generation LLDR

(9/5/07) DX510 Qualcomm RF Rx System HLDR for LCU

WEDGE (5/06) DX511 Qualcomm QSC6240/QSC6270 Qualcomm

Single Chip Design Guidelines (5/22/09) DX512 402/403/602/801/802 1995 ARRL Handbook for Radio Amateurs DX513 Campbell, R., "High-Performance Direct-

Conversion Receivers," QST, August 1992, pp. 19-28

DX514 106 Couch, L. "Digital and Analog Communication Systems," Second Edition

DX515 Crols, J. "A 1.5 GHz Highly Linear CMOS Downconversion Mixer," IEEE Journal of Solid State Circuits, Vol. 30, No. 7, July 1995

DX516 106/402/403/602/801/802 Enz, C. "Circuit Techniques for Reducing the Effects of Op-Amp Imperfections: Autozeroing, Correlated Double Sampling, and Chopper Stabilization," Proceedings of the IEEE, Vol. 84., No. 11, Nov. 1996, pp. 1584-614

DX517 U.S. Patent No. 4,346,477 (Gordy) (filed Aug. 1, 1977)

DX518 402/403/602/801/802 United States Patent No. 5,697,091 (Hirschenberger et al.) (filed 2/7/1996)

DX519 402/403/602/801/802 U.S. Patent No. 3,617,898 (Janning) (filed Apr. 9, 1969)

DX520 402/403/602/801/802 United Kingdom Patent Application GB 2,201,559 (Jones et al.) (Filed 1/23/1987)

DX521 402/403/602/801/802 U.S. Patent No. 5,937,013 (Lam et al.) (filed Jan. 3, 1997)

DX522 402/403/602/801/802 International Patent Application WO 96/02977 (Land) (Filed 7/13/1995)

DX523 402/403/602/801/802 U.S. Patent No. 5,379,457 (Nguyen) (filed Jun. 28, 1993)


24.

EXHIBIT

NO. DATE

IDENTIFIED DATE

ADMITTED SPONSORING



DX524 402/403/602/801/802 Parssinen, A. et al., "A 2-GHz Subharmonic Sampler for Signal Downconversion," IEEE Transactions on Microwave Theory and Techniques, Vol. 45, No. 12, December 1997

DX525 402/403/602/801/802 United States Patent No. 5,493,720 (Peterson) (Filed 5/20/1994)

DX526 402/403/602/801/802 United States Patent No. 4,888,557 (Puckette et al.) (Filed 4/10/1989)

DX527 Razavi, B. "Design Considerations for Direct-Conversion Receivers," IEEE Transactions on Circuits and Systems--II: Analog and Digital Signal Processing, Vol. 44, No. 6, June 1997

DX528 Rudell, J. et al. "A 1.9-GHz Wide-Band IF Double Conversion CMOS Receiver for Cordless Telephone Applications," IEEE Journal of Solid-State Circuits, Vol. 32, No. 12, December 1997

DX529 402/403/602/801/802 U.S. Patent No. 5,339,459 (Schiltz et al.) (filed Dec. 3, 1992)

DX530 402/403/602/801/802 Shahani, A. et al. "A 12-mW Wide Dynamic Range CMOS Front-End for a Portable GPS Receiver," IEEE Journal of Solid-State Circuits, Vol. 32, No. 12, December 1999

DX531 402/403/602/801/802 United States Patent No. 5,015,963 (Sutton) (Filed 9/29/1989)

DX532 U.S. Patent No. 6,121,819 (Traylor) (filed Apr. 6, 1998)

DX533 van Graas, D. H., "The Fourth Method: Generating and Detecting SSB Signals," QEX, September 1990, pp. 7-11

DX534 106 Weisskopf, P., "Subharmonic Sampling of Microwave Signal Processing Requirements," Microwave Journal, May 1992, pp. 239-47

DX535 402/403/602/801/802 United States Patent No. 5,742,189 (Yoshida et al.) (Filed 9/14/1995)

DX536 106/402/403/602/801/802 Yuan, J. "A Charge Sampling Mixer With Embedded Filter Function for Wireless Applications," 2000 2nd International Conference on Microwave and Millimeter Wave Technology Proceedings, pp. 315-18

DX537 402/403/602/801/802 United States Patent No. 4,320,536 (Dietrich) (Filed 9/18/1979)

DX538 402/403/602/801/802 U.S. Patent No. 5,630,228 (Mittel) (filed Apr. 24 1995)

DX539 Campbell, R., "High-Performance, Single-Signal Direct-Conversion Receivers," QST, January 1993, pp. 32-40

DX540 Advertisement for SBL-1 Mixer, Microwaves & RF, July 1991

DX541 106 Couch, L., "Modern Communications Systems: Principles and Applications," Prentice Hall, 1995

DX542 FCC CameraMan Certification (1996) DX543 106 Oppenheim, A. et al., "Signals and Systems,"

Prentice-Hall, 1983 DX544 106 Lee, T., "The Design of CMOS Radio Frequency

Integrated Circuits," Cambridge University Press, 1998


25.

EXHIBIT

NO. DATE

IDENTIFIED DATE

ADMITTED SPONSORING



DX545 Akers, N.P., "RF Sampling Gates: a Brief Review," IEEE Proceedings, Vol. 133, Pt. A, No. 1, January 1986, pp. 45-49

DX546 402/403/602/801/802 U.S. Patent No. 5,140,705 (Kosuga) (filed Jun. 13, 1990)

DX547 402/403/602/801/802 S. Maas, " A GaAs MESFET Balanced Mixer with Very Low Intermodulation," 1987 IEEE MTT-S Digest, 1987

DX548 Nozawa, Y., "The Merigo Method: SSB Generator/Producing A Demodulator," HAM Journal, July/August 1993 Issue, pp. 20-31

DX549 106 DeMaw, D., “Practical RF Design Manual,” Prentice-Hall, Inc., 1982

DX550 ParkerVision Circuit Description for MDS 2003 DX551 ParkerVision Rec. Bd. (1998) DX552 Photograph of CameraMan MDS-2000 DX553 Photograph of back of MDS-2000 Showing

Model Number and Serial Number DX554 Photograph of Interior of CameraMan Unit

Showing SBL-1 Component DX555 Photograph of Interior of CameraMan Unit

Showing SBL-1 Component DX556 402/403/602/801/802 United States Patent No. 5,428,836 (Sanecki et

al.) (Filed 10/14/1993) DX557 402/403/602/801/802 United States Patent No. 5,640,428 (Abe et al.)

(Filed 11/9/1995) DX558 402/403/602/801/802 United States Patent No. 5,802,463

(Zuckerman) (Filed 8/20/1996) DX559 402/403/602/801/802 United States Patent No. 6,029,052 (Isberg et

al.) (Filed 7/1/1997) DX560 106/402/403/602/801/802 Smith, R. "Circuits, Devices, and Systems,"

John Wiley & Sons, 1966 DX561 Qualcomm RaMSIS Objective Specification

(10/07) DX562 Qualcomm RAMSIS HLDR (2/06) DX563 Qualcomm Ramsis PRX Mixer and Base Band

Filter LLDR (8/8/06) DX564 Qualcomm Ramsis RF Top-Level LLDR

(10/6/06) DX565 Qualcomm Ramsis HWSW Control Document

(11/18/08) DX566 Qualcomm QSC6055, QSC6065, QSC6075,

and QSC6085 Qualcomm Single Chip Device Specification (2/25/11)

DX567 Qualcomm QSC6055, QSC6065, QSC6075, and QSC6085 Qualcomm Single Chip (QSC) User Guide (8/7/09)

DX568 Qualcomm RTR6500/RTR6570 (Voltron) ATE Test Specifications (8/15/08)

DX569 RTR6500 Objective Specification (3/08) DX570 Qualcomm Voltron PRx Cell High Linearity LNA

LLDR (11/1/06) DX571 Qualcomm RTR6500 Multiband CDMA RF

Transceiver Device Specification (11/20/08) DX572 Qualcomm RTR6500 Multiband CDMA RF

Transceiver User Guide (1/4/2008)


26.

EXHIBIT

NO. DATE

IDENTIFIED DATE

ADMITTED SPONSORING



DX573 Qualcomm WCN3660 Iris WLAN TX TOP LLDR (1/3/11)

DX574 Qualcomm WCN1314 FTM and QRCT (FFA and EVK) User Guide (2/15/11)

DX575 Qualcomm YWING_TOP_B0_LLDR (1/09) DX576 Qualcomm YWing LO Distribution Mid Level

Design Review (July 2009) DX577 Qualcomm WCN1320 System-in-Package (SiP)

Device Specification (2/5/10) DX578 Qualcomm WCN2243 (Bahama) Top Level

HLDR (9/09) DX579 Qualcomm Bahama Top-Level LLDR (2/4/10) DX580 Qualcomm WCN2243 (Bahama) Bench Low

Level Test Review (4/2/10) DX581 Qualcomm Volans RF Compliance Matrix

(12/2/11) DX582 Qualcomm Iris/WLAN 802.11a/b VCO HLDR

(5/27/10) DX583 Qualcomm WCN3660 Bench High Level Test

Review (10/21/10) DX584 Qualcomm WCN3660 (Iris) Bluetooth

Synthesizer Delta-LLDR (5/19/11) DX585 Qualcomm WCN3360 (Iris) Bluetooth TX/RX LO

Path Delta-LLDR (5/23/11) DX586 Qualcomm WCN3660 (Iris) RF Objective

Specification (12/9/10) DX587 Qualcomm WCN3660 (IRIS) WLAN Top LLDR

(2/17/11) DX588 Qualcomm Iris WLAN LO LLDR (4/11/11) DX589 Qualcomm WCN2243 System-on-Chip (SoC) DX590 Qualcomm WCN1312 Single Chip WLAN

Solution Device Specification (9/30/11) DX591 Qualcomm WCN1314 System-on-Chip (SoC)

WLAN Solution Device Specification (10/20/11) DX592 Qualcomm WCN3660 Device Specification

(4/6/12) DX593 Qualcomm WCN (Prima) QCT Development

Gate (PC-2) (4/22/10) DX594 Qualcomm RTR8600 Magellan WCDMA, GSM,

Zero-IF Transceiver with GPS IC Test Specifications (6/16/11)

DX595 Qualcomm RTR8605 Multimode RF Transceiver IC Device Specification (7/14/11)

DX596 Qualcomm RTR6500 Multiband CDMA RF Transceiver Device Specification (11/20/08)

DX597 Qualcomm Astra/RGR6240 Objective Specification (3/14/08)

DX598 Qualcomm Astra RGR6240 ADC Clock Clean-up PLL LLDR (2/15/08)

DX599 Qualcomm RTR8600 Magellan Chip Top Rx LLDR (1/5/09)

DX600 Qualcomm RTR8600 Objective Specification (5/10/11)

DX601 Qualcomm RTR8600 (Magellan) Receiver Top Level HLDR (Part I, Rx Front Ends) (11/27/07)

DX602 Qualcomm RTR8600 PDC/PCS/IMT Signal Path Mid-Level Design Review (3/21/08)


27.

EXHIBIT

NO. DATE

IDENTIFIED DATE

ADMITTED SPONSORING



DX603 Qualcomm RTR8600 (Magellan) PRx LB LO Low-Level Design Review (2/20/09)

DX604 Qualcomm RTR8600 (Magellan) HB RXFE Signal Path MLDR (5/16/08)

DX605 Qualcomm RTR8600 (Magellan) HB RXFE Signal Path LLDR (9/19/08)

DX606 Qualcomm RTR8600 (Magellan) PRX LO Generation MLDR (6/16/08)

DX607 Qualcomm RTR8600 (Magellan) Rx BBF MLDR (7/24/08)

DX608 Qualcomm RTR PDC/PCS/IMT Signal Path LLDR (10/9/08)

DX609 Qualcomm RTR8600 GPS Top LLDR (8/22/08) DX610 Qualcomm RTR6237/RTR6236 RF Transceiver

IC Device Specification (9/23/08) DX611 Qualcomm RTR6500 (Voltron) PRX BB Filter B0

Design Document (7/16/07) DX612 Qualcomm QTR9215 Qualcomm Transceiver IC

Device Specification (8/25/11) DX613 Qualcomm QTR9215 Qualcomm Transceiver IC

User Guide (8/11/11) DX614 Qualcomm QTR8615/QTR8615L Qualcomm

Transceiver IC Device Specification (10/26/11) DX615 Qualcomm RTR8600/RTR8601 Multimode RF

Transceiver User Guide (10/8/10) DX616 Qualcomm QTR8200/QTR8600/QTR8601

Qualcomm Transceiver User Guide (4/8/11) DX617 Qualcomm QTR9215 (Kepler) TX LO LLDR

(12/9/09) DX618 Qualcomm RTR9205/RTR9215 RX Top Level

LLDR (3/3/10) DX619 Qualcomm Halley 2.0/2.01/Iceman TX/RX VCO

and PLL LLDR (1/10/11) DX620 Qualcomm Europa (GPS RF Core For

RTR9205, QTR9215) Core Top LLDR (5/10) DX621 Qualcomm TO Ganymede 1.0 (Iceman) /

Europa 2.0 (Halley) GPS Core LLDR/LLVR (8/19/10)

DX622 Qualcomm Halley (RTR9205) Top-Level LLDR (5/7/10)

DX623 Qualcomm WTR1605/WTR1605L Wafer-level Transceiver IC Device Specification (4/3/12)

DX624 WTR1605 GPS (Eureka) HLDR (9/7/10) DX625 Qualcomm WTR1605 WAN (Odyssey) Rx

SigPath High-Level Design Review (8/19/10) DX626 Qualcomm Odyssey PRX LO Generation LLDR

(6/14/11) DX627 Qualcomm WTR1605 (Odyssey) DHB Rx Signal

Path LLDR (2/28/11) DX628 Qualcomm WTR1605 (Odyssey) PLB Rx Signal

Path LLDR (8/15/11) DX629 Qualcomm WTR1605 Diversity Mid-Band Rx

Signal Path LLDR (8/23/11)


28.

EXHIBIT

NO. DATE

IDENTIFIED DATE

ADMITTED SPONSORING



DX630 Letter from M. Lee to Assistant Commissioner for Patents re Submission of Provisional Application for "Method and System for Efficiently Down-Converting and Up-Converting Electromagnetic Signals with Energy Transfer" (1/24/00)

DX631 File History of U.S. Patent No. 6,061,551 (Sorrells et al.) (filed Oct. 21, 1998)

DX632 Qualcomm UBM Radio Receiver Integrated Circuit Tomahawk Objective Specification (2/9/09)

DX633 Qualcomm UBM RFIC (Spitfire) Top-Level LLDR (5/29/07)

DX634 Qualcomm UBM (Spitfire) Mixer LLDR (10/17/06)

DX635 Qualcomm MBP1600 Mobile Broadcast Platform Device Specification (9/26/08)

DX636 Qualcomm MBP1600 Mobile Broadcast Platform User Guide (10/26/07)

DX637 Qualcomm Gamla UBM2/2M (MBP2600/MBP2700) Baseband IC HDD (2/09)

DX638 Qualcomm FURY Universal Broadcast Modem (UBM) RFIC Objective Specifications (10/28/09)

DX639 Qualcomm UBM2 (MBP2600) Hardware/Software Interface Tomahawk-RFIC / Gamle-ADC (7/27/08)

DX640 Qualcomm UBM-2M RFIC (Fury) Mixer High Level Design Review (10/13/08)

DX641 Qualcomm UBM-2M (Fury) LO GEN LLDR (8/6/08)

DX642 Qualcomm UBM-2M (Fury) Synthesizer Top LLDR (8/11/08)

DX643 Qualcomm MXU6219 RF Transceiver Multi-Chip Module Device Specification (11/3/08)



DX646 Qualcomm MBP2700 Mobile Broadcast Platform User Guide (1/2/10)

DX647 Qualcomm FTR8700 ATE Low Level Test Review (1/10)

DX648 Qualcomm FTR8700/EagleRay Top Level MLDR (2/10)

DX649 Qualcomm FTR8700: Stingray LO Path: RX, TOR and TX (5/09)

DX650 Qualcomm FTR8700: HLDR Stingray LO Distribution Path (5/09)

DX651 Qualcomm FTR8700: HLDR Stingray RX Path: Femto Broadband LNA (6/09)

DX652 Qualcomm Eagleray LO Path: ADC Clock Divider Preliminary Review (5/09)

DX653 Qualcomm FTR8700: MLDR Eagleray Top VCO and LO (5/09)

DX654 Qualcomm Eagleray RX Path: BB Slice LLDR (5/13/09)

DX655 Qualcomm FTR8700: Eagleray RXFE LLDR (6/09)


29.

EXHIBIT

NO. DATE

IDENTIFIED DATE

ADMITTED SPONSORING



DX656 Qualcomm FTR8700: Eagleray RF LLDR VCO and LO (5/09)

DX657 Qualcomm FTR8700/EagleRay Top Level HLDR (5/09)

DX658 Qualcomm FTR8700: Eagleray Top LLDR PLL and VCO (6/19/09)

DX659 Qualcomm FTR8700: Eagleray RX Super Block LLDR (2/10)

DX660 Qualcomm FTR8700 Mode Control Superblock LLDR (11/18/09)

DX661 Qualcomm MDM6200 and MDM6600 Mobile Data Modem Device Specification (8/4/11)

DX662 Qualcomm FTR8700 Femtocell RF Transceiver IC Device Specification (3/29/12)

DX663 Qualcomm Hypnos Modem Core (QSC1100) High Level Design (4/1/08)

DX664 Qualcomm QSC1100 Napoleon Rx Top-Level HLDR (4/07)

DX665 Qualcomm QSC1100 Napoleon Rx Signal-Path Block-Level HLDR (4/07)

DX666 Qualcomm Napoleon (QSC1100 RF Die) Top-Level LLDR (Part 1) (10/16/08)

DX667 Qualcomm QSC11x0 RF Systems MLDR Part 1 (12/07)

DX668 Qualcomm QSC1105/QSC1215 Qualcomm Single Chip Device Specification (5/2/12)

DX669 Qualcomm QSC1105/QSC1115 Qualcomm Single Chip User Guide (8/10/11)

DX670 Qualcomm QSC1110/QSC1100 Qualcomm Single Chip Device Specification (10/29/09)

DX671 Qualcomm QSC1100/QSC1110 Qualcomm Single-Chip User Guide (6/10/10)

DX672 Qualcomm QSC61x5, QSC6295, and QSC6695 Qualcomm Single Chip Device Specification (8/5/11)

DX673 Qualcomm QSC6240/QSC6270 Enhanced Qualcomm Single Chip User Guide (11/5/09)

DX674 Qualcomm RTR6500 RF Chipset Product Council 2 (4/05)

DX675 Qualcomm BTS4020-R3 Characterization Test Plan (5/07)

DX676 RFMD Bali Project Update (12/20/06) DX677 Qualcomm BTS4025 A0 Digital Pads LLDR

(8/15/07) DX678 Qualcomm BTS4025 Fiji DAC Filter Gain Step

Scheme LLDR (8/28/07) DX679 Qualcomm BTS4025 Fiji PageScan LO

Generation LLDR (9/07) DX680 Qualcomm BTS4025 Fiji RX PageScan

Amplifier & HPF LLDR (9/17/07) DX681 Qualcomm BTS4025 (Fiji) TXRF LLDR (10/1/07)DX682 Qualcomm BTS4025 Fiji: DBIAS Reference

Generator LLDR (8/26/07) DX683 Qualcomm BTS4025 Bias LLDR (10/10/07) DX684 Qualcomm Napoleon (QSC1100 RF Die) A1

LLDR (2004) DX685 Qualcomm Marimba Chip HLDR (2/26/08)


30.

EXHIBIT

NO. DATE

IDENTIFIED DATE

ADMITTED SPONSORING



DX686 Qualcomm Marimba ATE Low Level Test Review (LLTR) (10/27/08)

DX687 Qualcomm Marimba Analog Top LLDR (10/3/08)DX688 Qualcomm BT65 (Penrhyn) Lo Path LLDR

(10/2/08) DX689 Qualcomm Marimba/BT65 Synthesizer and LO

Path High Level Design Review (10/8/08) DX690 Qualcomm Marimba/BT65 RXTOP and RXRF

High Level Design Review (10/1/08) DX691 Qualcomm FM65 Radio Top Level LLDR

(11/20/08) DX692 Qualcomm Gemini PLL MLDR (10/08) DX693 Qualcomm Namotu RFIC Objective

Specification (4/15/10) DX694 Qualcomm Hermes Rx BBF MLDR (6/10/09) DX695 Qualcomm Hermes PLL HLDR (6/09) DX696 Qualcomm Hermes Top Level MLDR (10/09) DX697 Qualcomm Kepler LB Signal Path MLDR

(7/31/09) DX698 Qualcomm Poseidon PLL and Synth Top LLDR

(10/27/10) DX699 Qualcomm Poseidon RxFE LLDR (3/2/10) DX700 Qualcomm Midas PLL LLDR (1/10) DX701 Qualcomm BTS4020/BTS4021 System-on-Chip

(SoC) Device Specification (10/13/10) DX702 Qualcomm BTS4020/BTS4021 System-on-Chip

(SoC) User Guide (7/29/08) DX703 Qualcomm BTS4020 BD RXRF LLDR (6/18/07) DX704 Qualcomm BTS4054 System-in-Package (SiP)

Device Specification (6/17/09) DX705 Qualcomm Catalina (BTS4054) Relaxation

Oscillator B0 LLDR (4/14/09) DX706 Qualcomm BTS4025 System-on-Chip (SoC)

Device Specification (1/18/11) DX707 Qualcomm BTS5045 System-in-Package (SiP)

Device Specification (4/29/09) DX708 Email Chain Between P. Kantak and J. Parker

re Qualcomm ParkerVision Discussion (8/19/98) DX709 801/802 Email Chain Between P. Kantak and C.

Wheatley re ParkerVision Demonstration Board (9/28/98)

DX710 801/802 Email From P. Kantak to S. Altman et al. re Current Status of ParkerVision Negotiations (6/22/99)

DX711 801/802 Email Chain Between P. Kantak and J. Parker re D2D Evaluation (6/29/99)

DX712 Email Chain Between P. Kantak and S. Jha et al. re ParkerVision Assessment (6/29/99)

DX713 Email Chain Between P. Kantak and M. Blecker et al. re Other Companies Approaching ParkerVision (8/13/99)

DX714 801/802 Email From P. Kantak to S. Jha et al. re Reservations re ParkerVision Technology (10/6/99)

DX715 Email from P. Kantak to J. Parker re D2D CDMA Transmitter Demonstration (11/1/99)


31.

EXHIBIT

NO. DATE

IDENTIFIED DATE

ADMITTED SPONSORING



DX716 Email From J. Jacobs to C. Wheatley et al. re ParkerVision Visit to Qualcomm (8/17/99)

DX717 801/802 Email Chain Between L. Wen and J. Jacobs et al. re Concerns re ParkerVision Process (8/17/98)

DX718 Email Chain Between R. Camarillo and P. Kantak et al. re ParkerVision Visit to Qualcomm (8/18/98)

DX719 ParkerVision White Paper "Technical Overview of an IEEE 802.11 WLAN Receiver Using ParkerVision Direct2Data Architecture" (1998)

DX720 Email Chain Between J. Parker and P. Kantak re ParkerVision Visit to Qualcomm (1/29/99)

DX721 Memo from P. Kantak to J. Parker re Salient Issues for Discussion Between Qualcomm and ParkerVision (6/10/99)

DX722 801/802 Email Chain Between S. Jha and P. Kantak et al. re Caution in Evaluating ParkerVision (6/24/99)

DX723 801/802 Email from R. Gilmore to P. Kantak re ParkerVision Technology (8/13/99)

DX724 Email Chain Between R. Gilmore and M. Blecker re Reservations re Benefit of ParkerVision Technology (10/11/99)

DX725 Email from P. Kantak to A. Oberst re ParkerVision Patent 6,091,940 (7/21/00)

DX726 Email From D. Sorrells to S. Younis re Results of Testing D2D CMOS IC (1/11/99)

DX727 801/802 Email from S. Younis to P. Kantak re Kantak's Premature Calculation of Cost Savings (8/28/98)

DX728 801/802 Email From S. Younis to J. Jacobs et al. re Status of ParkerVision Chip Tests (9/23/98)

DX729 402/403/801/802 Email from M. Blecker to D. Schrock Forwarding Arsenio & Company Article "ParkerVision Possesses No Valuable Technology" (9/28/99)

DX730 801/802 Email From C. Persico to P. Kantak et al. re Reservations re ParkerVision Technology (8/24/98)

DX731 Email Chain Between C. Wheatley and B. Weaver re D2D Briefing Presentation (6/23/00)

DX732 801/802 Qualcomm Presentation "Direct Down Conversion Using a Gated Switch" (1/19/99)

DX733 Email From P. Heidmann to C. Wheatley Forwarding Email Chain Between P. Heidmann and D. Sorrells re ParkerVision Product Presentation (11/18/02)

DX734 ParkerVision Presentation "Direct2Data Creates an Unfair Advantage... For Our Partners" (2002)

DX735 Email From S. Younis to J. Jacobs et al. re ParkerVision Status (9/23/98)

DX736 402/403/801/802 Atheros Single-Chip 2x2 MIMO MAC/BB/Radio with PCI Express Interface for 802.11n 2,4 and 5 GHz WLANs data Sheet (2/10)

DX737 801/802 Email Chain Between P. Kantak and S. Altman re P. Peterzell Direct Conversion Evaluation (9/16/99)

DX738 Email Chain Between P. Kantak and J. Parker re Termination of ParkerVision-IBM Agreement


32.

EXHIBIT

NO. DATE

IDENTIFIED DATE

ADMITTED SPONSORING



DX739 801/802 Email Chain Between S. Ciccarelli and K. Montalvo et al. re Testing ParkerVision Chip

DX740 Email Chain Between K. Montalvo and S. Ciccarelli re Measurements of ParkerVision Test Board (9/9/98)

DX741 Email Chain between R. Gilmore and B. Judson et al. re Direct Conversion (6/18/99)

DX742 801/802 Email Chain Between S. Ciccarelli and S. Jha re Reservations re ParkerVision D2P Technology (10/19/06)

DX743 801/802 Email From C. Persico to T. Frashure re Reservations re ParkerVision Technology (8/22/98)

DX744 801/802 Email Chain Between S. Jha and A. Behrooz re Reservations re ParkerVision (8/10/06)

DX745 801/802 Email from C. Wheatley to R. Padovani re Having Met With ParkerVision (10/18/01)

DX746 801/802 Email Chain Between S. Ciccarelli and S. Jha re Reservations re ParkerVision D2P Technology (9/8/06)

DX747 402/403/801/802 Qualcomm Presentation "Berkana Wireless Inc. Acquisition Recommendation" (11/21/05)

DX748 801/802 Email Chain Between C. Persico and J. Lodenius et al. re Qualcomm's Independent ZIF Development (2/25/00)

DX749 Email From S. Bazarjani to S. Younis re D2D Test (6/24/99)

DX750 402/403/801/802 Email Chain Between A. Oberst and S. Jha et al. re Berkana Acquisition Recommendation (11/20/05)

DX751 402/403/801/802 Email From K. Sahota to C. Persico et al. re Berkana Due Diligence (12/7/05)

DX752 402/403/801/802 Qualcomm Presentation "Berkana Wireless Inc. Acquisition Recommendation" (11/11/05)

DX753 402/403/801/802 Email Chain Between M. Khan and A. Oberst re Berkana Evaluation (9/26/05)

DX754 402/403/801/802 Qualcomm Presentation "RF Acquisition Analysis" (10/05)

DX755 402/403/801/802 Qualcomm Presentation "Sirific Wireless Corporation Company Information" (7/03)

DX756 ParkerVision "Technical Presentation of the ParkerVision Direct2Data Architecture" (8/20/98)

DX757 402/403/801/802 Qualcomm RTR6290 (gzif4) High Level Design Review (6/05)

DX758 402/403 ARM Technology License Agreement, Amendment 13






DX764 402/403 Letter From E. Youssef to N. Thomas Enclosing ARM Technology License Agreement (10/21/97)


33.

EXHIBIT

NO. DATE

IDENTIFIED DATE

ADMITTED SPONSORING












DX774 402/403 Memo and attachment from N. Thomas to B. Cheney et al. re Approval of ARM Technology License Agreement (9/30/97)






DX780 402/403 ARM Technology License Agreement, Amendment 1 to Amendment 20




DX784 801/802 TSMC 65 nm CMOS Mixed Signal Low Power 1P6M+AL_RDL Salicide Cu_Lowk 1.2 & 2.5V Spice Model (For U339 Only) (6/12/07)

DX785 Qualcomm Kepler 2.0/Iceman TX VCO and PLL LLDR (8/31/10)

DX786 Qualcomm QSC1100 Chipset HLDR (10/30/06) DX787 Qualcomm WCN3660 (IRIS) EM LLDR Final

Report (2/15/11) DX788 Poseidon RxFE LLDR (10/02/09) DX789 106/402/403/801/802 Atheros Internal Reference Specifications for

Project Kite (5/14/08) DX790 106/402/403/801/802 Atheros RX RF 2G Internal Reference

Specification for Project Mercury (8/7/07) DX791 106/402/403/801/802 Atheros Internal Reference Specifications for

Project Mercury (8/10/07) DX792 Email From C. Wheatley to P. Kantak et al. re

Evaluation of ParkerVision Patent Applications (5/28/99)


34.

EXHIBIT

NO. DATE

IDENTIFIED DATE

ADMITTED SPONSORING



DX793 801/802 Hadjichristos, A., "Single Chip RF CMOS UMTS/EGSM Transceiver with Integrated Receive Diversity and GPS," ISSCC 2009, Session 6, Cellular and Tuner, 6.4, pp. 12-14

DX794 402/403/801/802 Email chain between C. Conroy and B. Kim et al. re Berkana Designs (1/4/06)

DX795 801/802 Qualcomm RF / PM Product Roadmap (5/04) DX796 801/802 Qualcomm Presentation "Quarterly

Development Meeting" (1/05) DX797 Qualcomm Memo "Assessment of ParkerVision

D2D Technology" (3/23/99) DX798 801/802 TSMC Presentation "CM018 / CM025 Mixed-

Signal / RF Technology" (1998) DX799 402/403/801/802 Qualcomm Memo "Estimation of the Fair Value

of Certain Intangible Assets of Berkana Wireless, Inc." (12/31/05)

DX800 801/802 Email Chain Between C. Persico and S. Bazarjani re Limitations of RF Sampling (2/19/04)

DX801 801/802 Email From K. Sahota to analog.leads re ZIF Development Status (4/5/00)

DX802 801/802 Qualcomm Presentation "Advanced Research: Investigation of RX" (4/26/05)

DX803 801/802 Email From S. Bazarjani to G. McAllister et al. re RF Sampling (5/18/04)

DX804 Sterne Kessler "Appendix - Summary of Additional ParkerVision Proprietary and Confidential Information Disclosed to Qualcomm During the Meeting on April 6, 1999"

DX805 ParkerVision Presentation "D2D Technology Fundamentals" (3/24/99)

DX806 ParkerVision Presentation "Controlled Aperture Sub Harmonic Matched Filter Principles" (3/24/99)

DX807 Sterne Kessler Cover Sheet of Fax to Qualcomm (3/24/99)

DX808 Sterne Kessler Letter to Qualcomm re Provision of ParkerVision Materials to Qualcomm Pursuant to NDA (3/24/99)

DX809 ParkerVision Presentation "System Integration Theory and Practice" (3/16/99)

DX810 ParkerVision Presentation "CMOS D2D Circuit Design" (3/16/99)

DX811 ParkerVision Presentation "CMOS D2D Layout" (3/16/99)

DX812 ParkerVision Presentation "Utilizing and Configuring D2D: Advantages Made Practical" (3/16/99)

DX813 Sterne Kessler Cover Sheet of Fax to Qualcomm Forwarding NDA (3/12/99)

DX814 Mutual Non-Disclosure Agreement Between ParkerVision and Qualcomm (3/15/99)

DX815 ParkerVision Presentation "Who Are We and Why Are We Here" (3/16/99)

DX816 Qualcomm Schematics for IFR3000 (1999) DX817 Estabrook, P. et al., "The Design of a Mobile

Radio Receiver Using a Direct Conversion Architecture," IEEE, 1989


35.

EXHIBIT

NO. DATE

IDENTIFIED DATE

ADMITTED SPONSORING



DX818 106 U.S. Patent No. 6,061,551 (Sorrells et al.) (filed Oct. 21, 1998) (claims)

DX819 Qualcomm Zero IF Receiver HLDR (2000) DX820 Qualcomm Presentation "Sub Harmonic Mixers"

(3/18/99) DX821 Qualcomm RTR6275 RF Transceiver Device

Specification (Preliminary) (5/30/05) DX822 106 ParkerVision White Paper "Technical

Presentation" (1998) DX823 402/403 File History of U.S. Patent No. 6,061,551

(Sorrells et al.) (filed Oct. 21, 1998), Tenth Supplemental Information Disclosure Statement

DX824 Order Form for File History of U.S. Patent 6,061,551

DX825 Horney, C., "Cellular Handset & Chip Markets '08," Forward Concepts, May 2008

DX826 Email from R. Brockenbrough to H. Yoo et al. Attaching Qualcomm Astra RGR6240 RF Front End LLDR (10/2/07)

DX827 Qualcomm FTR8700/EagleRay Top Level LLDR (12/09)

DX828 801/802 Email from A. Zanzinger re ZIF Development (8/3/01)

DX829 ParkerVision White Paper "Technical Overview of an IEEE 802.11 WLAN Receiver Using ParkerVision Direct2Data Architecture" (1998)

DX830 801/802 Email from A. Savla to B. Walker et al. Attaching Qualcomm RGR6240 (Astra) 65nm Position Location Receiver A1V0 LLDR (8/06)

DX831 801/802 Qualcomm Presentation "Advanced Architectures Kick-Off Meeting" (8/08)

DX832 801/802 Email From P. Peterzell to R. Gilmore et al. re Direct Downconversion Tests (7/2/99)

DX833 801/802 Qualcomm RFR6155/6275 (Lightning) Multi-Band 1X/WCDMA-SGPS RFCMOS Zero IF Receive IC HLDR (9/04)

DX834 801/802 Qualcomm CDMA 1X PRX OBJ SPEC (2/2006) DX835 106/801/802 Cicalini, A. et al., "A 65nm CMOS SoC with

Embedded HSDPA/EDGE Transceiver, Digital Baseband and Multimedia Processor," ISSCC 2011, Session 21, Cellular, 21.3, pp. 9-11

DX836 801/802 Hadjichristos, A. et al., "Single-Chip, RF CMOS UMTS/EGSM Transceiver with Integrated Receive Diversity and GPS," 2009 IEEE International Solid-State Circuits Conference, 2009

DX837 801/802 Niknejad, A., "Lecture 20: Passive Mixers," University of California, EECS 142, 2008

DX838 Qualcomm GZIF3: WCDMA RX HLDR (6/3/04) DX839 Qualcomm RTR8600 Objective Specification

(8/18/08) DX840 801/802 Soer, M., "Analysis and Comparison of Switch-

Based Frequency Converters," University of Twente, MSc. Thesis, September 2007

DX841 Qualcomm Testing Document for Magellan High-Band Receiver in 1X Mode (5/10)

DX842 Qualcomm RTR6285 Objective Specification (8/3/06)


36.

EXHIBIT

NO. DATE

IDENTIFIED DATE

ADMITTED SPONSORING



DX843 801/802 Qualcomm RTR6285 (gzif4) TSMC18RF Delta-HLDR and Packaging Review (10/05)

DX844 Email chain between A. Hadjichristos and C. Conroy re RTR6285 (1/7/06)

DX845 801/802 Qualcomm RTR6280 (gzif4) High Level Design Review (6/05)

DX846 801/802 Email from C. Conroy to C. Park re Modena Test Chip Test Board (1/5/06)

DX847 Qualcomm BTS4025(FIJI) RX Signal Path LLDR (10/10/07)

DX848 402/403/801/802 Atheros Marketing Requirements Document "Mercury (AR6002x) Mobile Communications Wireless LAN Device" (1/15/06)

DX849 402/403/801/802 Atheros Product Requirements Document "Mercury-NG (AR6002NG) Mobile Communications Wireless LAN Device" (2/21/06)

DX850 402/403/801/802 Atheros Presentation "Phoenix Program Kick-off" (2/10/04)

DX851 402/403/801/802 Atheros Presentation "Bringing Radio-on-Chip Innovation to New Wireless Markets" (3/21/05)

DX852 801/802 Qualcomm Sapphire (WCN1312) LLDR (1/15/09)

DX853 801/802 TSMC "0.18UM Logic 1P6M Salicide 1.8V/3,3V Design Rule" (5/17/06)

DX854 402/403 Agreement and Plan of Merger by and Among Qualcomm Incorporated, BWI Acquisition Corporation, and Berkana Wireless Inc. (12/30/05)

DX855 402/403/801/802 Qualcomm Press Release "Qualcomm Acquires Berkana Wireless Inc., Strategic Developer of RF CMOS Solutions" (1/5/06)

DX856 402/403/801/802 Berkana Press Release "Berkana Wireless Introduced CMOS Transceivers with Best Performance/Power Combination for Single-Chip Quad-Band GSM/GPRS RFICs" (8/30/04)

DX857 402/403/801/802 Berkana Engineering Tape Out Schedules (6/6/04)

DX858 801/802 Qualcomm RTR6285 Product Council 2A Follow-Up (8/05)

DX859 801/802 Qualcomm RTR9205/RTR9215 PC2 Presentation (6/09)

DX860 801/802 Mini-Circuits SBL-1 Computer-Automated Performance Data

DX861 Email Chain Between S. Altman and D. Schrock et al. re ParkerVision's Opinion on Qualcomm's ZIF Announcement (12/19/00)

DX862 Qualcomm RTR6275 GSM-WCDMA, Zero-IF, Tx/Rx IC Test Specifications (6/14/06)

DX863 Qualcomm IFR3000 Rx IF-Baseband Converter IFT3000 Tx Baseband-IF Converter User Manual

DX864 801/802 Qualcomm RTR9605 Iceman LB MLDR (8/19/10)

DX865 801/802 Qualcomm RTR9605 (Iceman) MB Rx Signal Path LLDR (10/26/10)

DX866 Qualcomm RTR9605 Qualcomm Transceiver IC Device Specification (11/8/10)


37.

EXHIBIT

NO. DATE

IDENTIFIED DATE

ADMITTED SPONSORING



DX867 Qualcomm RTR6275 RF Transceiver IC Device Specification (10/1/08)

DX868 801/802 Qualcomm QZIF3: WCDMA RX HLDR (1/3/05) DX869 801/802 Qualcomm RTR6275 GZIF3 WCDMA IM2

Calibration Low-Level Design Review (11/9/05) DX870 801/802 Qualcomm RTR6275: GZIF3 GRSM RX

Frequency Dividers LLDR (11/22/04) DX871 801/802 Qualcomm RTR6275 High Level Design Review

(1/05) DX872 Qualcomm RTR8700 Product Requirements

Document (Preliminary Information) (5/9/07) DX873 Qualcomm RTR8700/XWING Objective

Specification (1/28/08) DX874 Qualcomm RTR8700 WCDMA Objective

Specification (6/9/08) DX875 Qualcomm RGR1000/RGR1100 RF Transceiver

IC Device Specification (9/15/08) DX876 Qualcomm RTR8700 (Hercules) Objective

Specification (6/5/09) DX877 801/802 Qualcomm Hercules (RTR8700) MLDR Digital

PLL, TX. RX (5/19) DX878 801/802 Email From P. Peterzell to P. Kantak re Minimal

Benefit of ParkerVision Technology (7/15/99) DX879 ParkerVision Generic License Agreement

(5/27/99) DX880 801/802/Late Produced /

Disclosed Qualcomm RTR6500 Transceiver with Rx Diversity (9/06)

DX881 LATE PRODUCED / DISCLOSED

Qualcomm RFR3100 Device Specification (12/14/00)

DX882 Qualcomm RFR6000 Zero-IF Receive IC Objective Specification (4/18/02)


Qualcomm RFR6185 RF Receiver IC Device Specification (10/1/08)


Qualcomm ZIFRIC Cell Mixer LLDR (6/27/01)


Qualcomm ZIFRIC PCS Mixer and IM2 Calibration Circuit (6/11/01)


Qualcomm MGP6200/RFR6000 RF Board Schematic (12/20/02)

DX887 801/802/Late Produced / Disclosed

Qualcomm RadioOne Performance Update (10/02)


Qualcomm Rx Diversity Using RFR6500/RFR6525 and RFT6150 ICs Design Guidelines (2/7/06)


Qualcomm GZIF3: WCDMA RX HLDR (1/13/05)


Qualcomm RTR6275 GZIF3 GSM IM2 Calibration LLDR (12/14/04)


Qualcomm RFR6000 RF Receiver Device Specification (2/5/10)

DX892 Qualcomm Presentation "Comparison of Rx SAWless Boxster front-end performance" (2/22/05)


ISSCC Digest of Technical Papers (1997)


38.

EXHIBIT

NO. DATE

IDENTIFIED DATE

ADMITTED SPONSORING



DX894 Late Produced / Disclosed Shahani, A. et al., "A 12mW Wide Dynamic Range CMOS Front-End for a Portable GPS Receiver,” 1997 International Solid-State Circuits Conference (Paper and Slides)


Escrow Agreement Between Qualcomm and Airgo Networks, Inc. (11/15/06)


Agreement and Plan of Merger By and Among Qualcomm Incorporated, Amethyst Acquisition Corporation and Airgo Networks, Inc. (11/15/06)


Agreement and Plan of Merger By and Among Qualcomm Incorporated, Amethyst Acquisition Corporation and Airgo Networks, Inc., Schedule 7.2(n)(i) (11/15/06)


Asset Purchase Agreement by and Among Qualcomm Incorporated, as Purchaser, RF Micro Devices, Inc., as Parent, and RFMD WPAN, Inc., as Seller (12/1/06)


Qualcomm-RFMD Merger Agreement, Exhibit A, Joint Defense Agreement (2006)


Qualcomm-RFMD Merger Agreement, Exhibit B, Agreement Regarding Certain Indemnity Claims Between Qualcomm and RFMD (2006)


Qualcomm-RFMD Merger Agreement, Exhibit C, Retained Know How Rights Between Qualcomm and RFMD (2006)


Qualcomm-RFMD Merger Agreement, Exhibit D, Letter re Qualcomm-RFMD Merger Agreement (2006)


Qualcomm-RFMD Merger Agreement, Exhibit E, Assignment (2006)


Qualcomm-RFMD Merger Agreement, Exhibit F, Assignment of Federal Registered Trademark (2006)


Qualcomm-RFMD Merger Agreement, Exhibit G, Instrument of Assumption of Liabilities (2006)


Qualcomm-RFMD Merger Agreement, Exhibit H, Indenture, Bill of Sale, and Assignment (2006)


Qualcomm-RFMD Merger Agreement, Disclosure Schedule (2006)


Master Agreement to Lease Equipment Between Cisco Systems and RFMD (7/28/04)


Qualcomm Press Release "Qualcomm CDMA Technologies Introduces Revolutionary Radio Frequency Architecture for CDMA Market" (12/18/00)


Qualcomm WTR1605 (WSP) Multi-Mode RF Transceiver (3G/4G) QCT Development Gate (PC-2) / Plan of Record (POR) Review (5/6/10)

DX911 Qualcomm RTR6500 RF Chipset Product Council 2 (4/05)

DX912 Late Produced / Disclosed Licensing Agreement Between Washington Research Foundation (WRF) and Qualcomm (12/13/12)

DX913 106/Late Produced / Disclosed

Licensing Agreement Between Washington Research Foundation (WRF) and Qualcomm (12/13/12) pp. 2-4


39.

EXHIBIT

NO. DATE

IDENTIFIED DATE

ADMITTED SPONSORING




Licensing Agreement Between Washington Research Foundation (WRF) and Qualcomm (12/13/12) p. 9


ABI Research, "Mobile Device Shipment Market Data, Global" (6/20/12)


Horney, C., "Cellular Handset & Chipset Markets '11," Forward Concepts (6/11)

DX917 402/403/801/802/Late Produced / Disclosed

Qualcomm Press Release "Qualcomm Completes $3.1 Billion Acquisition of Atheros Communications" (5/24/11)


Email Chain Between A. Hadjichristos and C. Cormac re RTR6285 (1/7/06)


Email chain between A. Hadjichristos and C. Conroy re RTR6285 RX Architecture Decision (1/10/06)


Qualcomm 2g Rx Front-End Review (1/06)


Qualcomm Alpina 2G/3G AIF Rx Front-End Review (1/06)

DX922 Email chain between D. Maldonado and A. Hadjichristos re 2G RX - Next Steps (1/23/06)


Email from C. Conroy to J. Tham et al. re Qualcomm Feedback on Firebird and Modena (5/15/04)


Berkana Spreadsheet "Firebird/Modena Tape Out Status for ES2" (6/6/04)


Berkana Modena Front-End Architecture Review (12/21/04)

DX926 Qualcomm Spreadsheet "RF/Analog/Mixed Signal Staffing" (7/22/05)


Qualcomm Presentation "Berkana Circuits and Preliminary Team Evaluation Summary" (12/2/05)

DX928 Qualcomm UMTS RF Product Development Roadmap (12/05)


Qualcomm TSMC19RF Process Tech L2 Exit Review (10/06)


Berkana Multimode WCDMA/GSM/EDGE Chipset Product Requirements Document V0.1 (2003)


Berkana Multimode WCDMA/GSM/EDGE Chipset Product Requirements Document V0.2 (10/14/03)


Berkana Firebird/Modena Tapeout Plan (5/12/04)


Berkana Modena Evaluation Board (8/1/04)


Email Chain Between C. Conroy and M. Choi re Shipment of Modena (8/24/04)


Qualcomm Presentation re Product Updates (1/6/06)

DX936 801/802/901/Late Produced / Disclosed

Mini-Circuits Product Specifications Sheet for Frequency Mixers


Qualcomm Presentation "8x10 Multimedia" (1/12)


40.

EXHIBIT

NO. DATE

IDENTIFIED DATE

ADMITTED SPONSORING




Email from B. Agia to Qualcomm.all Distribution List et al. Containing Qualcomm Press Release "Qualcomm CDMA Technologies Introduces Revolutionary Radio Frequency Architecture for CDMA Market" (12/18/00)


Email from D. Martel to Zifric.mail Distribution List et al. re ZIFRIC & TIC Design Actions (5/16/01)


Qualcomm Presentation "RF/Analog Development Metrics" (10/01)


Email chain between S. Getz and J. Thomson re RadioOne Technology Article in April 2002 Issue of Wireless Design and Development (3/4/02)


Wireless Design and Development Article "RadioOne Technology: An Evolutionary Leap for CDMA Phones" (4/02)


Email from D. Schrock to Qct.business Email Distribution List et al. re First Shipment of ZIF Products (4/1/02)


Email from P. Peterzell to S. Ball et al. re Availability of Direct Conversion Boards (11/1/99)


Email from P. Peterzell to S. Jha et al. re ZIF Development (5/12/00)


Qualcomm Presentation re ZIF Development (1/02)


Email from P. Peterzell to R. Gilmore re ZIF Development (5/4/99)


Qualcomm Presentation "Zero Intermediate Frequency (ZIF) Project Status" (4/17/01)


Qualcomm Presentation "Direct Downconversion Prototype Lessons Learned" (1/28/00)


Qualcomm Memo "Direct Conversion Receiver Project" (10/99)

DX951 Email Chain Between C. Wheatley and R. Blakeney et al. re Not Using ParkerVision Technique (12/21/00)


ParkerVision Main Docking Station Receiver Schematic (1998)


Breems, L., "A 1.8mW CMOS Modulator with Integrated Mixer for A/D Conversion of IF Signals," Slide Presentation, ISSCC 99, Session 3, Oversampled Modulators, Paper MO 3.2


Breems, L., "A 1.8mW CMOS Modulator with Integrated Mixer for A/D Conversion of IF Signals," IEEE International Solid-State Circuits Conference, Session 3, Paper MP 3.2, 1999


Razavi, B., "Principles of Data Conversion System Design," IEEE Press, 1995

DX956 402/403/602/801/802/Late Produced / Disclosed

Razavi, B., "Design of a 100-MHz 10-mW 3-V Sample-and-Hold Amplifier in Digital Bipolar Technology," IEEE Journal of Solid-State Circuits, Vol. 30, No. 7, July 1995, pp. 724-730


Qualcomm RFR6155 RF Receiver IC Device Specification (10/1/08)


Qualcomm RFR6500 Dual RF Receiver IC Device Specification (2/10/10)


41.

EXHIBIT

NO. DATE

IDENTIFIED DATE

ADMITTED SPONSORING




Hornery, C., "Cellphone & Tablet Core Chip Markets '13," Forward Concepts (2/13)


Mawston, N., "A Quarter-Billion LTE Phones Will Be Shipped Worldwide in 2013," Strategy Analytics (12/18/12)

DX961* 402/403/801/802/Late Produced / Disclosed

McGinnis, K., "21st Century EMS Communications Systems: 'Brick' to the Tricorder," National Association of State EMS Officials (3/13)

DX962 402/403/801/802 Handwritten Notes of Dr. Behzad Razavi DX963 402/403 ParkerVision Inc., Annual Report (Form 10-K)

(3/31/1994) DX964 402/403/801/802 Qualcomm’s Invalidity Contentions (4/16/12) DX965 402/403/801/802 Qualcomm’s Invalidity Contentions, Exhibits A-F

(4/16/12) DX966 402/403/Rule 16 Transcript of Deposition Testimony of Jeffrey

Leach (11/13/12) DX967 402/403/Rule 16 Transcript of Deposition Testimony of Michael

Quentin Lee (11/27/12) DX968 402/403/Rule 16 Transcript of Deposition Testimony of Richard

Harlan (11/27/12) DX969 402/403/Rule 16 Transcript of Deposition Testimony of William

Edwin Baker III (11/27/12) DX970 402/403/Rule 16 Transcript of Deposition Testimony of David F.

Sorrells (Vol. 1) (11/30/12) DX971 402/403/Rule 16 Transcript of Deposition Testimony of David F.

Sorrells (Vol. 2) (11/30/12) DX972 402/403/Rule 16 Transcript of Deposition Testimony of Jeffrey

Parker (Vol. 1) (12/12/12) DX973 402/403/Rule 16 Transcript of Deposition Testimony of Jeffrey

Parker (Vol. 2) (12/13/12) DX974 402/403/Rule 16 Transcript of Deposition Testimony of Paul C.

Benoit (05/08/13) DX975 402/403/Rule 16 Transcript of Deposition Testimony of Paul

Prucnal (05/09/13) DX976 402/403/Rule 16 Transcript of Deposition Testimony of David F.

Sorrells as expert (Corrected source code) (05/10/13)

DX977 402/403/Rule 16 Transcript of Deposition Testimony of David F. Sorrells as expert (Corrected redacted) (05/10/13)

DX978 402/403/Rule 16 Transcript of Deposition Testimony of Peter A. Weisskopf (05/10/13)

DX979* 402/403/801/802 Brave New World, "Public Safety Mobile Apps for 4G Networks, Digital Communities," 2013

DX980 402/403/801/802 Broadcom Fourth Quarter 2012 Earnings Call Transcript (1/29/13)

DX981 402/403 U.S. Patent Application 09/176,022 Second Supplemental Information Disclosure Statement (9/21/99)

DX982 402/403 U.S. Patent Application 09/176,022, Information Disclosure Statement

DX983 402/403 U.S. Patent Application 09/176,022, Examiner Interview Summary Record



42.

EXHIBIT

NO. DATE

IDENTIFIED DATE

ADMITTED SPONSORING



DX984 402/403 U.S. Patent Application 09/176,154, Examiner Interview Summary Record

DX985 106 Razavi, B. “RF Microelectronics," Prentice Hall, 1995

DX986 Sorrells, D. Presentation to Agilent, "The Coming Revolution: Direct Conversion Radios" (2000)

DX987 ParkerVision Presentation "ParkerVision" (2/14/05)

DX988 U.S. Patent No. 6,963,734 (Sorrells et al.) (filed Dec. 12, 2002)

DX989 402/403/602/801/802 U.S. Patent No. 4,253,006 (Fisher et al.) (filed May 13, 1980)

DX990 402/403/601/801/802 U.S. Patent No. 5,557,642 (Williams) (filed Nov. 14, 1994)

DX991 402/403/601/801/802 Faulkner, N. et al., "Subharmonic Sampling Measurement of Short-Term Stability of Microwave Oscillators" IEEE Transactions on Instrumentation and Measurement, Vol. IM-32, No. 1, March 1983, pp. 208-13

DX992 File History of U.S. Patent No. 6,061,551, Declaration and Statement of Verified Facts of Jeffrey L. Parker and David F. Sorrells (9/1/99)

DX993 Fax From S. Younis to J. Parker et al. Enclosing Qualcomm Memo "Assessment of ParkerVision D2D Technology" (3/23/99)

DX994 402/403 Email From J. Parker to D. Sorrells re More Qualcomm Product Documents (4/2/08)

DX995 Qualcomm RTR6285/RTR6280 RF Transceiver IC Device Specification (11/29/07)

DX996 402/403 ParkerVision Memorandum "ParkerVision Claim Analysis," D. Sorrells (8/11/11)

DX997 402/403 ParkerVision's Rule 26(a)(2)(C) Disclosure of Testimony by David Sorrells in Rebuttal to Dr. Razavi and Dr. Williams

DX998 ParkerVision Presentation "PVDC1000 D2D Frequency Downconverter Test Overview" (5/7/13)

DX999 ParkerVision Preliminary Document "PVDC1000 Frequency Downconverter Using a d2d Technology" (5/6/13)

DX1000 U.S. Patent No. 6,061,551 (Sorrells et al.) (filed Oct. 21, 1998), Claims, With Handwritten Markings

DX1001 U.S. Patent No. 6,266,518 (Sorrells et al.) (filed Aug. 18, 1999), Claims, With Handwritten Markings

DX1002 U.S. Patent No. 6,370,371 (Sorrells et al.) (filed Mar. 3, 1999), Claims, With Handwritten Markings

DX1003 ParkerVision General Ledger Report (1/31/98-12/31/98)

DX1004 ParkerVision Journal Batch Report (1/27/98) DX1005 Boeing, "Performance Evaluation Report for the

ParkerVision Universal Direct Conversion Receiver" (3/16/98)


43.

EXHIBIT

NO. DATE

IDENTIFIED DATE

ADMITTED SPONSORING



DX1006 Handwritten Notes re Boeing Tests as Cover Sheet for Boeing, "Performance Evaluation Report for the ParkerVision Universal Direct Conversion Receiver" (4/29/98)

DX1007 403/702/801/802 Expert Report of Dr. Behzad Razavi DX1008 106 U.S. Patent No. 6,061,551 (Sorrells et al.) (filed

Oct. 21, 1998), Figs. 110 and 111 DX1009 901/Late Produced /

Disclosed ParkerVision Meeting Invite for J. Parker and P. White et al. of VIA (7/18/07)


Email Chain Between H. Yang and C. Meng et al. (VIA Internal Email) Ending ParkerVision Project (3/14/12)


Email from J. Leach to F. Jungman et al. of VIA re Upcoming Meeting (1/11/08)


Email from M. Davis to J. Schrenger et al. re Proposed ParkerVision Royalty Rates (12/19/07)


Email From F. Jungman to J. Shrenger (Internal VIA Email) Evaluating Scope of ParkerVision License and Royalty Rates (12/18/07)


VIA Telecom / ParkerVision Draft CDMA Product Development Program Statement of Work Version 2.07 (12/15/07)


Draft License and Engineering Services Agreement Between ParkerVision and VIA Telecom (12/13/07)


Email From F. Jungman to J. Schrenger (Internal VIA Email) re Scope and Exclusivity of Potential License with ParkerVision (12/12/07)








Email From M. Davis to D. Lin et al. (Internal VIA Email) re Agenda for ParkerVision Meeting (11/15/07)


Email Chain Between K. Zhang and M. Davis at al. (Internal VIA Email)re Comments on Proposed ParkerVision Agreement (11/6/07)


Email Chain Between F. Jungman and M. David (Internal VIA Email) re Business Terms of Potential ParkerVision License Agreement (11/5/00)


Email from M. Davis to J. Stuckey et al. re ParkerVision's Proposed Royalty Rates (11/2/07)


Email From F. Jungman to M. Davis (Internal VIA Email) re ParkerVision's Key Assumptions in its Costing Model (9/7/07)


Email from J. Moon to P. White et al. re ParkerVision's Interest in Pursuing Relationship (7/20/07)


44.

EXHIBIT

NO. DATE

IDENTIFIED DATE

ADMITTED SPONSORING




Email From M. Davis to K. Zhang (Internal VIA Email) re Overall Assessment of License with ParkerVision (12/21/07)


VIA Telecom / ParkerVision Draft d2d CDMA Product Development Program Statement of Work Version 1.00 (12/19/07)


Email Chain Between M. Davis and K. Zhang (Internal VIA Email) re Exclusivity in ParkerVision License Agreement (8/8/07)


Email Chain Between J. Moon and K. Zhang re VIA Receiver Solution (8/7/07)


Email From M. Davis to K. Zhang (Internal VIA Email) re Negotiating ParkerVision Royalty Rates (12/13/07)

DX1031 ParkerVision Presentation "ParkerVision Board Meeting" (8/16/99)

DX1032 Foundation Handwritten Drawing DX1033 Foundation Handwritten Drawing, Voltage Follower DX1034 Foundation Handwritten Drawing DX1035 402/403 International Patent Examination Report of

International Application No. PCT/US99/24299 (2/22/01)

DX1036 801/802/901 “1X-EV-DO (Revision A),” CDMA Development Group

DX1037 801/802/901 “1X-EV-DO (Revision B)," CDMA Development Group

DX1038 801/802/901 “4Q 2011 Subscriber Statistics,” CDMA Development Group

DX1039 402/403/801/802 Non-Adversarial Tutorial Transcript (7/24/12) DX1040 402/403/602/801/802 Abidi, A., “Direct-Conversion Radio Transceivers

for Digital Communications,” IEEE Journal of Solid-State Circuits, Vol. 30, No. 12, December 1995

DX1041 801/802/901 About the IEEE Fellow Program DX1042 106/801/802 Allen, P and Hollenberg, D., "CMOS Analog

Circuit Design, Chpt. 9.8," Digital-Analog and Analog-Digital Converters, Oxford University Press, 2012

DX1043 801/802/901 Apple iPhone 4S Teardown, Summary, Tech Insights

DX1044 801/802/901 “At least two Thirds of Mobile Traffic Will Be Video by 2017 – Cisco report,” Faultline, The Register, February 11, 2013

DX1045 402/403/801/802/901 Atheros Press Release "Atheros Communications Introduces Industry's First Single-Chip 802.11a/b/g Wireless LAN Solution" (10/11/04)

DX1046 801/802 Binmore, K., Rubinstein, A. and Wolinsky, A. “The Nash Bargaining Solution in Economic Modeling,” RAND Journal of Economics, Vol. 17, No. 2, Summer 1986

DX1047 801/802/901 Bloomberg, "Qualcomm Chip Shortage Eases on Samsung, TSMC Output," December 5, 2012

DX1048 801/802 Boser, B.E. "EE 247: Analog-Digital Interface Integrated Circuits, Filters-Outcomes," UC Berkeley, 2011

DX1049 106/801/802/901 Broadcom Fourth Quarter 2012 Earnings Call Transcript


45.

EXHIBIT

NO. DATE

IDENTIFIED DATE

ADMITTED SPONSORING



DX1050 801/802 Carroll, A. and Heiser, G. “An Analysis of Power Consumption in a Smartphone,” USENIXATC '10, Proceedings of the 2010 USENIX Conference on USENIX Annual Technical Conference

DX1051 801/802/901 CDG, "CDMA Statistics" DX1052 402/403/601/801/802 Chang, P.J. “A CMOS Channel-Select Filter for

a Direct-Conversion Wireless Receiver,” Symposium on VLSI Circuits, Digest of Technical Papers, 1996

DX1053 801/802/901 Cheng, C. “The Dell XPS 10 and Qualcomm Snapdragon: Transforming Mobile Computing,” Dell World 2012, December 6, 2012

DX1054 801/802/901 Clarke, P. “Intel says no LTE integration until 2014,” EE Times, January 28, 2013

DX1055 402/403/601/801/802 Colebrook, F.M. “Homodyne,” Wireless World and Radio Review, No. 13, 1924

DX1056* 402/403/801/802 Comment of Verizon, In the Matter of NTIA Development of the Nationwide Interoperable Public Safety Broadband Network – FirstNet NOI, No. 12092850-2505-01, Nov. 9, 2012

DX1057* 402/403/801/802 Comments of Qualcomm Incorporated, In the Matter of Development of the Nationwide Interoperable Public Safety Broadband Network, No. 120928505-2505-01, Nov. 9, 2012

DX1058* 402/403/801/802 Comments of Qualcomm Incorporated, In the Matter of Promoting Interoperability in the 700 MH Commercial Spectrum, WT Docket No. 12-69 (FCC June 12, 2012)

DX1059* 402/403/801/802 "Comments on Nationwide Interoperable Public Safety Broadband Network NOI," National Telecommunications & Information Administration Interoperable Public Safety Broadband Network NOI

DX1060 801/802/901 Crothers, B. “Qualcomm Chip in HTC One S is Speed Demon, Says Analyst,” CNET, April 23, 2012

DX1061* 402/403/801/802 "Disaster Apps and Mobile Optimized Web Pages," Disaster Information Management Research Center

DX1062 402/403/601/801/802 Drafts, B. "Acoustic Wave Technology Sensors," Sensors Magazine, October 1, 2000

DX1063 106/402/403/601/801/802/901 EP Patent No. 0276130A2 (Jones et al.) (filed Jan 20, 1988)

DX1064 Estabrook, P. and Lusignan, B, “The Design of a Mobile Radio Receiver using a Direct Conversion Architecture,” IEEE, 1989

DX1065 Estabrook, P. et al., “A Mixer Computer-Aided Design Tool Based in the Time Domain," IEEE MTT-S Digest, 1988

DX1066 801/802 Qualcomm Presentation "Evolving 3G/LTE to Meet the Challenges of Mobile Connectivity"



46.

EXHIBIT

NO. DATE

IDENTIFIED DATE

ADMITTED SPONSORING



DX1067 801/802 Exhibit B to the Declaration of Jim Tran in support of Qualcomm’s Opposition to ParkerVision’s Motion to Compel Qualcomm’s Responses to Interrogatory Nos. 4 and 9, and for Qualcomm to Produce Correspondence with Subpoenaed Third Parties, Dkt. 174-1, 9/24/2012

DX1068 402/403/601/801/802 Franks, L. and Witt, F. “Solid-State Sampled-Data Bandpass Filters,” IEEE ISSCC Dig. Tech. Papers, Vol. III, February 1960

DX1069 801/802 Freeman, M. “New Nokia, Motorola phones powered by Qualcomm’s Snapdragon,” UT San Diego, September 5, 2012

DX1070* 402/403/801/802 Genachowski, J. “Mobile Broadband: A 21st Century Plan for U.S. Competitiveness, Innovation and Job Creation," Federal Communications Commission, February 24, 2010

DX1071 402/403/601/801/802 Gilbert, B. "A Precise Four-Quadrant Multiplier with Subnanosecond Response," IEEE Journal of Solid-State Circuits, Vol. SC-3, No. 4, December 1968

DX1072* 402/403/801/802 Grossman, A. "Win for First-Responders," WSJ.com, February 17, 2012

DX1073 402/403/601/801/802 Hanusch, T. et al., “Analog Baseband IC for Dual-Mode Direct Conversion Receiver,” Proceedings of European Solid-State Circuits Conference (ESSCIRC), September 1996

DX1074* 402/403/801/802 Heaton, B. "Emergency Texts Aid First Responders in New Mexico," Government Technology, Jan. 16, 2012

DX1075 801/802 Hickey, A. R. “Dell Laptops to Offer Qualcomm Gobi Mobile Broadband,” CRN, April 1, 2008

DX1076 801/802 Hubbard, M. “Taming the Smartphone Power Consumption Vicious Cycle,” Microwave Journal, November 2012

DX1077 402/403/601/801/802 Hugh H. Skilling, "Electrical Engineering Circuits," 2d Ed., John Wiley & Sons, 1965

DX1078 Hull, C. "A Direct Conversion Receiver for 900-MHz ISM Band Spread Spectrum Digital Cordless Telephone," IEEE J. of Solid-State Circuits, Vol. 31, No. 12, December 1996, 1955-1963

DX1079 801/802 IEEE Distinguished Lecturer Program Information Page

DX1080 106/801/802 Carusone, T. Et al., "Analog Integrated Circuit Design," John Wiley & Sons, 2012

DX1081 402/403 Joint Claim Construction Statement, Dkt. 110 (5/30/12)

DX1082 402/403 Joint Claim Construction Statement, Exhibit A, Dkt. 110-1 (5/30/12)

DX1083 801/802 Klug, B. “The State of Qualcomm's Modems - WTR1605 and MDM9X25,” AnandTech, January 4, 2013



47.

EXHIBIT

NO. DATE

IDENTIFIED DATE

ADMITTED SPONSORING



DX1084* 402/403/801/802 Knell, N. "Mobile County, Ala., Uses App To Supplement Radio Communications," Government Technology, March 22, 2013

DX1085 106/402/403/601/801/802 Krauss, H. et al., "Solid State Radio Engineering," John Wiley & Sons, 1980

DX1086 801/802 Kukil, B. “Samsung Galaxy S4 GT-I9505 Featuring Qualcomm Snapdragon 600 Processor Gets Rooted Successfully: Here’s How to Do It,” International Business Times, April 5, 2013

DX1087 106/402/403/601/801/802 Lathi, B.P. "Modern Digital and Analog Communication Systems," Oxford University Press, 3rd ed., 1998

DX1088 402/403/801/802 Lattman, P. and Sorkin, A.R. "Qualcomm Is Said to Be Set to Buy Atheros for $3.5 Billion," NY Times Dealbook, January 4, 2011

DX1089 801/802 Layne-Farrar, A. and Learner, J. “To Join or Not to Join: Examining Patent Pool Participation Rules and Rent Sharing Rules,” International Journal of Industrial Organization, March 2011, Vol. 29, No. 2

DX1090* 402/403/801/802 McKay, D. "APD’s New Crime-Fighting Tool: iPad," Albuquerque Journal, January 17, 2012

DX1091* 402/403/801/802 MetroPCS Press Release “MetroPCS Launches 4G LTE Service in Atlanta, Jacksonville, Miami and Orlando Metropolitan Areas” (1/25/11)

DX1092 801/802 MetroPCS Press Release “MetroPCS Launches First 4G LTE Services in the United States and Unveils World’s First Commercially Available 4G LTE Phone” (9/21/10)

DX1093 601/801/802 Mirzaei, A. et al., "Analysis and Optimization of Current-Driven Passive Mixers in Narrowband Direct-Conversion Receivers," IEEE J. Solid-State Circuits, Vol. 44, No. 10, October 2009

DX1094 801/802 Motorola Droid 4 Teardown, ifixit DX1095 402/403/601/801/802 Nakayama, K. and Mizukami, T., “A New IIR

Nyquist Filter With Zero Intersymbol Interference and Its Frequency Response Approximation,” IEEE Transactions on Circuits and Systems, Vol. CAS-29, No.1, Jan. 1982

DX1096 402/403/801/802 Mueller, S., "Nasdaq gives ParkerVision a delisting warning,” November 4, 2011

DX1097 801/802 Nash, J. “The Bargaining Problem,” Econometrica, 1950, 155-162

DX1098 801/802 Nash, J. “Two-Person Cooperative Games,” Econometrica, 1953

DX1099 402/403/601/801/802 Nyquist, H., "Certain Factors Affecting Telegraph Speed," Bell System Technical Journal, Vol. 3, pp. 324-346

DX1100 106/801/802 O’Haver, R. and Finnegan, B. “Estimating the Effects of Exclusivity and Geographic Market Characteristics on Royalty Rates: Some Preliminary Results,” The Licensing Economics Review, Vol. 4, No. 2, November 1993

DX1101 402/403/601/801/802 Oppenheim, A. et al., "Time Signal Processing," Prentice Hall, 1999



48.

EXHIBIT

NO. DATE

IDENTIFIED DATE

ADMITTED SPONSORING



DX1102 Oxner, E., “Commutation Mixer Achieves High Dynamic Range Introducing the Siliconix Si8901 QuadFET,” RF Design, February 1986, pp. 47-53

DX1103 801/802 Paczkowski, J. “After Just Two Years, Nearly Half of Verizon’s Data Traffic Is on LTE,” All Things D, January 11, 2013

DX1104* 402/403/801/802 "Paramedics Send Heart Images Via Cell Phone," 10News.com, Mar. 2, 2005














DX1118 ParkerVision Inc., Conference Call Transcript, 5/2/2007




DX1122 ParkerVision Inc., Conference Call Transcript, 12/8/2008



DX1125 402/403 ParkerVision Press Release "ParkerVision Reports Fourth Quarter and Year-End Results" (3/15/10)




49.

EXHIBIT

NO. DATE

IDENTIFIED DATE

ADMITTED SPONSORING



DX1127 402/403 ParkerVision Inc.’s Motion for Leave to Serve Supplemental Infringement Contentions, Ex. A (ParkerVision Inc.’s Supplemental Disclosure of Asserted Claims and Infringement Contentions), Dkt. 152-1, 8/27/2012

DX1128 402/403 ParkerVision, Inc.’s Opening Claim Construction Brief, Dkt. 122, 7/13/2012

DX1129 402/403 ParkerVision’s Inc.'s First Supplemental Objections and Responses to Qualcomm’s First Set of Interrogatories (Nos. 6-8)

DX1130 801/802 "ParkerVision Signal Max WLAN 1500 PC Card 1 Mile LAN Adapter Product Specifications," Geeks.com

DX1131 106/801/802/901 "ParkerVision WR3000 User's Guide," ManualsLib.com

DX1132* 402/403/801/802 Phend, C. "HRS: From the Ambulance, Calling in the ECG by Cellphone," MedPage Today, May 19, 2008

DX1133 402/403 Plaintiff ParkerVision Inc.’s Disclosure of Asserted Claims and Infringement Contentions, 3/02/2012

DX1134* 402/403/801/802 "Public Safety Broadband High-Level Launch Requirements Statement of Requirements for FirstNet Consideration," National Public Safety Telecommunications Council, December 7, 2012

DX1135 402/403/801/802 Qualcomm Inc., Annual Report (Form 10-K) (11/7/2012)

DX1136 801/802 Qualcomm, "Accelerating Mobility: How Qualcomm’s business model drives wireless innovation and growth,” July 2012

DX1137 801/802 Qualcomm Press Release "Qualcomm Announces Production Shipment of World’s First radioOne 3G CDMA2000 1X Chipset and System Software" (10/29/02)

DX1138 801/802 Qualcomm Press Release "Qualcomm Announces World’s First Single-Chip, RF CMOS UMTS Transceiver with Integrated Receive Diversity and GPS" (2/13/06)

DX1139 402/403/801/802 Qualcomm Press Release "Qualcomm to Acquire Atheros, Leader in Connectivity & Networking Solutions" (1/5/11)

DX1140 801/802 Qualcomm, "Sony Xperia Z Featuring a Snapdragon S4 Pro Processor"

DX1141 801/802 Qualcomm, “Blackberry Bold: Featuring a Snapdragon S2 Processor”

DX1142 801/802 Qualcomm Press Release “Qualcomm Begins Production Shipping of Industry-Leading Fifth-Generation CDMA Chipset and System Software to Major Handset Manufacturers” (1/27/99)

DX1143 801/802 Qualcomm Press Release “Qualcomm Introduces 28nm Mass Market LTE/DC-HSPA+ Chipsets for Mobile Broadband Products” (2/14/12)



50.

EXHIBIT

NO. DATE

IDENTIFIED DATE

ADMITTED SPONSORING



DX1144 801/802 Qualcomm Press Release “Qualcomm Receives Strong Initial Response for its CDMA New Fifth-generation Chipset and System Software” (9/24/98)

DX1145 801/802 Qualcomm.com History and Linked Video DX1146 Qualcomm’s Second Supplemental Exhibit B to

its First Supplemental Response to ParkerVision’s Interrogatory No. 2

DX1147 801/802 Randewich, N. and Gupta, P. “Dissected iPad Reveals Samsung, Qualcomm parts,” Reuters, March 15, 2012

DX1148 106/402/403/601/801/802 Razavi, B. "Analog-to-Digital Converter Architectures," 1995

DX1149 106/402/403/601/801/802 Razavi, B. "Principles of Data Conversion System Design," IEEE Press, 1995

DX1150 402/403/601/801/802 Razavi, B. “TP 3.1: A 1.5V 900MHz Downconversion Mixer,” IEEE International Solid State Circuits Conference, Session 3, 1996

DX1151 402/403/601/801/802 Sevenhans, J. "An Analog Radio Front-End Chip Set for a 1.9-GHz Mobile Radio Telephone Application," IEEE International Solid-State Circuits Conference, February 1994

DX1152 402/403/601/801/802 Sevenhans, J. et al., "An Integrated Silicon Bipolar RF Transceiver for a Zero-IF 900-MHz GSM Digital Mobile Radio Front-End of a Hand Portable Phone," IEEE CICC, May 1991

DX1153 402/403/601/801/802 Shannon C., "A Mathematical Theory of Communication," Bell System Technical Journal, Vol. 27, July and October 1948

DX1154 801/802 Shrivastava, S. “Android 5.0 Key Lime Pie: Samsung Galaxy S4 Mini Will Only Run Jelly Bean Like Samsung Galaxy S3?” Mobile & Apps, April 5, 2013

DX1155* 402/403/801/802 Advertisement, Sonim’s XP 3400 Armor S DX1156 106/801/802 “Technology Leadership,” Taiwan

Semiconductor Manufacturing Company, 2006 Annual Report

DX1157 U.S. Patent No. 5,339,459 (Schiltz) (filed Dec. 3, 1992)

DX1158 402/403/601/801/802 U.S. Patent No. 5,557,642 (Williams) (filed Nov. 14, 1994)

DX1159 U.S. Patent No. 5,579,347 (Lindquist) (filed Dec. 28, 1994)

DX1160 402/403/601/801/802 U.S. Patent No. 5,722,061 (Hutchison IV et al.) (filed Sep. 30, 1996)

DX1161 402/403/601/801/802 U.S. Patent No. 6,175,279 (Ciccarelli et al.) (filed Mar. 4, 1998)

DX1162 402/403/601/801/802 U.S. Patent No. 6,192,225 (Arpaia et al.) (filed Apr. 22, 1998)

DX1163 U.S. Patent No. 6,230,000 (Tayloe) (filed Oct. 15, 1998)

DX1164 U.S. Patent No. 6,266,518 (Sorrells et al.) (filed Aug. 18, 1999)

DX1165 402/403/601/801/802 U.S. Patent No. 6,275,687 (Lloyd) (filed Nov. 30, 1998)



51.

EXHIBIT

NO. DATE

IDENTIFIED DATE

ADMITTED SPONSORING



DX1166 U.S. Patent No. 6,370,371 (Sorrells et al.) (filed Mar. 3, 1999)

DX1167 402/403/601/801/802 U.S. Patent No. 6,407,689 (Bazarjani et al.) (filed Nov. 1, 2000)

DX1168 402/403/601/801/802 U.S. Patent No. 6,694,129 (Peterzell et al.) (filed Dec. 10, 2001)

DX1169 402/403/601/801/802 U.S. Patent No. 6,801,760 (Hutchison et al.) (filed Jul. 26, 2001)

DX1170 402/403/601/801/802 U.S. Patent No. 6,960,962 (Dunworth et al.) (filed Dec. 10, 2001)

DX1171 U.S. Patent No. 7,010,286 (Sorrells et al.) (filed May 16, 2001)

DX1172 402/403/601/801/802 U.S. Patent No. 7,076,225 (Li et al.) (filed Dec. 21, 2001)

DX1173 402/403/601/801/802 U.S. Patent No. 7,130,602 (Ciccarelli) (filed Oct 21, 2003)

DX1174 402/403/601/801/802 U.S. Patent No. 7,174,190 (Walker et al.) (filed May 16, 2005)

DX1175 402/403/601/801/802 U.S. Patent No. 7,283,851 (Persico et al.) (filed Nov. 17, 2004)

DX1176 402/403/601/801/802 U.S. Patent No. 7,482,852 (Samavati) (filed Aug. 30, 2009)

DX1177 U.S. Patent No. 7,496,342 (Sorrells et al.) (filed Oct. 25, 2004)

DX1178 402/403/601/801/802 U.S. Patent No. 7,769,361 (Zhuo et al.) (filed Sep. 14. 2006)


DX1180 402/403/601/801/802 U.S. Patent No. 7,834,698 (Sengupta et al.) (May 23, 2008)

DX1181 402/403/601/801/802 U.S. Patent No. 7,848,713 (Cabanillas et al.) (filed Sep. 28, 2007)

DX1182 402/403/601/801/802 U.S. Patent No. 7,876,867 (Filipovic et al.) (Mar 30, 2007)

DX1183 402/403/601/801/802 U.S. Patent No. 8,036,623 (Chang et al.) (filed Jul. 12, 2007)

DX1184 402/403/601/801/802 U.S. Patent No. 8,044,723 (Kim et al.) (filed Oct. 8, 2007)


DX1186 402/403/601/801/802 U.S. Patent No. 8,060,041 (Ballantyne) (filed Feb. 9, 2006)

DX1187 402/403/601/801/802 U.S. Patent No. 8,086,247 (Kraufvelin et al.) (filed Apr. 4, 2008)

DX1188 402/403/601/801/802 U.S. Patent No. 8,170,482 (Linsky) (filed Aug. 1, 2008)

DX1189 402/403/601/801/802 U.S. Patent No. 8,243,640 (Kohlmann et al.) (filed May 19, 2008)

DX1190 Wilson, J. "A Single-Chip VHF and UHF Receiver for Radio Paging," IEEE Journal of Solid-State Circuits, Vol. 26, No. 12, December 1991, 1944-1955

DX1191 801/802 “Wireless Technology Evolution,” Deutsche Bank Markets Research, May 7, 2012

DX1192 801/802 “Worldwide Data,” CDMA Development Group


52.

EXHIBIT

NO. DATE

IDENTIFIED DATE

ADMITTED SPONSORING



DX1193 801/802 Wyslouch, B. et al., "8.02 Physics II: Electricity and Magnetism," Massachusetts Institute of Technology: MIT OpenCourseWare, Ch.5, Spring 2007

DX1194 Qualcomm RTR6285 WCDMA Rx BB Filter LLDR (8/18/06)

DX1195 801/802 Active Cascode, IIP2 Calibration and RX Bias LLDR (6/12/06)

DX1196 RTR6285 MLDR WCDMA/HSDPA Balanced PRX High Band Front End (4/4/06)

DX1197 Email Chain Between D. Sorrells and M. Bultman re Conexant Receiver Design (2/13/01)

DX1198 Email Chain Between C. Moses and M. Bultman re LNA Test Boards (4/24/02)

DX1199 Email Chain Between C. Moses and M. Bultman re LNA Test Boards (4/24/02)

DX1200 ParkerVision PVI SPICE Model (1/23/01) DX1201 ParkerVision PVI SPICE Netlist (1/23/01) DX1202 ParkerVision PVI SPICE Model and Simulation

(12/7/00) DX1203 ParkerVision SPICE Netlist (12/7/00) DX1204 Email Chain Between J. Parker and J. Leach re

Freescale Meeting (5/3/07) DX1205 Email Chain Between D. Sorrells and J. Parker

et al. re Universal RX (7/6/09) DX1206 Email Chain Between J. Parker and J. Stuckey

re Meetings with LGE, GCT and FCI (9/3/08) DX1207 402/403/601/801/802 Holenstein, C., "Adaptive Dual-Loop Algorithm

for Cancellation of Time-Varying Offsets in Direct Conversion Mixers," IEEE, 2000, pp. 215-18

DX1208 ParkerVision Data Sheet "Vector Modulator" (5/26/05)

DX1209 Email Chain Between D. Sorrells and J. Parker et al. re Universal RX (7/6/09)

DX1210 REMOVED BY QC DX1211 Email From C. Moses to D. Sorrells re Electrical

Poles (8/26/09) DX1212 402/403/601/801/802 Peng, S. et al., "A Wide-Band Mixer for

WCDMA/CDMA2000 in 90nm Digital CMOS Process," 2005 IEEE Radio Frequency Integrated Circuits Symposium, pp. 179-82

DX1213 402/403/601/801/802 Wang, X. et al., "Comparison of the Image Rejection Between the Passive and Gilbert Mixer," ISCAS 2004, pp. I-968-71

DX1214 402/403/601/801/802 Goldfarb, M., "Even Harmonic Double-Balanced Active Mixer for Use in Direct Conversion Receivers," IEEE Journal of Solid-State Circuits, Vol. 38, No. 10, October 2008, pp. 1762-66

DX1215 402/403/601/801/802 Jussila, J. et al., "A Channel Selection Filter for a WCDMA Direct Conversion Receiver," IEEE

DX1216 Email From C. Moses to T. Hadley Forwarding Email from R. Harlan to C. Moses re Questions for Freescale (6/18/07)

DX1217 REMOVED BY QC DX1218 Email Chain Between D. Sorrells and J. Parker

et al. re Universal RX (7/6/09)


53.

EXHIBIT

NO. DATE

IDENTIFIED DATE

ADMITTED SPONSORING



DX1219 Email From A. Schwarzinger to J. Tung re Downconversion of Transmitted Signal (12/3/10)

DX1220 Email Chain Between J. Parker and C. Moses RX System Stack (12/13/07)

DX1221 Email From R. Rose to M. Rawlins re AGC (8/4/04)

DX1222 402/403/601/801/802 Bastani, B. et al., "A Quadrature Down Converter for Direct Conversion Receivers With High 2nd and 3rd Order Intercept Points," IEEE 2000

DX1223 402/403/601/801/802 Dufrene, K. et al., "A 0.13μm 1.5V CMOS I/Q Downconverter WithDigital Adaptive IIP2 Calibration," ISSCC 2007, Session 4, RF Building Blocks, pp. 86-87, 589

DX1224 402/403 Email From R. Harlan to J. Parker re QCT Patents (5/17/11)

DX1225 Email Chain Between R. Harlan and W. Wheeler re Presentation of ParkerVision Technology (11/25/08)

DX1226 801/802 MediaTek Presentation "Passive and Active CMOS Mixers, an Overview," IMS2012 Montreal

DX1227 ParkerVision Presentation "D2D" (4/04) DX1228 801/802 Atmel Data Sheet "WiMax Transceiver 802.16-

2004" (2004) DX1229 402/403/601/801/802 Pellat, B., "Fully-Integrated WCDMA SiGeC

BiCMOS Transceiver," Proceedings of ESSCIRC, Grenoble, France, 2005, pp. 519-22

DX1230 402/403/601/801/802 Razavi, B., "Recent Advances in RF Integrated Circuits," IEEE Communications Magazine, December 1997, pp. 36-43

DX1231 402/403/601/801/802 Niknejad, A., "Mixer Noise and Design," UC Berkeley EECS 242

DX1232 402/403/601/801/802 Subramanian, V., "A High Performance Low IF Receiver for Wireless Local Positioning Applications," Proceedings of the 38th European Microwave Conference, October 2008, pp. 159-62

DX1233 402/403/601/801/802 Lu, S. et al., "5.5 GHz Low Voltage and High LinearityRF CMOS Mixer Design," Proceedings of the 3rd European Microwave Integrated Circuits Conference, October 2008, pp. 171-74

DX1234 402/403/601/801/802 Tikka, T., "SiGe BiCMOS High Linearity Mixers for Base- Station Applications," Proceedings of the 3rd European Microwave Integrated Circuits Conference, October 2008, pp. 167-70

DX1235 ParkerVision's "An Overview of the D2D Direct RF Conversion Technology" (5/01)

DX1236 ParkerVision's "Competitive Analysis: Current Enterprise Market" (5/01)

DX1237 402/403/601/801/802 Yee, D., "Design and Implementation of a 2-GHz Low-Power CMOS Receiver for WCDMA Applications"

DX1238 402/403 ParkerVision Presentation "Superhet to Energy Sampling: Board Area & Parts Count" (7/18/12)

DX1239 402/403/801/802 3LP Presentation" ParkerVision Phase I: Final Read-Out" (5/21/12)


54.

EXHIBIT

NO. DATE

IDENTIFIED DATE

ADMITTED SPONSORING



DX1240 801/802 ParkerVision Presentation Slides "Energy Sampling Inflection Point" (7/12)

DX1241 ParkerVision "Notes From Receiver Meeting on 7/21" (7/26/11)

DX1242 402/403 ParkerVision Presentation "OEM Presentation" (5/05)

DX1243 801/802 Agilent Technologies "Mixer Design Guide" (12/03)

DX1244 801/802 Texas Instruments Application Report "Demystifying the Operational Transconductance Amplifier" (5/09

DX1245 402/403/601/801/802 Sastry, V., "Design of a CMOS RF Front End Receiver in 0.18μm Technology," Masters Thesis, Wright State University, 2008

DX1246 ParkerVision Spreadsheet "HEDGE RF Receiver Front End Summary," (9/09)

DX1247 ParkerVision "HEDGE RX Summary as of 12/15/09"

DX1248 ParkerVision "Bayhill Functional Specification" (9/30/09)

DX1249 ParkerVision "Bayhill Functional Specification" (10/30/09)

DX1250 801/802 Silicon & Software Systems Presentation "HEDGE RX - Study Update" (9/17/09)

DX1251 ParkerVision Presentation "AeA 2004 Financial Conference" (11/9/04-11/10/04)

DX1252 ParkerVision Presentation "Best Buy - ParkerVision" (1/19/05)

DX1253 ParkerVision Presentation "The D2D Advantage - Enabling Superior Radio Systems" (3/05)

DX1254 402/403/601/801/802 Tam, R., "ECE1352F – Analog Circuit Design I Term Paper: CMOS Variable Gain Amplifier (VGA)," University of Toronto (11/15/02)

DX1255 Tahoe RF Semiconductor, Inc. "Izzy9wl Buck_Reg Buck_VoltComp Block Revision 1.0" Critical Design Review," Prepared for ParkerVision (3/27/08)

DX1256 402/403/601/801/802 Silver, J., "Gilbert Cell Mixer Design Tutorial," RF, RFIC & Microwave Theory, Design (4/11)

DX1257 402/403/601/801/802 Dow, S., "Dual-Band Direct-Conversion/VLIF Transceiver for 50GSM/GSM/DCS/PCS," ISSCC 2002, Session 14, Cellular RF Wireless

DX1258 801/802 Agilent "Advanced Design System Documentation," "Various Simulations of a Gilbert Cell Mixer" (5/01)

DX1259 ParkerVision SPICE Model of a TCA (12/13/96) DX1260 ParkerVision "Polyphase Inverter Filter I/Q

Quadrature Generator Modified For TI Process" (6/20/01)

DX1261 402/403/601/801/802 Aparin, V. et al., "A Highly-Integrated Tri-Band/Quad-Mode SiGe BiCMOS RF-to-Baseband Receiver for Wireless CDMA/WCDMA/AMPS Applications with GPS Capability," ISSCC 2002, Session 14, Cellular RF Wireless

DX1262 402/403 ParkerVision Presentation "QCT Low Duty-Cycle Converter" (5/20/11)


55.

EXHIBIT

NO. DATE

IDENTIFIED DATE

ADMITTED SPONSORING



DX1263 402/403 ParkerVision Presentation "Vision, Innovation, Performance" (10/05)

DX1264 801/802 Signal Technologies, Inc., "Corporate Profile" DX1265 801/802 Signal Technologies, Inc., "SCL-105

MOD/DEMOD ASIC" Functional Description (1/6/98)

DX1266 Email From E. Cockrell to J. Parker re Bob Short Presentation re D2D (11/17/00)

DX1267 Signal Technologies "DSSS - Costas Loop ASIC Performance Development Specification" (11/2/95)

DX1268 ParkerVision Memorandum "Power" re Power Consumption and Dynamic Range (3/99)

DX1269 ParkerVision Presentation "RF Micro Devices D2D Technology IP Licensing Proposal Opportunity" (3/29/00)

DX1270 ParkerVision Whitepaper "ParkerVision d2d Receiver Technology Introduction" (10/28/10)

DX1271 402/403 ParkerVision Presentation "June 2012 Corporate Presentation" (6/12)

DX1272 Handwritten Notes With Fax From S. Younis to D. Parker and D. Sorrells Enclosing Qualcomm Assessment of ParkerVision D2D Technology (3/23/99)

DX1273 402/403 Contact Information for B. Bastani DX1274 ParkerVision D2D Brief (1/26/12) DX1275 The Wall Street Transcript, "ParkerVision, Inc.

(PRKR)" (2010) DX1276 402/403 ParkerVision Presentation "2004-2007 Business

Plan" (11/1/04) DX1277 ParkerVision Presentation "ParkerVision d2d-

Based Receiver: LG Innotek" (10/22/08) DX1278 402/403/901 Collection of Webpages from Internet Archive's

"Wayback Machine" of d2d.com from 1998 (retrieved 9/12)

DX1279 402/403/901 Collection of Webpages from Internet Archive's "Wayback Machine" of d2d.com from 1999 (retrieved 9/12)








56.

EXHIBIT

NO. DATE

IDENTIFIED DATE

ADMITTED SPONSORING




DX1287 402/403/901 Collection of Webpages from Internet Archive's "Wayback Machine" of parkervision.com from 1996 (retrieved 9/12)









DX1296 402/403/901 Collection of Webpages from Internet Archive's "Wayback Machine" of parkervision.com from 1/4/06-10/18/2006 (retrieved 9/12)

DX1297 402/403/901 Collection of Webpages from Internet Archive's "Wayback Machine" of parkervision.com from 10/22/06-12/31/06 (retrieved 9/12)







Collection of Webpages from Internet Archive's "Wayback Machine" of berkanawireless.com from 2001 (retrieved 12/12)




57.

EXHIBIT

NO. DATE

IDENTIFIED DATE

ADMITTED SPONSORING





















DX1314 ParkerVision’s Cameraman MDS-2000 Product, Bearing Model# MDS-2000-00 and FCCID# JFECM004


Circuit Board Disclosed in Nozawa, Y., "The Merigo Method: SSB Generator/Producing A Demodulator," HAM Journal, July/August 1993 Issue, pp. 20-31

DX1316 The Set of Qualcomm Schematics Referenced in the Opening Report of Dr. Paul Prucnal and Served by ParkerVision Via FedEx on 3/5/13

DX1317 402/403 All “Astra“ Schematics Qualcomm Made Available for Inspection Electronically on a Source Code Computer at the Iron Mountain Facility

DX1318 402/403 All “Bahama” Schematics Qualcomm Made Available for Inspection Electronically on a Source Code Computer at the Iron Mountain Facility

DX1319 402/403 All “Bali” Schematics Qualcomm Made Available for Inspection Electronically on a Source Code Computer at the Iron Mountain Facility

DX1320 402/403 All “Catalina” Schematics Qualcomm Made Available for Inspection Electronically on a Source Code Computer at the Iron Mountain Facility

DX1321 402/403 All “Clemente” Schematics Qualcomm Made Available for Inspection Electronically on a Source Code Computer at the Iron Mountain Facility


58.

EXHIBIT

NO. DATE

IDENTIFIED DATE

ADMITTED SPONSORING



DX1322 402/403 All “Eagleray” Schematics Qualcomm Made Available for Inspection Electronically on a Source Code Computer at the Iron Mountain Facility

DX1323 402/403 All “Fiji” Schematics Qualcomm Made Available for Inspection Electronically on a Source Code Computer at the Iron Mountain Facility

DX1324 402/403 All “Fury” Schematics Qualcomm Made Available for Inspection Electronically on a Source Code Computer at the Iron Mountain Facility

DX1325 402/403 All “GZIF3” Schematics Qualcomm Made Available for Inspection Electronically on a Source Code Computer at the Iron Mountain Facility

DX1326 402/403 All “GZIF4” Schematics Qualcomm Made Available for Inspection Electronically on a Source Code Computer at the Iron Mountain Facility

DX1327 402/403 All “Halley” Schematics Qualcomm Made Available for Inspection Electronically on a Source Code Computer at the Iron Mountain Facility

DX1328 402/403 All “Hercules” Schematics Qualcomm Made Available for Inspection Electronically on a Source Code Computer at the Iron Mountain Facility

DX1329 402/403 All “Iceman” Schematics Qualcomm Made Available for Inspection Electronically on a Source Code Computer at the Iron Mountain Facility

DX1330 402/403 All “IFR3000” Schematics Qualcomm Made Available for Inspection Electronically on a Source Code Computer at the Iron Mountain Facility

DX1331 402/403 All “Iris” Schematics Qualcomm Made Available for Inspection Electronically on a Source Code Computer at the Iron Mountain Facility

DX1332 402/403 All “K2” Schematics Qualcomm Made Available for Inspection Electronically on a Source Code Computer at the Iron Mountain Facility

DX1333 402/403 All “Kite” Schematics Qualcomm Made Available for Inspection Electronically on a Source Code Computer at the Iron Mountain Facility

DX1334 402/403 All “Kiwi” Schematics Qualcomm Made Available for Inspection Electronically on a Source Code Computer at the Iron Mountain Facility

DX1335 402/403 All “Libra/Gemini” Schematics Qualcomm Made Available for Inspection Electronically on a Source Code Computer at the Iron Mountain Facility

DX1336 402/403 All “Magellan” Schematics Qualcomm Made Available for Inspection Electronically on a Source Code Computer at the Iron Mountain Facility


59.

EXHIBIT

NO. DATE

IDENTIFIED DATE

ADMITTED SPONSORING



DX1337 402/403 All “Marimba” Schematics Qualcomm Made Available for Inspection Electronically on a Source Code Computer at the Iron Mountain Facility

DX1338 402/403 All “McKinley” Schematics Qualcomm Made Available for Inspection Electronically on a Source Code Computer at the Iron Mountain Facility

DX1339 402/403 All “Mercury” Schematics Qualcomm Made Available for Inspection Electronically on a Source Code Computer at the Iron Mountain Facility

DX1340 402/403 All “Merlin (QCA)” Schematics Qualcomm Made Available for Inspection Electronically on a Source Code Computer at the Iron Mountain Facility

DX1341 402/403 All “Merlin (QCT)” Schematics Qualcomm Made Available for Inspection Electronically on a Source Code Computer at the Iron Mountain Facility

DX1342 402/403 All “MnM” Schematics Qualcomm Made Available for Inspection Electronically on a Source Code Computer at the Iron Mountain Facility

DX1343 402/403 All “Napoleon” Schematics Qualcomm Made Available for Inspection Electronically on a Source Code Computer at the Iron Mountain Facility

DX1344 402/403 All “Odyssey” Schematics Qualcomm Made Available for Inspection Electronically on a Source Code Computer at the Iron Mountain Facility

DX1345 402/403 All “Osprey” Schematics Qualcomm Made Available for Inspection Electronically on a Source Code Computer at the Iron Mountain Facility

DX1346 402/403 All “Ramsis” Schematics Qualcomm Made Available for Inspection Electronically on a Source Code Computer at the Iron Mountain Facility

DX1347 402/403 All “Solo” Schematics Qualcomm Made Available for Inspection Electronically on a Source Code Computer at the Iron Mountain Facility

DX1348 402/403 All “Spitfire” Schematics Qualcomm Made Available for Inspection Electronically on a Source Code Computer at the Iron Mountain Facility

DX1349 402/403 All “Tomahawk” Schematics Qualcomm Made Available for Inspection Electronically on a Source Code Computer at the Iron Mountain Facility

DX1350 402/403 All “Volans” Schematics Qualcomm Made Available for Inspection Electronically on a Source Code Computer at the Iron Mountain Facility


60.

EXHIBIT

NO. DATE

IDENTIFIED DATE

ADMITTED SPONSORING



DX1351 402/403 All “ Voltron” Schematics Qualcomm Made Available for Inspection Electronically on a Source Code Computer at the Iron Mountain Facility

DX1352 402/403 All “Wasp” Schematics Qualcomm Made Available for Inspection Electronically on a Source Code Computer at the Iron Mountain Facility

DX1353 402/403 All “Ywing” Schematics Qualcomm Made Available for Inspection Electronically on a Source Code Computer at the Iron Mountain Facility

DX1354 1983 Motorola DynaTAC Handset Referenced in Figure 1 of the Opening Expert Report of Dr. Paul Prucnal

DX1355 Nokia 7110 Handset Referenced in Figure 2 of the Opening Expert Report of Dr. Paul Prucnal

DX1356 2002 RIM Blackberry 5810 Handset Referenced in Figure 3 of the Opening Expert Report of Dr. Paul Prucnal

DX1357 2007 Apple iPhone Handset Referenced in Figure 4 of the Opening Expert Report of Dr. Paul Prucnal

DX1358 2001 LG-TM510 Handset Referenced in Table 1 of the Opening Expert Report of Dr. Paul Prucnal

DX1359 2004 Sanyo PM-8200 Handset Referenced in Table 1 of the Opening Expert Report of Dr. Paul Prucnal

DX1360 2007 Samsung SGH-U700 Handset Referenced in Table 1 of the Opening Expert Report of Dr. Paul Prucnal

DX1361 2011 Apple iPhone 4S Handset Referenced in Table 1 of the Opening Expert Report of Dr. Paul Prucnal

DX1362 LG-TM510 Handset Board Referenced in Figure 14 of the Opening Expert Report of Dr. Paul Prucnal

DX1363 Sanyo PM-8200 Handset Board Referenced in Figure 14 of the Opening Expert Report of Dr. Paul Prucnal

DX1364 Samsung SGH-U700 Handset Board Referenced in Figure 14 of the Opening Expert Report of Dr. Paul Prucnal

DX1365 iPhone 4S Handset Board Referenced in Figure 14 of the Opening Expert Report of Dr. Paul Prucnal

DX1366 Eddie-1 Prototype Board Referenced on Page 96 of the Opening Expert Report of Dr. Paul Prucnal

DX1367 Eddie-2 Prototype Board Referenced on Page 96 of the Opening Expert Report of Dr. Paul Prucnal

DX1368 ParkerVision’s “CDMA Compliant” Receiver Prototype Referenced on Page 98 of the Opening Expert Report of Dr. Paul Prucnal

DX1369 ParkerVision WLAN Prototype Referenced in Figure 19 of the Opening Expert Report of Dr. Paul Prucnal


61.

EXHIBIT

NO. DATE

IDENTIFIED DATE

ADMITTED SPONSORING



DX1370 ParkerVision’s “fully integrated D2D WLAN demonstrator” Referenced in Figure 20 of the Opening Expert Report of Dr. Paul Prucnal

DX1371 SignalMAX WLAN1500 Product Referenced on Page 105 of the Opening Expert Report of Dr. Paul Prucnal

DX1372 SignalMAX WLAN3000 Product Referenced on Page 105 of the Opening Expert Report of Dr. Paul Prucnal

DX1373 SignalMAX USB1500 Product Referenced on Page 105 of the Opening Expert Report of Dr. Paul Prucnal

DX1374 SignalMAX WR1500 Product Referenced on Page 105 of the Opening Expert Report of Dr. Paul Prucnal

DX1375 SignalMAX WR3000 Product Referenced on Page 105 of the Opening Expert Report of Dr. Paul Prucnal

DX1376 PV8212X Board Referenced on Page 106 of the Opening Expert Report of Dr. Paul Prucnal

DX1377 ParkerVision’s Ellis IC Referenced on Page 106 of the Opening Expert Report of Dr. Paul Prucnal

DX1378 Samsung Galaxy SIII Handset Referenced in Figure 21 of the Opening Expert Report of Dr. Paul Prucnal

DX1379 402/403 Ribbon Copy of U.S. Patent No. D602,886 DX1380 402/403 Ribbon Copy of U.S. Patent No. 5,574,748 DX1381 402/403 Ribbon Copy of U.S. Patent No. 6,242,963 DX1382 402/403 Ribbon Copy of U.S. Patent No. 6,272,322 DX1383 402/403 Ribbon Copy of U.S. Patent No. 6,351,502 DX1384 402/403 Ribbon Copy of U.S. Patent No. 6,359,528 DX1385 402/403 Ribbon Copy of U.S. Patent No. 6,404,289 DX1386 402/403 Ribbon Copy of U.S. Patent No. 6,483,188 DX1387 402/403 Ribbon Copy of U.S. Patent No. 6,504,431 DX1388 402/403 Ribbon Copy of U.S. Patent No. 6,504,433 DX1389 402/403 Ribbon Copy of U.S. Patent No. 6,507,619 DX1390 402/403 Ribbon Copy of U.S. Patent No. 6,509,779 DX1391 402/403 Ribbon Copy of U.S. Patent No. 6,538,605 DX1392 402/403 Ribbon Copy of U.S. Patent No. 6,570,453 DX1393 402/403 Ribbon Copy of U.S. Patent No. 6,593,794 DX1394 402/403 Ribbon Copy of U.S. Patent No. 6,593,838 DX1395 402/403 Ribbon Copy of U.S. Patent No. 6,597,227 DX1396 402/403 Ribbon Copy of U.S. Patent No. 6,621,370 DX1397 402/403 Ribbon Copy of U.S. Patent No. 6,628,673 DX1398 402/403 Ribbon Copy of U.S. Patent No. 6,642,767 DX1399 402/403 Ribbon Copy of U.S. Patent No. 6,710,662 DX1400 402/403 Ribbon Copy of U.S. Patent No. 6,717,502 DX1401 402/403 Ribbon Copy of U.S. Patent No. 6,718,619 DX1402 402/403 Ribbon Copy of U.S. Patent No. 6,721,547 DX1403 402/403 Ribbon Copy of U.S. Patent No. 6,724,267 DX1404 402/403 Ribbon Copy of U.S. Patent No. 6,731,176 DX1405 402/403 Ribbon Copy of U.S. Patent No. 6,734,828 DX1406 402/403 Ribbon Copy of U.S. Patent No. 6,737,920 DX1407 402/403 Ribbon Copy of U.S. Patent No. 6,741,219 DX1408 402/403 Ribbon Copy of U.S. Patent No. 6,747,605


62.

EXHIBIT

NO. DATE

IDENTIFIED DATE

ADMITTED SPONSORING



DX1409 402/403 Ribbon Copy of U.S. Patent No. 6,754,197 DX1410 402/403 Ribbon Copy of U.S. Patent No. 6,762,703 DX1411 402/403 Ribbon Copy of U.S. Patent No. 6,765,441 DX1412 402/403 Ribbon Copy of U.S. Patent No. 6,768,364 DX1413 402/403 Ribbon Copy of U.S. Patent No. 6,779,261 DX1414 402/403 Ribbon Copy of U.S. Patent No. 6,781,425 DX1415 402/403 Ribbon Copy of U.S. Patent No. 6,784,740 DX1416 402/403 Ribbon Copy of U.S. Patent No. 6,785,523 DX1417 402/403 Ribbon Copy of U.S. Patent No. 6,788,232 DX1418 402/403 Ribbon Copy of U.S. Patent No. 6,795,407 DX1419 402/403 Ribbon Copy of U.S. Patent No. 6,807,146 DX1420 402/403 Ribbon Copy of U.S. Patent No. 6,810,093 DX1421 402/403 Ribbon Copy of U.S. Patent No. 6,836,193 DX1422 402/403 Ribbon Copy of U.S. Patent No. 6,844,761 DX1423 402/403 Ribbon Copy of U.S. Patent No. 6,850,117 DX1424 402/403 Ribbon Copy of U.S. Patent No. 6,853,197 DX1425 402/403 Ribbon Copy of U.S. Patent No. 6,870,815 DX1426 402/403 Ribbon Copy of U.S. Patent No. 6,874,222 DX1427 402/403 Ribbon Copy of U.S. Patent No. 6,883,227 DX1428 402/403 Ribbon Copy of U.S. Patent No. 6,891,496 DX1429 402/403 Ribbon Copy of U.S. Patent No. 6,894,563 DX1430 402/403 Ribbon Copy of U.S. Patent No. 6,900,699 DX1431 402/403 Ribbon Copy of U.S. Patent No. 6,928,127 DX1432 402/403 Ribbon Copy of U.S. Patent No. 6,940,865 DX1433 402/403 Ribbon Copy of U.S. Patent No. 6,954,171 DX1434 402/403 Ribbon Copy of U.S. Patent No. 6,960,963 DX1435 402/403 Ribbon Copy of U.S. Patent No. 6,961,545 DX1436 402/403 Ribbon Copy of U.S. Patent No. 6,973,476 DX1437 402/403 Ribbon Copy of U.S. Patent No. 6,976,051 DX1438 402/403 Ribbon Copy of U.S. Patent No. 7,005,930 DX1439 402/403 Ribbon Copy of U.S. Patent No. 7,027,530 DX1440 402/403 Ribbon Copy of U.S. Patent No. 7,035,589 DX1441 402/403 Ribbon Copy of U.S. Patent No. 7,039,004 DX1442 402/403 Ribbon Copy of U.S. Patent No. 7,042,406 DX1443 402/403 Ribbon Copy of U.S. Patent No. 7,046,072 DX1444 402/403 Ribbon Copy of U.S. Patent No. 7,051,063 DX1445 402/403 Ribbon Copy of U.S. Patent No. 7,057,635 DX1446 402/403 Ribbon Copy of U.S. Patent No. 7,061,278 DX1447 402/403 Ribbon Copy of U.S. Patent No. 7,079,600 DX1448 402/403 Ribbon Copy of U.S. Patent No. 7,088,787 DX1449 402/403 Ribbon Copy of U.S. Patent No. 7,091,784 DX1450 402/403 Ribbon Copy of U.S. Patent No. 7,091,791 DX1451 402/403 Ribbon Copy of U.S. Patent No. 7,098,821 DX1452 402/403 Ribbon Copy of U.S. Patent No. 7,103,116 DX1453 402/403 Ribbon Copy of U.S. Patent No. 7,113,559 DX1454 402/403 Ribbon Copy of U.S. Patent No. 7,120,166 DX1455 402/403 Ribbon Copy of U.S. Patent No. 7,123,106 DX1456 402/403 Ribbon Copy of U.S. Patent No. 7,123,670 DX1457 402/403 Ribbon Copy of U.S. Patent No. 7,129,884 DX1458 402/403 Ribbon Copy of U.S. Patent No. 7,130,225 DX1459 402/403 Ribbon Copy of U.S. Patent No. 7,130,646 DX1460 402/403 Ribbon Copy of U.S. Patent No. 7,132,865 DX1461 402/403 Ribbon Copy of U.S. Patent No. 7,133,958 DX1462 402/403 Ribbon Copy of U.S. Patent No. 7,154,980


63.

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NO. DATE

IDENTIFIED DATE

ADMITTED SPONSORING





64.

EXHIBIT

NO. DATE

IDENTIFIED DATE

ADMITTED SPONSORING





65.

EXHIBIT

NO. DATE

IDENTIFIED DATE

ADMITTED SPONSORING



DX1571 402/403 Ribbon Copy of U.S. Patent No. 7,821,305 DX1572 402/403 Ribbon Copy of U.S. Patent No. 7,822,059 DX1573 402/403 Ribbon Copy of U.S. Patent No. 7,825,723 DX1574 402/403 Ribbon Copy of U.S. Patent No. 7,826,466 DX1575 402/403 Ribbon Copy of U.S. Patent No. 7,826,521 DX1576 402/403 Ribbon Copy of U.S. Patent No. 7,834,790 DX1577 402/403 Ribbon Copy of U.S. Patent No. 7,835,456 DX1578 402/403 Ribbon Copy of U.S. Patent No. 7,835,467 DX1579 402/403 Ribbon Copy of U.S. Patent No. 7,835,711 DX1580 402/403 Ribbon Copy of U.S. Patent No. 7,847,613 DX1581 402/403 Ribbon Copy of U.S. Patent No. 7,848,219 DX1582 402/403 Ribbon Copy of U.S. Patent No. 7,853,216 DX1583 402/403 Ribbon Copy of U.S. Patent No. 7,865,150 DX1584 402/403 Ribbon Copy of U.S. Patent No. 7,894,487 DX1585 402/403 Ribbon Copy of U.S. Patent No. 7,904,021 DX1586 402/403 Ribbon Copy of U.S. Patent No. 7,907,080 DX1587 402/403 Ribbon Copy of U.S. Patent No. 7,912,095 DX1588 402/403 Ribbon Copy of U.S. Patent No. 7,916,746 DX1589 402/403 Ribbon Copy of U.S. Patent No. 7,920,441 DX1590 402/403 Ribbon Copy of U.S. Patent No. 7,924,932 DX1591 402/403 Ribbon Copy of U.S. Patent No. 7,929,508 DX1592 402/403 Ribbon Copy of U.S. Patent No. 7,936,642 DX1593 402/403 Ribbon Copy of U.S. Patent No. 7,944,395 DX1594 402/403 Ribbon Copy of U.S. Patent No. 7,957,757 DX1595 402/403 Ribbon Copy of U.S. Patent No. 7,898,309 DX1596 402/403 Ribbon Copy of U.S. Patent No. 7,899,472 DX1597 BlackBerry 8700 Handset DX1598 BlackBerry Storm 9530 Handset DX1599 HTC Droid Incredible 2 Handset DX1600 Kyocera QCP-6035 Handset DX1601 LG VX-4400 Handset DX1602 Mobira Senator Handset DX1603 Motorola 8000M Handset DX1604 Motorola RAZR V3 Handset DX1605 Motorola V710 Handset DX1606 PDQ-800 Smartphone Series Handset DX1607 QCP-860 Handset DX1608 Qualcomm "Q Phone" Handset DX1609 Samsung SCH-U620 Handset DX1610 Samsung Z510 Handset DX1611 QCP-2760 Handset DX1612 QCP-860 Handset DX1613 Samsung Z510 Handset DX1614 402/403/106 ParkerVision’s Objections and Responses to

Qualcomm’s First Set of Interrogatories (Nos. 1-12)

DX1615 402/403 ParkerVision, Inc.’s Objections and Responses to Qualcomm’s Second Set of Interrogatories (Nos. 13-19)

DX1616 402/403 ParkerVision’s Third Supp. Obj. & Resp. to Qualcomm’s First Set of Interrogatories (No. 3)

DX1617 Qualcomm’s First Supplemental Objection and Responses to ParkerVision’s First Set of Interrogatories (Nos. 1-9)


66.

EXHIBIT

NO. DATE

IDENTIFIED DATE

ADMITTED SPONSORING



DX1618 Qualcomm’s Fourth Supplemental Objections and Responses to ParkerVision’s First Set of Interrogatories (Nos. 1-9)

DX1619 Qualcomm’s Fourth Supplemental Objections and Responses to ParkerVision’s First Set of Interrogatories (Nos. 1-9), Exhibit E

DX1620 Qualcomm’s Objections and Responses to ParkerVision’s First Set of Interrogatories (1-9), Supplemental Exhibit A

DX1621 402/403 Qualcomm’s Objections and Responses to ParkerVision’s Second Set of Interrogatories (No. 10-14)

DX1622 Qualcomm’s Supplemental Objections and Responses to ParkerVision’s Third Set of Interrogatories (No. 15-18)

DX1623 402/403 Parkervision's Third Supplemental Objections and Responses to Qualcomm's First Set of Interrogatories (No. 6)

DX1624 Email Chain Between D. Fecher and J. Leach re Samsung (4/22/11)

DX1625 Email Chain Between D. Sorrells and J. Yarnell re Sorrells Paper (2/21/08)

DX1626 Email Chain Between J. Leach to SH Kim re Samsung Plan (7/26/11)

DX1627 Email and Attachment From R. Harlan to D. Sorrells Attaching Aparin, V. et al., "A Highly-Integrated Tri-Band/Quad-Mode SiGe BiCMOS RF-to-Baseband Receiver for Wireless CDMA/WCDMA/AMPS Applications with GPS Capability," ISSCC 2002, Session 14, Cellular RF Wireless (12/6/11)

DX1628 Fax From R. Sterne to V. Guyton Attaching Markup of Qualcomm-ParkerVision NDA (2/26/99)

DX1629 Letter From W. Hightower to W. Nuti Terminating ParkerVision-Symbol License (1/29/04)

DX1630 ParkerVision Presentation "ParkerVision Board Meeting" (8/9/07)

DX1631 ParkerVision Presentation "Board of Directors Meeting" (8/9/05)

DX1632 ParkerVision Statement of Work "Project Ellis - ITT/ParkerVision d2d Product Development Program" (6/18/08)

DX1633 Qualcomm QSC6240/QSC6270 LCU Qualification Report (3/16/10)

DX1634 Email from J. Parker to P. Kantak re ParkerVision Visit (9/3/98)

DX1635 ParkerVision Press Release "ParkerVision Develops Integrated WLAN Transceiver Chip" (9/1/02)

DX1636 Letter From J. Parker to J. Jacobs re Preliminary Specifications of ParkerVision Receiver Technology(2/5/98)


Email Chain Between U. Dhaliwal and L. Wen et al. re ParkerVision Press Release (4/9/98)

DX1638 801/802 Email Chain Between L. Wen and J. Nybeck re Eddie IIP3 (4/16/98)


67.

EXHIBIT

NO. DATE

IDENTIFIED DATE

ADMITTED SPONSORING



DX1639 801/802 Email Chain Between P. Baker and L. Wen et al. re ParkerVision Press Release (7/15/98)

DX1640 Fax From J. Parker to J. Jacobs re ParkerVision Technology (08/10/98)

DX1641 801/802 Email From P. Kantak to J. Jacobs re ParkerVision Technology (8/12/98)

DX1642 Letter From J. Parker to Jeff re General Discussion of Direct2Data (8/17/98)

DX1643 801/802 Email From L. Wen to R. Camarillo re ParkerVision Visit to Qualcomm (8/18/98)

DX1644 801/802 Email Chain Between C. Wheatley and J. Jacobs et al. re ParkerVision Visit to Qualcomm (8/18/98)

DX1645 801/802 Email Chain Between R. Camarillo and P. Kantak et al. re ParkerVision Visit to Qualcomm (8/18/98)

DX1646 801/802 Email Chain Between P. Kantak and J. Parker re ParkerVision Visit (8/19/98)

DX1647 801/802 Email From J. Parker to V. Gyton re Next Steps in Qualcomm / ParkerVision Discussion (8/19/98)

DX1648 801/802 Email Chain Between J. Parker and V. Gyton re San Diego Visit (8/26/98)

DX1649 801/802 Email Chain Between P. Kantak and J. Parker re Direct2Data Follow-up (8/25/98)

DX1650 801/802 Email Chain Between P. Kantak and S. Younis re ParkerVision (8/28/98)

DX1651 801/802 Email Chain Between J. Parker and V. Gyton re ParkerVision Visit (9/16/98)

DX1652 801/802 Email Chain Between P. Kantak and J. Jacobs re ParkerVision Visit to Qualcomm (9/14/98)

DX1653 801/802 Email From J. Jacobs to J. Parker re ParkerVision Visit to Qualcomm (9/14/98)

DX1654 801/802 Email Chain Between P. Kantak and J. Parker re ParkerVision Visit to Qualcomm (9/14/98)

DX1655 801/802 Email From C. Persico to J. Lodenius et al. re ParkerVision Article (9/21/98)

DX1656 801/802 DX1657 801/802 Email Chain Between U. Dhaliwal and P. Kantak

et al. re ParkerVision Test Plan (10/7/98) DX1658 801/802/Late Produced /

Disclosed Email From P. Kantak to S. Ciccarelli et al. re Conversation With Jeff Parker (10/8/98)

DX1659 801/802 Email From D. Sorrells to S. Younis re ParkerVision Visit (10/27/98)

DX1660 801/802 Email Chain Between P. Kantak and J. Lodenius re ParkerVision Evaluation (11/12/98)

DX1661 801/802 Email From P. Kantak to I. Jacobs re ParkerVision (11/21/98)

DX1662 801/802 Email Chain Between P. Kantak and J. Parker re Telephone Conversation re Business Agreement (11/23/98)

DX1663 801/802 Email Chain Between P. Kantak and J. Lodenius re ParkerVision Update (12/11/98)

DX1664 801/802 Email Chain Between P. Kantak and J. Parker re ParkerVision Update (1/21/99)

DX1665 801/802 Email Chain Between P. Kantak and J. Lodenius et al. re ParkerVision Business Models (2/22/99)


68.

EXHIBIT

NO. DATE

IDENTIFIED DATE

ADMITTED SPONSORING



DX1666 801/802 Email Chain Between S. Ciccarelli and P. Kantak et al. re D2D Report (2/26/99)

DX1667 801/802 Email Chain Between S. Ciccarelli and P. Kantak et al. re D2D Report (2/26/99)

DX1668 801/802 Qualcomm Memorandum re Strategic Alliance with ParkerVision (2/26/99)

DX1669 801/802 Qualcomm Memorandum re D2D Technical Evaluation Plan (2/28/99)

DX1670 801/802 Email Chain Between P. Kantak and S. Jha et al. re ParkerVision Disclosure (3/10/99)

DX1671 801/802 Email From P. Kantak to C. Wheatley et al. re ParkerVision Technical Update (3/19/99)

DX1672 801/802 Email From P. Kantak to J. Lodenius et al. re Other Solutions (3/19/99)

DX1673 801/802 Email Chain Between P. Kantak and B. Butler et al. re ParkerVision NDA (3/23/99)

DX1674 801/802 Email From R. Gilmore to C. Wheatley et al. re ParkerVision Technical Analysis (3/26/99)

DX1675 801/802 Email Chain Between P. Kantak and J. Parker re ParkerVision Meeting (4/12/99)

DX1676 801/802 Email Chain Between A. Oberst and S. Jha et al. re ParkerVision Deal Options (4/13/99)

DX1677 801/802 Email Chain Between P. Kantak and C. Wheatley et al. re D2D Information (4/22/99)

DX1678 801/802 Email Chain Between P. Kantak and J. Parker et al. re D2D Information (4/26/99)

DX1679 Email From D. Sorrells to J. Parker re Draft Term Sheet (5/3/99)

DX1680 801/802 Qualcomm Presentation PV/QC Terms of Agreement Strategic Alliance (5/4/99)

DX1681 801/802 Qualcomm Presentation ParkerVision Info (5/4/99)

DX1682 801/802 Email Chain Between L. Lupin and P. Kantak et al. re ParkerVision Negotiations (5/21/99)

DX1683 801/802 Email Chain Between P. Kantak and L. Lupin et al. re ParkerVision Negotiations (5/22/99)

DX1684 801/802 Email From P. Kantak to J. Jacobs et al. re ParkerVision Negotiations (5/28/99)

DX1685 801/802 Email Chain Between S. Jha and C. Wheatley et al. re D2D Patents (5/29/99)

DX1686 801/802 Email Chain Between P. Kantak and M. Blecker et al. re ParkerVision Meetings (6/2/99)

DX1687 801/802 Email Chain Between P. Kantak and J. Parker et al. re ParkerVision Meetings (6/2/99)

DX1688 801/802 Email From P. Kantak to L. Lupin et al. re ParkerVision Meeting (6/4/99)

DX1689 Memo From P. Kantak to J. Parker re Potential Licensing Opportunities (6/5/99)

DX1690 801/802 ParkerVision Meeting Agenda (6/7/99) DX1691 801/802 Email Chain Between J. Parker and P. Kantak et

al. re ParkerVision-Qualcomm Proposed Agreement (6/15/99)

DX1692 801/802 Email Chain Between C. Wheatley and R. Gilmore et al. re Direct Conversion (6/16/99)

DX1693 801/802 Email Chain Between P. Peterzell and R. Gilmore re Direct Conversion (6/16/99)


69.

EXHIBIT

NO. DATE

IDENTIFIED DATE

ADMITTED SPONSORING



DX1694 801/802 Email Chain Between S. Jha and B. Judson et al. re Direct Conversion (6/17/99)

DX1695 801/802 Email Chain Between C. Wheatley and R. Gilmore et al. re Direct Conversion (6/19/99)

DX1696 801/802 Email From P. Kantak to J. Lodenius et al. re D2D Evaluation Plan (6/21/99)

DX1697 801/802 Qualcomm Presentation ParkerVision Issues in Potential Acquisition (6/30/99)

DX1698 801/802 Email Chain Between P. Kantak and T. Thornley re Status of ParkerVision Negotiations (6/30/99)


Email Chain Between C. Wheatley and M. Blecker et al. re Arsenio & Company Article (9/28/99)

DX1700 801/802 Email Chain Between C. Wheatley and R. Gilmore et al. re Update on ParkerVision Negotiation (10/5/99)

DX1701 801/802/402/403 Email Chain Between D. Schrock and M. Blecker re Update on ParkerVision Negotiation (10/11/99)

DX1702 Email Chain Between J. Parker and K. Prashant re Update on ParkerVision Negotiation (10/22/99)

DX1703 Email Chain Between J. Parker and K. Prashant re D2D CDMA Transmitter Demonstration (11/2/99)

DX1704 801/802 Email Chain Between P. Kantak and C. Wheatley et al. re ParkerVision Update (11/19/99)

DX1705 801/802 Email Chain Between P. Kantak and C. Wheatley re ParkerVision Update (12/15/99)

DX1706 801/802 Email Chain Between P. Heidmann and C. Wheatley re Qualcomm History With ParkerVision (6/6/00)

DX1707 Memo From J. Parker to P. Kantak re D2D (11/30/00)

DX1708 801/802 Email From T. Thornley to C. Wheatley re ParkerVision-PrairieComm Agreement (3/2/01)

DX1709 801/802 Email From P. Kantak to K. Grajski re Qualcomm History With ParkerVision (2/11/05)

DX1710 801/802 Email Chain Between F. Carobolante and C. Persico re Lack of Value of ParkerVision Technology (8/21/08)

DX1711 801/802 Qualcomm Memorandum re Results of D2D Testing (2/26/99)

DX1712 801/802 Soer, M. et al., "A 0.2-to-2.0GHz 65nm CMOS Receiver Without LNA Achieving >11dBm IIP3 and <6.5 dB NF," ISSCC 2009, Session 12, RF Building Blocks, 12.4

DX1713 Couch, L. "Digital and Analog Communication Systems," Second Edition (Physical Exhibit)

DX1714 Couch, L., "Modern Communications Systems: Principles and Applications," Prentice Hall, 1995 (Physical Exhibit)

DX1715 Oppenheim, A. et al., "Signals and Systems," Prentice-Hall, 1983 (Physical Exhibit)

DX1716 Lee, T., "The Design of CMOS Radio Frequency Integrated Circuits," Cambridge University Press, 1998 (Physical Exhibit)


70.

EXHIBIT

NO. DATE

IDENTIFIED DATE

ADMITTED SPONSORING



DX1717 DeMaw, D., “Practical RF Design Manual,” Prentice-Hall, Inc., 1982 (Physical Exhibit)

DX1718 Razavi, B., "Principles of Data Conversion System Design," IEEE Press, 1995 (Physical Exhibit)

DX1719 Razavi, B. “RF Microelectronics," Prentice Hall, 1998 (Physical Exhibit)


Forbes article: "Fox Meyer lives" by Matthew Schifrin (09/20/1999)

DX1721 402/403 ParkerVision presentation: "ParkerVision Board Meeting" (05/02/2011)

DX1722 402/403 Slidedeck: "Nasdaq Compliance Fact Summary"DX1723 402/403/801/802 ParkerVision, Inc. Q1 2013 Earnings

Conference Call Transcript, 05/09/2013 DX1724 402/403/801/802 ParkerVision, Inc. Q2 2013 Earnings

Conference Call Transcript, 08/08/2013 DX1725 402/403 Fax from G. Rawlins to J. Parker et al., re

Concerning Manufacturing Engineering Efforts Moving Forward (08/26/2011); and Email chain from A. Grant to E. Cockrell re Fax (08/26/2011)

DX1726 402/403 Report: "Technical Audit of LGIT and Grenoble Projects (11/06/2009)

DX1727 402/403 ParkerVision Inc., Current report filing (Form 8-K) (filed 07/20/2010)

DX1728 402/403 ParkerVision Inc., Current report filing (Form 8-K) (filed 09/15/2010)


"White Paper, D2D"


"RTR8600 Rx BBF LLDR 80-VF535-81 Rev. A"


Performance Evaluation Report for the Parker Vision Universal Direct Conversion Receiver, dated 5/1/1998 (5/10/2013)

DX1732 402/403/801/802 Boeing Tests, dated 4/29/1998 (5/10/2013) DX1733 801/802 Facsimile from Saed Younis to Jeff Parker and

David Sorrells re D2D Assessment DX1734 402/403/801/802 ParkerVision Inc., Report of Unscheduled

Material Events or Corporate Changes (Form 8-K) (filed 12/03/2007)


Email chain from C. Wheatley to F. Antonio et al. re Parkervision patent (5/18/2002)


Email chain from P. Kantak to rgilmore et al., re Parkervision Update (10/18/1999)


Email chain from C. Wheatley to S. Toncich et al., re Holl Technology Contact (07/02/1999)


Email chain from P. Kantak to syounis et al., re Technical Meeting at Qualcomm Next Week (03/24/1999)


Image: Cameraman_2000_10_7_MHz_Flt_PartNumber


Toko CFSKN G Series FM Ceramic Filters (08/2005)


Toko CFSKN S Series FM Ceramic Filters (08/2005)


Toko CFSKN X Series FM Ceramic Filters (08/2005)


71.

EXHIBIT

NO. DATE

IDENTIFIED DATE

ADMITTED SPONSORING




Toko FM Ceramic Filters


Parkervision FCC Certifications

1170920 v2/HN


ATTACHMENT A-3

(Joint Exhibit List)


McKool 921628v1




JOINT EXHIBIT LIST

EXHIBIT NO.

DATE IDENTIFIED

DATE ADMITTED




JX 1 A Certified Copy of File History of U.S. Patent 6,061,551, dated 10/21/1998 (PV000000208 - PV00008384)

JX 2 A Certified Copy of File History of U.S. Patent 7,724,845, dated 03/28/2006 (PV00013966 - PV00015654)

JX 3 A US Patent 6,061,551, Method and System for Down Converting Electromagnetic Cross-Reference to Other Applications dated 5/9/2000 (QCPV005535525 - QCPV005535588)

JX 4 A Certified Copy of U.S. Patent 6,266,518, dated 7/24/2001 (PV00008385 – PV00008585)

JX 5 A Certified Copy of U.S. Patent 6,963,734, dated 11/08/2005

1 “A” indicates Stipulated Admission


2 McKool 921628v1

EXHIBIT NO.

DATE IDENTIFIED

DATE ADMITTED




(PV00015655 - PV00015833)

JX 6 A Certified Copy of U.S. Patent 7,496,342, dated 02/24/2009 (11/27/2012 Lee Deposition Ex. 11, PV00012434-12571)

JX 7 A Email from C. Wheatley to B. Weaver re Direct Conversion, and attachment entitled D2D briefing_11.ppt, dated 06/23/2000 (QCPV001392377 - QCPV001392389)

JX 8 A S. Younis Preliminary Memo, Assessment of ParkerVision D2D Technology, dated 3/23/1999 (12/6/2012 Younis Deposition Ex. 7, QCPV005420537 – QCPV005420542)

JX 9 A Email from C. Wheatley to P. Kantak re D2D, dated 5/28/1999 (QCPV005443938A)

JX 10 A Memo to J. Parker from P. Kantak re list of Salient Issues that ParkerVision and Qualcomm need to agree upon, dated 6/10/1999 (5/8/2013 Benoit Deposition Ex. 1 and 12/13/2012 Parker Deposition Ex. 22, QCPV001390369 – QCPV001390382)

JX 11 A Email from S. Bazarjani to S. Jha re D2D test, dated 6/24/1999 (QCPV001620217)

JX 12 A Email chain between S. Jha and P. Kantak re ParkerVision Meeting, dated 6/29/1999 (QCPV001389930 – QCPV001389932)

JX 13 A Qualcomm CDMA Technologies Berkana Wireless Inc. Acquisition


3 McKool 921628v1

EXHIBIT NO.

DATE IDENTIFIED

DATE ADMITTED




Recommendation, dated 11/21/2005 (QCPV001620009 - QCPV001620042)

JX 14 A Presentation from Jan 6, 2006 meeting, dated 01/06/2006 (QCPV011344278 - QCPV011344284)

JX 15 A Bahman Ahrari, RTR6285 MLDR WCDMA/HSDPA Balanced PRX High Band Front End design doc, RF Analog IC Design Group, dated 04/04/2006 (QCPV009381765 - QCPV009381840)

JX 16 A Qualcomm RTR8600 (Magellan) Receiver Top Level HLDR, (Part I, Rx Front Ends), 80-VF535-30 Rev. A, dated 11/27/2007 (11/07/2012 Wheatley Deposition Ex. 4, QCPV000183350 - QCPV000183655)

JX 17 A Qualcomm’s Resp. to ParkerVision’s Interrogatories (Nos. 1-9), dated 02/21/2012 (03/04/2013 Prucnal Exp Rpt)

JX 18 A Supplemental Exhibit B to Qualcomm's Objections and Responses to ParkerVision's First Set of Interrogatories (Nos. 1-9), dated 03/02/2012

JX 19 A Qualcomm’s Objections and Responses to ParkerVision’s First Request for the Production of Documents, ESI and Things, dated 4/30/2012

JX 20 A Qualcomm's Objections and Responses to ParkerVision's Second Set of Interrogatories


4 McKool 921628v1

EXHIBIT NO.

DATE IDENTIFIED

DATE ADMITTED




(Nos. 10-14), dated 04/30/2012

JX 21 A Qualcomm's Objections and Responses to ParkerVision's Second Request for the Production of Documents, ESI and Things, dated 06/07/2012

JX 22 A Exhibit C to Qualcomm's First Supplemental Objections and Responses to ParkerVision's First Set of Interrogatories (Nos. 1-9), dated 06/21/2012

JX 23 A Qualcomm's Second Supplemental Objections and Responses to ParkerVision's First Set of Interrogatories (Nos. 1-9), dated 09/14/2012

JX 24 A Qualcomm's First Supplemental Objections and Responses to ParkerVision's Second Set of Interrogatories (Nos. 10-14), dated 09/14/2012

JX 25 A Qualcomm's Third Supplemental Objections and Responses to ParkerVision's First Set of Interrogatories (Nos. 1-9), dated 10/03/2012

JX 26 A Exhibit D to Qualcomm's Third Supplemental Objections and Responses to ParkerVision's First Set of Interrogatories (Nos. 1-9), dated 10/03/2012

JX 27 A Qualcomm’s Objections and Responses to ParkerVision’s Third Set of Interrogatories (Nos. 15-18) (10/4/2012), dated 10/04/2012

JX 28 A Qualcomm’s Second Supplemental Objections and


5 McKool 921628v1

EXHIBIT NO.

DATE IDENTIFIED

DATE ADMITTED




Responses to ParkerVision’s Second Set of Interrogatories (Nos. 10-14), dated 10/16/2012

JX 29 A Qualcomm's Supplemental Objections and Responses to ParkerVision's Third Set of Interrogatories (Nos. 15-18), dated 11/01/2012

JX 30 A Qualcomm's Objections and Responses to ParkerVision's Fourth Set of Interrogatories (No. 19), dated 11/01/2012

JX 31 A Qualcomm's Objections and Responses to ParkerVision's Fifth Set of Interrogatories (Nos. 20-25), dated 11/30/2012

JX 32 A Qualcomm's Objections and Responses to ParkerVision's First Set of Requests for Admission, dated 12/04/2012

JX 33 A Qualcomm's Supplemental Objections and Responses to ParkerVision's Third Set of Interrogatories (Nos. 15-18), dated 12/07/2012

JX 34 A Qualcomm's Fourth Supplemental Objections and Responses to ParkerVision's First Set of Interrogatories (Nos. 1-9), dated 12/14/2012

JX 35 A Supplemental Exhibit D to Qualcomm's Fourth Supplemental Objections and Responses to ParkerVision's First Set of Interrogatories (Nos. 1-9), dated 12/14/2012

JX 36 A Qualcomm's Third Supplemental Objections and Responses to


6 McKool 921628v1

EXHIBIT NO.

DATE IDENTIFIED

DATE ADMITTED




ParkerVision's Second Set of Interrogatories, dated 01/16/2013

JX 37 A Qualcomm's Fifth Supplemental Objections and Responses to ParkerVision's First Set of Interrogatories (Nos. 1-9), dated 01/18/2013

JX 38 A Qualcomm’s Second Supplemental Objections and Responses to ParkerVision’s Third Set of Interrogatories, dated 01/24/2013

JX 39 A Qualcomm's First Supplemental Objections and Responses to ParkerVision's Fourth Set of Interrogatories (No. 19), dated 01/24/2013

JX 40 A Qualcomm's First Supplemental Objections and Responses to ParkerVision's Fifth Set of Interrogatories (Nos. 20-25), dated 01/25/2013

JX 41 A Qualcomm's Sixth Supplemental Objections and Responses to ParkerVision's First Set of Interrogatories (Nos. 1-9), dated 02/05/2013

JX 42 A Qualcomm's Fourth Supplemental Objections and Responses to ParkerVision's Second Set of Interrogatories (Nos. 10-14), dated 06/13/2013

JX 43 A Cicalini, et al., 21.3, A 65nm CMOS SoC with Embedded HSDPA/EDGE Transceiver, Digital Baseband and Multimedia Processor, 2011 IEEE International Solid-State Circuits Conference, pp 368-369, dated


7 McKool 921628v1

EXHIBIT NO.

DATE IDENTIFIED

DATE ADMITTED




00/00/2011 (11/27/2012 Harlan Deposition Ex. 5, 12/01/2012

JX 44 A RTR6500 RF Chipset Product Council 2, dated 04/00/2005 (05/08/2013 Benoit Deposition Ex. 4, QCPV00632578 - QCPV00632647)

JX 45 A WCDMA Specifications: LCU RX Front End HLDR, 80-VC067-11 Rev. A, Qualcomm, Confidential and Proprietary, dated 06/00/2006 (11/07/2012 Wheatley Deposition Ex. 3, QCPV000000257 - QCPV000000362)

JX 46 A QSC6240/QSC6270 (Enhanced and Nonenhanced) Device Specification 80-VF846-1 Rev. L, dated 02/18/2011 (QCPV000001914 - QCPV000002159)

JX 47 A QSC6240/QSC6270 Qualcomm Single Chip User Guide 80-VF846-3 Rev. E, dated 11/05/2009 (QCPV000002160 - QCPV000002477)

JX 48 A RTR6285/RTR6280 RF Transceiver IC Device Specification 80-VD861-1 Rev. K, dated 06/04/2010 (QCPV000004190 - QCPV000004251)

JX 49 A RTR/6285/RTR6280 RF Transceiver User Guide 80-VD861-3 Rev. D, dated 10/13/2008 (QCPV000004252 - QCPV000004289)

JX 50 A RTR6285 Design Kick-Off meeting 80-V4341-55 Rev. A,


8 McKool 921628v1

EXHIBIT NO.

DATE IDENTIFIED

DATE ADMITTED




dated 04/00/2007 (QCPV000005496 - QCPV000005839)

JX 51 A QSC6055, QSC6065, QSC6075, AND QSC6085 Qualcomm Single Chip Device Specification 80-VC881-1 Rev. Y, dated 02/25/2011 (Ex. D.6, QCPV000106800 - QCPV000107048)

JX 52 A QSC6055, QSC6065, QSC6075, AND QSC6085 Qualcomm Single Chip (QSC) User Guide 80-VC881-3 Rev. F, dated 08/07/2009 (QCPV000107144 - QCPV000107448)

JX 53 A RTR6500 Multiband CDMA RF Transceiver Device Specification 80-VC467-1 Rev. H, dated 11/20/2008 (03/25/2013 Suppl Ex. D.6, QCPV000111854 - QCPV000111911)

JX 54 A RFTR6500 Multiband CDMA RF Transceiver User Guide 80-VC467-3 Rev. C, dated 01/04/2008 (QCPV000112107 - QCPV000112159)

JX 55 A WCN1320 System-in-Package (SiP) Device Specification 80-VN163-1 Rev. B, dated 02/05/2010 (03/25/2013 Suppl Ex. D.6, QCPV000126488 - QCPV000126589)

JX 56 A WCN2243 System-on-Chip (SoC) Device Specification 80-WL024-1 Rev. E, dated 03/13/2012 (03/25/2013 Suppl Ex. D.6, QCPV000148299 - QCPV000148363)


9 McKool 921628v1

EXHIBIT NO.

DATE IDENTIFIED

DATE ADMITTED




JX 57 A WCN1312 Single Chip WLAN Solution Device Specification 80-WL100-1 Rev. F, dated 09/30/2011 (03/25/2013 Suppl Ex. D.6, Ex. 12 to PV's Rsp to QC's MPSJ, QCPV000149006 - QCPV000149067)

JX 58 A WCN1314 System-on-Chip (SoC) WLAN Solution Device Specification 80-WL114-1 Rev. E dated 10/20/2011 (QCPV000149502 - QCPV000149551)

JX 59 A WCN3660 Device Specification 80-WL300-1 Rev. J dated 4/6/2012 (QCPV000149971 - QCPV000150045)

JX 60 A RTR8605 Multimode RF Transceiver IC Device Specification 80-NO217-1 Rev. E dated 7/14/2011 (QCPV000163110 - QCPV000163180)

JX 61 A Astra/RGR6240 Objective Specification 80-VF107-3 Rev. A dated 3/14/2008 (QCPV000176188 - QCPV000176232)

JX 62 A RTR8600 (Magellan ) HB RXFE Signal Path LLDR 80-VF535-51 Rev. A dated 9/19/2008 (QCPV000184671 - QCPV000184878)

JX 63 A RTR6237/RTR6236 RF Transceiver IC Device Specification 80-VF879-1 Rev. D dated 9/23/2008 (QCPV000189327 - QCPV000189374)


10 McKool 921628v1

EXHIBIT NO.

DATE IDENTIFIED

DATE ADMITTED




JX 64 A QTR9215 Qualcomm Transceiver IC Device Specification 80-VL021-1 Rev. C dated 8/25/2011 (QCPV000190662 - QCPV000190735)

JX 65 A QTR9215 Qualcomm Transceiver IC User Guide 80-VL021-3 Rev. B dated 8/11/2011 (QCPV000190752 - QCPV000190833)

JX 66 A QTR8615/QTR8615 L Qualcomm Transceiver IC Device Specification 80-VL022-1 Rev. D dated 10/26/2011 (QCPV000191135 - QCPV000191247)

JX 67 A QTR8200/QTR8600/QTR8601 Qualcomm Transceiver User Guide 80-VP148-3 Rev. S dated 4/8/2011 (QCPV000203533 - QCPV000203655)

JX 68 A WTR1605/WTR1605L Wafer-level Transceiver IC Device Specification (Advance Information) 80-N5420-1 Rev. C dated 4/3/2012 (QCPV000227757 - QCPV000227835)

JX 69 A MBP1600 Mobile Broadcast Platform Device Specification 80-VD180-1 Rev. E dated 9/26/2008 (QCPV000362530 - QCPV000362586)

JX 70 A MBP1600 Mobile Broadcast Platform User Guide 80-VD180-3 Rev. C dated 10/26/2007 (QCPV000362659 - QCPV000362696)

JX 71 A MXU6219 RF Transceiver Multi-


11 McKool 921628v1

EXHIBIT NO.

DATE IDENTIFIED

DATE ADMITTED




Chip Module Device Specification 80-VF635-1 Rev. G dated 11/3/2008 (QCPV000376817 - QCPV000376868)

JX 72 A MBP2600 Mobile Broadcast Platform Device Specification 80-VJ231-1 Rev. D dated 5/19/2010 (QCPV000379132 - QCPV000379193)

JX 73 A MBP2700 Mobile Broadcast Platform Device Specification 80-VK428-1 Rev. C dated 2/11/2010 (QCPV000380986 - QCPV000381038)

JX 74 A MBP2700 Mobile Broadcast Platform User Guide 80-VK428-3 Rev. B dated 1/2/2010 (QCPV000381192 - QCPV000381229)

JX 75 A FTR8700 Femtocell RF Transceiver IC Device Specification 80-VU728-1 Rev. D dated 3/29/2010 (QCPV000410926 - QCPV000410972)

JX 76 A QSC1105/QSC1215 Qualcomm Single Chip Device Specification 80-VH110-1 Rev. D dated 5/2/2010 (QCPV000473131 - QCPV000473298)

JX 77 A QSC1105/QSC1215 Qualcomm Single Chip User Guide 80-VH110-3 Rev. A dated 8/10/2011 (QCPV000474335 - QCPV000474569)

JX 78 A QSC1110/QSC1100 Qualcomm Single Chip Device Specification 80-VH115-1 Rev. K dated 10/29/2009 (QCPV000475425 -


12 McKool 921628v1

EXHIBIT NO.

DATE IDENTIFIED

DATE ADMITTED




QCPV000475610)

JX 79 A QSC1110/QSC1100 Qualcomm Single Chip User Guide 80-VH115-3 Rev. C dated 6/10/2010 (QCPV000476692 - QCPV000476962)

JX 80 A QSC61x5, QSC6295, and QSC6695 Qualcomm Single Chip Device Specification 80-VP447-1 Rev. G dated 8/5/2011 (QCPV000493465 - QCPV000493678)

JX 81 A BTS4020/BTS4021 System-on-Chip (SoC) Device Specification 80-VE132-1 Rev. M dated 10/13/2010 (QCPV001381895 - QCPV001381955)

JX 82 A BTS4020/BTS4021 System-on-Chip (SoC) User Guide 80-VE132-3 Rev. B dated 7/29/2008 (QCPV001382208 - QCPV001382272)

JX 83 A BTS4054 System-in-Package (SiP) Device Specification 80-VG139-1 Rev. D dated 6/17/2009 (QCPV001384928-QCPV001384977)

JX 84 A BTS4025 System-on-Chip (SoC) Device Specification 80-VH397-1 Rev. L dated 1/18/2011 (QCPV001386232 - QCPV001386290)

JX 85 A BTS5045 System-in-Pachage (SiP) Device Specification 80-VJ120-1 Rev. C dated 4/29/2009 (QCPV001387460 - QCPV001387511)


13 McKool 921628v1

EXHIBIT NO.

DATE IDENTIFIED

DATE ADMITTED




JX 86 A QSC1100 Chipset HLDR 80-VD635-15 Rev. A dated 10/30/2006 (QCPV000463232 - QCPV00046412)

JX 87 A Qualcomm CDMA Technologies RFR6000 Zero-IF Receive IC Objective Specification dated 4/18/2002 (QCPV005416764 - QCPV005416806)

JX 88 A Email chain between S. Younis to QC re ParkerVision status dated 09/23/1998 (QCPV005526968)

JX 89 A File History of US Patent 6,061,551, dated 10/21/1998 (QCPV005584752 - QCPV005585660)

JX 90 A RTR9605 RF Transceiver IC Device Specification (Advance Information), 3.7 Receivers, dated 10/1/2012 (QCPV010469989 - QCPV010470050)

JX 91 A RTR8700 Product Requirements Document (Preliminary Information), dated 5/09/2007 (QCPV010480549 - QCPV010480569)

JX 92 A Comparison of Rx SAWless Boxster front-end performance, dated 2/22/2005 (QCPV010787084)

JX 93 A RTR6500 RF Chipset Product Council 2, dated 4/00/2005 (QCPV011163223 - QCFPV011163293)

JX 94 A RF/Analog/Mixed Signal Staffing, dated 00/00/2005 (QCPV011273755 -


14 McKool 921628v1

EXHIBIT NO.

DATE IDENTIFIED

DATE ADMITTED




QCPV011273831)

JX 95 A Qualcomm CDMA Technologies UMTS RF Product Development Roadmap, dated 00/00/0000 (QCPV011273996 - QCPV011274006)

JX 96 A Email from P. Kantak to S. Ciccarelli, et al. Resending…Talk with Jeff Parker, dated 10/08/1998 (QCPV011507721)

JX 97 A Exhibit 7 to Docket No. 305, dated 7/25/2013: Qualcomm's Objections and Responses to ParkerVision's First Set of Request for Admissions, dated 12/4/2012

JX 98 A Email chain from R. Padovani to C. Wheatley regarding bmiller, dated 10/18/2001 (QCPV001555717)


ATTACHMENT B-1

(Plaintiff’s Witness List)


McKool 899983v3


JACKSONVILLE DIVISION PARKERVISION, INC., Plaintiff, v. QUALCOMM INCORPORATED, Defendant.

Case No. 3:11-cv-719-J-37TEM

PLAINTIFF PARKERVISION, INC.’S WITNESS LIST

WILL CALL MAY CALL Jeffrey L. Parker Prashant Kantak David Sorrells Qualcomm Corporate

Representative Paul C. Benoit Paul R. Prucnal


ATTACHMENT B-2

(Defendant’s Witness List)


Exhibit B-2 Qualcomm’s Witness List

1

Qualcomm hereby provides the following list of witnesses it currently intends to call and

the list of witnesses it may call at trial. Qualcomm reserves the right to supplement or otherwise

amend this list in accordance with the orders in this case and the Court’s practice guidelines.

Will call

May call

Cormac Conroy Jim Jaffee

Prashant Kantak Charles Persico Paul Peterzell

Robert Fox

Greg Leonard Behzad Razavi Tim Williams

Mark Davis (VIA Telecom)

Saed Younis

Joseph Hanna1

Richard Harlan Jeffrey Leach

Cynthia Poehlman

Jong-Kwon Im (Samsung Electronics)

1 In any post-trial proceedings on an injunction, Qualcomm also expects to offer the opinion of Mr. Hanna. He will testify regarding opinions about the topics identified in his expert reports and previously testified to in his deposition. His expertise includes emergency communications systems and the importance of certain communications technology to emergency communication networks.


ATTACHMENT C-1

(Plaintiff’s Deposition Designations)


1 McKool 922399v3




PLAINTIFF’S DEPOSITION DESIGNATIONS

Plaintiff ParkerVision, Inc. reserves the right to remove designations based on rulings

that may issue on motions before the Court, time limitations, or on alternative ways to present

facts that may become available or apparent during trial.

I. JEFF JACOBS (OCTOBER 25, 2012)

ParkerVision’s Designations

Qualcomm’s Objections

Qualcomm’s Counter-

Designations

ParkerVision’s Objections to Qualcomm’s Counter-

Designations

31:21-32:10 F.R.E. 106 7:17-7:19

11:24:12:3

32:23-33:5 30:19 - 31:1

33:10-33:18 33:20 - 34:2

35:4-35:11 F.R.E. 106 F.R.E. 402 F.R.E. 403

35:12 - 36:4 F.R.E. 402

36:22-37:9 F.R.E. 106 F.R.E. 403

38:11 - 39:3 F.R.E. 402 F.R.E. 403 F.R.E. 611(a)

39:11-39:22

42:2-42:14


2 McKool 922399v3

67:9-67:25 F.R.E. 106 65:3 - 65:19

66:19 - 67:8

68:2-68:14 67:9-67:25

73:2-73:19 (…when he ran the chip

business)

75:18-75:21

76:9-76:12

76:20-77:1

89:20-90:8

90:21-91:2

91:11-91:13

91:18-91:25

92:21-92:23

96:16-96:20

100:15-100:18 F.R.E. 602

II. PRASHANT KANTAK (OCTOBER 19, 2012)




Designations

ParkerVision’s Objections to Qualcomm’s

Counter-Designations

6:23-6:25 F.R.E. 106 11:19-11:23

21:21:-22:6 F.R.E. 106 F.R.E. 402 F.R.E. 403

23:7-24:8

22:10-23:5

25:11-26:9

26:19-28:7

28:21-29:20 F.R.E. 106 29:21-30:2

30:3-30:22

32:24-33:11


3 McKool 922399v3

33:14-34:2 F.R.E. 106 34:5-34:5

34:6-34:10 F.R.E. 106 34:11-34:15 F.R.E. 611(a)

34:20-35:1 F.R.E. 402 F.R.E. 403

35:7-36:4

36:6-36:25

37:12-38:24 F.R.E. 106 38:25-39:11 F.R.E. 611(a)

39:21-39:25

40:3-40:13

40:15-41:22

42:11-42:15

43:5-43:9

45:7-45:10

46:8-46:16

46:18-46:20

48:20-49:8 F.R.E. 602

50:14-51:5

51:23-52:1 F.R.E. 402 F.R.E. 403

53:18-54:13

54:16-54:23

63:3-63:11 F.R.E. 602

63:13-63:21 F.R.E. 602

63:23-63:25

64:14-64:19

65:13-65:17 F.R.E. 106 65:18-65:23

67:6-68:11

69:9-69:14

69:16-69:16

69:18-70:7

70:15-70:17


4 McKool 922399v3

72:8-73:6 F.R.E. 402 F.R.E. 403

73:8-73:10 F.R.E. 106 73:21-74:1 F.R.E. 611(a)

73:12-73:17

74:2-74:12 F.R.E. 402 F.R.E. 403

74:22-76:25

77:9-77:13

77:19-78:4 F.R.E. 402 F.R.E. 403

78:12-78:16 F.R.E. 402 F.R.E. 403 F.R.E. 106

78:17-79:6

79:7-79:25

80:11-80:19

80:21-80:24

81:1-81:4

81:6-81:8

81:10-81:14

82:9-82:17 F.R.E. 106 82:18-82:20

84:6-84:10

84:20-85:22 F.R.E. 402 F.R.E. 403

85:25-86:1 F.R.E. 402 F.R.E. 403

86:8-88:8 F.R.E. 402 F.R.E. 403

88:24-89:20 F.R.E. 402 F.R.E. 403

90:4-90:9

94:6-94:10 F.R.E. 106 F.R.E. 402 F.R.E. 403

94:11-94:14 F.R.E. 611(a)

96:7-96:23 F.R.E. 402 F.R.E. 403


5 McKool 922399v3

100:13-100:25 F.R.E. 402 F.R.E. 403

103:20-103:22 F.R.E. 402 F.R.E. 403

103:25-103:25 F.R.E. 402 F.R.E. 403

104:15-104:18 F.R.E. 402 F.R.E. 403

104:20-105:3 F.R.E. 402 F.R.E. 403

105:5-105:8 F.R.E. 106 F.R.E. 402 F.R.E. 403

105:17-105:20 F.R.E. 402 F.R.E. 403


6 McKool 922399v3

III. JOHN ARTHUR SCOTT (NOVEMBER 16, 2012)




Designations



11:3-11:3 “I spoke with Ray Horn and

Tim Loomis, …

F.R.E. 402 F.R.E. 403

11:9-11:15 F.R.E. 402 F.R.E. 403


7 McKool 922399v3

IV. CHARLES WHEATLEY, III (NOVEMBER 7, 2012)




Designations

ParkerVision’s Objections to

Qualcomm’s Counter-Designations

12:21 - 12:23

16:6-16:12 F.R.E. 402 F.R.E. 403

18:21-19:7

23:17-23:20

23:24-24:16

32:2-32:5 F.R.E. 106 31:23-32:1

34:10-34:20 32:6-32:8

36:3-36:5

36:9-36:12

41:12-41:17 F.R.E. 402 F.R.E. 403

47:9-47:25

49:22-50:4

51:4-53:9 F.R.E. 402 F.R.E. 403

54:11-54:17 F.R.E. 402 F.R.E. 403

54:19-55:4 F.R.E. 402 F.R.E. 403

55:19-56:23 F.R.E. 402 F.R.E. 403

62:18-63:8 F.R.E. 106 63:9-63:24 F.R.E. 602 F.R.E. 701

64:1-64:6

67:22-68:7 F.R.E. 106 F.R.E. 402 F.R.E. 403 F.R.E. 602

67:10-67:12


8 McKool 922399v3

69:21-70:2 F.R.E. 106 F.R.E. 402 F.R.E.403 F.R.E. 602

70:3-70:10 F.R.E. 602 F.R.E. 611(a) F.R.E. 701

74:3-77:22

78:23-80:17 F.R.E. 403

80:22-82:2 F.R.E. 403

83:20-84:2

84:25-85:4 F.R.E. 106 85:5-86:12 F.R.E. 602 F.R.E. 611(a) F.R.E. 701

86:14-86:17 F.R.E. 106 85:5-86:12 F.R.E. 602 F.R.E. 611(a) F.R.E. 701

88:22-89:6

91:15-92:11

93:21-94:1 F.R.E. 106 92:19-93:9 F.R.E. 106

94:6-94:7

95:15-97:25 F.R.E. 106 98:1-98:6

98:8-98:19

101:19-101:23 F.R.E. 106 101:7-101:18 F.R.E. 602 F.R.E. 611(a)

108:6-108:18 F.R.E. 402 F.R.E. 403 F.R.E. 602 F.R.E. 701 F.R.E. 702



9 McKool 922399v3




125:15-126:10

128:12-131:13

131:15:133:3 F.R.E. 402 F.R.E. 403 F.R.E. 602 F.R.E. 701 F.R.E. 702

134:16-135:8 F.R.E. 402 F.R.E. 403 F.R.E. 602

135:10-136:24 F.R.E. 402 F.R.E. 403 F.R.E. 602

137:25-139:18 F.R.E. 402 F.R.E. 403 F.R.E. 602

141:13-141:16

147:13-148:5

152:12-152:15

152:20-154:12 F.R.E. 106 154:25-155:16 F.R.E. 401 F.R.E. 402 F.R.E. 403 F.R.E. 611(a)

155:21-156:21


10 McKool 922399v3

159:1-159:24

160:6-160:19

164:15-165:9

170:7-171:7 F.R.E. 402 F.R.E. 403 F.R.E. 602

172:6-175:18

178:17-179:5

179:19-180:18

182:14-184:13 F.R.E. 402 F.R.E. 403

191:3-191:25 F.R.E. 402 F.R.E. 403 F.R.E. 602

200:19-201:16

202:17-203:25 F.R.E. 106 202:8-202:13

207:9-209:17 F.R.E. 402 F.R.E. 403

210:6-211:13

213:22-215:14

216:10-216:12

216:19-217:9

218:6-219:11 F.R.E. 106 221:18-221:21 F.R.E. 106

225:9-225:12 22:2-22:8 F.R.E. 106 F.R.E. 401 F.R.E. 402 F.R.E. 403 F.R.E. 404 F.R.E. 405

227:19-227:23 F.R.E. 402 F.R.E. 403 F.R.E. 602

233:1-233:16 F.R.E. 402 F.R.E. 403

237:6-239:3


11 McKool 922399v3

240:1-240:17

240:22-241:4

241:25-242:3

245:19-246:16 F.R.E. 402 F.R.E. 403

247:2-247:10 F.R.E. 402 F.R.E. 403

249:3-249:8 F.R.E. 402 F.R.E. 403 F.R.E. 602






268:20-268:23

269:14-269:14

270:5-270:20


12 McKool 922399v3



277:10-279:12 F.R.E. 402 F.R.E. 403 F.R.E. 602





282:3-282:22 F.R.E. 404 F.R.E. 405 F.R.E. 602 F.R.E. 702


288:15-288:19

290:18-291:11


13 McKool 922399v3

V. SAED G. YOUNIS (DECEMBER 6, 2012)




Designations



13:18-14:10 F.R.E. 402 F.R.E. 403

15:21-16:3 F.R.E. 106 F.R.E. 402 F.R.E. 403

15:14-15:15

16:25-17:7

20:5-20:19

21:15-21:18 F.R.E. 106 20:20-21:14 F.R.E. 106

22:18-22:20 F.R.E. 106 F.R.E. 402 F.R.E. 403

22:23-23:8

26:10-27:2

31:8-31:10 F.R.E. 106 30:8-31:7

33:14-34:16 F.R.E. 402 F.R.E. 403 F.R.E. 602 F.R.E. 701

37:15-38:14 F.R.E. 402 F.R.E. 403

46:7-46:9

49:19-49:22 F.R.E. 106 49:13-49:17

49:23-50:4 F.R.E. 602 F.R.E. 702

50:6-50:23 F.R.E. 106 50:24-51:3 F.R.E. 106

53:1-53:19 F.R.E. 106 52:19-52:25

55:18-56:21 F.R.E. 106 55:12-55:17 F.R.E. 106

59:25-60:9

60:24-61:1 F.R.E. 402 F.R.E. 403 F.R.E. 602


14 McKool 922399v3

61:13-61:15 F.R.E. 402 F.R.E. 403 F.R.E. 602

61:18-61:25 F.R.E. 402 F.R.E. 403 F.R.E. 602

62:21-66:1 F.R.E. 402 F.R.E. 403 F.R.E. 602

69:5-69:20 F.R.E. 402 F.R.E. 403

70:2-71:2

71:10-71:22 F.R.E. 106 71:24-72:19 F.R.E. 106

73:1-73:21

74:12-75:4

76:4-76:23

77:14-77:19

78:7-78:11

80:18-81:2

86:1-86:4

86:21-86:24

90:2-90:22 F.R.E. 402

F.R.E. 403

F.R.E. 602

92:20-95:4

96:24-99:18

100:18-101:9

103:19-104:17 F.R.E. 106 F.R.E. 402 F.R.E. 403

104:19-105:23 F.R.E. 602 F.R.E. 701 F.R.E. 702 F.R.E. 901(a)

108:12-108:23

109:8-109:23

114:13-115:4


15 McKool 922399v3

127:15-128:22

130:3-132:5 F.R.E. 106 F.R.E. 402 F.R.E. 403

133:6-133:21 F.R.E. 106 F.R.E. 402 F.R.E. 403

134:3-135:2 F.R.E. 106 F.R.E. 402 F.R.E. 403

136:3-136:22 F.R.E. 106 F.R.E. 402 F.R.E. 403

138:9-139:7 F.R.E. 106 F.R.E. 402 F.R.E. 403

139:21-141:7 F.R.E. 106 F.R.E. 402 F.R.E. 403

143:7-150:14 F.R.E. 106 F.R.E. 402 F.R.E. 403

151:2-151:12

151:24-152:25

155:3-155:23 F.R.E. 106 158:6-159:6 F.R.E. 401 F.R.E. 402 F.R.E. 403 F.R.E. 602 F.R.E. 611(a)

159:8-160:3

164:11-164:16

164:23-166:14

176:17-177:25 F.R.E. 106 174:2-176:8 F.R.E. 106 F.R.E. 402 F.R.E. 611(a) F.R.E. 702


16 McKool 922399v3

VI. CHARLES PERSICO ( OCTOBER 23, 2012)




Designations



9:14-9:16

35:14-35:18

36:11-36:18

37:23-38:1

48:1-49:1 F.R.E. 402 F.R.E. 403 F.R.E. 602

49:16-49:20

50:17-51:3

51:16-54:16

55:16-55:25 F.R.E. 106 211:15-217:25 F.R.E. 403 F.R.E. 611(a) F.R.E. 802

56:25-57:5

65:3-66:12 F.R.E. 402 F.R.E. 403

67:1-68:7 F.R.E. 402 F.R.E. 403

70:17-70:24 F.R.E. 402 F.R.E. 403 F.R.E. 602

72:13-73:6 F.R.E. 402 F.R.E. 403

73:22-74:19 F.R.E. 402 F.R.E. 403

77:2-77:10

77:24-78:13

78:20-78:24


17 McKool 922399v3

90:18-91:3

91:24-92:25

95:18-96:10

101:5-101:15

104:16-105:18

106:13-107:10 F.R.E. 402 F.R.E. 403

108:3-108:7 F.R.E. 106 107:22-108:2 F.R.E. 403 F.R.E. 802

108:8-108:12 F.R.E. 403 F.R.E. 611(a) F.R.E. 802

110:20-111:4 F.R.E. 402 F.R.E. 403

113:25-114:18 F.R.E. 402 F.R.E. 403

118:1-118:18

119:20-120:7 F.R.P. 402 F.R.P. 403 F.R.P. 602

120:20-122:4 F.R.P. 402 F.R.P. 403

122:21-123:5 F.R.P. 402 F.R.P. 403

123:11-124:6 F.R.P. 402 F.R.P. 403

124:10-124:15

124:19-124:22

125:7-125:19

128:7-128:14

128:24-129:7


18 McKool 922399v3

129:21-130:9

132:18-134:2 F.R.P. 402 F.R.P. 403 F.R.P. 602

134:14-135:19

164:24-166:13

169:8-169:13

169:18-169:21

176:11-176:14

178:9-179:1

180:1-180:17

181:22-182:15 F.R.E. 106

182:23-183:21

185:11-186:17 F.R.E. 602

191:3-191:11

192:4-192:16

194:3-195:2 F.R.E. 402 F.R.E. 403 F.R.E. 701

196:15-196:23 F.R.E. 402 F.R.E. 403 F.R.E. 701

199:17-200:3

200:21-201:16 F.R.E. 402 F.R.E. 403 F.R.E. 602

202:9-204:7

204:24-206:12

206:21-207:19

219:8-219:13

226:22-226:25 F.R.E. 402 F.R.E. 403

228:5-228:13

229:20-230:5


19 McKool 922399v3

230:12-230:23

231:1-232:3


ATTACHMENT C-2

(Defendant’s Deposition Designations)


1




DEFENDANT’S DEPOSITION DESIGNATIONS

I. RICHARD HARLAN (NOV. 27, 2012)

Qualcomm’s Designations

ParkerVision’s Objections

ParkerVision’s Counter-

Designations

Qualcomm’s Objections to


Designations

10:11-12 10:11-12

11:11-17 11:18-13:17

12:24-13:17 16:18-17:1 Improper counter-designation; 802; 403

14:17-15:1 This testimony is the subject of a Motion in Limine

17:13-19:3 Improper counter-designation; 802; 403

19:13-25 Improper counter-designation; 802; 403





2




Designations



Designations





32:18-25 Improper counter-designation; 802; 403,

602





602




45:24-49:4 F.R.E. 106 F.R.E. 401 F.R.E. 402 F.R.E. 403

49:5-10 802

67:21-68:9 F.R.E. 401 F.R.E. 402 F.R.E. 403

69:13-70:16 F.R.E. 701


3




Designations



Designations

71:25-72:22 F.R.E. 701

75:1-76:9 F.R.E. 701

106:23-107:4 F.R.E. 402

108:7-16

109:12-110:1 F.R.E. 701

141:17-142:16 F.R.E. 106 F.R.E. 602

142:25-143:9 F.R.E. 602 143:10-15

147:23-148:4 F.R.E. 402

149:8-152:12 Improper counter-designation; 802; 403,

602








4

II. JEFFREY LEACH (NOV. 13, 2012)




Designations



Designations

9:5-20 10:21-11:12 Improper counter-designation; 802; 403

12:16-13:10 F.R.E. 402 12:8-12




602 19:7-9 Improper counter-

designation; 802; 403 19:15-18 Improper counter-

designation; 802; 403 26:5-16 Improper counter-

designation; 802; 403, 602


38:4-10


39:9-24 F.R.E. 401 F.R.E. 402 F.R.E. 403

39:25-40:2

40:18-41:1 F.R.E. 401 F.R.E. 402 F.R.E. 403


41:9-15 F.R.E. 401 F.R.E. 402 F.R.E. 403

41:2-8

41:22-25, 42:14-44:5 F.R.E. 402 F.R.E. 602 F.R.E. 701



5




Designations



Designations


48:21-50:13 F.R.E. 401 F.R.E. 402 F.R.E. 403


50:19-51:2 F.R.E. 401 F.R.E. 402 F.R.E. 403 F.R.E. 602 F.R.E. 611(a) F.R.E. 701



52:20-53:13 F.R.E. 401 F.R.E. 402 F.R.E. 403

54:20-55:5 F.R.E. 401 F.R.E. 402 F.R.E. 403


55:20-23 F.R.E. 401 F.R.E. 402 F.R.E. 403

56:18-57:12 F.R.E. 401 F.R.E. 402 F.R.E. 403


58:14-59:6 F.R.E. 401 F.R.E. 402 F.R.E. 403





6




Designations



Designations

63:13-25 F.R.E. 401 F.R.E. 402 F.R.E. 403 F.R.E. 602 F.R.E. 701


66:6-18 F.R.E. 401 F.R.E. 402 F.R.E. 403 F.R.E. 602 F.R.E. 901(a)




74:7-14

76:2-77:13 F.R.E. 401 F.R.E. 402 F.R.E. 403








7




Designations



Designations

86:1-9 F.R.E. 401 F.R.E. 402 F.R.E. 403 F.R.E. 602 F.R.E. 701 F.R.E. 901(a)



88:3-14 F.R.E. 401 F.R.E. 402 F.R.E. 403


602

90:13-91:13 F.R.E. 401 F.R.E. 402 F.R.E. 403

91:22-24

92:1-23 F.R.E. 401 F.R.E. 402 F.R.E. 403




98:11-99:2 F.R.E. 401 F.R.E. 402 F.R.E. 403 F.R.E. 602 F.R.E. 611(a) F.R.E. 701 F.R.E. 901(a)


104:16-21 F.R.E. 401 F.R.E. 402 F.R.E. 403

104:22-105:10


8




Designations



Designations

105:11-13 F.R.E. 401 F.R.E. 402 F.R.E. 403





107:24-108:11 F.R.E. 401 F.R.E. 402 F.R.E. 403

108:12-17

108:18-109:7 F.R.E. 401 F.R.E. 402 F.R.E. 403

109:8-12

110:16-113:21 F.R.E. 401 F.R.E. 402 F.R.E. 403

113:22-114:2

114:3-6 F.R.E. 401 F.R.E. 402 F.R.E. 403

114:13-21

115:14-25 F.R.E. 401 F.R.E. 402 F.R.E. 403





9




Designations



Designations


127:12

127:14-17

F.R.E. 701 127:22-24

128:3-13

133:3-9

133:15-19

133:25-134:3 134:4-23 Improper counter-designation; 802; 403


140:1-16 F.R.E. 401 F.R.E. 402 F.R.E. 403

141:10-142:16 F.R.E. 401 F.R.E. 402 F.R.E. 403 F.R.E. 602 F.R.E. 611(a) F.R.E. 701


146:20-21

146:24-147:4


10




Designations



Designations

147:5-24 F.R.E. 401 F.R.E. 402 F.R.E. 403 F.R.E. 404 F.R.E. 405 F.R.E. 602 F.R.E. 701

147:25-148:4

148:7-11 602



402


402


402


402

173:15-174:16 F.R.E. 401 F.R.E. 402 F.R.E. 403

184:14-16 184:6-13 802

184:22-185:1 184:17-21 802

185:2-6 802

185:18-19 F.R.E. 702


201:17-202:11

207:1-9 206:19-25 Improper counter-designation; 802; 403


11




Designations



Designations

207:25-208:10 F.R.E. 602 F.R.E. 701



210:20-22 210:14-19

210:23-211:2

213:10-12

213:15-21

214:21-24 213:23-214:4

217:16-19 217:10-15 Improper counter-designation; 802; 403;

602

217:25-218:3 217:20-24 Improper counter-designation; 802; 403;

602

219:14-220:3 F.R.E. 106 219:6-13










12




Designations



Designations


















13




Designations



Designations






14

III. PETER WEISSKOPF (MAY 10, 2013)




Designations



Designations

5:9-11


26:16-20

27:11-25

28:11-29:11 F.R.E. 402 F.R.E. 702


44:5-20 F.R.E. 611(a) 44:21-45:12 Improper counter-designation; 802; 403

45:13-16

46:9-12

47:1-48:16

50:9-16

51:16-52:20

53:15-23 F.R.E. 106 53:4-14 Improper counter-designation; 802; 403


54:14-19


59:9-13 F.R.E. 106 59:14-19 Improper counter-designation; 802; 403

61:12-16

62:5-21

64:6-20


15




Designations



Designations

65:7-16 F.R.E. 106 65:17-66:20 Improper counter-designation; 802; 403






73:24-74:10 F.R.E. 106 74:11-23 Improper counter-designation; 802; 403




137:2-15 This testimony is the subject of a Motion in Limine



McKool 920028v1 1168798 v4/HN McKool 920028v4 McKool 920028v4

IN THE UNITED STATES DISTRICT COURT

FOR THE MIDDLE DISTRICT OF FLORIDA


PARKERVISION, INC.,

Plaintiff,

v.

QUALCOMM INC.,

Defendant.

PARKERVISION, INC.’S AND QUALCOMM, INC.’S JOINT PRELIMINARY AND FINAL PROPOSED JURY INSTRUCTIONS

Case No. 3:11-CV-719-J-37-TEM Judge: Honorable Roy B. Dalton



I. Preliminary Instructions.......................................................................................................1

The Jury’s Duty - AGREED....................................................................................1

B. What Is Evidence - AGREED..................................................................................1

C. What is Not Evidence - AGREED...........................................................................2

D. Credibility of Witnesses - AGREED .......................................................................3

E. Expert Witnesses - AGREED ..................................................................................3

F. Taking Notes - PARTIALLY DISPUTED..............................................................4

G. What is a Patent and How One Is Obtained - PARTIALLY DISPUTED ..............................................................................................................5

H. Description of the Case - PARTIALLY DISPUTED..............................................8

I. The Patents Involved in this Case- DISPUTED ......................................................9

J. Burden of Proof - AGREED..................................................................................11

K. Conduct of the Jury - AGREED ............................................................................12

L. Course of the Trial - AGREED..............................................................................13

II. Trial Instructions................................................................................................................15

A. Stipulations - AGREED.........................................................................................15

B. Use of Depositions - AGREED .............................................................................15

C. Use of Interrogatories - AGREED.........................................................................15

III. Final Instructions ...............................................................................................................16

A. Introduction - AGREED ........................................................................................16

B. The Duty to Follow Instructions - AGREED ........................................................16

D. Consideration of Direct and Circumstantial Evidence; Argument of Counsel; Comments by the Court - AGREED.................................17

C. Credibility of Witnesses - AGREED .....................................................................17

D. Impeachment of Witnesses Because of Inconsistent Statements - AGREED ..........................................................................................18



E. Expert Witnesses - AGREED ................................................................................19

E. Responsibility for Proof - AGREED .....................................................................19

F. Summary of Contentions - PARTIALLY DISPUTED .........................................20

G. Claim Construction ................................................................................................22

1. Claim Construction – Generally - AGREED.............................................22

2. Independent and Dependent Claims - AGREED.......................................23

3. Claim Construction for the Case - AGREED ...........................................23

4. Claim Construction of Means-Plus-Function Claims for the Case - PARTIALLY DISPUTED ..................................................25

H. Infringement Generally - AGREED ......................................................................27

1. Direct Infringement - DISPUTED.............................................................28

a) Direct Infringement - Literal Infringement - AGREED .......................................................................................29

b) Direct Infringement - Literal Infringement of Means-Plus-Function Claims - AGREED.................................30

c) Direct Infringement Under the Doctrine of Equivalents - PARTIALLY DISPUTED.......................................31

2. Indirect Infringement .................................................................................32

a) Active Inducement - PARTIALLY DISPUTED ....................................................................................32

b) Contributory Infringement - DISPUTED ......................................36

I. Willful Infringement - DISPUTED .......................................................................38

J. Invalidity ................................................................................................................40

1. Summary of Invalidity Defense - DISPUTED ..........................................40

2. Prior Art .....................................................................................................41

a) Prior Art Defined - DISPUTED.....................................................41

b) Date of Invention - DISPUTED.....................................................42



c) Corroboration of Oral Testimony - DISPUTED ....................................................................................49

d) Prior Art Considered or Not Considered by the PTO - DISPUTED ...................................................................51

3. Anticipation................................................................................................52

4. Obviousness ...............................................................................................54

a) Scope and Content of the Prior Art................................................56

b) Differences Between the Claims of the Patents-in-Suit and the Prior Art....................................................57

c) Ordinary Skill in the Art ................................................................59

d) Secondary Considerations of Nonobviousness .............................................................................59

5. Non-Enablement ........................................................................................61

K. Damages.................................................................................................................62

1. Damages - Generally - AGREED..............................................................62

1. Date Damages Begin - DISPUTED..........................................................63

2. Reasonable Royalty - The “Hypothetical Negotiation” - DISPUTED ........................................................................64

3. Reasonable Royalty - Relevant Factors - PARTIALLY DISPUTED.........................................................................66

2. Convoyed Sales - DISPUTED...................................................................70

3. Any Damages Award Must Be Founded on Evidence, Not Speculation - DISPUTED ..................................................71

IV. Closing Instructions ...........................................................................................................73

A. Duty to Deliberate - AGREED ..............................................................................73

B. Election of Foreperson – Explanation of Verdict Form - AGREED ...............................................................................................................74


McKool 920028v1 1168798 v4/HN McKool 920028v4

1

I. PRELIMINARY INSTRUCTIONS

Members of the Jury: Now that you’ve been sworn, I need to explain some basic

principles about a civil trial and your duty as jurors. These are preliminary instructions. I’ll give

you more detailed instructions at the end of the trial.1

A. The Jury’s Duty2 - AGREED

It’s your duty to listen to the evidence, decide what happened, and apply the law to the

facts. It’s my job to provide you with the law you must apply – and you must follow the law

even if you disagree with it.

B. What Is Evidence3 - AGREED

You must decide the case on only the evidence presented in the courtroom. Evidence

comes in many forms. It can be testimony about what someone saw, heard, or smelled. It can be

someone’s opinion.

Some evidence may prove a fact indirectly. Let’s say a witness saw wet grass outside and

people walking into the courthouse carrying wet umbrellas. This may be indirect evidence that it

rained, even though the witness didn’t personally see it rain. Indirect evidence like this is also

called “circumstantial evidence” – simply a chain of circumstances that likely proves a fact.

As far as the law is concerned, it makes no difference whether evidence is direct or

indirect. You may choose to believe or disbelieve either kind. You job is to give each piece of

evidence whatever weight you think it deserves.

1 Modeled after United States Court of Appeals Eleventh Judicial Circuit Pattern Jury Instructions (Civil Cases), Preliminary Instructions (2013).





2

C. What is Not Evidence4 - AGREED

During the trial, you’ll hear certain things that are not evidence, and you must not

consider them as evidence. First, the lawyers’ statements and arguments aren’t evidence. In their

opening statements and closing arguments, the lawyers will discuss the case. Their remarks may

help you follow each side’s arguments and presentation of evidence. But the remarks themselves

aren’t evidence and shouldn’t play a role in your deliberations.

Second, the lawyers’ questions and objections aren’t evidence. Only the witnesses’

answers are evidence. Don’t decide that something is true just because a lawyer’s question

suggests that it is. For example, a lawyer may ask a witness, “You saw Mr. Jones hit his sister,

didn’t you?” That question is not evidence of what the witness saw or what Mr. Jones did –

unless the witness agrees with it.

There are rules of evidence that control what the court can receive into evidence. When a

lawyer asks a witness a question or presents an exhibit, the opposing lawyer may object if he

thinks the rules of evidence don’t permit it. If I overrule the objection, then the witness may

answer the question or the court may receive the exhibit. If I sustain the objection, then the

witness cannot answer the question, and the court cannot receive the exhibit. When I sustain an

objection to a question, you must ignore the question and not guess what the answer might have

been.

Sometimes I may disallow evidence – this is also called “striking” evidence – and order

you to disregard or ignore it. That means that you must not consider that evidence when you are

deciding the case.




3

I may allow some evidence for only a limited purpose. When I instruct you that I have

admitted an item of evidence for a limited purpose, you must consider it for only that purpose

and no other.

D. Credibility of Witnesses5 - AGREED

To reach a verdict, you may have to decide which testimony to believe and which

testimony not to believe. You may believe everything a witness says, part of it, or none of it.

When considering a witness’s testimony, you may take into account:

1. the witness’s opportunity and ability to see, hear, or know the things the witness is

testifying about;

2. the witness’s memory;

3. the witness’s manner while testifying;

4. any interest the witness has in the outcome of the case;

5. any bias or prejudice the witness may have;

6. any other evidence that contradicts the witness’s testimony;

7. the reasonableness of the witness’s testimony in light of all the evidence; and

8. any other factors affecting believability.

At the end of the trial, I’ll give you additional guidelines for determining a witness’s

credibility.

E. Expert Witnesses - AGREED

When scientific, technical or other specialized knowledge might be helpful, a person who

has special training or experience in that field is allowed to state an opinion about the matter.




4

But that doesn’t mean you must accept the witness’s opinion. As with any other witness’s

testimony, you must decide for yourself whether to rely upon the opinion.6

F. Taking Notes - PARTIALLY DISPUTED

If you wish, you may take notes to help you remember what the witnesses said. If you do

take notes, please don’t share them with anyone until you go to the jury room to decide the case.

Don’t let note-taking distract you from carefully listening to and observing the witnesses. When

you leave the courtroom, you should leave your notes hidden from view in the jury room.7

[ParkerVision proposes: I am going to ask the court security officer to pass out some

notebooks and pens to you at this time. The notebooks each have a cover page under the plastic

cover. Slide the cover page out so you can write your name at the top of that, so you will know

which notebook is yours, then slide it back in. If you will open your notebook, you should find a

blank pad on the inside for taking notes. Please write your name on the front page of that tablet

so you can identify your tablet and your notebook. And then you can flip to the second page to

begin taking any notes, if you desire to do so.

You will find in your notebook a copy of the patents in this case and a copy of the

Court’s claim construction chart. I’ll go over all of that with you as I go through these

instructions. So please just listen to my instructions now.8]9

6 Modeled after United States Court of Appeals Eleventh Judicial Circuit Pattern Jury Instructions (Civil Cases), Basic Instructions (2013). 7 Modeled after United States Court of Appeals Eleventh Judicial Circuit Pattern Jury Instructions (Civil Cases), Preliminary Instructions (2013).

8 Modeled after VirnetX Inc. v. Cisco Systems, Inc., Case No. 6:10-cv:417, Dkt. No. 484-1 at 2-3 (E.D. Tex. Sept. 4, 2012).

9 Qualcomm objects that providing the jury with some of the exhibits but not others is confusing and prejudicial.



5

Whether or not you take notes, you should rely on your own memory of the testimony.

Your notes are there only to help your memory. They’re not entitled to greater weight than your

memory or impression about the testimony.10

G. What is a Patent and How One Is Obtained - PARTIALLY DISPUTED

This case involves a dispute over a United States patent. Before summarizing the

positions of the parties and the legal issues involved in the dispute, let me take a moment to

explain what a patent is and how one is obtained.11

[ParkerVision proposes: The United States Constitution grants Congress the powers to

enact laws “to promote the progress of science and useful arts, by securing for limited times to

authors and inventors the exclusive right to their respective writings and discoveries.” Using this

power, Congress enacted the patent laws.12]13

Patents are granted by the United States Patent and Trademark Office (sometimes called

“the PTO”). A valid United States patent gives the patent holder certain rights for up to 20 years

from the date the patent application was filed. The patent holder may prevent others from

making, using, offering to sell, or selling the patented invention within the United States, or from

importing it into the United States without the patent holder’s permission. A violation of the


11 Modeled after the Federal Circuit Bar Association Model Patent Jury Instructions § A.1 (February 2013); the National Jury Instruction Project: Model Patent Jury Instructions § 1.1 (June 17, 2009). 12 Modeled after the National Jury Instruction Project: Model Patent Jury Instructions § 1.1 (June 17, 2009). 13 Qualcomm objects that informing the jury of Congress’s power to enact patent laws, if it so desired, is irrelevant, confusing, and prejudicial.



6

patent holder’s rights is called infringement. The patent holder may try to enforce a patent

against persons believed to be infringers by a lawsuit filed in federal court.14

The process of obtaining a patent is called patent prosecution. To obtain a patent, one

must file an application with the PTO. The PTO is an agency of the federal government and

employs trained examiners, who review applications for patents. The application includes a

section called the “specification,” which contains a written description of the claimed invention

telling what the invention is, how it works, and how to make and use it. The specification

concludes with one or more numbered sentences. These are the patent “claims.”15

When the patent is eventually granted by the PTO, the claims define the boundaries of its

protection and give notice to the public of those boundaries. Claims can be independent or

dependent. An independent claim is self-contained. A dependent claim refers back to an earlier

claim and includes the requirements of the earlier claim.16

After the applicant files a patent application, a PTO patent examiner reviews it to

determine whether [ParkerVision proposes: the claims are patentable17] [Qualcomm proposes:

he or she believes the claims are patentable] and whether the specification adequately describes

the invention claimed. In examining a patent application, the patent examiner may review “prior

14 Modeled after the Federal Circuit Bar Association Model Patent Jury Instructions § A.1 (February 2013); the National Jury Instruction Project: Model Patent Jury Instructions § 1.1 (June 17, 2009). 15 Modeled after the Federal Circuit Bar Association Model Patent Jury Instructions § A.1 (February 2013). 16 Modeled after the National Jury Instruction Project: Model Patent Jury Instructions § 1.1 (June 17, 2009). 17 ParkerVison’s proposed language adheres to the language of the National Jury Instruction Project: Model Patent Jury Instructions § 1.1 (June 17, 2009) and the Federal Circuit Bar Association Model Patent Jury Instructions § A.1 (February 2013). Qualcomm’s proposed language modifies the model instructions to be “slanted” in its favor. See Dkt. 84 at 12.



7

art.” Prior art is defined by law, and, at a later time, I will give you specific instructions on what

constitutes prior art. In general, though, prior art includes things that existed before the claimed

invention, that were publicly known or used in this country, or that were patented or described in

a publication in any country. The examiner considers, among other things, whether each claim

defines an invention that is new, useful, and not obvious when compared with the prior art. A

patent lists the prior art the examiner considered; this list is called the “cited references.” The

cited references include the prior art found by the examiner as well as any prior art submitted to

the PTO by the applicant.18

After the prior art search and examination of the application, the patent examiner then

informs the applicant in writing what the examiner has found and whether any claim is

patentable and, thus, will be “allowed.” This writing from the patent examiner is called an

“office action.” If the examiner rejects any of the claims, the applicant then responds and

sometimes changes the claims or submits new claims. This process, which takes place only

between the examiner and the patent applicant, may go back and forth for some time until the

examiner believes that the application and claims meet the requirements for a patent. The papers

generated during this time of communicating back and forth between the patent examiner and the

applicant make up what is called the “prosecution history.”19

If the PTO grants a patent, that does not necessarily mean that any invention claimed in

the patent is, in fact, legally entitled to the protection of a patent. One or more claims may, in

18 Modeled after the Federal Circuit Bar Association Model Patent Jury Instructions § A.1 (February 2013); the National Jury Instruction Project: Model Patent Jury Instructions § 1.1 (June 17, 2009). 19 Modeled after the Federal Circuit Bar Association Model Patent Jury Instructions § A.1 (February 2013); the National Jury Instruction Project: Model Patent Jury Instructions § 1.1 (June 17, 2009).



8

fact, not be patentable under the law. A person accused of infringement has the right to argue

here in federal court that a claimed invention in the patent is not entitled to patent protection

because it does not meet the requirements for a patent. In other words, an accused infringer may

defend a suit for patent infringement on the grounds that the patent is invalid.20

H. Description of the Case - PARTIALLY DISPUTED

To help you follow the evidence, I’ll summarize the parties’ positions.

The parties in this case are the Plaintiff, ParkerVision, Inc., and the Defendant,

Qualcomm Incorporated.21 This case involves four U.S. Patents identified by their numbers as

follows: U.S. Patent No. 6,061,551, U.S. Patent No. 6,266,518, U.S. Patent No. 6,370,371, and

U.S. Patent No. 7,496,342. For convenience, the parties and I will often refer to these patents by

the last three digits of the patent number. For example, U.S. Patent No. 6,061,551 may be

referred to as the ’551 patent. The parties and I will often refer to these patents collectively as the

“Patents-in-Suit.”22

ParkerVision alleges that Qualcomm directly and indirectly infringes the Patents-in-Suit

by making, using, selling, offering for sale, and/or importing products that are covered by the

Patents-in-Suit. ParkerVision further contends that Qualcomm’s infringement was willful.23

20 Modeled after the Federal Circuit Bar Association Model Patent Jury Instructions § A.1 (February 2013); the National Jury Instruction Project: Model Patent Jury Instructions § 1.1 (June 17, 2009). 21 Modeled after United States Court of Appeals Eleventh Judicial Circuit Pattern Jury Instructions (Civil Cases), Preliminary Instructions (2013).

22 Modeled after the Federal Circuit Bar Association Model Patent Jury Instructions § A.2 (February 2013); the National Jury Instruction Project: Model Patent Jury Instructions § 1.3 (June 17, 2009). 23 Modeled after the Federal Circuit Bar Association Model Patent Jury Instructions § A.2 (February 2013).



9

Qualcomm denies ParkerVision’s claims. Qualcomm contends that it has not, and

currently does not, infringe any claims of the Patents-in-Suit, either directly, indirectly, or in any

other manner. Qualcomm further contends that each claim of the Patents-in-Suit is invalid. 24

Your job will be to decide whether or not claims the claims of the Patents-in-Suit have

been infringed and whether or not those claims are invalid. If you decide that any of the claims

of the Patents-in-Suit have been infringed and are not invalid, you will then need to decide any

monetary damages [ParkerVision proposes: to be awarded to ParkerVision to compensate it for

the infringement. You will also need to make a finding as to whether the infringement was

willful.25] [Qualcomm proposes: to be awarded to ParkerVision and to make a finding as to

whether the infringement was willful.] If you decide that any infringement was willful, that

decision [ParkerVision proposes: should26] [Qualcomm proposes: must27] not affect any

damages award you give. I will take willfulness into account later.28

I. The Patents Involved in this Case - DISPUTED

[ParkerVision proposes: Let’s take a moment to look at one of the patents in this case.

24 Modeled after the Federal Circuit Bar Association Model Patent Jury Instructions § A.2 (February 2013).

25 ParkerVision’s proposed language faithfully adheres to the language of the National Jury Instruction Project: Model Patent Jury Instructions § 1.3 (June 17, 2009) and the Federal Circuit Bar Association Model Patent Jury Instructions § A.2 (February 2013). Qualcomm’s proposed language modifies the model instructions to be “slanted” in its favor. See Dkt. 84 at 12.


27 Qualcomm contends that ParkerVision’s instruction misstates the law. The jury has no discretion to enhance a damages award based on a finding of willfulness.

28 Modeled after the Federal Circuit Bar Association Model Patent Jury Instructions § A.2 (February 2013); the National Jury Instruction Project: Model Patent Jury Instructions § 1.3 (June 17, 2009).



10

You have been provided with a copy of the Patents-in-Suit, including the ’551 patent. The cover

page of the patent identifies the patent number and the date the patent was granted along the top,

as well as the inventor’s name, the filing date, and a list of the references considered in the

PTO.29

The specification of the patent begins with an abstract, also found on the cover page. The

abstract is a brief statement about the subject matter of the invention. Next comes the drawings.

The drawings illustrate various aspects or features of the invention. The written description of

the invention appears after the drawings, and it is organized into two columns on each page. The

specification ends with numbered paragraphs. These are the patent claims. 30

I have already determined the meaning of the claims of the Patents-in-Suit. You have

been given a document reflecting those meanings. If I have not provided you with a definition

for any claim term, you should apply the ordinary meaning. You are to apply my definitions of

these terms throughout this case. However, my interpretation of the language of the claims

should not be taken as an indication that I have a view regarding issues such as infringement and

invalidity. Those issues are yours to decide. I will provide you with more detailed instructions on

the meaning of the claims before you retire to deliberate your verdict.31]32

29 Modeled after the National Jury Instruction Project: Model Patent Jury Instructions § 1.2 (June 17, 2009). 30 Modeled after the National Jury Instruction Project: Model Patent Jury Instructions § 1.2 (June 17, 2009). 31 Modeled after the Federal Circuit Bar Association Model Patent Jury Instructions § A.3 (February 2013).

32 Qualcomm contends that ParkerVision’s proposed instruction is confusing and redundant.



11

J. Burden of Proof - AGREED

There are two standards of proof at issue in this case. The first standard of proof is called

a “preponderance of the evidence.” For example, plaintiff ParkerVision has the burden of

proving its claims of infringement by what the law calls a “preponderance of the evidence.” That

means ParkerVision must prove that, in light of all the evidence, what it claims is more likely

true than not. So, if you could put the evidence favoring ParkerVision and the evidence favoring

Qualcomm on opposite sides of balancing scales, ParkerVision needs to make the scales tip to its

side.33

To decide whether any fact has been proved by a preponderance of the evidence, you

may – unless I instruct you otherwise – consider the testimony of all witnesses, regardless of

who called them, and all exhibits that the court allowed, regardless of who produced them. After

considering all the evidence, if you decide a claim or fact is more likely true than not, then the

claim or fact has been proved by a preponderance of the evidence. 34

The second standard of proof is called “clear and convincing evidence.” For example,

ParkerVision bears the burden of proving willful infringement by clear and convincing evidence,

and Qualcomm bears the burden of proving invalidity by clear and convincing evidence. This is

a higher standard of proof than proof by a preponderance of the evidence. It means the evidence

must persuade you that the claim or defense is highly probable or reasonably certain.35

33 Modeled after United States Court of Appeals Eleventh Judicial Circuit Pattern Jury Instructions (Civil Cases), Preliminary Instructions (2013). 34 Modeled after United States Court of Appeals Eleventh Judicial Circuit Pattern Jury Instructions (Civil Cases), Preliminary Instructions (2013). 35 Modeled after United States Court of Appeals Eleventh Judicial Circuit Pattern Jury Instructions (Civil Cases), Preliminary Instructions (2013).



12

To decide whether any fact has been proved by clear and convincing evidence, you may –

unless I instruct you otherwise – consider the testimony of all witnesses, regardless of who called

them, and all exhibits that the court allowed, regardless of who produced them. After considering

all the evidence, if you decide a claim or fact is highly probable or reasonably certain, then the

claim or fact has been proved by clear and convincing evidence.36

K. Conduct of the Jury - AGREED

While serving on the jury, you may not talk with anyone about anything related to the

case. You may tell people that you’re a juror and give them information about when you must be

in court. But you must not discuss anything about the case itself with anyone.37

You shouldn’t even talk about the case with each other until you begin your

deliberations. You want to make sure you’ve heard everything—all the evidence, the lawyers’

closing arguments, and my instructions on the law—before you begin deliberating. You should

keep an open mind until the end of the trial. Premature discussions may lead to a premature

decision.38

In this age of technology, I want to emphasize that in addition to not talking face-to-face

with anyone about the case, you must not communicate with anyone about the case by any other

means. This includes e-mails, text messages, and the Internet, including social-networking

websites such as Facebook, MySpace, and Twitter.39

36 Modeled after United States Court of Appeals Eleventh Judicial Circuit Pattern Jury Instructions (Civil Cases), Preliminary Instructions (2013). 37 Modeled after United States Court of Appeals Eleventh Judicial Circuit Pattern Jury Instructions (Civil Cases), Preliminary Instructions (2013). 38 Modeled after United States Court of Appeals Eleventh Judicial Circuit Pattern Jury Instructions (Civil Cases), Preliminary Instructions (2013). 39 Modeled after United States Court of Appeals Eleventh Judicial Circuit Pattern Jury Instructions (Civil Cases), Preliminary Instructions (2013).



13

You also shouldn’t Google or search online or offline for any information about the case,

the parties, or the law. Don’t read or listen to any news about this case, visit any places related to

this case, or research any fact, issue, or law related to this case. The law forbids the jurors to talk

with anyone else about the case and forbids anyone else to talk to the jurors about it. It’s very

important that you understand why these rules exist and why they’re so important. You must

base your decision only on the testimony and other evidence presented in the courtroom. It is not

fair to the parties if you base your decision in any way on information you acquire outside the

courtroom. For example, the law often uses words and phrases in special ways, so it’s important

that any definitions you hear come only from me and not from any other source. Only you jurors

can decide a verdict in this case. The law sees only you as fair, and only you have promised to be

fair – no one else is so qualified.40

L. Course of the Trial - AGREED

Let’s walk through the trial. First, each side may make an opening statement, but they

don’t have to. Remember, an opening statement isn’t evidence, and it’s not supposed to be

argumentative; it’s just an outline of what that party intends to prove. 41

Next, ParkerVision will present its witnesses and ask them questions. After ParkerVision

questions the witness, Qualcomm may ask the witness questions—this is called “cross-

examining” the witness. Then Qualcomm will present its witnesses, and ParkerVision may cross-

40 Modeled after United States Court of Appeals Eleventh Judicial Circuit Pattern Jury Instructions (Civil Cases), Preliminary Instructions (2013). 41 Modeled after United States Court of Appeals Eleventh Judicial Circuit Pattern Jury Instructions (Civil Cases), Preliminary Instructions (2013).



14

examine them. You should base your decision on all the evidence, regardless of which party

presented it. 42

After all the evidence is in, the parties’ lawyers will present their closing arguments to

summarize and interpret the evidence for you, and then I’ll give you instructions on the law.

You’ll then go to the jury room to deliberate. 43

42 Modeled after United States Court of Appeals Eleventh Judicial Circuit Pattern Jury Instructions (Civil Cases), Preliminary Instructions (2013). 43 Modeled after United States Court of Appeals Eleventh Judicial Circuit Pattern Jury Instructions (Civil Cases), Preliminary Instructions (2013).



15

II. TRIAL INSTRUCTIONS

A. Stipulations - AGREED

Sometimes the parties have agreed that certain facts are true. This agreement is called a

stipulation. You must treat these facts as proved for this case.44

B. Use of Depositions - AGREED

A deposition is a witness’s sworn testimony that is taken before the trial. During a

deposition, the witness is under oath and swears to tell the truth, and the lawyers for each party

may ask questions. A court reporter is present and records the questions and answers. 45

The deposition of [name of witness], taken on [date], is about to be presented to you by a

video. Deposition testimony is entitled to the same consideration as live testimony, and you must

judge it in the same way as if the witness was testifying in court. 46

C. Use of Interrogatories - AGREED

You’ll now hear answers that [name of party] gave in response to written questions the

other side submitted. The questions are called “interrogatories.” Before the trial, [name of party]

gave the answers in writing while under oath.

You must consider [name of party]’s answers to as though it gave the answers on the

witness stand.47

44 Modeled after United States Court of Appeals Eleventh Judicial Circuit Pattern Jury Instructions (Civil Cases), Trial Instruction 2.1 (2013).






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III. FINAL INSTRUCTIONS

A. Introduction48 - AGREED

Members of the jury: It’s my duty to instruct you on the rules of law that you must use in

deciding this case.

When I have finished, you will go to the jury room and begin your discussions,

sometimes called deliberations.

B. The Duty to Follow Instructions49 - AGREED

Your decision must be based only on the evidence presented here. You must not be

influenced in any way by either sympathy for or prejudice against anyone.

You must follow the law as I explain it – even if you do not agree with the law – and you

must follow all of my instructions as a whole. You must not single out or disregard any of the

instructions on the law. 50

The fact that the parties are corporations must not affect your decision in any way. A

corporation and all other persons stand equal before the law and must be dealt with as equals in a

court of justice. When a corporation is involved, of course, it may act only through people as its

employees; and, in general, a corporation is responsible under the law for the acts and statements

of its employees that are made within the scope of their duties as employees of the company. 51

48 Modeled after United States Court of Appeals Eleventh Judicial Circuit Pattern Jury Instructions (Civil Cases), Basic Instruction (2013).

49 Modeled after United States Court of Appeals Eleventh Judicial Circuit Pattern Jury Instructions (Civil Cases), Basic Instruction 3.2.2 (2013).





17

D. Consideration of Direct and Circumstantial Evidence; Argument of Counsel; Comments by the Court52 - AGREED

As I said before, you must consider only the evidence that I have admitted in the case.

Evidence includes the testimony of witnesses and the exhibits admitted. But, anything the

lawyers say is not evidence and isn’t binding on you.

You shouldn’t assume from anything I’ve said that I have any opinion about any factual

issue in this case. Except for my instructions to you on the law, you should disregard anything I

may have said during the trial in arriving at your own decision about the facts.

Your own recollection and interpretation of the evidence is what matters.

In considering the evidence you may use reasoning and common sense to make

deductions and reach conclusions. You shouldn’t be concerned about whether the evidence is

direct or circumstantial.

“Direct evidence” is the testimony of a person who asserts that he or she has actual

knowledge of a fact, such as an eyewitness.

“Circumstantial evidence” is proof of a chain of facts and circumstances that tend to

prove or disprove a fact. There’s no legal difference in the weight you may give to either direct

or circumstantial evidence.

C. Credibility of Witnesses53 - AGREED

Now, in saying that you must consider all of the evidence, I do not mean that you must

accept all of the evidence as true or accurate. You should decide whether you believe what each

witness had to say, and how important that testimony was. In making that decision, you may


53 Modeled after United States Court of Appeals Eleventh Judicial Circuit Pattern Jury Instructions (Civil Cases), Basic Instructions § 3.4 (2013).



18

believe or disbelieve any witness, in whole or in part. The number of witnesses testifying

concerning any particular dispute is not controlling.

In deciding whether you believe or do not believe any witness, I suggest that you ask

yourself a few questions:

Did the witness impress you as one who was telling the truth?

Did the witness have any particular reason not to tell the truth?

Did the witness have a personal interest in the outcome of the case?

Did the witness seem to have a good memory?

Did the witness have the opportunity and ability to observe accurately the things he or

she testified about?

Did the witness appear to understand the questions clearly and answer them directly?

Did the witness’s testimony differ from other testimony or other evidence?

D. Impeachment of Witnesses Because of Inconsistent Statements54 - AGREED

You should also ask yourself whether there was evidence tending to prove that the

witness testified falsely concerning some important fact, or whether there was evidence that at

some other time the witness said or did something, or failed to say or do something, that was

different from the testimony the witness gave before you during the trial.

But keep in mind that a simple mistake by a witness does not necessarily mean that the

witness was not telling the truth as he or she remembers it. People naturally tend to forget some

things or remember them inaccurately. So, if a witness misstated something, you must decide

whether it was because of an innocent lapse in memory or an intentional deception. The

54 Modeled after United States Court of Appeals Eleventh Judicial Circuit Pattern Jury Instructions (Civil Cases), Basic Instructions § 3.5.1 (2013).



19

significance of your decision may depend on whether the misstatement is about an important fact

or about an unimportant detail.

E. Expert Witnesses55 - AGREED

When scientific, technical or other specialized knowledge might be helpful, a person who

has special training or experience in that field is allowed to state an opinion about the matter.

But that doesn’t mean you must accept the witness’s opinion. As with any other witness’s

testimony, you must decide for yourself whether to rely upon the opinion.

When a witness is being paid for reviewing and testifying concerning the evidence, you

may consider the possibility of bias.

E. Responsibility for Proof - AGREED

There are two standards of proof at issue in this case. The first standard of proof is called

a “preponderance of the evidence.” For example, plaintiff ParkerVision has the burden of

proving its claims of infringement by what the law calls a “preponderance of the evidence.” That

means ParkerVision must prove that, in light of all the evidence, what it claims is more likely

true than not. So, if you could put the evidence favoring ParkerVision and the evidence favoring

Qualcomm on opposite sides of balancing scales, ParkerVision needs to make the scales tip to its

side.56

To decide whether any fact has been proved by a preponderance of the evidence, you

may – unless I instruct you otherwise – consider the testimony of all witnesses, regardless of

who called them, and all exhibits that the court allowed, regardless of who produced them. After

55 United States Court of Appeals Eleventh Judicial Circuit Pattern Jury Instructions (Civil Cases), Basic Instructions § 3.6.2 (2013).




20

considering all the evidence, if you decide a claim or fact is more likely true than not, then the

claim or fact has been proved by a preponderance of the evidence. 57

The second standard of proof is called “clear and convincing evidence.” For example,

ParkerVision bears the burden of proving willful infringement by clear and convincing evidence,

and Qualcomm bears the burden of proving invalidity by clear and convincing evidence. This is

a higher standard of proof than proof by a preponderance of the evidence. It means the evidence

must persuade you that the claim or defense is highly probable or reasonably certain.58

To decide whether any fact has been proved by clear and convincing evidence, you may –

unless I instruct you otherwise – consider the testimony of all witnesses, regardless of who called

them, and all exhibits that the court allowed, regardless of who produced them. After considering

all the evidence, if you decide a claim or fact is highly probable or reasonably certain, then the

claim or fact has been proved by clear and convincing evidence.59

F. Summary of Contentions60 - PARTIALLY DISPUTED

As I did at the start of the case, I will first give you a summary of each side’s contentions

in this case. I will then provide you with detailed instructions on what each side must prove to

win on each of its contentions.

As I previously told you, ParkerVision alleges that Qualcomm infringes the following

claims of United States Patents owned by Parker Vision:

57 Modeled after United States Court of Appeals Eleventh Judicial Circuit Pattern Jury Instructions (Civil Cases), Preliminary Instructions (2013). 58 Modeled after United States Court of Appeals Eleventh Judicial Circuit Pattern Jury Instructions (Civil Cases), Preliminary Instructions (2013). 59 Modeled after United States Court of Appeals Eleventh Judicial Circuit Pattern Jury Instructions (Civil Cases), Preliminary Instructions (2013). 60 Modeled after the Federal Circuit Bar Association Model Patent Jury Instructions § B.1 (February 2013).



21

Claims 23, 25, 161, 193, and 202 of the ’551 patent;

claims 1, 27, 82, 90, and 91 of the ’518 patent;

claim 2 of the ’371 patent;

claim 18 of the ’342 patent.

These claims have been referred to as the “Asserted Claims” and these patents have been

referred to as the “Patents-in-Suit.” ParkerVision also contends that Qualcomm is inducing its

customers and/or end-users to directly infringe the Asserted Claims of the Patents-in-Suit and is

contributing to direct infringement of the Asserted Claims of the Patents-in-Suit by others who

make or use the patented wireless products or perform the patented methods.61 ParkerVision also

claims that Qualcomm has infringed the Patents-in-Suit willfully. ParkerVision is seeking

damages for the alleged infringement of Qualcomm.

Qualcomm denies ParkerVision’s claims. Qualcomm contends that it has not, and

currently does not, infringe any claims of the Patents-in-Suit, either directly, indirectly, or in any

other manner. Qualcomm further contends that each asserted claim of the Patents-in-Suit is

invalid.

Your job is to decide whether Qualcomm has infringed the asserted claims of the Patents-

in-Suit and whether any of the asserted claims of the Patents-in-Suit are invalid. If you decide

that any claims of the Patents-in-Suit have been infringed and are not invalid, you will then need

to decide any money damages [ParkerVision proposes: to be awarded to ParkerVision to

compensate it for the infringement. You will also need to make a finding as to whether the

61 Qualcomm objects to the inclusion of contributory infringement as ParkerVision has not preserved that issue for trial.



22

infringement was willful.62] [Qualcomm proposes: to be awarded to ParkerVision and to make

a finding as to whether the infringement was willful.] If you decide that any infringement was

willful, that decision [ParkerVision proposes: should63] [Qualcomm proposes: must64] not

affect any damages award you make. I will take willfulness into account later.

G. Claim Construction

1. Claim Construction – Generally65 - AGREED

Before you decide whether Qualcomm has infringed the asserted claims or whether the

asserted claims are invalid, you will have to understand the patent claims. The patent claims are

numbered sentences at the end of the patent. The claims are intended to define, in words, the

boundaries of the invention. Only the claims of the patent can be infringed. Neither the written

description, nor the drawings of a patent can be infringed. Each of the claims must be

considered individually. You must use the same claim meaning for both your decision on

infringement and your decision on invalidity.



64 As noted above, Qualcomm maintains that the jury has no discretion to enhance a damages award based on a finding of willfulness.

65 Modeled after the American Intellectual Property Law Association’s Model Patent Jury Instructions V.2.0 (2012).



23

2. Independent and Dependent Claims66 - AGREED

This case involves two types of patent claims: independent claims and dependent claims.

An “independent claim” sets forth all of the requirements that must be met in order to be covered

by that claim. Thus, it is not necessary to look at any other claim to determine what an

independent claim covers. In this case, for example, claim 23 of the ’551 patent; claims 1, 82 and

90 of the ’518 patent; claim 2 of the ’371 patent; and claim 18 of the ’342 patent are each

independent claims.

The rest of the claims being asserted in this case are “dependent claims.” A dependent

claim does not itself recite all of the requirements of the claim but refers to another claim for

some of its requirements. In this way, the claim “depends” on another claim. The law considers a

dependent claim to incorporate all of the requirements of the claims to which it refers. The

dependent claim then adds its own, additional requirements. To determine what a dependent

claim covers, it is necessary to look at both the dependent claim and any other claims to which it

refers. A product or method that meets all of the requirements of both the dependent claim and

the claims to which the dependent claim refers is covered by that dependent claim.

3. Claim Construction for the Case67 - AGREED

It is my job as judge to provide to you the meaning of any claim language that must be

interpreted. You must accept the meanings I give you and use them when you decide whether

any claim of the patent has been infringed and whether any claim is invalid. I will now tell you

the meanings of the following words and groups of words from the patent claims.

66 Modeled after the Federal Circuit Bar Association Model Patent Jury Instructions § B.2 (February 2013). 67 Modeled after the American Intellectual Property Law Association’s Model Patent Jury Instructions V.2.1 (2012).



24

1. “Carrier Signal” means “an electromagnetic wave that is capable of carrying

information via modulation.”

2. “Aliasing rate” means “sampling rate that is less than or equal to twice the

frequency of the carrier signal.”

3. “Aperture periods” means “the durations of time over which energy is transferred

from the carrier signal.”

4. “Electrically coupling” means “indirectly or directly connecting such that an

electric signal can flow between the coupled points.”

5. “Baseband signal” means “any generic information signal desired for

transmission and/or reception.”

6. “Sampling” means “reducing a continuous-time signal to a discrete-time signal.”

7. “Sub-sampling” and “sub-samples” mean “sampling at an aliasing rate.”

8. “Sampling the carrier signal . . . to transfer energy” means “transferring energy in

amounts that are distinguishable from noise.”

9. “Receives non-negligible amounts of energy transferred from a carrier signal”

means “receives energy from the carrier signal in amounts that are distinguishable from noise.”

10. “Sub-sampling the first signal . . . to transfer energy” means “transferring energy

in amounts that are distinguishable from noise.”

11. “Lower frequency signal” means “a signal with frequency below the carrier signal

frequency.”

12. “Lower frequency signal is generated from the transferred energy,” “generates a

I.F. signal from the integrated energy,” “generating the BB signal from the integrated energy,”



25

and “generating the 2nd signal from the integrated energy” should be given their plain and

ordinary meaning.

13. “Where n represents a harmonic or sub-harmonic of the carrier signal” and

“wherein n indicates a harmonic or sub-harmonic of the carrier signal” mean “n is 0.5 or an

integer greater than or equal to 1.”

14. “Integrating the energy” means “accumulating the energy.”

15. “Energy is integrated” means “energy is accumulated.”

16. “Integrates the . . . energy” means “accumulates the energy.”

17. “The integrated energy” means “the accumulated energy.”

18. “Impedance matching” means “transferring desired power.”

19. “Output impedance match circuit” means “a circuit configured to transfer desired

power from the energy sampling circuitry.”

20. “Universal frequency down converter” means “circuitry that generates a down

converted output signal from an input signal.”

4. Claim Construction of Means-Plus-Function Claims for the Case68 - PARTIALLY DISPUTED

21. The following four clauses used in the following three asserted claims are in a

special form called a “means-plus-function” clause. These clauses require a special

interpretation. They do not cover all means that perform the recited functions, but cover only the

structure described in the patent specification and drawings that performs the functions or an

equivalent of that structure. The court has found that the structures in the patent specifications

that perform the recited functions. You must use my interpretation of the means-plus-function




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element in your deliberations regarding infringement and validity, as further discussed below.

Means-plus-function limitations are found within the following asserted claims: claims 82, 90,

and 91 of the ‘518 patent.

22. The function associated with the means-plus-function limitation “means for

integrating the energy over the aperture periods” is “integrating the energy over the aperture

periods.” The structure that corresponds to that function is “one or more of energy storage

circuitry disclosed in Figures 68C, 68F, or equivalents thereof.”


integrating the transferred energy over the aperture periods” is “integrating the transferred energy

over the aperture periods.” The structure that corresponds to that function is “one or more of

energy storage circuitry disclosed in Figures 68C, 68F, or equivalents thereof.”


generating the baseband signal from the integrated energy” is “generating the baseband signal

from the integrated energy.” The structure that corresponds to that function is “any arrangement

of (i) one or more of the switch circuitry controlled by any one of pulse generators and (ii) one or

more of the energy storage circuitry disclosed or described in Figures 63, 64A, 64B, 65, 67A,

68G, 69, 74, 76A–E, 77A–C, 82A, 82B, 86, 88, 90, 92, 94A, 95, 101, 110, 111, or equivalents

thereof.”


generating the second signal from the integrated energy” is “generating the second signal from

the integrating energy.” The structure that corresponds to that function is “any arrangement of

(i) one or more of the switch circuitry controlled by any one of pulse generators and (ii) one or

more of the energy storage circuitry disclosed or described in Figures 63, 64A, 64B, 65, 67A,



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68G, 69, 74, 76A–E, 77A–C, 82A, 82B, 86, 88, 90, 92, 94A, 95, 101, 110, 111, or equivalents

thereof.”

Where I have not specifically construed a claim term, you should give the rest of the

words in the claims [ParkerVision proposes: their ordinary meaning69] [Qualcomm proposes:

their ordinary meaning to a person of skill in the art] in the context of the patent specification and

prosecution history.

H. Infringement Generally - AGREED

I will now instruct you as to the rules you must follow when deciding whether

ParkerVision has proven that Qualcomm infringed any of the asserted claims.

Patent law gives the owner of a valid patent the right to exclude others from importing,

making, using, offering to sell, or selling the patented invention within the United States during

the term of the patent. Any person or business entity that has engaged in any of those acts

without the patent owner’s permission infringes the patent. Here, ParkerVision alleges that

Qualcomm has infringed the asserted claims.

In deciding the issue of infringement you may not compare the accused Qualcomm

products and methods to any ParkerVision products or methods. Rather, you must compare the

accused Qualcomm products and methods to the asserted claims when making your decision

regarding infringement.

A patent claim may be infringed directly or indirectly. I will instruct you about both

direct infringement and indirect infringement. 70

69 ParkerVision’s instruction misstates how claim terms must be interpreted.

70 Modeled after the American Intellectual Property Law Association’s Model Patent Jury Instructions V.3 (2012).



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Infringement is assessed on a claim-by-claim basis. Therefore, there may be infringement

as to one claim but no infringement as to another.71

1. Direct Infringement - DISPUTED

[ParkerVision proposes: In this case, ParkerVision asserts that Qualcomm has directly

infringed the patent. Qualcomm is liable for directly infringing ParkerVision’s Patents-in-Suit if

you find that ParkerVision has proven that it is more likely than not that Qualcomm made, used,

imported, offered to sell, or sold the invention defined in at least one claim of ParkerVision’s

Patents-in-Suit.

Someone can directly infringe a patent without knowing of the patent or without knowing

that what they are doing is an infringement of the patent. They also may directly infringe a

patent even though they believe in good faith that what they are doing is not an infringement of

any patent. 72]73

[Qualcomm proposes: An accused infringer directly infringes a claim if it makes, uses,

sells, offers to sell within the United States, or imports into the United States, an accused product

that is covered by the claim.

In this case, ParkerVision asserts that Qualcomm has directly infringed the asserted

claims of the Patents-in-Suit. You may find Qualcomm liable for direct infringement only if you

find that ParkerVision has proven that it is more likely than not that Qualcomm has made, used,

71 Modeled after the Federal Circuit Bar Association Model Patent Jury Instructions § B.3 (February 2013). 72 ParkerVision’s proposed instruction for direct infringement adheres (nearly verbatim) to the language of the American Intellectual Property Law Association’s Model Patent Jury Instructions V.3.1 (2012). Qualcomm’s proposed language modifies the model instructions to be “slanted” in its favor. See Dkt. 84 at 12. 73 ParkerVision’s proposed instruction incorrectly states that infringement is determined on a patent-by-patent basis, rather than on a claim-by-claim and product-by-product basis, and fails to recite the extraterritoriality limitations on patents, which are at-issue in this litigation.



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offered to sell, sold within the United States, or imported into the United States, the invention

defined in at least one claim of any of the Patents-in-Suit. Direct infringement must be

determined on a claim-by-claim and product-by-product basis.

An accused infringer can directly infringe a patent claim without knowing that what it is

doing is an infringement of the patent claim. An accused infringer also may directly infringe a

patent claim even though it believes in good faith that what it is doing is not an infringement of

any patent claim.]

There are two types of “direct infringement”: (1) “literal infringement” and (2)

“infringement under the doctrine of equivalents.”74

a) Direct Infringement - Literal Infringement75 - AGREED

To determine literal infringement, you must compare the accused product or method with

each claim that ParkerVision asserts is infringed, using my instructions as to the meaning of the

patent claims. A patent claim is literally infringed only if Qualcomm’s product or method

includes each and every element or method step in that patent claim. If Qualcomm’s product or

method does not contain one or more elements or method steps recited in a claim, Qualcomm

does not literally infringe that claim. You must determine literal infringement with respect to

each patent claim individually. The accused product or method must be compared to the

invention described in each patent claim it is alleged to infringe. The same element or method

step of the accused product or method may satisfy more than one element of a claim.

74 Qualcomm objects. As described in Qualcomm’s motions in limine, Qualcomm objects to the inclusion of any instruction regarding the doctrine of equivalents because ParkerVision has not preserved that issue for trial.

75 Modeled after the American Intellectual Property Law Association’s Model Patent Jury Instructions V.3.2 (2012)



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b) Direct Infringement - Literal Infringement of Means-Plus-Function Claims76 - AGREED

I have already instructed you that certain claims contain means-plus-function clauses. To

show infringement for the means plus function claims, ParkerVision must prove that it is more

likely than not that the part of Qualcomm’s product that performs the recited function is identical

to, or equivalent to, the structure I have identified in the specification for performing the

identical function.

In deciding whether ParkerVision has proven that Qualcomm’s product includes structure

covered by a means-plus-function requirement, you must first decide whether the product has

any structure that performs the function I just described to you. If not, the claim containing that

means-plus-function requirement is not infringed.

If you find that Qualcomm’s accused product performs the claimed function, you must

next identify the structure in Qualcomm’s accused product that performs this function. After

identifying that structure, you must then determine whether ParkerVision has shown that that

structure is either identical to, or equivalent to, the structure I identified in the patent

specification as performing the function. If they are the same or equivalent, the means-plus-

function requirement is satisfied by that structure of the accused product. If all the other

requirements of the claim are satisfied by structures found in the accused product, the accused

product infringes the claim.

Whether the structure of the accused product is equivalent to a structure described in the

patent specification is decided from the perspective of a person of ordinary skill in the art. If a

person of ordinary skill in the art would consider the differences between the structure found in




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Qualcomm’s product and a structure described in the patent specification to be insubstantial, the

structures are equivalent.

c) Direct Infringement Under the Doctrine of Equivalents77 - PARTIALLY DISPUTED

If you decide that Qualcomm’s product does not literally infringe an asserted patent

claim, you must then decide whether that product infringes the asserted claim under what is

called the “doctrine of equivalents.” Under the doctrine of equivalents, the product can infringe

an asserted patent claim if it includes parts that are identical or equivalent to the requirements of

the claim. If the product is missing an identical or equivalent part to even one part of the asserted

patent claim, the product cannot infringe the claim under the doctrine of equivalents. Thus, in

making your decision under the doctrine of equivalents, you must look at each individual

requirement of the asserted patent claim and decide whether the product has an identical or

equivalent part to that individual claim requirement.

A part of a product is equivalent to a requirement of an asserted claim if a person of

ordinary skill in the field would think that the differences between the part and the requirement

were not substantial as of the time of the alleged infringement. If a person of ordinary skill in the

art would consider the differences between the structure found in Qualcomm’s product and a

structure described in the patent specification to be insubstantial, the structures are equivalent.

One way to decide whether any difference between a requirement of an asserted claim

and a part of the accused product is not substantial is to consider whether, as of the time of the

alleged infringement, the part of the product performed substantially the same function, in

77 Modeled after Graphic Packaging Int’l, Inc. v. C.W. Zumbiel Co., Case No. 3:10-CV-891-J-37JBT, Dkt. No. 149, (M.D. Fla. Jan. 19, 2012).



32

substantially the same way, to achieve substantially the same result as the requirement in the

patent claim.

In deciding whether any difference between a claim requirement and the product is not

substantial, you may consider whether, at the time of the alleged infringement, persons of

ordinary skill in the field would have known of the interchangeability of the part with the

claimed requirement. However, the known interchangeability between the claim requirement and

the part of the accused product is not necessary to find infringement under the doctrine of

equivalents. The same element of the accused product may satisfy more than one element of a

claim.78

2. Indirect Infringement

a) Active Inducement79 - PARTIALLY DISPUTED

ParkerVision alleges that Qualcomm is liable for infringement by actively inducing its

customers and/or users of the infringing products to directly infringe the [ParkerVision

proposes: Patents-in-Suit literally or under the doctrine of equivalents.80] [Qualcomm

78 Qualcomm objects. As described in Qualcomm’s motions in limine, Qualcomm objects to the inclusion of any instruction regarding the doctrine of equivalents because ParkerVision has not preserved that issue for trial. In addition, to the extent ParkerVision is permitted to pursue an equivalents theory, Qualcomm reserves the right to seek additional instructions relating to defenses to the doctrine of equivalents, including the doctrine against recapture, prosecution history estoppel, and the dedication doctrine.

79 Modeled after the Federal Circuit Bar Association Model Patent Jury Instructions, Instruction § B.3 (3.2) (February 2013). 80 ParkerVision’s contends that its proposed instruction for direct infringement adheres more closely to the language of the Federal Circuit Bar Association Model Patent Jury Instructions § B.3 (3.3) (2012).



33

proposes: asserted claims. You must determine whether there has been, and continues to be,

active inducement on a claim-by-claim and product-by-product basis.]81

To show induced infringement, ParkerVision must prove by a preponderance of the

evidence that:

(1) The acts are actually carried out by Qualcomm’s customers and/or users of the accused products and directly infringe the asserted claim;

(2) Qualcomm took action during the time [ParkerVision proposes: the patent] [Qualcomm proposes: the asserted claim] was in force intending to cause the infringing acts by Qualcomm’s customers and/or users of the accused products; and

(3) [ParkerVision proposes: Qualcomm was aware of the Patents-in-Suit and either (A) knew that the acts, if taken, would constitute infringement of that patent, or (B) believed there was a high probability that the acts by Qualcomm’s customers and/or users of the accused product would infringe the Patents-in-Suit but deliberately avoided confirming that belief. In other words, Qualcomm was willfully blind to the infringement of the patent.] 82

[Qualcomm proposes: Qualcomm either (A) knew of the asserted claim, knew that the acts, if taken, would constitute infringement of that asserted claim, and knew that the claim was valid; or (B) believed there was a high probability that the acts by Qualcomm’s customers and/or users of the accused product would

81 ParkerVision objects on the grounds that this instruction (“claim by claim”) is repetitive of the preceding instruction under “general infringement” which appropriately expresses the requirement that infringement be addressed on a claim by claim basis. ParkerVision further objects to Qualcomm’s inclusion of an instruction that requires that the jury determine infringement on a product by product basis. Qualcomm’s proposed language modifies the model instructions to change “patents” to “asserted claims” and to add (with no citation to authority) a requirement that active inducement be determined on a product by product basis. This instruction directly contradicts an agreement of the parties entered into as a result of Qualcomm’s refusal for produce schematics for each product at issue in this case. See Joint Pretrial Order at ¶22

82 ParkerVision’s instruction incorrectly fails to include a good-faith belief in invalidity as a grounds for a finding of no inducement. Commil USA, LLC v. Cisco Sys., Inc., __ F.3d __, No. 2012-1042, 2013 WL 3185535, at *6 (Fed. Cir. June 25, 2013) (“We now hold that evidence of an accused inducer’s good-faith belief of invalidity may negate the requisite intent for induced infringement. This is, of course, not to say that such evidence precludes a finding of induced infringement. Rather, it is evidence that should be considered by the fact-finder in determining whether an accused party knew that the induced acts constitute patent infringement.”).



34

infringe the asserted claim and that the claim was valid but took deliberate steps to avoid confirming that belief.83]

In considering whether Qualcomm has actively induced infringement by others, you may

consider all the circumstances, [ParkerVision proposes: including whether or not it obtained

the advice of a competent lawyer, whether or not it knew of the patents or was willfully blind to

the patents when designing and manufacturing its products, and whether or not it removed or

diminished the allegedly infringing features.84]

In order to establish active inducement of infringement, it is not sufficient that the alleged

direct infringer itself directly infringes the claim. Nor is it sufficient that Qualcomm was aware

of the acts by Qualcomm’s customers and/or users of the accused product that allegedly

constitute the direct infringement. Rather, you must find either that Qualcomm specifically

intended Qualcomm’s customers and/or users of the accused product to infringe [ParkerVision

proposes: any of the Patents-in-Suit85] [Qualcomm proposes: a valid asserted claim86] or that

83 ParkerVision objects to Qualcomm’s proposed instruction on the grounds that it imposes a heightened standard for induced infringement with no basis in the law. The law of induced infringement does not require that a defendant know that an asserted claim is valid in order to be liable for induced infringement. See Global-Tech Appliances, Inc. v. SEB S. A., 131 S.Ct. 2060, 2068-2071 (2012); Muniauction Inc. v. Thomson Corp., 532 F.3d 1318, 1329-30 (Fed. Cir. 2008); Lucent Technologies, Inc. v. Gateway, Inc., 580 F.3d 1301, 1340 (Fed. Cir. 2009); DSU Med. Corp. v. JMS Co., 471 F.3d 1293, 1306 (Fed. Cir. 2006). 84 Modeled after VirnetX Inc. v. Apple, Inc, Case No. 6:10-cv-4170, Dkt. No. 597 at p. 17 (E.D. Tex. Nov. 6, 2012); see Broadcom Corp. v. Qualcomm, Inc., 543 F.3d 683, 699 (Fed. Cir. 2008) (“Because opinion-of-counsel evidence, along with other factors, may reflect whether the accused infringer ‘knew or should have known’ [or was willfully blind] that its actions would cause another to directly infringe, we hold that such evidence remains relevant to the second prong of the intent analysis.”).

85 ParkerVision’s contends that its proposed instruction for direct infringement adheres more closely to the language of the Federal Circuit Bar Association Model Patent Jury Instructions § B.3 (3.3) (2013). Qualcomm’s proposed language modifies the model instructions to change “patents” to “a valid asserted claim.” Qualcomm’s proposed language modifies the model instructions to be “slanted” in its favor. See Dkt. 84 at 12.



35

Qualcomm believed there was a high probability that Qualcomm’s customers and/or users of the

accused product would infringe [ParkerVision proposes: any of the Patents-in-Suit, but

deliberately avoided learning the infringing nature of Qualcomm’s customers and/or users of its

accused products’ acts.]87 [Qualcomm proposes: the claim and that the claim was valid but

remained willfully blind as to those issues. Negligence or recklessness is not enough to find

inducement.88

If Qualcomm did not know of the asserted claim or if Qualcomm had a good faith belief

that the claim was invalid or that the devices using Qualcomm products do not infringe the

claim, then there is no active inducement of infringement. 89

86 Contrary to ParkerVision’s instruction, infringement is and validity are analyzed on a claim-by-claim basis, not a patent-by-patent basis. See, e.g., Amazon.com, Inc. v. Barnesandnoble.com, Inc., 239 F.3d 1343, 1351 (Fed. Cir. 2001) (“Of course, whether performed at the preliminary injunction stage or at some later stage in the course of a particular case, infringement and validity analyses must be performed on a claim-by-claim basis.”).

87 Qualcomm’s instruction regarding “negligence or recklessness” not being sufficient accurately states the law and is necessary to ensure that the jury applies the correct standard.

88 ParkerVision objects to this instruction as confusing to the jury because it introduces new legal terms to the jury without any explanation as to their meaning. The instruction is also not relevant to any issue the jury will decide. ParkerVision notes that this instruction is not included in the 2012 American Intellectual Property Law Association’s Model Patent Jury Instructions or the 2013 Federal Circuit Bar Association Model Patent Jury Instructions.

89 ParkerVision objects to this instruction and contends that it is legally incorrect. See Commil USA, LLC v. Cisco Sys., Inc., __ F.3d __, No. 2012-1042, 2013 WL 3185535, at *6 (Fed. Cir. June 25, 2013) (“We now hold that evidence of an accused inducer’s good-faith belief of invalidity may negate the requisite intent for induced infringement. This is, of course, not to say that such evidence precludes a finding of induced infringement. Rather, it is evidence that should be considered by the fact-finder in determining whether an accused party knew that the induced acts constitute patent infringement.”).



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b) Contributory Infringement - DISPUTED

(1) ParkerVision’s Proposed Instruction90 91

ParkerVision argues that Qualcomm is liable for contributory infringement by

contributing to the direct infringement of the Patents-in-Suit by Qualcomm’s customers and/or

users of its infringing products.

Qualcomm is liable for contributory infringement of a claim if ParkerVision proves by a

preponderance of the evidence that:

(1) Qualcomm sells, offers to sell, or imports within the United States a component of a

product, or apparatus for use in a process, during the time the Patents-in-Suit were in force;

(2) the component or apparatus has no substantial, noninfringing use;

(3) the component or apparatus constitutes a material part of the invention;

(4) Qualcomm is aware of the Patents-in-Suit and knows that the products and/or

methods for which the component and/or apparatus has no other substantial use may be covered

by a claim of the Patents-in-Suit or may satisfy a claim of the Patents-in-Suit under the doctrine

of equivalents; and

(5) that use directly infringes the claim.

90 Modeled after the Federal Circuit Bar Association Model Patent Jury Instructions § B.3 (3.3) (2012). 91 Qualcomm objects. As described in Qualcomm’s motions in limine, Qualcomm objects to the inclusion of any instruction regarding contributory infringement or the doctrine of equivalents because ParkerVision has not preserved those issues for trial. Qualcomm objects to the language “may be covered” as misstating the legal standard, which requires knowledge that the use is covered by the asserted claim. In addition, the Commil case’s holding that a good-faith belief in invalidity may negate the requisite intent for induced infringement should also be applied to contributory infringement. See Commil USA, LLC v. Cisco Sys., Inc., 720 F.3d 1361, 1364 (Fed. Cir. 2013); Global-Tech Appliances, Inc. v. SEB SA, 563 U.S. ___, 131 S. Ct. 2060, 2068 (2011).]



37

In order to prove contributory infringement, ParkerVision must prove that each of the

above requirements is met. This proof of each requirement must be by a preponderance of the

evidence, i.e., that it is more likely than not that each of the above requirements is met.

(2) Qualcomm’s Proposed Instruction92

ParkerVision alleges that Qualcomm is liable for contributory infringement. You must

determine contributory infringement on a claim-by-claim and product-by-product basis.

Qualcomm is liable for contributory infringement of a claim only if ParkerVision proves

by a preponderance of the evidence that:

(1) Qualcomm sells, offers to sell, or imports within the United States a component of a

product, or apparatus for use in a process, during the time the asserted claim was in force;

(2) the component or apparatus has no substantial, noninfringing use;

(3) the component or apparatus constitutes a material part of the invention;

(4) Qualcomm is aware of the asserted claim and knows that the products and/or methods

for which the component and/or apparatus has no other substantial use is covered by the claim

and the claim is valid; and

(5) that use directly infringes the claim.

In order to prove contributory infringement, ParkerVision must prove each of the above

elements by a preponderance of the evidence.

[ParkerVision proposes: including instructions on willfulness here because it is a type

of infringement and should be grouped with infringement.93] [Qualcomm proposes: including

92 Modeled after the Federal Circuit Bar Association Model Patent Jury Instructions § B.3 (3.3) (2013). 93 See the Federal Circuit Bar Association Model Patent Jury Instructions § B.3 (3.10) (2013).



38

instructions on willfulness after invalidity and damages, because invalidity affects willfulness

analysis and any damages awarded must not incorporate any aspect of willfulness.]

I. Willful Infringement - DISPUTED

1. ParkerVision’s Proposed Instruction94 95 96

If you find that it is more likely than not that Qualcomm infringed any of the Patents-in-

Suit, either literally or under the doctrine of equivalents, then you must further determine if this

infringement was willful.

To prove willfulness, ParkerVision must show that it is highly probable that:

1. Qualcomm was aware of ParkerVision’s patent;

2. Qualcomm acted despite a high likelihood that its actions infringed a valid patent,

and

3. This unjustifiably high likelihood of infringement was either known or so obvious

that it should have been known to Qualcomm.

In making the determination as to willfulness, you must consider the totality of the

circumstances. The totality of the circumstances comprises a number of factors, which include,

but are not limited to, whether Qualcomm intentionally copied the claimed invention or a

product covered by ParkerVision’s patents, whether or not Qualcomm obtained and followed the

94 Modeled after Graphic Packaging Int’l, Inc. v. C.W. Zumbiel Co., Case No. 3:10-CV-891-J-37JBT, Dkt. No. 149, (M.D. Fla. Jan. 19, 2012); the American Intellectual Property Law Association’s Model Patent Jury Instructions V.12.1 (2012).

95 Qualcomm objects. ParkerVision’s willfulness instruction misstates the legal standard because it does not require an analysis of willfulness on a claim-by-claim and product-by-product basis.

96 ParkerVision responds that the general infringement section of the instructions states that infringement is to be addressed on a claim by claim basis. Further instruction is unnecessarily repetitive.



39

advice of a competent lawyer with regard to infringement, and whether Qualcomm presented a

substantial defense to infringement.97

2. Qualcomm’s Proposed Instruction98 99

If you find that it is more likely than not that Qualcomm infringed an asserted claim, then

you must also determine if that infringement was willful. Willfulness requires a claim-by-claim

and product-by-product analysis.

To prove willfulness, ParkerVision must show that it is highly probable that:

1. Qualcomm was aware of ParkerVision’s patent,

2. Qualcomm acted despite an objectively high likelihood that its actions infringed the claim and that the claim was valid patent, and

3. This objectively high likelihood of infringement was either known or so obvious that it should have been known to Qualcomm.

In making the determination of whether Qualcomm acted despite an objectively high

likelihood that its actions infringed a valid patent, you may not consider Qualcomm’s actual state

of mind.

In determining willfulness, you must consider the totality of the circumstances.

97 See Broadcom Corp. v. Qualcomm, Inc., 543 F.3d 683, 699 (Fed. Cir. 2008).


99 ParkerVision objects. Qualcomm misstates the law with its proposed instruction: “you may not consider Qualcomm’s actual state of mind.” It is the Judge who decides the first, objective prong of willfulness and may not consider the state of mind of the jury. The second, subjective prong of willfulness is decided by the jury. In evaluating the subjective prong, the jury should consider the state of mind of the alleged infringer. Bard Peripheral Vascular, Inc. v. W.L. Gore & Assocs., Inc., 682F.3d 1003, 1007 (Fed. Cir. 2012).



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J. Invalidity

1. Summary of Invalidity Defense - DISPUTED

a) ParkerVision’s Proposed Instruction

Qualcomm contends that the asserted claims of the patents-in-suit are invalid. Qualcomm

must prove that it is highly probable that each asserted claim is invalid. Claims of an issued

patent may be found to be invalid. Thus, you must determine whether each of ParkerVision’s

asserted claims is invalid.100

An issued patent is accorded a presumption of validity based on the presumption that the

United States Patent and Trademark Office acted correctly in issuing the patent. From the

issuance of the patent, it is presumed that a claimed invention is new, useful and not obvious and

satisfies the other legal requirements for a valid U.S. patent. Each claim of a patent is presumed

valid independently of the validity of the other claims. The presumption of validity remains

intact and the burden of proof remains on Qualcomm throughout this litigation. In other words,

the burden never shifts to ParkerVision to prove that its patents are valid. 101 102 103

100 Modeled after the American Intellectual Property Law Association’s Model Patent Jury Instructions V.4 (2012). 101 Modeled after VirnetX Inc. v. Apple, Inc., Case No. 6:10-CV-417, Dkt. No. 597, pg. 18 (E.D. Tex. Nov. 6, 2012); see Novo Nordisk A/S v. Caraco Pharm. Labs., Ltd., No. 2011-1223, 2013 U.S. App. LEXIS 12251, at *12-13 (Fed. Cir. June 18, 2013) (“It is black-letter law that a patent is presumed valid under 35 U.S.C. § 282, that a party challenging its validity bears the burden of proving the factual elements of invalidity by clear and convincing evidence, and that ‘because the presumption of validity remains intact . . . throughout the litigation,’ the burden of persuasion never shifts to the patentee during the course of a district court obviousness challenge.”).

102 As described in Qualcomm’s motions in limine, Qualcomm objects to the inclusion of any description of the “presumption” of validity as such inclusion would be confusing and prejudicial. Qualcomm objects to ParkerVision’s language “you must determine whether each of ParkerVision’s asserted claims is invalid” as improperly suggesting that Qualcomm must prove that all claims are invalid, rather than invalidity being analyzed on a claim-by-claim basis.

103 ParkerVision responds that patents are presumed valid. 35 U.S.C. § 282(a). This Court has ruled on this issue. Graphical Packaging Int’l, Inc. v. C.W. Zumbiel Co., No. 3:10-cv-891-J-



41

b) Qualcomm’s Proposed Instruction

Qualcomm contends that the asserted claims of the patents-in-suit are invalid.

Qualcomm must prove its invalidity defenses by clear and convincing evidence. Invalidity is

determined on a claim-by-claim basis.104

2. Prior Art

a) Prior Art Defined - DISPUTED

(1) ParkerVision’s Proposed Instruction105

Prior art may include items that were publicly known or that have been used or offered

for sale, publications, or patents that disclose the claimed invention or the elements of the

claimed invention. To be prior art, the item or reference must have been made, known, used,

37JBT (M.D. Fla. Dec. 13, 2011). In Graphical, this Court adopted the opinion as to the issue in Harris Corp. v. Federal Express Corp., No. 6:07-cv-1819-JA-KRS (M.D. Fla. July 19, 2010). In Harris, the court noted that the defendant’s reliance on Chiron Corp. v. Genentech, Inc., 363 F.3d 1247 (Fed. Cir. 2004) was misplaced. Id. at slip op. 2–3 (“Rather, the Chiron court found that it was not error to decline to instruct the jury regarding the presumption where the correct burden of proof was nonetheless applied.”); see also Lighting Ballast Control, LLC v. Philips Elecs. North Am. Corp., No. 7:09-cv-29-O, 2011 U.S. Dist. LEXIS 154682, at *21–22 (N.D. Tex. June 10, 2011) (denying similar motion in limine, noting: “ULT’s contention that LBC’s reference to a patent’s statutory presumption of validity is prejudicial is not well taken. Moreover, ULT’s argument that references to the presumption would be compounded by LBC’s insistence on a ‘clear and convincing evidence’ instruction to the jury is without merit given the Supreme Court’s resounding endorsement of that standard in Microsoft[ Corp. v. i4i Ltd. P’ship, 131 S. Ct. 2238, 2243 (2011)].”).

104 ParkerVision objects. Patents are presumed valid. 35 U.S.C. § 282(a). Inclusion of this presumption is not prejudicial, nor confusing. See Lighting Ballast Control, LLC v. Philips Elecs. North Am. Corp., No. 7:09-cv-29-O, 2011 U.S. Dist. LEXIS 154682, at *21–22 (N.D. Tex. June 10, 2011) (denying similar motion in limine, noting: “ULT’s contention that LBC’s reference to a patent’s statutory presumption of validity is prejudicial is not well taken. Moreover, ULT’s argument that references to the presumption would be compounded by LBC’s insistence on a ‘clear and convincing evidence’ instruction to the jury is without merit given the Supreme Court’s resounding endorsement of that standard in Microsoft[ Corp. v. i4i Ltd. P’ship, 131 S. Ct. 2238, 2243 (2011)].”).

105 Modeled after the Federal Circuit Bar Association Model Patent Jury Instructions § B.4 (4.3a) (February 2013); Graphic Packaging Int’l, Inc. v. C.W. Zumbiel Co., Case No. 3:10-CV-891-J-37JBT, Dkt. No. 149, (M.D. Fla. Jan. 19, 2012).



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published, or patented either before the invention was made or more than one year before the

filing date of the patent application.


Prior art includes any of the following items received into evidence during trial:

1. any product or method that was publicly known or used by others in the United

States before the patented invention was made;

2. patents that issued more than one year before the filing date of the patent, or

before the invention was made;

3. publications having a date more than one year before the filing date of the patent,

or before the invention was made;

4. any product or method that was in public use or on sale in the United States more

than one year before the patent was filed;

5. any product or method that was made by anyone before the named inventors

created the patented product or method where the product or method was not

abandoned, suppressed, or concealed.

b) Date of Invention - DISPUTED


ParkerVision contends that the invention date for the 518’ ,551ۥ, and ’371 patents is

March 6, 1997, rather than each patent’s effective filing date of October 21, 1998. For the 342ۥ

Patent, the parties agree that the invention date was the effective date of filing, April 14, 2000.

106 ParkerVision objects to this instruction as unnecessary and confusing. ParkerVision’s contends that its proposed instruction for prior art adheres more closely to the language of the Federal Circuit Bar Association Model Patent Jury Instructions § B.4 (4.3a) (2013).

107 Modeled after the Federal Circuit Bar Association Model Patent Jury Instructions § B.4 (4.3a) (February 2013).



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The date of invention is either the date the invention was reduced to practice or the date it

was conceived, provided the inventor(s) were diligent in reducing the invention to practice.

Diligence means working continuously, though not necessarily every day.

First, I will address the concept of conception. Conception is the mental part of an

inventive act, i.e., the formation in the mind of the inventor of a definite and permanent idea of

the complete and operative invention as it is thereafter to be applied in practice. Conception of an

invention is complete when the idea is so clearly defined in the inventor’s mind that a person of

ordinary skill in the field of the technology would be able to reduce the invention to practice

without undue research or experimentation. This requirement does not mean that the inventor has

to have a prototype built or actually explain her or his invention to another person. But there

must be some evidence beyond the inventor’s own testimony that confirms the date on which the

inventor had the complete idea. Conception may be proven when the invention is shown in its

complete form by drawings, disclosure to another person, or other forms of evidence presented at

trial.

Second, a claimed invention is reduced to practice when it has been constructed, used, or

tested sufficiently to show that it will work for its intended purpose or when the inventor files a

patent. An invention may also be reduced to practice even if the inventor has not made or tested

a prototype of the invention, if it has been described in a filed patent application.108 109

108 Qualcomm objects. ParkerVision’s instruction fails to provide the full legal standard required for the jury to decide the complicated issues of conception, diligence, and reduction to practice. Qualcomm’s proposed instruction provides the details of this standard. ParkerVision’s instruction does not recognize that ParkerVision bears the burden of producing evidence of an earlier invention date.

109 ParkerVision’s contends in response that its proposed instruction for date of invention adheres more closely to the language of the Federal Circuit Bar Association Model Patent Jury Instructions § B.4 (4.3a) (2013).



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The parties agree that the invention date for the ‘342 patent is April 14, 2000.

The parties disagree on the invention date for the ‘551, ‘518, and ‘371 patents.

ParkerVision contends that the invention date for those three patents is March 6, 1997.

Qualcomm contends that the invention date for those three patents is October 21, 1998, the

patents’ effective filing date.

A patent’s invention date is its effective filing date, unless the named inventors conceived

the invention by an earlier date and were continuously diligent from that date until they reduced

their invention to practice. I will now explain what I mean by “conception,” “diligence,” and

“reduction to practice.”

Conception

Conception is the formation in the mind of the inventor, of a definite and permanent idea

of the complete and operative invention, as it is hereafter to be applied in practice.111 Conception

requires both (1) the idea of the invention’s structure and (2) possession of an operative method

of making it.112

110 ParkerVision objects to this instruction as unnecessary and confusing. ParkerVision’s contends that its proposed instruction for prior art adheres more closely to the language of the Federal Circuit Bar Association Model Patent Jury Instructions § B.4 (4.3a) (2013). Qualcomm’s proposed language modifies the model instructions to be “slanted” in its favor.

111 Hybritech Inc. v. Monoclonal Antibodies, Inc., 802 F.2d 1367, 1376 (Fed. Cir. 1986) (“Conception is the ‘formation in the mind of the inventor, of a definite and permanent idea of the complete and operative invention, as it is hereafter to be applied in practice.’), quoting 1 Robinson On Patents 532 (1890) and Coleman v. Dines, 754 F.2d 353, 359 (Fed. Cir. 1985); see also Dawson v. Dawson, __ F.3d __, Appeal Nos. 2012-1214, -1215, -1216, -1217, slip. op. at 10 (Fed. Cir. March 25, 2013), quoting Hybritech, 802 F.2d at 1376 (conception is the “formation in the mind of the inventor, of a definite and permanent idea of the complete and operative invention, as it is hereafter to be applied in practice”).

112 Invitrogen Corp. v. Clontech Laboratories, Inc., 429 F. 3d 1052, 1063 (Fed. Cir. 2005) (“This requires both (1) the idea of the invention’s structure and (2) possession of an operative method



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Conception is complete only when the idea is so clearly defined in the inventor’s mind

that only ordinary skill would be necessary to reduce the invention to practice, without extensive

research or experimentation.113 Complete conception requires the formation in the inventor’s

mind of each limitation of the patent claim at issue.114 Conception must be evaluated on a claim-

by-claim basis for each claimed invention.115

An idea is definite and permanent when the inventor has a specific, settled idea – a

particular solution to the problem at hand – not just a general goal or research plan he hopes to

pursue.116 Conception requires an idea to be so “definite and permanent” that all that remains to

be accomplished is to construct the invention.117

of making it”) (citation omitted); see also Dawson v. Dawson, __ F.3d __, Appeal Nos. 2012-1214, -1215, -1216, -1217, slip. op. at 18 (Fed. Cir. March 25, 2013), quoting Invitrogen, 429 F.3d at 1063 (“part of the conception inquiry asks whether the inventor ‘possess[ed] an operative method of making [the invention].’”).

113 Burroughs Wellcome Co. v. Barr Labs., Inc., 40 F.3d 1223, 1228 (Fed. Cir. 1994) (“Conception is complete only when the idea is so clearly defined in the inventor's mind that only ordinary skill would be necessary to reduce the invention to practice, without extensive research or experimentation”) (citations omitted); see also Dawson v. Dawson, __ F.3d __, Appeal Nos. 2012-1214, -1215, -1216, -1217, slip. op. at 10 (Fed. Cir. March 25, 2013), quoting Burroughs Wellcome, 40 F.3d at 1228 (same).

114 Kridl v. McCormick, 105 F.3d 1446, 1449 (Fed. Cir. 1997) (“Conception must include every feature or limitation of the claimed invention.”).

115 Kridl v. McCormick, 105 F.3d 1446, 1449 (Fed. Cir. 1997) (“Conception must include every feature or limitation of the claimed invention.”).

116 Burroughs Wellcome Co. v. Barr Labs., Inc., 40 F.3d 1223, 1228 (Fed. Cir. 1994) (“An idea is definite and permanent when the inventor has a specific, settled idea, a particular solution to the problem at hand, not just a general goal or research plan he hopes to pursue.”) (citations omitted); see also Dawson v. Dawson, __ F.3d __, Appeal Nos. 2012-1214, -1215, -1216, -1217, slip. op. at 10 (Fed. Cir. March 25, 2013), quoting Burroughs Wellcome, 40 F.3d at 1228 (Fed. Cir. 1994) (same).

117 Dawson v. Dawson, __ F.3d __, Appeal Nos. 2012-1214, -1215, -1216, -1217, slip. op. at 10, 15 (Fed. Cir. March 25, 2013) (“Conception requires an idea to be so ‘definite and permanent’ that ‘all that remains to be accomplished . . . belongs to the department of construction,’”) quoting 1 Robinson on Patents 532 (1890); see also Dawson, __ F.3d at __, slip op. at 10 (“all



46

Conception also requires that the inventor appreciate that which he or she has invented.118

In other words, the inventor must understand his invention to have all of the features that make

up the invention.119 An inventor who failed to appreciate the claimed inventive features at the

time of the alleged conception cannot use his later recognition to retroactively cure his or her

incomplete conception.120

Diligence to Reduction to Practice

I will now define for you the meaning of the term “diligence” and “reduction to practice.”

Establishing an invention date earlier than a patent’s filing date also requires diligence in

reducing the claimed invention to practice throughout the entire critical period.

To establish an earlier invention date, the named inventors must be continuously diligent

in reducing their claimed inventions to practice throughout the critical period. Reduction to

practice refers to either (1) actually building a device or performing a method that meets all the

that remains to be accomplished, in order to perfect the art or instrument, belongs to the department of construction, not creation), quoting 1 Robinson on Patents 532 (1890).

118 Invitrogen Corp. v. Clontech Laboratories, Inc., 429 F.3d 1052, 1063 (Fed. Cir. 2005) (“conception requires that the inventor appreciate that which he has invented.”).

119 Invitrogen, 429 F.3d at 1064 (“The priority determination requires evidence that the inventor actually first made the invention, and that he understood his creation to have the features that comprise the inventive subject matter at bar.”).

120 Hitzeman v. Rutter, 243 F.3d 1345, 1359 (Fed. Cir. 2001) (“[A]n inventor who failed to appreciate the claimed inventive features of a device at the time of the alleged conception cannot use his later recognition of those features to retroactively cure his imperfect conception.”).



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claim requirements and testing it enough to show that it would work for its intended purpose121

or (2) filing a patent application that describes all the claim requirements.122

The question of diligence must be considered in light of all the circumstances. The

question is whether the inventors were diligently working to reduce to practice the claimed

invention in a reasonable fashion. If the inventors were doing things reasonably necessary to

reduce the invention to practice, then they were diligent even if they did not actually work on the

invention every day. An inventor is not diligent where the invention was the second and third

priority for the inventor.123 In addition, the work relied upon must be directed toward a reduction

to practice of the claimed invention.124

121 Cooper v. Goldfarb, 154 F.3d 1321, 1327 (Fed. Cir. 1998) (“In order to establish an actual reduction to practice, the inventor must prove that: (1) he constructed an embodiment or performed a process that met all the limitations ...; and (2) he determined that the invention would work for its intended purpose.”).

122 Hyatt v. Boone, 146 F.3d 1348, 1352 (Fed. Cir. 1998) (“The filing of a patent application serves as conception and constructive reduction to practice of the subject matter described in the application.”).

123 Griffith v. Kanamaru, 816 F.2d 624, 629 (Fed. Cir. 1987) (“The conclusion we reach from the record is that the aminocarnitine project was second and often third priority in laboratory research as well as the solicitation of funds. We agree that Griffith failed to establish a prima facie case of reasonable diligence or a legally sufficient excuse for inactivity to establish priority over Kanamaru”).

124 Gunn v. Bosch, 181 U.S.P.Q. 758, 761 (Bd. Pat. Inter. 1973) (“The work relied on must be directed to attaining a reduction to practice of the subject matter of the counts. It is not sufficient that the activity relied on concerns related subject matter”); Naber v. Cricchi, 567 F.2d 382, 384-86 (C.C.P.A. 1977) (“There is no evidence that Cricchi’s layer deposition techniques work was in preparation for filing related patent applications or was required to develop a first invention needed to proceed with the invention of the counts. . . . We hold that work done at Westinghouse during the period from June to October 1970 directed at improving oxide and nitride layer deposition techniques generally applicable to all MNOS devices did not satisfy the requirement of ‘reasonable diligence’ on the part of Cricchi.”).



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Inactivity can be justified by the reasonable everyday problems and limitations

encountered by an inventor. However, to find diligence, the evidence must show that the alleged

earlier inventor was diligent throughout the entire critical period.125

Burden of Proof on Invention Date

As the party seeking to establish an earlier invention date, ParkerVision bears the burden

to offer corroborated evidence showing both (1) that ParkerVision’s inventors conceived the

asserted claims by the asserted date of conception and (2) that the inventors were continuously

diligent in reducing the claimed invention to practice throughout the critical period until the

purported reduction to practice.126 If you find that ParkerVision has not satisfied this burden,

you must find that the invention date for the ‘551, ‘518, and ‘371 patents is October 21, 1998.127

125 Monsanto Co. v. Mycogen Plant Sci., Inc., 261 F.3d 1356, 1369 (Fed. Cir. 2001) (“The law regarding diligence is settled. The evidence must show that the alleged earlier inventor was diligent throughout the entire critical period.”).

126 Mahurkar v. C.R. Bard, Inc., 79 F. 3d 1572, 1576-77 (Fed. Cir. 1996) (“Bard [the accused infringer] offered into evidence at trial a document published about three months before the filing date of Dr. Mahurkar's patent disclosing each and every element of the claimed invention. Dr. Mahurkar then had the burden to offer evidence showing he invented the subject matter of his patent before the publication date of the document. Had Dr. Mahurkar not come forward with evidence of an earlier date of invention, the Cook catalog would have been anticipatory prior art under section 102(a) because Dr. Mahurkar's invention date would have been the filing date of his patent.”); id. (also referring to “burden to offer evidence” as the “burden of production”); see also Cordance Corp. v. Amazon.com, Inc., 658 F.3d 1330 (Fed. Cir. 2011) (“To establish an earlier effective date, Cordance [the patentee] was required to prove prior conception.”); In re NTP, 654 F.3d 1279, 1291 (Fed. Cir. 2011) (“A party seeking to antedate a reference based on reduction to practice must present evidence of the actual reduction to practice of the invention prior to the effective date of the reference.”).

127 Mahurkar v. C.R. Bard, Inc., 79 F. 3d 1572, 1576-77 (Fed. Cir. 1996); Stamps.com, Inc. v. Endicia, Inc., 437 F. App’x. 897, 907-08 (Fed. Cir. 2011).



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c) Corroboration of Oral Testimony - DISPUTED


Oral testimony alone is insufficient to prove that something is prior art or that a particular

event or reference occurred before the filing date of the Patents-in-Suit. A party must provide

evidence that corroborates any oral testimony, especially when the oral testimony comes from an

interested witness or a witness testifying on behalf of an interested party. This includes any

witness or company testifying that his or its invention predates the Patents-in-Suit, and also

includes a patent owner seeking to prove an earlier date of invention than the effective date

stated on the face of the patent. Documentary or physical evidence that is made

contemporaneously with the inventive process provides the most reliable proof that the testimony

has been corroborated, but corroborating evidence may also consist of testimony of a witness,

other than an inventor, to the actual reduction to practice, or it may consist of evidence of

surrounding facts and circumstances independent of information received from the inventor. If

you find that the party has not corroborated a witness’s oral testimony with other evidence, you

are not permitted to find that the subject of that oral testimony qualifies as prior art or supports a

prior date of invention.

If evidence is presented for purposes of attempting to corroborate oral testimony, then

you must determine whether this evidence does, in fact, properly corroborate the oral testimony.

In making this determination, you should consider the following factors:

1) The relationship between the corroborating witness and the alleged prior user;

128 Modeled after i4i Limited P’ship v. Microsoft Corp., Case No. 6:07-CV-113, Dkt. 323, pg. 20 (E.D. Tex. May 19, 2009); Lazare Kaplan Int’l, Inc. v. Photosribe Techs, Inc., 628 F.3d 1359, 1374 (Fed. Cir. 2010); see Finnigan Corp. v. Int’l Trade Comm’n, 180 F.3d 1354, 1367 (Fed. Cir. 1999); Juicy Whip, Inc. v. Orange Bang, Inc., 292 F.3d 728, 737-38 (Fed. Cir. 2002); Woodland Trust v. Flowertree Nursery, Inc., 148 F.3d 1368, 1371 (Fed. Cir. 1998).



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2) The time period between the event and this trial;

3) The interest of the corroborating witness in the subject matter of this suit;

4) Contradiction or impeachment of the witness’s testimony;

5) Extent and detail of the corroborating witness’s testimony;

6) The witness’s familiarity with the subject matter of the patented invention and the alleged prior use;

7) Probability that a prior use could occur considering the state of the art at the time; and

8) Impact of the invention on the industry, and the commercial value of its practice.129 130


The party seeking an earlier conception date must provide corroborating evidence of a

contemporaneous disclosure that would enable one skilled in the art to make the invention.132

129 Qualcomm objects. ParkerVision’s corroboration instruction is too broad in referring to “a particular event or reference occurred.” Corroboration applies to a limited set of issues, such as oral testimony from the named inventor himself or herself about conception, diligence, and reduction to practice. ParkerVision’s corroboration instruction does not accurately describe what counts as corroborating evidence; corroborating evidence must be independent from the inventors.

130 ParkerVision responds that this instruction is legally accurate and modeled after i4i Limited P’ship v. Microsoft Corp., Case No. 6:07-CV-113, Dkt. 323, pg. 20 (E.D. Tex. May 19, 2009); Lazare Kaplan Int’l, Inc. v. Photosribe Techs, Inc., 628 F.3d 1359, 1374 (Fed. Cir. 2010); see Finnigan Corp. v. Int’l Trade Comm’n, 180 F.3d 1354, 1367 (Fed. Cir. 1999); Juicy Whip, Inc. v. Orange Bang, Inc., 292 F.3d 728, 737-38 (Fed. Cir. 2002); Woodland Trust v. Flowertree Nursery, Inc., 148 F.3d 1368, 1371 (Fed. Cir. 1998).

131 ParkerVision objects to this instruction as confusing. ParkerVision’s contends that its proposed instruction for corroborating evidence adheres more closely to case law and adopted jury instructions. See i4i Limited P’ship v. Microsoft Corp., Case No. 6:07-CV-113, Dkt. 323, pg. 20 (E.D. Tex. May 19, 2009); Lazare Kaplan Int’l, Inc. v. Photosribe Techs, Inc., 628 F.3d 1359, 1374 (Fed. Cir. 2010); see Finnigan Corp. v. Int’l Trade Comm’n, 180 F.3d 1354, 1367 (Fed. Cir. 1999); Juicy Whip, Inc. v. Orange Bang, Inc., 292 F.3d 728, 737-38 (Fed. Cir. 2002); Woodland Trust v. Flowertree Nursery, Inc., 148 F.3d 1368, 1371 (Fed. Cir. 1998).

132 Burroughs Wellcome Co. v. Barr Labs., Inc., 40 F.3d 1223, 1228 (Fed. Cir. 1994) (“Because it is a mental act, courts require corroborating evidence of a contemporaneous disclosure that would enable one skilled in the art to make the invention.”); see also Dawson v. Dawson, __



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Corroborating evidence is evidence independent of the inventors, such as testimony by a non-

inventor or a document that was provided to a non-inventor.133 Conception must be proved by

corroborating evidence that shows that the inventor disclosed to others his complete thought,

expressed in such clear terms as to enable those skilled in the art to make the invention.134

Conception also requires proof by corroborating evidence that the inventor appreciated the

complete invention at the time of the alleged conception.135 Likewise, diligence in reducing the

claimed invention to practice must also be proved by independent corroborating evidence.136

d) Prior Art Considered or Not Considered by the PTO - DISPUTED137

(1) ParkerVision’s Proposed Instruction

ParkerVision proposes that no instruction be given on this topic.

F.3d __, Appeal Nos. 2012-1214, -1215, -1216, -1217, slip. op. at 10 (Fed. Cir. March 25, 2013), quoting Burroughs Wellcome, 40 F.3d at 1228 (same).

133 Martek Biosciences Corp. v. Nutrinova, Inc., 579 F.3d 1363, 1375 (Fed. Cir. 2009) (inventor “must provide independent corroborating evidence in addition to his own statements and documents”).

134 Kridl v. McCormick, 105 F.3d 1446, 1449-50 (Fed. Cir. 1997).

135 Invitrogen Corp. v. Clontech Laboratories, Inc., 429 F. 3d 1052, 1064-66 (Fed. Cir. 2005) (“[The appreciation] analysis requires objective corroboration of the inventor’s subjective beliefs.... [I]t is not enough that a party adduce evidence that objective test results comport with an inventor’s testimony concerning his state of mind. Rather, there must also be evidence that the junior party timely interpreted or evaluated the results, and understood them to show the existence of the invention.”).

136 Price v. Symsek, 988 F.2d 1187, 1196 (Fed. Cir. 1993) (“[C]orroboration is required to support [the inventor’s] testimony regarding communication and reasonable diligence.”).




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When a party challenging the validity of a patent relies on prior art that was considered

by the PTO examiner during the prosecution of the application which resulted in the issued

patent, that party’s ability to satisfy its clear and convincing evidence burden may be more

difficult. When a party challenging the validity of a patent presents evidence that was not

considered by the Examiner during the prosecution of the application which resulted in the

issued patent, such new evidence may be given more weight and may make it easier to satisfy

that party’s highly probable evidence burden.139

3. Anticipation - PARTIALLY DISPUTED

If a device or process has been previously invented and disclosed to the public, then it is

not new, and therefore the claimed invention is “anticipated” by the prior invention. Simply put,

the invention must be new to be entitled to patent protection under the U.S. patent laws. To prove

anticipation, Qualcomm must prove with clear and convincing evidence that the claimed

invention is not new. Qualcomm contends that all of the Asserted Claims are invalid for being

anticipated. Anticipation must be analyzed on a claim-by-claim basis.

To anticipate a claim, each and every element in the claim must be present in a single

item of prior art, arranged as in the claim. You may not combine two or more items of prior art to

prove anticipation. In determining whether every one of the elements of the claimed invention is


139 ParkerVision objects to this instruction because it inappropriately instructs the jury to find facts that are in dispute. There is no evidence that the PTO did not “consider” certain prior art. In fact, as the Supreme Court noted, a PTO examiner is under no duty to cite every reference he considers. Microsoft Corp. v. i4i Ltd. P’ship, 131 S.Ct. 2238, 2251 (2011). In addition, the proposed instruction also incorrectly omits the materiality element set out by the Supreme Court in i4i and incorrectly and prejudicially suggests that the presumption of validity and/or the clear and convincing standard borne by Qualcomm is lessened.



53

found in an item of prior art, you should take into account what a person of ordinary skill in the

art would have understood from his or her review of the particular prior art reference.

[Qualcomm proposes: A reference may anticipate a claim even if the reference states that the

claimed invention would not work well. 140]141

[Qualcomm proposes: In determining whether the single item of prior art anticipates a

patent claim, you should take into consideration not only what is expressly disclosed in the

particular item of prior art reference, but also what is inherently present or disclosed in that prior

art or what inherently results from its practice. Prior art inherently anticipates a patent claim if

the missing element or feature would be the natural result of following what the prior art teaches

to persons of ordinary skill in the art. A party claiming inherent anticipation must prove that it is

highly probable that the claim is inherently anticipated. Evidence outside of the prior art

reference itself including experimental testing may be used to show that the elements not

expressly disclosed in the reference are actually present. Mere probabilities are not enough. It is

not required, however, that persons of ordinary skill actually recognized the inherent disclosure

at the time the prior art was first known or used. Thus, the prior use of the patented invention

that was unrecognized and unappreciated can still be an invalidating anticipation. 142]143

140 E.g., Billups-Rothenberg, Inc. v. Associated Regional & Univ. Pathologists, Inc., 642 F.3d 1031, 1038-39 (Fed. Cir. 2011) (“A reference is no less anticipatory if, after disclosing the invention, the reference then disparages it.”) (internal quotation omitted).

141 ParkerVision objects to this instruction because Qualcomm has not set forth case law sufficient to support this proposed instruction. ParkerVision objects on the ground that this instruction is “slanted” towards Qualcomm and does not appear in the neutral model jury instructions.

142 Qualcomm’s instruction was modeled after the American Intellectual Property Law Association’s Model Patent Jury Instructions V.6.0 (2012), and Qualcomm incorporates the case law cited therein by reference.



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4. Obviousness - PARTIALLY DISPUTED

Qualcomm also contends that [ParkerVision proposes: some] [Qualcomm proposes:

each]144 of the claims of the Patents-in-Suit are invalid because they are rendered obvious by the

prior art

A claimed invention is invalid as “obvious’ if it would have been obvious to persons

having ordinary skill in the art at the time the invention of each asserted claim was made. Unlike

anticipation, which allows consideration of only one item of prior art, obviousness may be shown

by considering more than one item of prior art.145

[ParkerVision proposes: Keep in mind that the existence of each and every element of

the claimed invention in the prior art does not necessarily prove obviousness. Most, if not all,

inventions rely on building blocks of prior art. In considering whether a claimed invention is

obvious, you may, but are not required to, find obviousness if you find that at the time of the

claimed invention there was a reason that would have prompted a person having ordinary skill in

the field of RF technology to combine the known elements in a way the claimed invention does,

taking into account such factors as:

1) Whether Qualcomm has identified a reason that would have prompted a person of ordinary skill in the field of the invention to combine the requirements or concept from the prior art in the same way as in the claimed invention. There is no single way to define the line between true inventiveness on one hand (which is patentable) and the application of common sense and ordinary skill to solve a problem on the other hand (which is not patentable). For example, market forces or other design incentives may be what produced a change, rather than true inventiveness.

143 Qualcomm has not set forth case law sufficient to support this proposed instruction. ParkerVision objects on the ground that this instruction is “slanted” towards Qualcomm.

144 ParkerVision contends that Qualcomm has only provided expert testimony on three of the remaining twelve asserted claims.

145 Modeled after the Federal Circuit Bar Association Model Patent Jury Instructions V.7.0 (February 2013).



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2) Whether the claimed invention applies a known technique that had been used to

improve a similar device or method in a similar way; and 3) Whether the claimed invention would have been obvious to try, meaning that the

claimed innovation was one of a relatively small number of possible approaches to the problem with a reasonable expectation of success by those skilled in the art.146] 147

In determining whether the claimed invention was obvious, consider each claim

separately. You must be careful not to determine obviousness using hindsight. You should put

yourself in the position of a person of ordinary skill in the field of the invention at the time the

claimed invention was made, and you should not consider what is known today or what is

learned from the teaching of the patent.

The following factors must be evaluated to determine whether Qualcomm has established

that the claimed invention is obvious:

1) The scope and content of the prior art relied upon by Qualcomm;

2) The difference or differences, if any, between each claim of the Patents-in-Suit that Qualcomm contends is obvious and the prior art;

3) The level of ordinary skill in the art at the time the inventions of the Patents-in-Suit were made; and

4) Additional, or “secondary,” considerations, if any, that indicate that the invention was obvious or not obvious.

Each of these factors must be evaluated, although they may be analyzed in any order.

You must perform a separate analysis for each of the claims that Qualcomm contends is obvious.

Qualcomm must prove obviousness by clear and convincing evidence. I will now explain each of

the four factors in more detail.

146 Modeled after the Federal Circuit Bar Association Model Patent Jury Instructions V.7.0 (February 2013).

147 ParkerVision’s proposed instruction is impermissibly slanted and misstates the law.



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a) Scope and Content of the Prior Art148

The prior art that you considered previously for anticipation purposes is also prior art for

obviousness purposes.

[ParkerVision proposes: You must determine what the prior art is that may be

considered in determining whether the Patents-in-Suit are obvious. A prior art reference may be

considered if it discloses information designed to solve the same problem(s) faced by the

inventor or if the reference discloses information that has obvious uses beyond its main purpose

that a person of ordinary skill in the art would reasonably examine to solve the same problem(s)

faced by the inventor.]

[Qualcomm’s proposes: Qualcomm also asserts that certain additional references are

relevant for the obviousness analysis. To be relevant to your consideration of obviousness, prior

art must be “analogous art.” Analogous art may be a reference from the same field of endeavor.

Even if the reference is not within the field of the inventors’ endeavor, a reference may still be

considered as analogous art if it is reasonably pertinent to any known problem for which there

was a solution encompassed by the patent’s claims. 149]150


149 E.g., KSR Int’l Co. v. Teleflex Inc., 550 U.S. 398, 420 (2007) (“Under the correct analysis, any need or problem known in the field of endeavor at the time of invention and addressed by the patent can provide a reason for combining the elements in the manner claimed.”).

150 ParkerVision objects to this instruction because it is confusing to the jury. ParkerVision’s contends that its proposed instruction for obviousness adheres more closely to the language of the American Intellectual Property Law Association’s Model Patent Jury Instructions V.7.1 (2012).



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b) Differences Between the Claims of the Patents-in-Suit and the Prior Art151

You should analyze whether there are any relevant differences between the prior art and

the claimed invention from the view of a person of ordinary skill in the art at the time of the

invention. Your analysis must determine the impact, if any, of such differences on the

obviousness or nonobviousness of the invention as a whole, and not merely some portion of it.

[Qualcomm proposes: What matters is the objective reach of the claim. If the claim covers any

obvious embodiment, it is invalid. It does not matter if the claim also covers a non-obvious

embodiment. 152]153

In analyzing the relevance of the differences between the claimed invention and the prior

art, you do not need to look for precise teaching in the prior art directed to the subject matter of

the claimed invention. You may take into account the inferences and creative steps that a person

of ordinary skill in the art would have employed in reviewing the prior art at the time of the

invention.

For example, if the claimed invention combined elements known in the prior art and the

combination yielded results that were predictable to a person of ordinary skill in the art at the


152 KSR Int’l Co. v. Teleflex Inc., 550 U.S. 398, 419 (2007) (“In determining whether the subject matter of a patent claim is obvious, neither the particular motivation nor the avowed purpose of the patentee controls. What matters is the objective reach of the claim. If the claim extends to what is obvious, it is invalid under § 103.”); Muniauction, Inc. v. Thomson Corp., 532 F.3d 1318, 1328 n.4 (Fed. Cir. 2008) (noting that “long-established rule that claims which are broad enough to read on obvious subject matter are unpatentable even though they also read on nonobvious subject matter.”) (internal quotation omitted).

153 ParkerVision objects to this instruction because it is confusing to the jury and unnecessary. ParkerVision contends that its proposed instruction for obviousness adheres more closely to the language of the American Intellectual Property Law Association’s Model Patent Jury Instructions V.7.2 (2012).



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time of the invention, then this evidence would make it more likely that the claim was obvious.

On the other hand, if the combination of known elements yielded unexpected or unpredictable

results, or if the prior art teaches away from combining the known elements, then this evidence

would make it more likely that the claim that successfully combined those elements was not

obvious.

A claim is not proved obvious merely by demonstrating that each of the elements was

independently known in the prior art. Most, if not all, inventions rely on building blocks long

since uncovered, and claimed discoveries almost of necessity will likely be combinations of what

is already known. Therefore, you should consider whether a reason existed at the time of the

invention that would have prompted a person of ordinary skill in the art in the relevant field to

combine the known elements in the way the claimed invention does. [Qualcomm proposes: The

reason could come from the prior art, the background knowledge of one of ordinary skill in the

art, the nature of any problem or need to be addressed, market demand, or common sense. You

may also consider whether the problem or need was known, the possible approaches to solving

the problem or addressing the need were known and finite, and the solution was predictable

through use of a known option. 154]155

154 Qualcomm’s instruction is modeled after the American Intellectual Property Law Association’s Model Patent Jury Instructions V.7.2 (2012), and it incorporates by reference the authorities cited therein. See also, e.g., KSR Int’l Co. v. Teleflex Inc., 550 U.S. 398, 420-21 (2007) (“Common sense teaches, however, that familiar items may have obvious uses beyond their primary purposes, and in many cases a person of ordinary skill will be able to fit the teachings of multiple patents together like pieces of a puzzle. Regardless of Asano's primary purpose, the design provided an obvious example of an adjustable pedal with a fixed pivot point; and the prior art was replete with patents indicating that a fixed pivot point was an ideal mount for a sensor. The idea that a designer hoping to make an adjustable electronic pedal would ignore Asano because Asano was designed to solve the constant ratio problem makes little sense. A person of ordinary skill is also a person of ordinary creativity, not an automaton.”).

155 ParkerVision objects to this instruction because it is confusing to the jury and unnecessary. ParkerVision contends that its proposed instruction for direct infringement adheres more closely



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If you find that a reason existed at the time of the invention to combine the elements of

the prior art to arrive at the claimed invention, this evidence would make it more likely that the

claimed invention was obvious. Again, you must undertake this analysis separately for each

claim that Qualcomm contends is obvious.

c) Ordinary Skill in the Art

The determination of whether a claimed invention is obvious is based on the perspective

of a person of ordinary skill in the relevant art field. The person of ordinary skill is presumed to

know all prior art that you have determined to be reasonably relevant. The person of ordinary

skill is also a person of ordinary creativity that can use common sense to solve problems. You

should consider all of the evidence introduced at trial in making this decision, including, but not

limited to:

1. the levels of education and experience of the inventor and other persons actively working in the field;

2. the types of problems encountered in the field;

3. the sophistication of the technology at the time of the invention, including the rapidity with which innovations were made in the art at the time of the invention.

d) Secondary Considerations of Nonobviousness

Before deciding the issue of obviousness, you must also consider certain factors, which,

if established, may indicate that the invention would not have been obvious. No factor alone is

dispositive, and you must consider the obviousness or nonobviousness of the invention as a

whole.

1. Were products covered by the claim commercially successful due to the merits of the claimed invention rather than due to advertising, promotion, salesmanship, or features of the product other than those found in the claims?

to the language of the American Intellectual Property Law Association’s Model Patent Jury Instructions V.7.2 (2012).



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2. Was there a long felt need for a solution to the problem facing the inventors, and was that need satisfied by the claimed invention?

3. Did others try, but fail, to solve the problem solved by the claimed invention?

4. Did others copy the claimed invention?

5. Did the invention achieve unexpected results?

6. Did others in the field or Qualcomm praise the claimed invention or express surprise at the claimed invention?

7. Did others [ParkerVision proposes: seek or obtain rights to the patent from the patent holder?] [Qualcomm proposes: accept licenses under the patents-in-suit because of the merits of the claimed invention?]156

8. Did the inventor proceed contrary to accepted wisdom in the field? 157

Answering any, or all, of these questions “yes” may suggest that the claim was not

obvious.

These factors are relevant only if there is a connection, or nexus, between them and the

invention covered by the patent claims. [Qualcomm proposes: For example, if commercial

success is due to other research and development activities, market position, advertising,

promotion, salesmanship, or other factors, or if commercial success is due to features of the

products that were in the prior art or are not required by the asserted claims, then any commercial

success may have no relation to the issue of obviousness.]158 Even if you conclude that some of

the above indicators have been established, those factors should be considered along with all the

156 ParkerVision objects and contends that its proposed instruction for secondary considerations for obviousness adheres more closely to the language of the Federal Circuit Bar Association Model Patent Jury Instructions § B.4(4.3c) (February 2013).

157 Modeled after the Federal Circuit Bar Association Model Patent Jury Instructions § B.4(4.3c) (February 2013).

158 ParkerVision objects to this instruction because it is confusing to the jury and unnecessary.



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other evidence in the case in determining whether Qualcomm has proven that the claimed

invention would have been obvious as of invention date.

5. Non-Enablement159

Qualcomm contends that claims 23, 25, 161, 193, and 202 of the ’551 patent; claims 1,

27, and 82 of the ’518 patent; and claim 2 of the ’371 patent are invalid for lack of enablement.

A patent must disclose sufficient information to enable one skilled in the field of the

invention, at the time the application was filed (or its effective filing date), to make and use the

claimed invention without undue experimentation. This requirement is known as the enablement

requirement. If a patent claim is not enabled, it is invalid. Each claim must be analyzed for

compliance with the enablement requirement. Qualcomm must prove by clear and convincing

evidence that the claim was not enabled.

In considering whether a patent claim satisfies the enablement requirement, you must

keep in mind that patents are written for persons of skill in the field of the invention. Thus, a

patent need not expressly state information that skilled persons would be likely to know or could

obtain.

The fact that some experimentation may be required for a person of ordinary skill to

practice the claimed invention does not mean that a patent does not meet the enablement

requirement. Factors you may consider in determining whether making the invention would

require undue experimentation include:

1. the quantity of experimentation necessary;

2. the amount of direction or guidance disclosed in the patent;

3. the presence or absence of working examples in the patent;

159 Modeled after the National Jury Project, Model Patent Jury Instructions (June 17, 2009); the Federal Circuit Bar Association Model Patent Jury Instructions § B.4(4.2b) (February 2013).



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4. the nature of the invention;

5. the state of the prior art;

6. the relative skill of those in the art;

7. the predictability of the art; and

8. the breadth of the claims.

No one or more of these factors is alone dispositive. Rather, you must make your

decision whether or not the degree of experimentation required is undue based upon all of the

evidence presented to you. You should weigh all the evidence presented and determine whether

or not, in the context of this invention and the state of the art at the time of the original

application, a person having ordinary skill would need to experiment unduly to make and use the

full scope of the claimed invention.

K. Damages

1. Damages - Generally160 - AGREED

If you find that the accused products infringe any of the claims of the Patents-in-Suit and

that those claims are not invalid, you must determine the amount of damages to be awarded to

ParkerVision for the infringement.

The fact that I am instructing you as to the proper measure of damages should not be

construed as suggesting any view of the Court as to which party is entitled to prevail in this case.

Instructions as to the measure of damages are given for your guidance in the event you find the

evidence in favor of ParkerVision.

160 Modeled after Graphic Packaging Int’l, Inc. v. C.W. Zumbiel Co., Case No. 3:10-CV-891-J-37JBT, Dkt. No. 149, (M.D. Fla. Jan. 19, 2012); the Federal Circuit Bar Association Model Patent Jury Instructions § B.6 (February 2013).



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If you need to determine damages, the amount of those damages must be adequate to

compensate ParkerVision for the infringement. Your damages award should put ParkerVision in

approximately the financial position it would have been in had the infringement not occurred, but

in no event may the damage award be less than a reasonable royalty. You may not add anything

to the amount of damages to punish the accused infringer or to set an example.

ParkerVision is seeking an award of damages in the form of a reasonable royalty.

1. Date Damages Begin - DISPUTED

a. ParkerVision’s Proposed Instruction


b. Qualcomm’s Proposed Instruction161

For any damages based on direct infringement of the ‘551, ‘518, and ‘371 patents,

damages may begin to run no earlier than January 2006.162 For any damages based on direct

infringement of the ‘342 patent, damages may begin to run no earlier than February 24, 2009.163

For any damages based on direct infringement of the ‘845 patent, damages may begin to run no

earlier than May 25, 2010.164

161 ParkerVision objects. Qualcomm cites no authority whatsoever for this instruction. This instruction does not appear in the Federal Circuit Bar Association Model Patent Jury Instructions or the American Intellectual Property Law Association’s Model Patent Jury Instructions. ParkerVision objects to Qualcomm’s proposed instructions regarding indirect infringement damages as being redundant with the active inducement instruction and therefore unnecessarily confusing to the jury.

162 By using the January 2006 date, Qualcomm does not concede that ParkerVision’s assessment of the date of the hypothetical negotiation is correct.

163 35 U.S.C. §§ 271(a), 284.

164 35 U.S.C. §§ 271(a), 284.



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For any damages based on indirect infringement, damages may not begin before all the

requirements for a finding of indirect infringement are met.165 You may not assess any damages

based on inducement of the ‘342 patent before February 24, 2009, and may not assess any

damages based on inducement of the ‘845 patent before May 25, 2010. In addition, if you find

that Qualcomm indirectly infringed at some time, you must also determine the first date when

Qualcomm had the required mental state for indirect infringement. You may not assess damages

for indirect infringement before that date. ParkerVision bears the burden of proving the first date

when Qualcomm had the required mental state by a preponderance of the evidence.

2. Reasonable Royalty - The “Hypothetical Negotiation” - DISPUTED

a) ParkerVision’s Proposed Instruction166

A royalty is a payment made to the owner of a patent by a non-owner in exchange for

rights to make, use, or sell the claimed invention. A reasonable royalty is the royalty that would

have resulted from a hypothetical license negotiation between the patent owner and a company in

the position of Qualcomm and that would have taken place just before the infringement began. In

considering this hypothetical negotiation, you should focus on what the expectations of the

patent holder and the infringer would have been had they entered into an agreement at that time,

and had they acted reasonably in their negotiations. You should also assume that both parties to

that negotiation would have understood the patent to be valid and infringed and were willing to

enter into an agreement. The reasonable royalty you determine must be a royalty that would have

resulted from the hypothetical negotiation, and not simply a royalty either party would have

preferred.

165 35 U.S.C. §§ 271(b), 284. See supra Active Inducement Instruction.

166 Modeled after the Federal Circuit Bar Association Model Patent Jury Instructions § B.6 (6.6-6.7) (February 2013).



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Although the relevant date for the hypothetical reasonable royalty negotiation is just

before the infringement began, you may consider in your determination of reasonably royalty

damages any actual profits by Qualcomm after that time and any commercial success of the

patented invention in the form of sales of the patented or infringing products after that time. You

may only consider this information, however, if it was foreseeable at the time that the

infringement began.

b) Qualcomm’s Proposed Instruction167

A reasonable royalty is the royalty that would have resulted from a hypothetical license

negotiation between ParkerVision and Qualcomm. Of course, we know that they did not agree to

a license and royalty payment. But, in order to decide on the amount of reasonable royalty

damages, you should assume that that the parties did negotiate a license just before the

infringement began. This is why it is called a “hypothetical” license negotiation. You should

assume that both parties to the hypothetical negotiation understood that the patent was valid and

infringed and both were willing to enter into a license. You are to determine the royalty that

would have resulted from the hypothetical negotiation; the test for damages is not what the

patent owner would have preferred to receive or what the accused infringer would have preferred

to pay.168


168 See, e.g., Lucent v. Gateway, 580 F.3d 1301, 1336 (Fed. Cir. 2009) (“[W]hat an infringer would prefer to pay is not the test for damages.”) (internal quotation omitted).



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3. Reasonable Royalty - Relevant Factors169 - PARTIALLY DISPUTED

In determining the reasonable royalty, you should consider all the facts known and

available to the parties at the time the infringement began. Some of the kinds of factors that you

may consider in making your determination are:

1. Any royalties received by the licensor for the licensing of the Patents-in-Suit, proving

or tending to prove an established royalty;

2. The rates paid by Qualcomm to license other patents comparable to the Patents-in-Suit;

3. The nature and scope of the license, as exclusive or non-exclusive, or as restricted or

non-restricted in terms of its territory or with respect to whom the manufactured product may be

sold [Qualcomm proposes: , as compared to the non-exclusive, U.S.-only patent license at-issue

in this case;]170

4. The licensor’s established policy and marketing program to maintain its right to

exclude others from using the patented invention by not licensing others to use the invention, or

by granting licenses under special conditions designed to preserve that exclusivity;

5. The commercial relationship between the licensor and the licensee, such as whether or

not they are competitors in the same territory in the same line of business;

6. The effect of selling the patented product in promoting sales of other products of the

licensee; the existing value of the invention to the licensor as a generator of sales of its non-

patented items; and the extent of such collateral sales;


170 ParkerVision objects to this addition as in improperly “slanted” instruction that is not found in the American Intellectual Property Law Association’s Model Patent Jury Instructions V.11.15 (2012) or the Federal Circuit Bar Association Model Patent Jury Instructions (February 2013). See Dkt. 84 at 12. ParkerVision further objects that this instruction is an improper commentary on facts in disputed.



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7. The duration of the patents-in-suit and the term of the license;

8. Any established profitability of the product made under the patents-in-suit; commercial

success; and [ParkerVision proposes: their current popularity] [Qualcomm proposes: their

current popularity derived from the claimed inventions as compared to other factors];171

9. The utility and advantages of the patented invention [Qualcomm proposes: , if

any,]172 over the old modes or devices, if any, that had been used for achieving similar results;

10. The nature of the patented invention, the character of the commercial embodiment of

it as owned and produced by the licensor, and the benefits to those who have used the invention;

11. The extent to which Qualcomm has made use of the invention, and any evidence that

shows the value of that use;

12. The portion of the profit or of the selling price that may be customary in the particular

business or in comparable businesses to allow for the use of the invention or analogous

inventions;

13. The portion of the profit that arises from the patented invention itself, as opposed to

profit arising from unpatented features, such as the manufacturing process, business risks, or

significant features or improvements added by the accused infringer;

171 ParkerVision objects to Qualcomm’s proposed addition to this instruction. Unlike the vast the rest of this section, Qualcomm’s proposed addition does not appear either within the American Intellectual Property Law Association’s Model Patent Jury Instructions V.11.15 (2012), nor does it appear within the Federal Circuit Bar Association Model Patent Jury Instructions (February 2013). Instead, Qualcomm’s proposed instruction attempts to slant the otherwise party-neutral model instructions in its favor and will lead to jury confusion.

172 ParkerVision objects to Qualcomm’s proposed addition to this instruction. Unlike the vast majority of the rest of this section, Qualcomm’s proposed addition does not appear either within the American Intellectual Property Law Association’s Model Patent Jury Instructions V.11.15 (2012), nor does it appear within the Federal Circuit Bar Association Model Patent Jury Instructions (February 2013). Instead, Qualcomm’s proposed instruction attempts to slant the otherwise party-neutral model instructions in its favor.



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14. The opinion testimony of qualified experts; and

15. The amount that a licensor and a licensee (such as Qualcomm) would have agreed

upon (at the time the infringement began) if both sides had been reasonably and voluntarily

trying to reach an agreement; that is, the amount that a prudent licensee—who desired, as a

business proposition, to obtain a license to manufacture and sell a particular article embodying

the patented invention—would have been willing to pay as a royalty and yet be able to make a

reasonable profit, and that would also have been acceptable by a patentee who was willing to

grant a license.

[Qualcomm proposes: You should also determine the impact of noninfringing

alternatives to the asserted claims on the royalty negotiated in the hypothetical negotiation.173

You should consider whether the noninfringing alternatives were available during the relevant

time period. You should also consider the value of any differences in benefits and costs between

the noninfringing alternatives and the asserted claims.174 An accused infringer with an available

173 E.g., Riles v. Shell Exploration & Prod. Co., 298 F.3d 1302, 1312 (Fed. Cir. 2002) (“under the constraints of the hypothetical negotiation, the market could not award Riles a royalty for his method divorced of all relation to a potential non-infringing alternative method. The economic relationship between the patented method and non-infringing alternative methods, of necessity, would limit the hypothetical negotiation.”).

174 E.g., Zygo Corp. v. Wyko Corp., 79 F.3d 1563, 1571-72 (Fed. Cir. 1996) (“The fact that Wyko could have continued marketing the SIRIS is a factor relevant to the determination of a proper royalty during hypothetical negotiations. Wyko would have been in a stronger position to negotiate for a lower royalty rate knowing it had a competitive noninfringing device ‘in the wings.’”); Black v. Thorne, 111 U.S. 122, 124 (1884) (“It does not always follow that because a party may have made an improvement in a machine and obtained a patent for it, another using the improvement and infringing upon the patentee’s rights will be mulcted in more than nominal damages for the infringement. If other methods in common use produce the same results, with equal facility and cost, the use of the patented invention cannot add to the gains of the infringer, or impair the just rewards of the inventor.”).



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competitive noninfringing device would have a stronger negotiating position in the hypothetical

negotiation.175]176

No one factor is dispositive, and you can and should consider the evidence that has been

presented to you in this case on each of these factors. [ParkerVision proposes: You may also

consider any other factors that, in your mind, would have increased or decreased the royalty the

infringer would have been willing to pay and the patent holder would have been willing to

accept, acting as normally prudent business people.177] Factor 15 establishes the framework that

you should use in determining a reasonable royalty; that is, the payment that would have resulted

from a negotiation between the patent holder and the infringer taking place at a time prior to

when the infringement began.178

175 E.g., Zygo, 79 F.3d at 1571-72.

176 ParkerVision objects to this instruction as it is a misstatement of the law. Qualcomm proposes to instruct the jury that it “should determine the impact of noninfringing alternatives.” However, the American Intellectual Property Law Association’s Model Patent Jury Instructions V.11.15 (2012) states that, “[i]n determining a reasonable royalty, [a jury] may also consider evidence concerning the availability and cost of non-infringing substitutes for the patented invention.” Qualcomm’s divergence from this language is improper because the very case it cites in support of its proposed addition - E.g., Riles v. Shell Exploration & Prod. Co., 298 F.3d 1302, 1312 (Fed. Cir. 2002) - is also cited by the AIPLA in the reasonable royalty section of its Model Instructions. Clearly, then, the AIPLA has taken Riles under consideration in drafting its Model Instructions and has chosen strikingly different language from Qualcomm’s proposal. Furthermore, the Federal Circuit Bar Association Model Patent Jury Instructions (February 2013) contains no “noninfringing substitute” instruction within its reasonable royalty section whatsoever and instead only addresses that topic within its lost profits section.

177 Cited without modification, along with the rest of the mutually proposed paragraph, from the Federal Circuit Bar Association Model Patent Jury Instructions § B.6 (6.6-6.7) (February 2013). ParkerVision objects to Qualcomm’s deletion of this legally correct instruction. See Georgia- Pacific Corp. v. U.S. Plywood Corp., 318 F. Supp. 1116, 1120 (S.D.N.Y. 1970).




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2. Convoyed Sales - DISPUTED




ParkerVision alleges that Qualcomm is liable for damages for sales of certain Qualcomm

chips referred to as “discrete basebands” or “baseband processor” chips. ParkerVision does not

allege that Qualcomm’s baseband processor chips infringe the patents-in-suit. Instead,

ParkerVision alleges that Qualcomm’s sales of the accused receiver or transceiver chips lead to

sales of baseband processor chips.

To find any damages for sales of the non-accused baseband processor chips,

ParkerVision must prove that the allegedly infringing feature in the accused receiver or

transceiver chips was the basis for customer demand of the baseband processor chips.180 Merely

179 ParkerVision objects to the instruction on convoyed sales because it is a misstatement of the law. See Dkt. 305 at 19-20; see Rite-Hite Corp. v. Kelley Co., 56 F.3d 1538, 1550 (Fed. Cir. 1995) (en banc); Micro Chem., Inc. v. Lextron, Inc., 317 F.3d 1387, 1393 (Fed. Cir. 2003). Georgia-Pacific Factor 6, discussed above in the agreed reasonable royalty section, explicitly provides for consideration of “the effect of selling the patented specialty in promoting sales of other products of the alleged infringer; the existing value of the invention to the patent holder as a generator of sales of its nonpatented items; and the extent of such derivative or convoyed sale.” Georgia-Pacific Corp. v. United States Plywood Corp., 318 F. Supp. 1116, 1120 (S.D.N.Y. 1970). In addition, Qualcomm’s instruction constitutes an improper commentary on the evidence.

180 See, e.g., LaserDynamics, 694 F.3d at 66-67 (“Where small elements of multi-component products are accused of infringement, calculating a royalty on the entire product carries a considerable risk that the patentee will be improperly compensated for non-infringing components of that product. Thus, it is generally required that royalties be based not on the entire product, but instead on the smallest-salable patent-practicing unit.... The entire market value rule is a narrow exception to this general rule. If it can be shown that the patented feature drives the demand for the entire multi-component product, a patentee may be awarded damages as a percentage of revenues or profits attributable to the entire product.”) (emphasis added); Lucent v. Gateway, 580 F.3d 1301, 1336 (Fed. Cir. 2009) (to prove entitlement for damages to unaccused functionality, “the patentee must prove that the patent-related feature is the basis for customer demand”).



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showing that the patented feature was valuable, important, or even essential to a commercially

viable product is not enough.181 If you find that ParkerVision did not meet this standard of

proof, you may not award any damages for convoyed sales.

3. Any Damages Award Must Be Founded on Evidence, Not Speculation - DISPUTED




A damages award must be based on sound economic proof of the nature of the market for

the claimed invention, not speculation.183 Damages must be limited to the incremental value of

any contribution of the claimed invention to the accused product.184 For example, contributions

181 E.g., LaserDynamics, 694 F.3d at 68 (“It is not enough to merely show that the disc discrimination method is viewed as valuable, important, or even essential to the use of the laptop computer. Nor is it enough to show that a laptop computer without an ODD practicing the disc discrimination method would be commercially unviable. Were this sufficient, a plethora of features of a laptop computer could be deemed to drive demand for the entire product. To name a few, a high resolution screen, responsive keyboard, fast wireless network receiver, and extended-life battery are all in a sense important or essential features to a laptop computer; take away one of these features and consumers are unlikely to select such a laptop computer in the marketplace. But proof that consumers would not want a laptop computer without such features is not tantamount to proof that any one of those features alone drives the market for laptop computers.”).

182 This instruction should be eliminated because the question of reliability of a damages model presents a Daubert issue to be resolved by the Judge, not the jury.

183 E.g., Grain Processing v. American Maize-Products Co., 185 F.3d 1341, 1350 (Fed. Cir. 1999) (“To prevent the hypothetical from lapsing into pure speculation, this court requires sound economic proof of the nature of the market and likely outcomes with infringement factored out of the economic picture.”); ResQNet.com, Inc.v. Lansa, Inc., 594 F.3d 860, 869 (Fed. Cir. 2010) (“[A] reasonable royalty analysis requires a court to hypothesize, not to speculate.”).

184 E.g., ResQNet, 594 F.3d at 869 (“At all times, the damages inquiry must concentrate on compensation for the economic harm caused by infringement of the claimed invention.... [T]he trial court must carefully tie proof of damages to the claimed invention’s footprint in the market place.”); Riles v. Shell Exploration & Prods. Co., 298 F.3d 1301, 1312 (Fed. Cir. 2002) (rejecting damages model because it “does not associate [the] proposed royalty with the value of



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from the prior art to the accused product and the accused infringer’s own efforts in designing,

manufacturing, marketing, and selling the accused product must be excluded from the damages

award.185 Damages unrelated to the claimed invention would improperly punish beyond the

reach of the patent.186

Any evidence used to assess damages must be tied to the facts and circumstances of the

hypothetical negotiation in this case.187 For example, any use of past patent license agreements

must account for the differences between the past agreements and the hypothetical negotiation in

this case.188 Potential differences between the past agreements and the hypothetical negotiation

include differences in time, availability of noninfringing alternatives, types of technology, types

of rights conveyed (such as exclusive versus non-exclusive licenses, technology transfers versus

bare patent licenses), and the number of patents involved.189 Proposed or considered royalties

the patented method at all, but with the unrelated cost of the entire Spirit platform”—“[T]he market would pay [the patentee] only for his product.”).

185 See, e.g., ResQNet, 594 F.3d at 869; Riles, 298 F.3d at 1312.

186 E.g., Uniloc USA, Inc. v. Microsoft Corp., 632 F.3d 1292 (Fed. Cir. 2011) (“Any evidence unrelated to the claimed invention does not support compensation for infringement but punishes beyond the reach of the statute.”) (internal quotation omitted).

187 E.g., Uniloc, 632 F.3d at 1317-18 (“[E]vidence purporting to apply to these [Georgia-Pacific], and any other factors, must be tied to the relevant facts and circumstances of the particular case at issue and the hypothetical negotiations that would have taken place in light of those facts and circumstances at the relevant time.”).

188 E.g., Wordtech Sys., Inc. v. Integrated Networks Solutions, 609 F.3d 1308,1320 (Fed. Cir. 2010) (“[C]omparisons of past patent licenses to the infringement must account for the technological and economic differences between them.”) (internal quotation omitted).

189 E.g., ResQNet, 594 F.3d at 870 (technology transfer re-bundling licenses found non-comparable); Lucent, 580 F.3d at 1327-32 (rejecting reliance on non-comparable agreements); ePlus, Inc. v. Lawson Software, 700 F.3d 509, 523 (Fed. Cir. 2012) (timing of agreements); Odetics v. Storage Tech. Corp., 185 F.3d 1259, 1276-77 (Fed. Cir. 1999) (same).



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that were not the basis for an agreement should be given little, if any, weight in your analysis.190

In assessing any damages, you may find that a prior agreement is so non-comparable to the

hypothetical negotiation in this case that it should play no part in the damages calculation.191

You may also find that a prior agreement is sufficiently comparable that with adjustments it may

provide useful information in reaching your damages decision.192

IV. CLOSING INSTRUCTIONS

A. Duty to Deliberate193 - AGREED

Your verdict must be unanimous – in other words, you must all agree. Your deliberations

are secret, and you’ll never have to explain your verdict to anyone.

Each of you must decide the case for yourself, but only after fully considering the

evidence with the other jurors. So you must discuss the case with one another and try to reach an

agreement. While you’re discussing the case, don’t hesitate to reexamine your own opinion and

change your mind if you become convinced that you were wrong. But don’t give up your honest

beliefs just because others think differently or because you simply want to get the case over with.

190 E.g., ResQNet, 594 F.3d at 870 (“By its terms, this [first Georgia-Pacific] factor considers only past and present licenses to the actual patent and the actual claims in litigation.”); Whitserve v. Computer Packages, 694 F.3d 10, 29 (Fed. Cir. 2012) (“We acknowledge that proposed licenses may have some value for determining a reasonable royalty in certain situations. Their evidentiary value is limited, however, by, inter alia, the fact that patentees could artificially inflate the royalty rate by making outrageous offers.”) (citing Deere & Co. v. Int'l Harvester Co., 710 F.2d 1551, 1557 (Fed.Cir.1983).)

191 E.g., ResQNet, 594 F.3d at 871 (certain non-comparable licenses “simply have no place in this case”); LaserDynamics, 694 F.3d at 80 (same).

192 E.g., Lucent, 580 F.3d at 1325, 1332 (requiring that “licenses relied upon by the patentee in proving damages [be] sufficiently comparable to the hypothetical license at issue in suit”).

193 Modeled after United States Court of Appeals Eleventh Judicial Circuit Pattern Jury Instructions (Civil Cases) 3.8.1 (2013).



74

Remember that, in a very real way, you’re judges – judges of the facts. Your only interest

is to seek the truth from the evidence in the case.

B. Election of Foreperson – Explanation of Verdict Form194 - AGREED

When you get to the jury room, choose one of your members to act as foreperson. The

foreperson will direct your deliberations and speak for you in court.

A verdict form has been prepared for your convenience.

[Insert explanation of verdict after form is finalized]

Take the verdict form with you to the jury room. When you’ve all agreed on the verdict,

your foreperson must fill in the form, sign it and date it. Then you’ll return it to the courtroom.

If you wish to communicate with me at any time, please write down your message or

question and give it to the court security officer. The court security officer will bring it to me and

I’ll respond as promptly as possible – either in writing or by talking to you in the courtroom.

Please understand that I may have to talk to the lawyers and the parties before I respond to your

question or message, so you should be patient as you await my response. But I caution you not to

tell me how many jurors have voted one way or the other at that time. That type of information

should remain in the jury room and not be shared with anyone, including me, in your note or

question.

194 Modeled after United States Court of Appeals Eleventh Judicial Circuit Pattern Jury Instructions (Civil Cases) 3.8.1 (2013).


ATTACHMENT E-1

(Plaintiff’s Proposed Jury Verdict Form)


McKool 912678v2

1


JACKSONVILLE DIVISION PARKERVISION, INC., Plaintiff, v. QUALCOMM INCORPORATED, Defendant.

Case No. 3:11-cv-719-J-37-RBD-TEM

VERDICT FORM

In answering these questions, you are to follow all of the instructions I have given you in

the Court’s Charge. Do you, the jury, find the following:

FINDINGS ON INFRINGEMENT

1. Has ParkerVision proven by a preponderance of the evidence that

Qualcomm infringes any of the following claims of the following patents?

Please answer “Yes” or “No for Each Claim.

U.S. Patent No. 6,061,551

Claim 1

Claim 2

Claim 3

Claim 8

Claim 9

Claim 12

Claim 16


McKool 912678v2

2

Claim 20

Claim 23

Claim 24

Claim 25

Claim 26

Claim 31

Claim 32

Claim 39

Claim 41

Claim 50

Claim 54

Claim 55

Claim 57

Claim 92

Claim 108

Claim 113

Claim 126

Claim 135

Claim 161

Claim 192

Claim 193

Claim 195

Claim 196

Claim 198

Claim 202


McKool 912678v2

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Claim 203


Claim 1

Claim 2

Claim 3

Claim 12

Claim 17

Claim 24

Claim 27

Claim 77

Claim 81

Claim 82

Claim 90

Claim 91


Claim 1

Claim 2

Claim 22

Claim 23

Claim 25

Claim 31


Claim 1


McKool 912678v2

4

Claim 4

Claim 5

Claim 6

Claim 9

Claim 12

Claim 13

Claim 14

Claim 15


Claim 18

Claim 19

Claim 20

Claim 21

Claim 22

Claim 23


Claim 1

Claim 3

Claim 4

Claim 5

Claim 6

Claim 7

Claim 8

Claim 9


McKool 912678v2

5

Claim 12

Claim 13

Claim 17

Claim 18

Claim 19

Claim 20

Claim 22

Claim 23

Claim 24

FINDINGS ON WILLFULNESS

NOTE: If you found at least one claim of the Patents-in-Suit infringed in Question 1,

please answer Question 2.

2. Did ParkerVision prove by clear and convincing evidence that Qualcomm’s

infringement was willful?

Please answer “Yes” or “No for Each Patent.







McKool 912678v2

6


FINDINGS ON INVALIDITY

3. Has Qualcomm proven by clear and convincing evidence that any or all of

the following asserted claims of the following patents are invalid?

Please answer “Yes” or “No for Each Claim.


Claim 1

Claim 2

Claim 3

Claim 8

Claim 9

Claim 12

Claim 16

Claim 20

Claim 23

Claim 24

Claim 25

Claim 26

Claim 31

Claim 32

Claim 39


McKool 912678v2

7

Claim 41

Claim 50

Claim 54

Claim 55

Claim 57

Claim 92

Claim 108

Claim 113

Claim 126

Claim 135

Claim 161

Claim 192

Claim 193

Claim 195

Claim 196

Claim 198

Claim 202

Claim 203


Claim 1

Claim 2

Claim 3

Claim 12

Claim 17


McKool 912678v2

8

Claim 24

Claim 27

Claim 77

Claim 81

Claim 82

Claim 90

Claim 91


Claim 1

Claim 2

Claim 22

Claim 23

Claim 25

Claim 31


Claim 1

Claim 4

Claim 5

Claim 6

Claim 9

Claim 12

Claim 13

Claim 14

Claim 15


McKool 912678v2

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Claim 18

Claim 19

Claim 20

Claim 21

Claim 22

Claim 23


Claim 1

Claim 3

Claim 4

Claim 5

Claim 6

Claim 7

Claim 8

Claim 9

Claim 12

Claim 13

Claim 17

Claim 18

Claim 19

Claim 20

Claim 22

Claim 23


McKool 912678v2

10

Claim 24

FINDINGS ON DAMAGES

NOTE: If you found at least one claim of the Patents-in-Suit infringed in Question 1 and

did not find that particular claim invalid in Question 3, then please answer Question 4.

4. What sum of money, if any, do you find from a preponderance of the evidence is

adequate to compensate ParkerVision for Qualcomm’s conduct that you found infringing?

Provide the amount, if any, in dollars and cents.

Answer: Amount $ _____________________ of reasonable royalty.

You are finished. The Jury Foreperson should sign on the space provided at the end of

this charge and then alert the Court Security Officer that you have reached a verdict.

The foregoing is the unanimous verdict of the jury.

DATED: __________________, 2013. _______________________________ Signature of Jury Foreperson


ATTACHMENT E-2, Part 1

(Defendant’s Proposed Verdict Form)


Exhibit E-2, Part 1 Qualcomm’s Proposed Verdict Form

1

UNITED STATES DISTRICT COURT THE MIDDLE DISTRICT OF FLORIDA


PARKERVISION, INC.,

Plaintiff,

v. Case No. 3:11-cv-719-J-37-TEM

QUALCOMM INCORPORATED,

Defendant.

JURY VERDICT FORM



2

We, the jury, unanimously find as follows:

I. DIRECT INFRINGEMENT

Question 1: Has ParkerVision proven that any accused Qualcomm product includes each

element or method step of any asserted claim?1

___ Yes (for ParkerVision) ___ No (for Qualcomm)

If you answer “Yes” to Question 1, proceed to Question 2; if you answer “No” to Question 1, skip to Question 3.

1 As detailed in Qualcomm’s motions in limine, ParkerVision has not preserved the issue of infringement under the doctrine of equivalents. To the extent ParkerVision is allowed to proceed under any doctrine-of-equivalents theory, Qualcomm reserves the right to ask a separate question addressing the doctrine of equivalents.



3

Question 2: If you answered “Yes” to Question 1, place an “X” in the column and row

corresponding to each accused product and asserted claim for which you found that the accused

product included each element or method step of the asserted claim.

‘551 ‘518 ‘371 ‘342

23 25 161 193 202 1 27 82 90 91 2 18

Astra

Bahama

Eagleray

GZIF3

GZIF4

Halley

Hercules

Iceman

Iris

Libra/Gemini

Magellan

Marimba

Merlin

Napoleon

Odyssey

Ramsis

Solo

Volans

Voltron

Ywing

Proceed to Question 3.



4

II. INVALIDITY

Question 3: Do you find that Qualcomm has proven that any of the asserted claims are

invalid?

Answer “Yes” or “No” for each claim.

Claim Invalidity Found?

‘551 Patent, Claim 23












Proceed to the signature page and sign and date your verdict.



5

Have the presiding juror sign and date this form. Signed: ______________________________________________ Presiding Juror Dated: _______________________________________________


ATTACHMENT E-2, Part 2

(Defendant’s Proposed Verdict Form)



1

UNITED STATES DISTRICT COURT THE MIDDLE DISTRICT OF FLORIDA


PARKERVISION, INC.,

Plaintiff,

v. Case No. 3:11-cv-719-J-37-TEM

QUALCOMM INCORPORATED,

Defendant.

JURY VERDICT FORM



2

We, the jury, unanimously find as follows:

I. INDUCEMENT

Question 1: Has ParkerVision proven that Qualcomm induced another person or

company to directly infringe any of the asserted claims?1


If you answer “Yes” to Question 1, proceed to Question 2; if you answer “No” to Question 1, skip to Question 4.

1 As detailed in Qualcomm’s motions in limine, ParkerVision has not preserved the issue of contributory infringement. To the extent ParkerVision is allowed to proceed under any contributory infringement theory, Qualcomm reserves the right to ask a separate question addressing contributory infringement.



3


corresponding to each accused product and asserted claim for which you found inducement.

‘551 ‘518 ‘371 ‘342

23 25 161 193 202 1 27 82 90 91 2 18

Astra

Bahama

Eagleray

GZIF3

GZIF4

Halley

Hercules

Iceman

Iris

Libra/Gemini

Magellan

Marimba

Merlin

Napoleon

Odyssey

Ramsis

Solo

Volans

Voltron

Ywing




4

Question 3: In the corresponding column and row for each claim and accused product

for which you found inducement in Question 2, write the first date for which ParkerVision

proved either of the following:

(A) Qualcomm knew of the patent claim, knew that the acts, if taken by the third-party,

would constitute infringement of that claim, and knew that the claim was valid; or

(B) Qualcomm believed there was a high probability that the acts, if taken, would

constitute infringement of the claim and that the claim was valid but deliberately avoided

confirming those beliefs.

‘551 ‘518 ‘371 ‘342

23 25 161 193 202 1 27 82 90 91 2 18

Astra

Bahama

Eagleray

GZIF3

GZIF4

Halley

Hercules

Iceman

Iris

Libra/Gemini

Magellan

Marimba

Merlin

Napoleon

Odyssey

Ramsis

Solo

Volans

Voltron

Ywing




5

II. DAMAGES

A. Damages for Direct Infringement

[If the jury found infringement by any products shipped by Qualcomm into the United

States, include the following question in the verdict form]

Question 4: What is the total dollar amount of damages that ParkerVision has proven for

any direct infringement by Qualcomm?

$ ________________

If you found that Qualcomm induced the infringement of at least one asserted claim,

proceed to Question 5. Otherwise, skip to Question 6.



6

B. Damages for Inducement

Question 5: What is the total dollar amount of damages that ParkerVision has proven for

any induced infringement by Qualcomm?

$ ________________




7

C. Damages by Product

Question 6: For the damages found above, provide the dollar breakdown by product.

Accused Product Design Damages Amount RGR6240 Astra WCN2243 Bahama FTR8700 Eagleray RTR6275 GZIF3 RTR6236 GZIF4 RTR6237 GZIF4 RTR6280 GZIF4 RTR6285 GZIF4 RTR6285A GZIF4 MXU6219 GZIF4 RGR1000 GZIF4 RGR1100 GZIF4 QTR9215 Halley RTR8700 Hercules RTR9605 Iceman WCN3660 Iris WCN1312 Libra/Gemini MDM6200 Magellan MDM6600 Magellan QSC6155 Magellan; Marimba QSC6165 Magellan; Marimba QSC6175 Magellan; Marimba QSC6185 Magellan; Marimba QSC6195 Magellan; Marimba QSC6295 Magellan; Marimba QSC6695 Magellan; Marimba QTR8200 Magellan; Marimba QTR8201 Magellan; Marimba QTR8215 Magellan QTR8600 Magellan; Marimba QTR8600L Magellan; Marimba QTR8601 Magellan; Marimba QTR8615 Magellan



8

Accused Product Design Damages Amount QTR8615L Magellan RTR8201 Magellan RTR8600 Magellan RTR8601 Magellan RTR8605 Magellan QSC1105 Merlin QSC1100 Napoleon QSC1110 Napoleon WTR1605 Odyssey WTR1605L Odyssey QSC6055 Ramsis QSC6065 Ramsis QSC6075 Ramsis QSC6085 Ramsis MDM6085 Ramsis QSC6240 Solo ESC6240 Solo MDM6270 Solo ESC6270 Solo QSC6270 Solo WCN1314 Volans RTR6500 Voltron MXC6369 Voltron WCN1320 Ywing




9

III. WILLFUL INFRINGEMENT

Question 7: If you found one or more of the asserted claims to be valid and infringed by

Qualcomm, has ParkerVision proven that Qualcomm’s infringement was willful?


If you answer “Yes” to Question 7, proceed to Question 8; if you answer “No” to Question 7, proceed to the signature page and sign and date your verdict.



10


corresponding to each accused product and asserted claim for which you found willful

infringement.

‘551 ‘518 ‘371 ‘342

23 25 161 193 202 1 27 82 90 91 2 18

Astra

Bahama

Eagleray

GZIF3

GZIF4

Halley

Hercules

Iceman

Iris

Libra/Gemini

Magellan

Marimba

Merlin

Napoleon

Odyssey

Ramsis

Solo

Volans

Voltron

Ywing




11

Question 9: In the corresponding column and row for each claim and accused product

for which you found willful infringement in Question 8, write the first date on which you find

that ParkerVision proved:

Qualcomm was aware of ParkerVision’s patent;

Qualcomm acted despite an objectively high likelihood that its actions infringed a valid

patent, and

Qualcomm either knew or should have known of the objectively high likelihood of

infringement and validity.

‘551 ‘518 ‘371 ‘342

23 25 161 193 202 1 27 82 90 91 2 18

Astra

Bahama

Eagleray

GZIF3

GZIF4

Halley

Hercules

Iceman

Iris

Libra/Gemini

Magellan

Marimba

Merlin

Napoleon

Odyssey

Ramsis

Solo

Volans

Voltron

Ywing



12

Proceed to the signature page and sign and date your verdict.



13

Have the presiding juror sign and date this form.

Signed: ______________________________________________ Presiding Juror Dated: _______________________________________________


ATTACHMENT F

(Joint Proposed Voir Dire Questions)


Exhibit F Joint Voir Dire

1 McKool 923021v2

ParkerVision and Qualcomm propose the following questions be asked to the jury.

Objections to individual questions by either party are noted at the beginning of the question. To

the extent the jurors respond affirmatively to any of the questions, the parties request that the

Court ask appropriate follow-up questions, doing so at side-bar where necessary. For some of

the proposed questions, the parties have proposed follow-up questions, which have been listed as

sub-parts to the numbered questions.

Relationship to attorneys, parties, and relevant third-parties:

1. Do any of you have any personal knowledge of this case, or have you read or heard it discussed?

a. If so, what do you know or what have you heard about this matter?

b. Where did you obtain your knowledge in this case?

2. Have any of your formed or expressed any opinions about this case?

a. If so, what are the opinions, feelings, or bias that you have formed?

b. When did your opinions or feelings form?

c. In light of your feelings, could you be a fair and impartial juror if selected in this case?

3. You have been given a list of the attorneys and law firms involved in this litigation. Are you related to, personally acquainted with, or have an awareness of any of the lawyers or law firms in this case?

a. Do you know any lawyers practicing at the law firms involved in this case?

b. To the best of your knowledge, have you, your employer, any member of your immediate family, or anyone close to you ever been represented by any of those lawyers or their law firms?

4. You have been given a list of companies. Are you familiar with or knowledgeable about any of these companies?

a. Have you, a family member, or close friend ever worked for any of these companies?

b. Are you, a family member, or close friend acquainted with any current or former employee or officer of any of these companies?



2 McKool 923021v2

c. Have you, a family member, or close friend ever owned any stocks or bonds in any of these companies?

d. Have you, a family member, or close friend purchased or had experience with a product from these companies?

e. Do you have any strong negative or positive opinions towards any of these companies?

5. You have been given a list of the individuals who might appear as witnesses in this case. Have you ever heard of any of these individuals?

a. Do you have any opinions or feelings about any of these individuals that would prevent you from being a fair and impartial juror?

Background:

6. Have any of you or any member of your family worked in the legal profession or had any legal training?

a. If so, what was the nature and extent of your experience with the legal profession?

7. Does anyone here have any education or training in engineering or science other than high school science?

a. Do you or any member of your immediate family have any specialized knowledge of radio frequency technology or the cellular telephone industry?

8. Have any of you worked for a company that designed or sold cell phones or other wireless devices?

9. Do you own or have you owned a cell phone?

10. Do you own or have you owned a smart phone?

Experience with and opinions about patents and IP:

11. Do you, a family member, or close friend have knowledge about or experience with patents?

a. Have you, any member of your immediate family, or anyone close ever applied for or obtained a patent in the United States or abroad?

b. If you have a patent, what is the subject matter?

c. Have you, any member of your immediate family, or anyone close to you ever had any dealings with the United States Patent and Trademark Office?



3 McKool 923021v2

d. Do you have any opinions about the U.S. Patent and Trademark Office?

12. Does anyone have strong opinions about the United States Patent system?

13. Have any of you been involved in the development of a new product or process?

a. Did you consider obtaining a patent?

b. Why or why not?

14. Have you ever been involved in a dispute over an invention or a patent?

a. If so, what was the nature of the dispute?

b. Have you or someone close to you been accused of infringing a patent? Please explain the details.

15. Does anyone here have any strong opinions about whether the Patent and Trademark Office usually makes the right or wrong decision in granting patents?

16. [OBJECTED TO BY QUALCOMM] A patent gives an inventor the right to exclude or prevent others from making, using or selling the invention claimed in a patent for a set of time. Is there anyone who feels for any reason that inventors should not be allowed to exclude or prevent others from making, using, or selling their inventions, no matter how helpful the invention may be?

17. [OBJECTED TO BY QUALCOMM] The Defendants in this case will claim that ParkerVision’s patents are invalid. Judge Dalton will tell you that to prove that the patents are invalid, you have to prove that by a higher burden of proof than normal. Is there any one who feels like that’s not fair that the Defendants should have a higher burden of proving the patent invalid?

Experience with and opinions about U.S. legal system:

18. Have any of you been a party or a witness in a lawsuit?

a. What was the case about?

b. Did anything occur during the lawsuit that caused you to be dissatisfied with the courts or our system of justice?

19. Have any of you served as a juror before?

a. Was there anything about that experience which would cause you to lean in favor of the plaintiff or defendant in this case?

20. Does anyone have any strong negative or positive opinions about government agencies?



4 McKool 923021v2

21. Do you have any strong negative or positive feelings regarding a company that files a lawsuit?

a. Do you agree that it is okay for someone to bring a lawsuit to collect money damages?

b. Do you believe that a company should not file a lawsuit even if it has been wronged?

22. Do you have any strong negative or positive feelings regarding a company that has a lawsuit filed against them?

23. [OBJECTED TO BY QUALCOMM] ParkerVision has asked for damages of almost $500 million. Does anyone feel that that there is no way any patent could be worth that much money?

Ability to serve:

24. Are you able to read, write and understand English fluently?

25. Do any of you have a financial interest in the outcome of this case?

26. Does anyone have any strong negative or positive opinions about large or small corporations?

27. Does the length of this trial or the schedule contemplated by the court present a special problem to any member of the panel?

28. Do any of you have any moral or religious reason why you would feel uncomfortable to serve on a jury?

29. This case will involve testimony from people who because of education, training, or experience may be allowed to testify as expert witnesses. Are any of you more inclined to believe an expert witness than another kind of witness, such as a fact witness who has been involved with the companies involved in this case?

30. Do any of you know any other members of the jury panel?

31. Do any of you know His Honor Judge Roy Dalton?

32. Does any member of the jury have any health problems, such as problems with vision or hearing, which might affect his or her ability to serve as a juror?

33. You have been given a list of subject areas. Is anyone unwilling or uncomfortable to serve as a juror considering such technology?

34. Are you aware of any strong feelings, bias, or prejudice that you may have about this case, any of the parties, or their lawyers?



5 McKool 923021v2

35. If you are selected to sit on this case, is there any reason you would be unable to render a verdict based solely on the evidence presented at the trial and in the context of the law as I will give it to you in my instructions, disregarding any other ideas, notions or beliefs about the law you may have or that you may have encountered in reaching your verdict?



6 McKool 923021v2

Law Firms/Lawyers Law Firms McKool Smith, PC Allen, Dyer, Doppelt, Milbrath & Gilchrist, PA Smith, Hulsey & Busey Cooley LLP Cravath, Swaine & Moore, LLP Cadwalader, Wickersham & Taft, LLP Bedell, Dittmar, DeVault, Pillans & Coxe, PA Goodwin Proctor, LLP MoloLamken LLP Law Office of James T. Bailey Lawyers Ava K. Doppelt Brian R. Gilchrist Douglas Aaron Cawley Ivan Wang James Arthur Bolling Jeffrey Scott Boyles Joshua W. Budwin Kevin L. Burgess Leah Buratti Mario A. Apreotesi Richard Kamprath James Quigley Kevin Kneupper Stephen D. Busey Travis Gordon White Aaron I. Karp Andrei Harasymiak Christopher A. Hughes Courtney Kneece Grimm David Greenwald Howard Wizenfeld James Timothy Bailey James E. Canning Jeffrey Alan Lamken John Andrew DeVault , III John Moehringer John M. Whealan Joseph Everett Lasher Keith R. Hummel Kurt M. Kjelland



7 McKool 923021v2

Nicole S. Cunningham Peter A. Emmi Richard William Thill Robert Pollaro Stephen C. Neal Steven Arthur Moore Timothy S. Teter Ben Damstedt Jeffrey Karr



8 McKool 923021v2

Companies ParkerVision, Inc. Qualcomm Incorporated VIA Telecom Symbol Technologies HTC Nokia Motorola Samsung Berkana



9 McKool 923021v2

Subject Matter Integrated Circuits Radio Frequency (“RF”) Technology, Including Receiver, Transmitter, and Downconversion Electrical Circuit Design Cellular/Mobile Telephones Wi-Fi Bluetooth
