`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE DISTRTICT OF DELAWARE
`
`VLSI TECHNOLOGY LLC,
`
`Plaintiff,
`
`Civil Action No. 18-966-CFC-CJB
`
`
`
`v.
`
`INTEL CORPORATION,
`
`Defendant.
`
`VLSI’S SECOND NOTICE OF SUBSEQUENT DEVELOPMENTS IN
`CONNECTION WITH
`INTEL’S LICENSE DEFENSE
`
`Plaintiff VLSI Technology LLC respectfully submits this second notice of
`
`subsequent developments relating to the cross-motions for summary judgment on Intel’s
`
`license defense. D.I. 804 (“VLSI’s License Motion”); D.I. 799 (“Intel’s Cross-Motion”).
`
`On April 21, 2022, the Texas Court entered Final Judgment in favor of VLSI and
`
`against Intel in Case No. 6:21-CV-057-ADA (W.D. Tex.). A copy of the Final Judgment is
`
`attached as Exhibit 1. As explained in VLSI’s License Motion, now that Final Judgment has
`
`been entered in Texas, Intel’s license defense is plainly barred by res judicata. This is
`
`especially true here because prior to entering Final Judgment, the Texas Court specifically
`
`found that Intel’s license defense lacks merit. See D.I. 955.
`
`Dated: April 21, 2022
`
`Respectfully submitted,
`
`FARNAN LLP
`
`/s/ Brian E. Farnan
`Brian E. Farnan (Bar No. 4089)
`Michael J. Farnan (Bar No. 5165)
`919 N. Market St., 12th Floor
`Wilmington, DE 19801
`Telephone: (302) 777-0300
`
`
`
`Case 1:18-cv-00966-CFC-CJB Document 966 Filed 05/12/22 Page 2 of 2 PageID #: 37822
`
`Fax: (302) 777-0301
`bfarnan@farnanlaw.com
`mfarnan@farnanlaw.com
`
`Morgan Chu (admitted pro hac vice)
`Ben Hattenbach (admitted pro hac vice)
`Iian D. Jablon (admitted pro hac vice)
`Christopher Abernethy (admitted pro hac vice)
`Amy E. Proctor (admitted pro hac vice)
`Dominik Slusarczyk (admitted pro hac vice)
`S. Adina Stohl (admitted pro hac vice)
`Charlotte J. Wen (admitted pro hac vice)
`IRELL & MANELLA LLP
`1800 Avenue of the Stars, Suite 900
`Los Angeles, California 90067
`Telephone: (310) 277-1010
`Facsimile: (310) 203-7199
`mchu@irell.com
`bhattenbach@irell.com
`ijablon@irell.com
`cabernethy@irell.com
`aproctor@irell.com
`dslusarczyk@irell.com
`astohl@irell.com
`cwen@irell.com
`Attorneys for VLSI Technology LLC
`
`- 2 -
`
`
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