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`UNITED STATES INTERNATIONAL TRADE COMMISSION
`WASHINGTON, D.C.
`
`Before the Honorable David P. Shaw
`Administrative Law Judge
`
`
`In the Matter of
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`CERTAIN UMTS AND LTE CELLULAR
`COMMUNICATIONS MODULES AND
`PRODUCTS CONTAINING THE SAME
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`Investigation No. 337-TA-1240
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`PRIVATE PARTIES’ REQUEST FOR
`RECEIPT OF EVIDENCE WITHOUT A SPONSORING WITNESS
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` Complainants Koninklijke Philips N.V. and Philips North America, LLC (collectively,
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`“Philips”) and Thales DIS AIS USA, LLC, Thales DIS AIS Deutschland GmbH, Thales USA,
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`Inc., and Thales S.A. (collectively, “Thales”), Telit Wireless Solutions, Inc. and Telit
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`Communications PLC (collectively, “Telit”), Quectel Wireless Solutions Co., Ltd. (“Quectel”),
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`CalAmp Corp. (“CalAmp”), Xirgo Technologies, LLC (“Xirgo”), Laird Connectivity, Inc.
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`(“LCI”) (collectively, “Respondents”) respectfully submit this request for the receipt of evidence
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`without a sponsoring witness (“Request”). Complainants and Respondents (“the Parties”)
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`request that certain documents currently listed on the Joint Exhibit List, Complainants’ Exhibit
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`List, and Respondents’ Exhibit List be received into evidence without sponsoring witnesses. A
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`listing of the exhibits is provided herein, and copies of the exhibits will be submitted
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`electronically to the ALJ due to the voluminous nature of the exhibits.1 The exhibits fall into the
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`following general categories:
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`(I)
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`(II)
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`Patents-in-suit, file histories and assignments
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`Parties’ discovery responses
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`(III) Pleadings from this Investigation
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`(IV) Pleadings from other litigation between the Parties
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`(V) Correspondence between the Parties related to the patents-in-suit
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`(VI) Deposition Designations (subject to HPOs and MILs)
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`Commission Rule 210.37 provides that “[r]elevant, material, and reliable evidence shall
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`be admitted” into the record. 19 C.F.R. § 210.37. Good cause exists to admit these exhibits as
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`evidence and into the record as they are relevant, material, reliable and non-controversial. The
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`1 The Parties are set to exchange exhibits on August 20, 2021 and will provide a copy of each
`exhibit mentioned herein to the ALJ via Box by August 23, 2021.
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`337-TA-1240
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`1
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`Parties’ Request for Receipt of Evidence
`Without a Sponsoring Witness
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`

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`Parties make this Request in order to streamline the hearing and avoid the cumbersome and
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`inefficient process of requiring a witness to identify and authenticate various non-controversial
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`exhibits, and subsequently to move these exhibits into evidence on a piecemeal basis. Each of
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`the proposed exhibits that is the subject of this Request is a true and accurate copy.
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`Pursuant to the Second Amended Scheduling Order (Order No. 7), the deadline for
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`submission of motions for receipt of evidence without a sponsoring witness was August 19,
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`2021. The Parties respectfully request that this current motion be granted, despite being filed one
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`day out of time. Good cause exists to grant this motion out of time because the Parties have been
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`working together to narrow the disputes and submit this motion jointly.
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`OUII was consulted about this motion and does not oppose.
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`Accordingly, for the reasons stated below, the Parties respectfully request that the
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`exhibits identified in this Request be received into evidence at the hearing without sponsoring
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`witnesses.
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`I.
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`Patents-in-suit, File Histories and Assignments
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`Philips submits that copies of the patents-in-suit and related provisional applications, in
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`addition to their certified file histories and certified assignment records, should be received at the
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`hearing without a sponsoring witness. The exhibit numbers for these documents are identified in
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`the chart below.
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`These documents are non-controversial and are appropriate for receipt into evidence
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`because they are relevant, material, and reliable. The documents are relevant, material, and of
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`importance to issues being litigated in this Investigation, including infringement, domestic
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`industry and validity, and the receipt of these documents benefits all Parties to this Investigation.
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`337-TA-1240
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`2
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`Parties’ Request for Receipt of Evidence
`Without a Sponsoring Witness
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`

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`The reliability of the documents is further demonstrated by the self-authenticating nature of the
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`documents as records from the U.S. Patent and Trademark Office and the fact that Respondents
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`likewise seek the introduction of many of the same documents into the record without a
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`sponsoring witness. Permitting introduction of these documents without a sponsoring witness
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`will conserve both time and resources at the hearing.
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`Respondents indicated that they do not oppose the admission of the exhibits included in
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`Category I of this request without a sponsoring witness. Accordingly, Philips requests that the
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`following exhibits be received into evidence:
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`Exhibit No.
`JX-0001
`JX-0002
`JX-0003
`JX-0004
`JX-0005
`JX-0006
`JX-0007
`JX-0008
`JX-0009
`JX-0010
`JX-0012
`JX-0011
`
`Description
`U.S. Patent No. 7,944,935
`U.S. Patent No. 7,554,943
`U.S. Patent No. 8,199,711
`U.S. Patent No. 7,831,271
`Certified File History for U.S. Patent No. 7,944,935
`Certified File History for U.S. Patent No. 7,554,943
`Certified File History for U.S. Patent No. 7,831,711
`Certified File History for U.S. Patent No. 8,199,271
`Certified Assignment History for U.S. Patent No. 7,944,935
`Certified Assignment History for U.S. Patent No. 7,554,943
`Certified Assignment History for U.S. Patent No. 7,831,711
`Certified Assignment History for U.S. Patent No. 8,199,271
`
`II.
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`Parties’ Discovery Responses
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`The Parties’ responses to various interrogatories and requests for admission are
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`appropriate for receipt into evidence without a sponsoring witness because they are relevant,
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`material, and reliable. In particular, these exhibits are relevant to issues in this Investigation,
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`including infringement, importation, and remedy. Moreover, the Parties’ discovery responses
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`337-TA-1240
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`3
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`Parties’ Request for Receipt of Evidence
`Without a Sponsoring Witness
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`

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`are authentic as they were signed by counsel, verified by the party and constitute admissions of a
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`party-opponent.
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`Accordingly, the Parties request that the following exhibits be received into evidence:
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`Exhibit No.
`CX-0428C
`CX-0429
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`CX-0430C
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`CX-0432C
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`CX-0433C
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`CX-0434C
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`CX-0437C
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`CX-0435
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`CX-0431C
`CX-0436C
`CX-0420C
`CX-0421
`CX-0422
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`CX-0423C
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`CX-0425
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`CX-0426
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`CX-0424C
`CX-0427
`CX-0408
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`Description
`Thales’ Response to Philips’ First Set of Interrogatories
`Thales’ Supplemental Response to Philips’ First Set of Interrogatories
`(filed 3/22)
`Thales’ Supplemental Response to Philips’ First Set of Interrogatories
`(filed 4/15)
`Thales’ Second Supplemental Response to Philips’ First Set of
`Interrogatories
`Thales’ Supplemental Response to Philips’ First Set of Interrogatories
`(filed 5/27)
`Thales’ Supplemental Response to Philips’ First Set of Interrogatories
`(filed 6/10)
`Thales’ Supplemental Response to Philips’ First Set of Interrogatories
`(Nos. 3, 13, 41, 42, 48, 49, 54, 55) (filed 6/22)
`Thales’ Amended Supplemental Response to Philips’ First Set of
`Interrogatories (Nos. 13, 39)
`Thales’ Response to Philips’ Second Set of Interrogatories
`Thales’ Response to Philips’ Third Set of Interrogatories
`Telit’s Response to Philips’ First Set of Interrogatories
`Telit’s First Supplement Response to Philips’ First Set of Interrogatories
`Telit’s Second Supplement Response to Philips’ First Set of
`Interrogatories
`Telit’s Amended and Third Supplement Response to Philips’ First Set
`of Interrogatories
`Telit’s Fourth Supplement Response to Philips’ First Set of
`Interrogatories
`Telit’s Fifth Supplement Response to Philips’ First Set of
`Interrogatories
`Telit’s Response to Philips’ Second Set of Interrogatories
`Telit’s Response to Philips’ Third Set of Interrogatories
`Quectel’s Response to Philips’ First Set of Interrogatories
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`337-TA-1240
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`4
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`Parties’ Request for Receipt of Evidence
`Without a Sponsoring Witness
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`

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`Exhibit No.
`CX-0409C
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`CX-0410C
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`CX-0411C
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`CX-0086C
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`CX-0413C
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`CX-0414
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`CX-0415C
`CX-0416C
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`CX-0417C
`CX-0418C
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`CX-0419C
`CX-0395
`CX-563
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`CX-0396C
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`CX-0397C
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`CX-0102C
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`CX-0399
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`CX-0400C
`CX-0438
`CX-0439
`CX-0440C
`CX-0401C
`CX-0402C
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`Description
`Quectel’s First Supplemental Response to Philips’ First Set of
`Interrogatories
`Quectel’s Second Supplemental Response to Philips’ First Set of
`Interrogatories (Nos. 28, 31-33, 40)
`Quectel’s Third Supplemental Response to Philips’ First Set of
`Interrogatories (Nos. 2, 16-28, 40)
`Quectel’s Fourth Supplemental Response to Philips’ First Set of
`Interrogatories (Nos. 6, 12, 13, 28, 39, & 40)
`Quectel’s Fifth Supplemental Response to Philips’ First Set of
`Interrogatories (Nos. 4, 5, 7, 11, 16-27, 35, 40) (filed 6/10)
`Quectel’s Fifth Supplemental Response to Philips’ First Set of
`Interrogatories (Nos. 2, 6, 8, 9, 12, 13, 16-28, 36-38, 40) (filed 6/14)
`Quectel’s Response to Philips’ Second Set of Interrogatories
`Quectel’s Supplemental Response to Philips’ Second Set of
`Interrogatories
`Quectel’s Response to Philips’ Third Set of Interrogatories
`Quectel’s Supplemental Response to Philips’ Third Set of
`Interrogatories
`Quectel’s Response to Philips’ Fourth Set of Interrogatories
`CalAmp’s Response to Philips’ First Set of Interrogatories
`CalAmp’s First Supplemental Response to Philips’ First Set of
`Interrogatories (Nos. 39 & 47)
`CalAmp’s First Supplemental Response to Philips’ First Set of
`Interrogatories (filed 3/22)
`CalAmp’s First Supplemental Response to Philips’ First Set of
`Interrogatories (Nos. 27-38, 40-43) (filed 4/15)
`CalAmp’s Final Supplemental Response to Philips’ First Set of
`Interrogatories (Nos. 39 and 47)
`CalAmp’s Final Supplemental Response to Philips’ First Set of
`Interrogatories (Nos. 27-38, 40-43)
`CalAmp’s Response to Philips’ Second Set of Interrogatories
`Xirgo’s Response to Philips’ First Set of Interrogatories
`Xirgo’s First Amended Response to Philips’ First Set of Interrogatories
`Xirgo’s Response to Philips’ Second Set of Interrogatories
`LCI’s Response to Philips’ First Set of Interrogatories
`LCI’s Amended Response to Philips’ First Set of Interrogatories
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`337-TA-1240
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`5
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`Parties’ Request for Receipt of Evidence
`Without a Sponsoring Witness
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`

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`Exhibit No.
`CX-0403
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`CX-0404
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`CX-0405
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`CX-0406
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`CX-0407C
`CX-0390C
`CX-0391
`CX-0388
`CX-0389
`CX-0386
`CX-0387
`CX-0382
`CX-0383C
`CX-0392
`CX-0393
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`CX-0394
`CX-0384C
`CX-0385
`RX-0034C
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`RX-0113C
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`RX-0119
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`RX-0120
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`RX-0121C
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`RX-0122C
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`Description
`LCI’s Supplemental Response to Philips’ First Set of Interrogatories
`(No. 33)
`LCI’s Supplemental Response to Philips’ First Set of Interrogatories
`(Nos. 21-32)
`LCI’s Second Supplemental Response to Philips’ First Set of
`Interrogatories (No. 33)
`LCI’s Supplemental Response to Philips’ First Set of Interrogatories
`(filed 6/10)
`LCI’s Response to Philips’ Second Set of Interrogatories
`Thales’ Response to Philips’ First Requests for Admission
`Thales’ Response to Philips’ Second Requests for Admission
`Telit’s Response to Philips’ First Requests for Admission
`Telit’s Response to Philips’ Second Requests for Admission
`Quectel’s Response to Philips’ First Requests for Admission
`Quectel’s Response to Philips’ Second Requests for Admission
`CalAmp’s Response to Philips’ First Requests for Admission
`CalAmp’s Response to Philips’ Second Requests for Admission
`Xirgo’s Response to Philips’ First Requests for Admission
`Xirgo’s First Amended Response to Philips’ First Requests for
`Admission
`Xirgo’s Response to Philips’ Second Requests for Admission
`LCI’s Response to Philips’ First Requests for Admission
`LCI’s Response to Philips’ Second Requests for Admission
`Complainants’ Fifth Supplemental Responses and Objections to
`Respondents’ First Set of Common Interrogatories (Excerpt) (Bowen
`Depo. Ex. D)
`Complainants’ Fifth Supplemental Responses and Objections to
`Respondents’ First Set of Common Interrogatories (Slater Depo. Ex. 5)
`Complainants’ Responses to Respondents’ First Set of Common
`Interrogatories
`Complainants’ Corrected First Supplemental Responses to
`Respondents’ First Set of Common Interrogatories
`Complainants’ Corrected Second Supplemental Responses to
`Respondents’ First Set of Common Interrogatories
`Complainants’ Corrected Third Supplemental Responses to
`Respondents’ First Set of Common Interrogatories
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`337-TA-1240
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`6
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`Parties’ Request for Receipt of Evidence
`Without a Sponsoring Witness
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`

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`Exhibit No.
`RX-0123C
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`RX-0124C
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`RX-1974
`RX-2581C
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`RX-2618C
`RX-0125
`RX-0126
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`RX-0127C
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`RX-0128C
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`RX-0129
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`RX-0130
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`RX-0131
`RX-0132C
`RX-0133C
`
`RX-0134
`RX-0135
`RX-0136C
`RX-0137C
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`RX-2578C
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`RX-2579C
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`RX-2580C
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`RX-2620C
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`Description
`Complainants’ Fourth Supplemental Responses to Respondents’ First
`Set of Common Interrogatories
`Complainants’ Seventh Supplemental Responses to Respondents’ First
`Set of Common Interrogatories
`Complainants’ Initial Infringement Contentions, Exhibit C
`Philips Sixth Supplemental Responses and Objections to Respondents’
`First Set of Common Interrogatories
`Philips’ Infringement Contentions
`Complainants’ Responses to Thales Interrogatories (Nos. 61-72)
`Complainants’ Supplemental Responses to Thales’ First Set of
`Interrogatories (No. 66)
`Complainants’ Corrected First Supplemental Responses and Objections
`to Thales’ First Set of Interrogatories (Nos. 61-72)
`Complainants’ Second Supplemental Responses and Objections to
`Thales’ First Set of Interrogatories (Nos. 61-72)
`Complainants’ Third Supplemental Responses and Objections to
`Thales’ First Set of Interrogatories (Nos. 61-72)
`Complainants’ Response to Thales’ Second Set of Interrogatories (No.
`73)
`Complainants’ Response to Thales’ Third Set of Interrogatories
`Complainants’ Responses to Thales’ Fourth Set of Interrogatories
`Complainants’ First Supplemental Responses to Thales’ Fourth Set of
`Interrogatories
`Complainants’ Responses to Thales’ Fifth Set of Interrogatories
`Complainants’ Responses to Thales’ Sixth Set of Interrogatories
`Complainants’ Responses to Thales’ Seventh Set of Interrogatories
`Complainants’ Corrected First Supplemental Responses to Thales’
`Seventh Set of Interrogatories
`Quectel’s Third Supplemental Responses to Complainants’ First Set of
`Interrogatories
`Quectel’s Fourth Supplemental Responses to Complainants’ First Set of
`Interrogatories
`Quectel’s Fifth Supplemental Responses to Complainants’ First Set of
`Interrogatories
`Quectel’s Fifth Supplemental Responses to Complainants’ First Set of
`Interrogatories
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`337-TA-1240
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`7
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`Parties’ Request for Receipt of Evidence
`Without a Sponsoring Witness
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`

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`Exhibit No.
`RX-2622C
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`RX-2623C
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`RX-2624C
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`RX-2625C
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`RX-2626
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`RX-2627
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`RX-2656C
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`RX-2657
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`RX-2658C
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`RX-2659C
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`RX-2660C
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`RX-2661C
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`RX-2662C
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`RX-2663C
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`RX-2664
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`RX-2665
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`RX-2666C
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`RX-2667
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`Description
`Philips Responses and Objections to Quectel’s First Set of
`Interrogatories
`Philips Corrected First Supplemental Responses and Objections to
`Quectel’s First Set of Interrogatories
`Philips Third Supplemental Responses and Objections to Quectel’s First
`Set of Interrogatories
`Philips Responses and Objections to Quectel’s Third Set of
`Interrogatories
`Philips Responses and Objections to Quectel’s First Set of Requests for
`Admission
`Philips Responses and Objections to Quectel’s Second Set of Requests
`for Admission
`Complainants’ May 14, 2021 Responses to LCI’s First Set of ROGs
`(Nos. 1-7)
`Complainants’ May 20, 2021 First Supplemental Responses to LCI’s
`First Set of ROGs
`Complainants’ June 11, 2021 Second Supplemental Responses to LCI’s
`First Set of ROGs
`Exhibit 1 to Complainants’ June 11, 2021 Second Supplemental
`Responses to LCI’s First Set of ROGs
`Exhibit 2 to Complainants’ June 11, 2021 Second Supplemental
`Responses to LCI’s First Set of ROGs
`Exhibit 3 to Complainants’ June 11, 2021 Second Supplemental
`Responses to LCI’s First Set of ROGs
`LCI’s February 22, 2021 Responses to Complainants’ First Set of ROGs
`(Nos. 1-41)
`LCI’s March 10, 2021 Amended Answers to Complainants’ First Set of
`ROGs (Nos. 1-41)
`LCI’s March 22, 2021 Supplemental Answer to Complainants’ ROG
`No. 33
`LCI’s April 15, 2021 Supplemental Answers to Complainants’ ROG
`Nos. 21-32
`LCI’s May 19, 2021 Objections and Responses to Complainants’ First
`Set of RFAs (Nos. 1-8)
`LCI’s May 20, 2021 Second Supplemental Response to Complainants’
`ROG No. 33
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`337-TA-1240
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`8
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`Parties’ Request for Receipt of Evidence
`Without a Sponsoring Witness
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`

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`Exhibit No.
`RX-2668C
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`RX-2669
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`RX-2670C
`
`RX-3202
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`RX-3203
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`RX-3204
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`RX-3205C
`RX-3206
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`RX-3207
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`RX-2677
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`RX-2678C
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`RX-2679C
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`RX-2680C
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`RX-2681C
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`RX-2682
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`RX-2683
`
`Description
`LCI’s June 10, 2021 Supplemental Objections and Responses to
`Complainants’ ROG Nos. 1-2, 5-7, 12-15, 17-18, 20-32, and 38-41
`LCI’s June 14, 2021 Objections and Responses to Complainants’
`Second Set of RFAs (Nos. 9-32)
`LCI’s June 14, 2021 Objections and Responses to Complainants’
`Second Set of ROGs (Nos. 42-43)
`Complainants’ Responses to CalAmp’s First Set of Interrogatories (Nos.
`1-13)
`Philips’ First Supplemental Responses to CalAmp’s First Interrogatories
`(with Exhibits)
`Philips’ Second Supplemental Responses to CalAmp’s First
`Interrogatories (3-9)
`Philips’ Response to CalAmp’s Second Interrogatories
`Philips’ Second Supplemental Responses to CalAmp’s First
`Interrogatories
`Philips’ Third Supplemental Responses to CalAmp’s First
`Interrogatories
`Complainant’s Responses and Objections to Respondent Telit Wireless
`Solutions, Inc. and Telit Communications PLC’s First Set of
`Interrogatories
`Complainant’s Updated First Supplemental Responses and Objections
`to Respondent Telit Wireless Solutions, Inc. and Telit Communications
`PLC’s First Set of Interrogatories
`Complainant’s Second Supplemental Responses and Objections to
`Respondent Telit Wireless Solutions, Inc. and Telit Communications
`PLC’s First Set of Interrogatories
`Complainant’s Third Supplemental Responses and Objections to Telit’s
`First Set of Interrogatories
`Complainant’s First Supplemental Responses and Objections to
`Respondent Telit Wireless Solutions, Inc. and Telit Communications
`PLC’s First Set of Interrogatories
`Complainant’s Responses and Objections to Respondent Telit Wireless
`Solutions, Inc. and Telit Communications PLC’s Second Set of
`Interrogatories
`Complainant’s Responses and Objections to Respondents Telit Wireless
`Solutions, Inc. and Telit Communications PLC’s Third Set of
`Interrogatories
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`337-TA-1240
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`9
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`Parties’ Request for Receipt of Evidence
`Without a Sponsoring Witness
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`

`

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`Exhibit No.
`RX-2684C
`
`RX-2685
`
`RX-2686C
`
`RX-3145
`
`Description
`Complainant’s Fourth Supplemental Responses and Objections to
`Telit’s First Set of Interrogatories
`Complainant’s Corrected Responses and Objections to Telit’s First Set
`of Requests for Admissions
`Complainant’s Responses and Objections to Respondents Telit’s Fourth
`Set of Interrogatories
`Complainants Corrected Response to Telit’s 1st Request for Admission
`No. 29
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`III.
`
`Pleadings from this Investigation and from Other Litigation Involving the Parties
`
`The Parties request that certain pleadings and other documents of record in this
`
`Investigation be received into evidence without a sponsoring witness. These exhibits are
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`relevant, material, and reliable and are therefore appropriate for receipt into evidence without a
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`sponsoring witness. In particular, these exhibits are relevant to issues in this Investigation,
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`including infringement, domestic industry, invalidity, FRAND, importation, remedy, and public
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`interest.
`
`JX-0013 is a copy of the Joint Claim Construction Statement submitted by the Parties in
`
`this Investigation on April 19, 2021, which contains the Parties’ and Staff’s agreed constructions
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`of certain claim terms. JX-0014 is a copy of the Corrected Joint Claim Construction Statement
`
`submitted by the Parties and Staff in this Investigation on July 21, 2021 setting forth disputed
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`claim terms, proposed constructions, and evidence identified by the Parties and Staff in support
`
`of their respective proposed constructions.
`
`CX-0001C is a copy of a stipulation executed in this Investigation between Philips and
`
`CalAmp regarding inventory and importation as it relates to CalAmp. CX-0004C is a copy of a
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`stipulation executed in this Investigation between Philips and LCI regarding inventory and
`
`importation as it relates to LCI. CX-0002C is a copy of a stipulation executed in this
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`337-TA-1240
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`10
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`Parties’ Request for Receipt of Evidence
`Without a Sponsoring Witness
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`

`

`
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`Investigation between Philips and Xirgo regarding inventory and importation as it relates to
`
`Xirgo. CX-0615C is a copy of a stipulation executed in this Investigation between Philips and
`
`Telit regarding inventory and importation as it relates to Telit. The Parties do not oppose the
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`admission of these exhibits without a sponsoring witness.
`
`CX-0470C, CX-0537C, CX-0612C, CX-0618C, and CX-0622C are copies of
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`confidential exhibits to the responses to the complaint, which provide verified data regarding
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`importation, sales, manufacturing capacity and relative significance required by 19 C.F.R.
`
`§ 210.13(b). Respondents have indicated that they do not oppose the admission of these exhibits.
`
`Philips respectfully submits that these exhibits are material and relevant to infringement,
`
`importation and remedy. The exhibits are also reliable and therefore appropriate for receipt into
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`evidence without a sponsoring witness as this information is to be provided under oath by the
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`Respondents pursuant to Commission Rule 210.13(b). Moreover, these exhibits constitute
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`admissions of a party-opponent.
`
`RX-2063 is the Public Interest Statement of Telit, as filed in this Investigation. Philips
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`has indicated that it does not oppose the admission of this exhibit. Telit respectfully submits that
`
`this exhibit is material and relevant to one or more of its defenses.
`
`RX-0139C, RX-0145C, RX-0147C, RX-0402C, RX-1193C, RX-1194C, RX-02301, RX-
`
`2693, RX-2687, RX-3304, RX-3321, and RX-3322 are copies of pleadings or other documents
`
`filed by one of the Parties in the litigation currently pending in the United States District Court
`
`for the District of Delaware. The Parties respectfully submit that these exhibits are material and
`
`relevant to one or more of the Respondents’ defenses. The exhibits are also reliable and therefore
`
`appropriate for receipt into evidence without a sponsoring witness.
`
`Accordingly, the Parties request that the following exhibits be received into evidence:
`
`337-TA-1240
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`
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`
`
`11
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`Parties’ Request for Receipt of Evidence
`Without a Sponsoring Witness
`
`

`

`
`
`Exhibit No.
`JX-0013
`JX-0014
`CX-0001C
`CX-0004C
`CX-0002C
`CX-0615C
`CX-0618C
`CX-0612C
`CX-2380C
`CX-0470C
`CX-0537C
`CX-0622C
`RX-2063
`
`RX-2687
`
`RX-0139C
`
`RX-0147C
`
`RX-0402C
`
`RX-3321
`
`RX-3322
`
`RX-1193C
`
`RX-0145C
`
`Description
`Joint Claim Construction Statement
`Corrected Joint Claim Construction Statement
`Stipulation Relating to Importation and Inventory of CalAmp
`Stipulation Relating to Importation and Inventory of LCI
`Stipulation Relating to Importation and Inventory of Xirgo
`Stipulation Relating to Importation and Inventory of Telit
`Appendix A to Thales’ Response to Complaint
`Ex. A to Telit’s Response to Complaint
`Appendix B to Quectel’s Response to Complaint
`Ex. 1 to CalAmp’s Response to Complaint
`Ex. 1 to LCI’s Response to Complaint
`Appendix B to Xirgo’s Response to Complaint
`Public Interest Statement of Respondents Telit Wireless Solutions, Inc.
`and Telit Communications PLC
`Complaint (D.I. 1) in Koninklijke Philips N.V. v. Telit Wireless
`Solutions, Inc., Telit Communications PLC, CalAmp Corp., C.A. No.
`1:20-cv-01711 (D. Del.)
`2021-03-05 First Declaration of Robert Antonitsch [D.I. 19-1] in
`Koninklijke Philips N.V. v. Thales DIS AIS USA LLC, C.A. No. 20-
`1713-CFC (D. Del.)
`2021-03-05 Second Declaration of Robert Antonitsch, [D.I. 24] in
`Koninklijke Philips N.V. v. Thales DIS AIS USA LLC, C.A. No. 20-
`1713-CFC (D. Del.)
`2021-03-05 Declaration of Christopher Moorhead, [D.I. 26] in
`Koninklijke Philips N.V. v. Thales DIS AIS USA LLC, C.A. No. 20-
`1713-CFC (D. Del.)
`Declaration of Remy Rougeron in Support of Motion to Dismiss by
`Thales S.A., [D.I. 57] in Koninklijke Philips N.V. v. Thales DIS AIS
`USA LLC, C.A. No. 20-1713-CFC (D. Del.)
`Declaration of Daniel Marion in Support of Motion to be Severed and
`Dismissed by Thales USA, Inc., [D.I. 60] in Koninklijke Philips N.V. v.
`Thales DIS AIS USA LLC, C.A. No. 20-1713-CFC (D. Del.)
`Declaration of David Djavaherian, [D.I. 65] in Koninklijke Philips N.V.
`v. Thales DIS AIS USA LLC, C.A. No. 20-1713-CFC (D. Del.)
`[CBI] 2021-03-24 Borghetti Decl., [D.I. 40] in Koninklijke Philips N.V.
`v. Thales DIS AIS USA LLC, C.A. No. 20-1713-CFC (D. Del.)
`
`337-TA-1240
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`
`
`
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`12
`
`Parties’ Request for Receipt of Evidence
`Without a Sponsoring Witness
`
`

`

`
`
`Exhibit No.
`RX-1194C
`
`RX-2301
`
`RX-2693
`
`RX-3304
`
`Description
`Declaration of Dr. Bertram Huber In Support Of Philips’ Opposition To
`Thales’ Motion For Preliminary Injunction, March 24, 2021
`Koninklijke Philips N.V. v. Thales DIS AIS USA LLC, C.A. No. 20-
`1713-CFC (D. Del.), Plaintiff’s Notice of Lodging of Slides, dated
`06/24/2021, Exhibit A, Slide 3
`Transcript of May 21, 2021, hearing before the Honorable Colm F.
`Connolly, U.S.D.C.J., in 1:20-cv-01711 and 1:20-cv-01708 (D. Del.)
`Declaration of Dennis Kelly in Support of Telit Wireless Solutions,
`Inc’s Motion for a Preliminary Injunction to Prevent Philips From
`Litigation in the International Trade Commission
`
`IV. Correspondence Between the Parties
`
`The Parties request that certain correspondence between the Parties be admitted into
`
`evidence without a sponsoring witness. The Parties respectfully submit that these exhibits are
`
`appropriate for receipt into evidence without a sponsoring witness because they are relevant and
`
`material to issues in this investigation, including one or more of the Respondents’ defenses. In
`
`addition, these exhibits are reliable as the communications were exchanged between the Parties
`
`prior to or during this Investigation, and no Party disputes their authenticity.
`
`Accordingly, the Parties request that the following exhibits be received into evidence:
`
`Exhibit No.
`RX-2286C
`RX-2287C
`
`RX-2289C
`
`RX-2294C
`RX-2568C
`
`RX-2569C
`RX-2629C
`RX-2630C
`RX-2638
`RX-2639
`RX-2640
`
`Description
`2021 03 25 Ltr to Philips re Arbitration.pdf
`20210112 Letter Axinn Foley & Lardner Philips re Certain UMTS and
`LTR Cellular Docket no. 3514.pdf
`20210201 Letter Axinn Foley & Lardner Philips - Thales resp Jan 22
`letter.pdf
`Thales Letter to Philips December 28,2020.pdf
`Email to Pasquier fm Feng re Quectel-Philips IoT Cellular
`Communication Patent License
`Letter to Philips fm Quectel re FRAND
`Email from S. Pasquier re Philips and Telit M2M Patent License
`Email from S. Pasquier re Philips and Telit M2M Patent License
`PRSNA-ITC0517775 Email
`PRSNA-ITC0517776 Attachment
`PRSNA-ITC0517789 Attachment
`
`337-TA-1240
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`
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`13
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`Parties’ Request for Receipt of Evidence
`Without a Sponsoring Witness
`
`

`

`
`
`PRSNA-ITC0517797 Attachment
`RX-2641
`PRSNA-ITC0518026 Attachment
`RX-2642
`PRSNA-ITC0518272 Attachment
`RX-2643
`PRSNA-ITC0518279 Attachment, Letter
`RX-2644
`PRSNA-ITC0518284 Attachment
`RX-2645
`PRSNA-ITC0518359 Email
`RX-2646
`PRSNA-ITC0518356 Email
`RX-2647
`PRSNA-ITC0518315 Email
`RX-2648
`PRSNA-ITC0518322 Email
`RX-2649
`PRSNA-ITC0518329 Email
`RX-2650
`PRSNA-ITC0518287 Email
`RX-2651
`PRSNA-ITC0518296 Email
`RX-2652
`PRSNA-ITC0518305 Email
`RX-2653
`PRSNA-ITC0518347 Email
`RX-2654
`PRSNA-ITC0518337 Email
`RX-2655
`V.
`Deposition Designations
`
`The Parties request that the Parties’ deposition designations be admitted into evidence
`
`without a sponsoring witness, subject to any rulings on any potential HPOs and/or MILs related
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`to such designations. The Parties respectfully submit that these exhibits are appropriate for
`
`receipt into evidence without a sponsoring witness because they are relevant and material to
`
`issues in this investigation, including Philips’s claims and Respondents’ defenses. In addition,
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`these exhibits include sworn testimony of the Parties’ fact witnesses and the named inventors of
`
`the patents-in-suit, and no party disputes their authenticity.
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`Accordingly, the Parties request that the following exhibits be received into evidence:
`
`Exhibit No.
`JX-0015C
`JX-0016C
`JX-0017C
`JX-0018C
`JX-0019C
`JX-0020C
`JX-0021C
`JX-0022C
`JX-0023C
`
`Description
`Deposition designations of Baker, Mathew (6/21/2021)
`Deposition designations of Bednasz, Ken (6/9/2021)
`Deposition designations of Bossard, Gildas Paul (6/9/2021)
`Deposition designations of Bowen, Kevin (6/15/2021)
`Deposition designations of Bucknell, Paul (6/10/2021)
`Deposition designations of Cormas, Nick (6/11/2021)
`Deposition designations of Depew, Amy (6/10/2021)
`Deposition designations of Feng, Yaffa (6/12/2021)
`Deposition designations of Kelly, Dennis (6/11/2021)
`
`337-TA-1240
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`
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`14
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`Parties’ Request for Receipt of Evidence
`Without a Sponsoring Witness
`
`

`

`
`
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`
`
`
`JX-0024C
`JX-0025C
`JX-0026C
`JX-0027C
`JX-0028C
`JX-0029C
`JX-0030C
`JX-0031C
`JX-0032C
`JX-0033C
`JX-0034C
`JX-0035C
`JX-0036C
`JX-0037C
`JX-0038C
`JX-0039C
`
`
`
`
`Deposition designations of Moulsley, Timothy (6/11/2021)
`Deposition designations of Pasquier, Sophie (6/14/2021)
`Deposition designations of Rogers, Jeffrey (6/10/2021)
`Deposition designations of Scott, Kevin (6/10/2021)
`Deposition designations of Slater, Donna (6/9/2021)
`Deposition designations of Burrington, Steve (6/14/2021)
`Deposition designations of Gardner, Jeff (6/11/2021)
`Deposition designations of Hu, Jean (6/19/2021)
`Deposition designations of Moorhead, Christopher (6/11/2021)
`Deposition designations of Petsch, Carsten (6/14/2021)
`Deposition designations of Steinike, William (6/18/2021)
`Deposition designations of Wan-Dall, Leandro (6/8/2021)
`Deposition designations of Wu, Andy (6/18/2021)
`Deposition designations of Young, Joel (6/21/2021)
`Deposition designations of Zhang, Ivan (6/17/2021)
`Deposition designations of Zhang, Lynn (6/13/2021)
`
`
`
`337-TA-1240
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`
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`15
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`Parties’ Request for Receipt of Evidence
`Without a Sponsoring Witness
`
`

`

`
`
`Dated: August 20, 2021
`
`
`
`
`
`
`
`
`
`
`Respectfully submitted,
`
`
`
`
`
`
` Lucas I. Silva
`Eley O. Thompson
`FOLEY & LARDNER LLP
`321 N. Clark Street
`Suite 2800
`Chicago, IL 60654-5313
`Phone: (312) 832-4359
`
`David A. Hickerson
`FOLEY & LARDNER LLP
`3000 K Street, N.W.
`Suite 600
`Washington, D.C. 20007-5109
`Phone: (202) 672-5399
`
`Kevin M. Littman
`Lucas I. Silva
`John W. Custer
`FOLEY & LARDNER LLP
`111 Huntington Avenue
`Suite 2500
`Boston, MA 02199-7610
`Phone: (617) 342-4000
`
`Counsel for Complainants
`Philips North America, LLC and Koninklijke
`Philips N.V.
`
`337-TA-1240
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`
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`16
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`Parties’ Request for Receipt of Evidence
`Without a Sponsoring Witness
`
`

`

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`
`
`/s/ Jeannine Sano
`Eric A. Krause
`AXINN, VELTROP & HARKRIDER LLP
`560 Mission Street
`San Francisco, CA 94105
`
`Counsel for Respondents Thales DIS AIS
`Deutschland GmbH, Thales DIS AIS USA,
`LLC, Thales USA, Inc., and Thales S.A.
`
`
`
`/s/ David A. Loewenstein
`David A. Loewenstein
`PEARL COHEN ZEDEK LATZER
`BARATZ LLP
`1500 Broadway, 12th Floor
`New York, NY 10036
`
`Counsel for Respondents Telit Wireless
`Solutions, Inc. and Telit Communications
`PLC
`
`
`
`
`
`/s/ Thomas H. Reger
`Thomas H. Reger II
`FISH & RICHARDSON P.C.
`1717 Main Street, Suite 5000
`Dallas, TX 75201
`Telephone: (214) 747-5070
`Facsimile: (214) 747-2091
`
`
`Ruffin Cordell
`Linhong Zhang
`Thomas S. Fusco
`FISH & RICHARDSON P.C.
`1000 Maine Avenue, S.W., Suite 1000
`Washington, D.C. 20024
`Telephone: (202) 783-5070
`Facsimile: (202) 783-2331
`
`
`Lawrence Jarvis
`FISH & RICHARDSON P.C.
`1180 Peachtree Street NE, 21st Floor
`Atlanta, GA 30309
`Telephone: (404) 892-5005
`Facsimile: (404) 892-5002
`
`
`Markus Weyde
`Jared A. Smith
`FISH & RICHARDSON P.C.
`12860 El Camino Real, Suite 400
`San Diego, CA 92130
`Telephone: (858) 678-5070
`Facsimile: (858) 678-5099
`
`
`Elizabeth G.H. Ranks
`FISH & RICHARDSON P.C.
`1 Marina Park Drive
`Boston, MA 02210
`Telephone: (617) 542-5070
`Facsimile: (617) 542-8906
`
`