`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE EASTERN DISTRICT OF TEXAS
`MARSHALL DIVISION
`
`ADVANCED MICRO DEVICES, INC.; and ATI
`TECHNOLOGIES ULC,
`
`Plaintiffs,
`
`v.
`
`C. A. NO. 2:22-CV-00134
`
`JURY TRIAL DEMANDED
`
`
`TCL INDUSTRIES HOLDINGS CO., LTD.; TCL
`INDUSTRIES HOLDINGS (H.K.) LIMITED;
`TCL ELECTRONICS HOLDINGS LIMITED;
`TCL TECHNOLOGY GROUP CORPORATION;
`TTE CORPORATION; TCL HOLDINGS (BVI)
`LIMITED; TCL KING ELECTRICAL
`APPLIANCES (HUIZHOU) CO. LTD.;
`SHENZHEN TCL NEW TECHNOLOGIES CO.,
`LTD.; TCL MOKA INTERNATIONAL
`LIMITED; TCL SMART DEVICE (VIETNAM)
`CO., LTD; MANUFACTURAS AVANZADAS
`SA DE CV; TCL ELECTRONICS MEXICO, S
`DE RL DE CV; TCL OVERSEAS MARKETING
`LTD.; and REALTEK SEMICONDUCTOR
`CORP.,
`
`
`Defendants.
`
`
`PLAINTIFFS ADVANCED MICRO DEVICES, INC.’S AND ATI TECHNOLOGIES
`ULC’S NOTICE OF COMPLIANCE
`
`In compliance with P.R. 3-1 and 3-2, Plaintiffs Advanced Micro Devices, Inc. and ATI
`
`Technologies ULC (collectively, “AMD”) file this Notice of Compliance notifying the Court that
`
`AMD’s Disclosure of Asserted Claims and Infringement Contentions, and accompanying
`
`document production were served on Defendant Realtek Semiconductor Corp. via electronic mail
`
`on July 26, 2022.1
`
`
`1 As noted in the disclosures, the TCL Defendants (TCL Industries Holdings Co. Ltd., TCL
`Industries Holdings (H.K.) Limited., TCL Electronics Holdings Limited, TCL Technology Group
`Corporation, TTE Corporation, TCL Holdings (BVI) Limited, TCL King Electrical Appliances
`(Huizhou) Co. Ltd., Shenzhen TCL New Technologies Co., Ltd., TCL MOKA International
`1
`
`
`
`
`
`Case 2:22-cv-00134-JRG-RSP Document 38 Filed 07/27/22 Page 2 of 3 PageID #: 462
`
`Dated: July 27, 2022
`
`Respectfully submitted,
`
`By: __/s/Eric H. Findlay_______________
`Eric H. Findlay
`State Bar No. 00789886
`Brian Craft
`State Bar No. 04972020
`FINDLAY CRAFT, P.C.
`102 N. College Ave. Suite 900
`Tyler, Texas 75702
`Tel: (903) 534-1100
`Fax: (903) 534-1137
`Email: efindlay@findlaycraft.com
`Email: bcraft@findlaycraft.com
`
`Michael T. Renaud
`James M. Wodarski
`Michael J. McNamara
`Adam S. Rizk
`William Meunier
`Marguerite McConihe
`Matthew A. Karambelas
`Catherine Xu
`Tianyi Tan
`MINTZ LEVIN COHN FERRIS
` GLOVSKY AND POPEO PC
`One Financial Center
`Boston, MA 02111
`617-542-6000
`
`
`
`Limited, TCL Smart Device (Vietnam) Co., Ltd., Manufacturas Avanzadas SA de CV, TCL
`Electronics Mexico, S de RL de CV, and TCL Overseas Marketing Ltd.) have elected to seek an
`unopposed mandatory stay of this action pursuant to § 1659(a) until the determination of the
`Commission becomes final in a parallel ITC proceeding. See Dkt. No. 36 (July 22, 2022); Dkt.
`No. 28 (July 7, 2022). Plaintiffs object to providing these disclosures to Realtek to the extent they
`are premature in view of (i) Realtek’s refusal to acknowledge service or accept reasonable methods
`of service (see Dkt. No. 31 (July 11, 2022)), and (ii) the likelihood that the case against Realtek
`will be stayed in view of Plaintiffs’ pending Motion for Discretionary Stay of Remainder of Action
`Against Realtek Pending Final Determination By The International Trade Commission of
`Investigation No. 337-TA-1318 (Dkt. No. 37 (July 22, 2022)). Plaintiffs nevertheless served these
`disclosures on Defendant Realtek out of an abundance of caution and reserve all rights to
`supplement these disclosures on Defendants TCL and Realtek at the appropriate time in the
`procedural schedule upon a lift of the anticipated stay of this case.
`
`
`
`
`2
`
`
`
`Case 2:22-cv-00134-JRG-RSP Document 38 Filed 07/27/22 Page 3 of 3 PageID #: 463
`
`Attorneys for Plaintiffs Advanced Micro Devices,
`Inc. and ATI Technologies ULC
`
`
`
`
`
`
`
`
`
`
`
`CERTIFICATE OF SERVICE
`
`I hereby certify that on July 27, 2022 I electronically filed the foregoing NOTICE OF
`
`COMPLIANCE with the Clerk of the Court using the CM/ECF system which will send
`
`notification of such filing via electronic mail to all counsel of record.
`
`
`
`
`
`
`
`
`
`
`
`
`/s/ Eric H. Findlay
`Eric H. Findlay
`
`
`
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`3
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