TPL has certified specialists that reverse engineer the chips to find out what is in them, as has been reported in previous share holders meetings, TPL would not foolishly sue a company that is not infringing.

Your idea that "there remains a factual dispute" is wrong.

HTC with their immense wealth and power may be trying to spread false information to Judge Grewal, hoping that they can influence an oppsite decision of what they expect to be a loss.

I believe that HTC may be refering to some chips that do not infringe, not all chips on a mother board do the same thing, while some my use a ring ocilator others do not because they perform a different function that may not be related at all to a ring occilator process.

The chips that do infringe are the ones that TPL is arguing about.

You can rest assured that TPL has expected these type of arguments and with the reverse engineered schematics they can prove that HTC and other have infringed.