`Case 2:l2—cv—O2825—JPM—tmp Document 50-1 Filed 07/23/13 Page 1 of 2 Page|D 506
`
`UNITED STATES DISTRICT COURT
`WESTERN DISTRICT OF TENNESSEE
`
`WESTERN DIVISION
`
`Civil Action No. 12-cv-02824-JPM—tmp
`
`JURY TRIAL DEMANDED
`
`Civil Action No. 12-cv-02825-JPM-tmp
`
`JURY TRIAL DEMANDED
`
`
`
`B.E. TECHNOLOGY, L.L.C.,
`
`Plaintiff,
`
`v.
`
`SAMSUNG TELECOMMUNICATIONS
`
`AMERICA, LLC,
`
`Defendant.
`
`B.E. TECHNOLOGY, L.L.C.,
`
`
`
`
`
`Plaintiff,
`
`v.
`
`SAMSUNG ELECTRONICS AMERICA
`
`INC.,
`
`
`Defendant.
`
`DECLARATION OF RICHARD C. PETTUS IN SUPPORT OF DEFENDANTS
`
`SAMSUNG TELECOMMUNICATIONS AMERICA, LLC AND SAMSUNG
`ELECTRONICS AMERICA INC.’S MOTION TO (A) COMPEL SUPPLEMENTAL
`INFRINGEMENT CONTENTIONS THAT COMPLY VVITH LOCAL PATENT RULE
`
`3.1, AND (B) RELIEVE DEFENDANTS OF CERTAIN RESPONSIVE DISCOVERY
`OBLIGATIONS PENDING SERVICE OF COMPLIANT CONTENTIONS
`
`1, Richard C. Pettus, declare as follows:
`
`I am an attorney duly licensed to practice in the state of New York and admitted pro hac
`
`Vice before this Court. I am an attorney at Greenberg Traurig LLP, counsel of record for
`
`Defendant Samsung Telecommunications America, LLC and Samsung Electronics America, Inc.
`
`(collectively, “Samsung”). I have personal knowledge of the facts stated in this declaration, and
`
`
`
`Case 2:12-cv-02825-JPM-tmp Document 50-1 Filed 07/23/13 Page 2 of 2 PageID 507
`Case 2:l2—cv—O2825—JPM—tmp Document 50-1 Filed 07/23/13 Page 2 of 2 Page|D 507
`
`if called upon to do so, could and would competently testify thereto. I make this declaration in
`
`support of Samsung’s Motion to (a) Compel Supplemental Infringement Contentions that
`
`Comply with Local Patent Rule 3.1 and (b) Relieve Defendants of Certain Responsive Discovery
`
`Obligations Pending Service of Compliant Contentions (“Motion”).
`
`Attached hereto are true and correct copies of material referenced in Samsung’s Motion:
`
`1.
`
`Exhibit A is a true and correct copy of an excerpt from of Plaintiffs Preliminary
`
`Infringement Contentions (“ICS”) relating to the Samsung “Acclaim” product
`
`(dated January 7, 2013). The complete ICs accused 177 products and comprised
`
`10,363 pages.
`
`2.
`
`Exhibit B is a true and correct copy of Samsung’s correspondence to B.E.
`
`Technology
`
`(“Plaintiff”)
`
`regarding Plaintiffs
`
`Preliminary
`
`Infringement
`
`Contentions (“ICS”) (sent January 18, 2013).
`
`3.
`
`Exhibit C is a true and correct copy of Plaintiffs correspondence to Samsung in
`
`response to Samsung’s January 18, 2013 correspondence regarding Plaintiffs ICs
`
`(received January 30, 2013).
`
`4.
`
`Exhibit D is a true and correct copy of Samsung’s correspondence with Plaintiff
`
`regarding supplementing Plaintiffs ICs (dated July 17, 2013 through July 23,
`
`2013).
`
`I declare under the penalty of perjury that the foregoing is true and correct.
`
`DATE:
`
`July 23, 2013
`
`Richard C. Pettus
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