`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE EASTERN DISTRICT OF TEXAS
`MARSHALL DIVISION
`
`
`
`CASE NO. 2:21-cv-00040-JRG
`(Lead Case)
`
`JURY TRIAL DEMANDED
`
`
`
`CASE NO. 2:21-cv-00041-JRG
`(Member Case)
`
`JURY TRIAL DEMANDED
`
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`GESTURE TECHNOLOGY
`PARTNERS, LLC,
`
`Plaintiff
`
`v.
`
`HUAWEI DEVICE CO., LTD.,
`HUAWEI DEVICE USA, INC.,
`
`Defendants.
`
`
`GESTURE TECHNOLOGY
`PARTNERS, LLC,
`
`Plaintiff
`
`v.
`
`SAMSUNG ELECTRONICS CO., LTD.
`AND SAMSUNG ELECTRONICS
`AMERICA, INC.,
`
`Defendants.
`
`DECLARATION OF RADHESH DEVENDRAN IN SUPPORT OF DEFENDANTS
`SAMSUNG ELECTRONICS CO., LTD. AND SAMSUNG ELECTRONICS AMERICA,
`INC.’S MOTION FOR RECONSIDERATION OF THE COURT’S CLAIM
`CONSTRUCTION ORDER (DKT. 93) ON THE “FORWARD FACING” TERMS
`
`I, Radhesh Devendran, hereby declare as follows:
`
`1.
`
`I am an attorney at the law firm Paul Hastings LLP, counsel of record for
`
`Samsung Electronics Co., Ltd. and Samsung Electronics America, Inc. in this action. I have
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`personal knowledge of the facts herein and, if called as a witness, I could and would testify
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`competently as to their truth.
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`
`
`Case 2:21-cv-00040-JRG Document 107-1 Filed 10/26/21 Page 2 of 2 PageID #: 3268
`
`2.
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`Attached hereto as Exhibit A is a true and correct copy of the Patent Owner’s
`
`Preliminary Response filed in IPR2021-00921 on September 15, 2021.
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`I declare under penalty of perjury under the laws of the State of California that the
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`foregoing is true and correct. Executed this 26th day of October, 2021in Palo Alto, California.
`
`
`
`
`
` /s/ Radhesh Devendran
`Radhesh Devendran
`
`
`
`
`
`-2-
`
`