`
`
`
`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
`
`§
`§
`§
`§
`§
`§
`§
`§
`§
`§
`§
`
` §
`
`
`§
`§
`§
`§
`§
`§
`§
`§
`§
`§
`
`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 SAMSUNG
`DEFENDANTS’ MOTION FOR SUMMARY JUDGMENT OF INVALIDITY
`UNDER § 101
`
`I, Radhesh Devendran, hereby declare as follows:
`
`I am an attorney at the law firm of Paul Hastings LLP, counsel for Defendants Samsung
`
`Electronics Co. Ltd. and Samsung Electronics America, Inc. (collectively, “Samsung”) in the
`
`above-entitled consolidated action. I have personal knowledge of the facts stated herein and if
`
`called to testify could and would competently testify thereto.
`
`
`
`
`
`Case 2:21-cv-00040-JRG Document 145-1 Filed 12/03/21 Page 2 of 3 PageID #: 5740
`
`
`
`1.
`
`Attached hereto as Exhibit 1 is a true and correct copy of excerpts from Exhibit
`
`SAMSUNG-079 to the Expert Report of Benedict Occhiogrosso Regarding Infringement, dated
`
`October 20, 2021.
`
`2.
`
`3.
`
`Attached hereto as Exhibit 2 is a true and correct copy of U.S. Patent No. 8,553,079.
`
`Attached hereto as Exhibit 3 is a true and correct copy of excerpts from the
`
`deposition of Benedict Occhiogrosso, taken November 23, 2021.
`
`4.
`
`5.
`
`Attached hereto as Exhibit 4 is a true and correct copy of U.S. Patent No. 8,878,949.
`
`Attached hereto as Exhibit 5 is a true and correct copy of excerpts from the
`
`Corrected Expert Report of Dr. Robert Stevenson Regarding Invalidity, dated October 27, 2021.
`
`6.
`
`Attached hereto as Exhibit 6 is a true and correct copy of excerpts from Exhibit
`
`SAMSUNG-949 to the Expert Report of Benedict Occhiogrosso Regarding Infringement, dated
`
`October 20, 2021.
`
`7.
`
`Attached hereto as Exhibit 7 is a true and correct copy of the July 20, 2009
`
`Applicant Remarks from the file history of U.S. Patent No. 7,756,297.
`
`8.
`
`Attached hereto as Exhibit 8 is a true and correct copy of excerpts from Exhibit
`
`SAMSUNG-431 to the Expert Report of Benedict Occhiogrosso Regarding Infringement, dated
`
`October 20, 2021.
`
`9.
`
`Attached hereto as Exhibit 9 is a true and correct copy of excerpts from the claim
`
`chart for U.S. Patent No. 7,933,431 from Plaintiff's Final Infringement Contentions, dated
`
`September 20, 2021.
`
`10.
`
`Attached hereto as Exhibit 10 is a true and correct copy of excerpts from the
`
`deposition of Benedict Occhiogrosso, taken November 19, 2021.
`
`-2-
`
`
`
`Case 2:21-cv-00040-JRG Document 145-1 Filed 12/03/21 Page 3 of 3 PageID #: 5741
`
`
`
`11.
`
`Attached hereto as Exhibit 11 is a true and correct copy of U.S. Patent No.
`
`7,933,431.
`
`12.
`
`Attached hereto as Exhibit 12 is a true and correct copy of excerpts from the
`
`deposition of Timothy Pryor, taken October 8, 2021.
`
`13.
`
`Attached hereto as Exhibit 13 is a true and correct copy of U.S. Patent No.
`
`8,194,924.
`
`14.
`
`Attached hereto as Exhibit 14 is a true and correct copy of excerpts from Exhibit
`
`SAMSUNG-924 to the Expert Report of Benedict Occhiogrosso Regarding Infringement, dated
`
`October 20, 2021.
`
`I declare under penalty of perjury under the laws of the State of California that the
`
`foregoing is true and correct. Executed this 1st day of December, 2021 in Palo Alto, California.
`
`
`
` /s/ Radhesh Devendran
`Radhesh Devendran
`
`
`
`
`
`-3-
`
`
Accessing this document will incur an additional charge of $.
After purchase, you can access this document again without charge.
Accept $ Charge
Still Working On It
This document is taking longer than usual to download. This can happen if we need to contact the court directly to obtain the document and their servers are running slowly.
Give it another minute or two to complete, and then try the refresh button.
A few More Minutes ... Still Working
It can take up to 5 minutes for us to download a document if the court servers are running slowly.
Thank you for your continued patience.
This document could not be displayed.
We could not find this document within its docket. Please go back to the docket page and check the link. If that does not work, go back to the docket and refresh it to pull the newest information.
Your account does not support viewing this document.
You need a Paid Account to view this document. Click here to change your account type.
Your account does not support viewing this document.
Set your membership
status to view this document.
With a Docket Alarm membership, you'll
get a whole lot more, including:
- Up-to-date information for this case.
- Email alerts whenever there is an update.
- Full text search for other cases.
- Get email alerts whenever a new case matches your search.
One Moment Please
The filing “” is large (MB) and is being downloaded.
Please refresh this page in a few minutes to see if the filing has been downloaded. The filing will also be emailed to you when the download completes.
Your document is on its way!
If you do not receive the document in five minutes, contact support at support@docketalarm.com.
Sealed Document
We are unable to display this document, it may be under a court ordered seal.
If you have proper credentials to access the file, you may proceed directly to the court's system using your government issued username and password.
Access Government Site
