`
`
`
`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 SAMSUNG
`DEFENDANTS’ MOTION TO PRECLUDE THE OPINIONS AND TESTIMONY OF
`PLAINTIFF’S TECHINICAL EXPERT BENEDICT OCCHIOGROSSO
`
`I, Radhesh Devendran, hereby declare as follows:
`
`1.
`
`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”)
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`in the above-entitled consolidated action. I have personal knowledge of the facts stated herein and
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`if called to testify could and would competently testify thereto.
`
`2.
`
`Attached as Exhibit 1 is a true and correct copy of the Expert Report of Mr.
`
`Benedict Occhiogrosso on issues of purported infringement, dated October 20, 2021.
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`
`
`
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`Case 2:21-cv-00040-JRG Document 146-1 Filed 12/03/21 Page 2 of 2 PageID #: 5898
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`
`
`3.
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`Attached as Exhibit 2 is a true and correct copy of excerpts from the transcript of
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`the deposition of Mr. Occhiogrosso taken on November 19, 2021.
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`4.
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`Attached as Exhibit 3 is a true and correct copy of excerpts from the transcript of
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`the deposition of Jeongho Cho taken on October 1, 2021.
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`5.
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`Attached as Exhibit 4 is a true and correct copy of excerpts from the transcript of
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`the deposition of Yonggyoo Kim taken on September 30, 2021.
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`6.
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`Attached as Exhibit 5 is a true and correct copy of excerpts from the transcript of
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`the deposition of Ryangguen Oh taken on October 4, 2021.
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`7.
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`Attached as Exhibit 6 is a true and correct copy of excerpts from the transcript of
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`the deposition of Byungyun Son taken on October 6, 2021.
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`8.
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`Attached as Exhibit 7 is a true and correct copy of excerpts from the transcript of
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`the deposition of Juwoan Yoo taken on October 5, 2021.
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`9.
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`Attached as Exhibit 8 is a true and correct copy of plaintiff Gesture Technology
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`Partners, LLC’s (“GTP”) Sept. 20, 2021 Supplemental Amended Infringement Contentions.
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`10.
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`Attached as Exhibit 9 is a true and correct copy of GTP’s April 30, 2021 Disclosure
`
`of Asserted Claims and Infringement Contentions.
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`11.
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`Attached as Exhibit 10 is a true and correct copy of a May 19, 2021 Letter to F.
`
`Williams from C. Kennerly.
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`12.
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`Attached as Exhibit 11 is a true and correct copy of a May 25, 2021 Letter to C.
`
`Kennerly from F. Williams.
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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 1st day of December 1, 2021 in Palo Alto, California.
`
` /s/ Radhesh Devendran
`Radhesh Devendran
`
`
`
`
`
`-2-
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`