`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE EASTERN DISTRICT OF TEXAS
`MARSHALL DIVISION
`
`
`GESTURE TECHNOLOGY PARTNERS,
`LLC,
`
`Plaintiff
`
`
`v.
`HUAWEI DEVICE CO., LTD., AND
`HUAWEI DEVICE USA, INC.,
`
`
`Defendants.
`
`
`JURY TRIAL DEMANDED
`
`C.A. NO. 2:21-cv-00040-JRG
` LEAD CONSOLIDATED CASE
`
`
`SAMSUNG ELECTRONICS CO., LTD. AND
`SAMSUNG ELECTRONICS AMERICA, INC.,
`Defendants.
`
`
`C.A. NO. 2:21-cv-00041-JRG
`
`
`
`DECLARATION OF FRED I. WILLIAMS IN SUPPORT OF PLAINTIFF’S OPPOSED
`MOTIONS IN LIMINE
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`I, Fred I. Williams, state and declare as follows:
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`1.
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`I am a partner of Williams Simons & Landis PLLC and counsel to Plaintiff Gesture
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`Technology Partners, LLC (“GTP”). I make this declaration in support of Plaintiff’s Opposed
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`Motions in Limine. I have personal knowledge of the matters stated in this declaration and would
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`testify truthfully to them if called upon to do so.
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`2.
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`Attached hereto as Exhibit A is a true and correct copy of Order on Motions in
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`Limine as filed in Estech Sys. v. Target Corp., No. 2:20-cv-00123-JRG-RSP, Dkt. No. 304, (E.D.
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`Tex. July 21, 2021) (Payne, J.);
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`3.
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`Attached hereto as Exhibit B is a true and correct copy of Order Regarding Motions
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`in Limine, Motions for Summary Judgment, and Daubert Motions as filed in MV3 Partners LLC
`
`v. Roku, Inc., No. 6:18-cv-308-ADA, ECF No. 332, (W.D. Tex. Sept. 29, 2020) (Albright, J.);
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`1
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`
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`Case 2:21-cv-00040-JRG Document 195-1 Filed 01/10/22 Page 2 of 2 PageID #: 9325
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`I declare under penalty of perjury under the laws of the United States of America that the foregoing
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`is true and correct. Executed in Travis County, Texas, on this 10th day of January, 2022.
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`Dated: January 10, 2022
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`
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`
`
`
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`
`
`/s/ Fred I. Williams
`Fred I. Williams
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`2
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`