`Case 2:21-cv-00040-JRG Document 211-2 Filed 01/25/22 Page 1of5 PagelD#: 9727
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`
`EXHIBIT B
`EXHIBIT B
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`
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`Case 2:21-cv-00040-JRG Document 211-2 Filed 01/25/22 Page 2 of 5 PageID #: 9728
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`
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`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.
`
`
`SAMSUNG DEFENDANTS’ OBJECTIONS TO GESTURE
`TECHNOLOGY PARTNERS, LLC’S WITNESS LIST
`
`
`
`Pursuant to the Court’s Sixth Amended Docket Control Order (Dkt. No. 155), Defendants
`
`Samsung Electronics Co., Ltd. and Samsung Electronics America, Inc. object to the following
`
`disclosures on Plaintiff Gesture Technology Partners, LLC’s Witness List.
`
`
`
`Defendants reserve the right to object independent of any pending motions, including
`
`without limitation Defendants’ Motions for Summary Judgment, Daubert Motions, Motions to
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`Strike, and forthcoming Motions in Limine, and their objections are not intended to limit the scope
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`of any such motions. Defendants generally object to any witness testimony insofar as it pertains
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`
`
`
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`Case 2:21-cv-00040-JRG Document 211-2 Filed 01/25/22 Page 3 of 5 PageID #: 9729
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`to, or may be used in a manner that, on its face or as argued at trial is contrary to any of Defendants’
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`Motions for Summary Judgment, Daubert Motions, Motions to Strike, and/or forthcoming
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`Motions in Limine. Defendants further generally object to any use of deposition designation
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`testimony of any witness where Plaintiff has not demonstrated these individuals are unavailable to
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`testify live, see Fed. R. Evid. 804. Defendants object to any attempt to call Defendants’ employees
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`as live trial witnesses, see Fed. R. Civ. P. 45(c)(1). Defendants object to Plaintiff calling any
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`witness by designation who Defendants intend to present live at trial. Defendants intend to
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`incorporate by reference their objections and counter-designations to Plaintiff’s deposition
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`designations as well as any evidentiary issues to be raised at the pre-trial conference. Defendants
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`further reserve the right to object on any ground of improper or irrelevant testimony advanced at
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`trial by any of Plaintiff’s witnesses (including on cross-examination of Plaintiff’s or third-party
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`witnesses).
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`
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`Defendants do not know the precise nature or scope of the testimony and evidence that
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`Plaintiff may seek to present at trial. As such, Defendants reserve the right to amend or supplement
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`their objections prior to or during trial including, by way of example and not of limitation, rulings
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`by the Court including on any of Defendants’ Motions for Summary Judgment, Daubert Motions,
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`Motions to Strike, and forthcoming Motions in Limine, or any other case developments.
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`
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`
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`-2-
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`
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`Case 2:21-cv-00040-JRG Document 211-2 Filed 01/25/22 Page 4 of 5 PageID #: 9730
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`
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`DATED: January 5, 2022
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`
`
`By: /s/ Christopher W. Kennerly
`Christopher W. Kennerly (TX Bar No. 00795077)
`chriskennerly@paulhastings.com
`Radhesh Devendran (pro hac vice)
`radheshdevendran@paulhastings.com
`Boris S. Lubarsky (pro hac vice)
`borislubarsky@paulhastings.com
`David M. Fox (pro hac vice)
`davidfox@paulhastings.com
`PAUL HASTINGS LLP
`1117 S. California Avenue
`Palo Alto, CA 94304
`Telephone: (650) 320-1800
`Facsimile: (650) 320-1900
`
`Allan M. Soobert
`allansoobert@paulhastings.com
`PAUL HASTINGS LLP
`2050 M Street NW
`Washington, D.C. 20036
`Telephone: 202-551-1700
`Facsimile: 202-551-1705
`
`Elizabeth L. Brann
`elizabethbrann@paulhastings.com
`PAUL HASTINGS LLP
`4747 Executive Drive, 12th Floor
`San Diego, CA 92121
`Telephone: (858) 458-3000
`Facsimile: (858) 458-3005
`
`Robert Laurenzi
`robertlaurenzi@paulhastings.com
`PAUL HASTINGS LLP
`200 Park Avenue
`New York, NY 10166
`Telephone: (212) 318-6000
`Facsimile: (212) 319-4090
`
`Harry Lee Gillam, Jr. (TX Bar No. 07921800)
`gil@gillamsmithlaw.com
`Melissa R. Smith (TX Bar No. 24001351)
`melissa@gillamsmithlaw.com
`James Travis Underwood (TX Bar No. 24102587)
`travis@gillamsmithlaw.com
`GILLAM & SMITH, LLP
`
`-3-
`
`
`
`Case 2:21-cv-00040-JRG Document 211-2 Filed 01/25/22 Page 5 of 5 PageID #: 9731
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`
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`
`
`303 S. Washington Ave.
`Marshall, TX 75670
`Telephone: (903) 934-8450
`Facsimile: (903) 934-9257
`
`Attorneys for Defendants Samsung Electronics
`Co., Ltd and Samsung Electronics America, Inc.
`
`
`CERTIFICATE OF SERVICE
`
`I hereby certify that a true and correct copy of the foregoing document has been served via
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`email on all counsel of record on this 5th day of January, 2022.
`
` /s/ Christopher W. Kennerly
`Christopher W. Kennerly
`
`
`
`-4-
`
`
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