Case 2:21-cv-00040-JRG Document 34 Filed 05/18/21 Page 1 of 13 PageID #: 331
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`IN THE UNITED STATES DISTRICT COURT
`FOR THE EASTERN DISTRICT OF TEXAS
`MARSHALL DIVISION
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`
`
`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.
`
`DEFENDANTS SAMSUNG ELECTRONICS CO., LTD. AND SAMSUNG
`ELECTRONICS AMERICA, INC.’S REPLY IN SUPPORT OF THEIR
`MOTION TO DISMISS PURSUANT TO FED. R. CIV. P. 12(b)(6)
`
`
`
`
`
`
`

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`Case 2:21-cv-00040-JRG Document 34 Filed 05/18/21 Page 2 of 13 PageID #: 332
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`GTP’s Response to Defendants’ Motion to Dismiss does nothing to resolve GTP’s failure
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`to plead facts sufficient to provide fair notice of GTP’s claims and the grounds on which they rest.
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`Instead, GTP relies on an incorrect reading of case law to justify identifying 24 Accused Features
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`but failing to provide notice as to how any, much less all, allegedly meet the claims of the Asserted
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`Patents. Moreover, even taking all inferences in a light most favorable to GTP, no facts exist to
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`allege Samsung’s knowledge of the Asserted Patents before they expired, and none have been
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`pleaded. Samsung requests that the Court dismiss GTP’s claims for patent infringement.
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`I.
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`GTP FAILS TO STATE A CLAIM FOR DIRECT INFRINGEMENT
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`GTP’s Complaint is so vague that Samsung does not have fair notice of the accused
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`instrumentalities and cannot reasonably prepare an answer much less its defenses. GTP does no
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`more than provide a bare bones recitation of the exemplary patent claim while generally averring
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`to the Accused Products and Features. GTP only generally identifies 24 Accused Features in its
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`Complaint. Some of these identified features, such as Adjust Blur, Smile Shot, and Active Shape
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`Connect, are so vague that Samsung is unsure what the Accused Feature is, let alone how it might
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`infringe. The four screenshots GTP does include do not identify how each illustrated feature
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`allegedly meets the text of the exemplary claim nor even which feature each screenshot allegedly
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`illustrates. Both this Court’s holding in Chapterhouse, LLC v. Shopify, Inc., No. 2:18-CV-00300-
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`JRG, 2018 WL 6981828 (E.D. Tex. Dec. 10, 2018) and the cases cited in GTP’s Response support
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`the conclusion that GTP’s factual allegations fail to provide Samsung with fair notice of the
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`grounds on which GTP’s direct infringement claim rests. The Court should dismiss GTP’s
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`allegations of direct infringement under § 271(a).
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`As an initial matter, GTP misreads this Court’s reasoning and holding in Chapterhouse.
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`GTP argues that because Samsung has not alleged a single entity theory for a patent with a system
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`claim that “Chapterhouse is easily distinguished from this case.” Response at 9. While it is true
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`1
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`

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`Case 2:21-cv-00040-JRG Document 34 Filed 05/18/21 Page 3 of 13 PageID #: 333
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`that in Chapterhouse the Court dismissed the allegations of direct infringement for one of the four
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`asserted patents on this basis, GTP ignores that the Court further dismissed direct infringement
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`allegations for all four patents because—as in this case—plaintiff failed to provide a sufficient
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`factual basis to establish a plausible allegation of patent infringement. Compare Chapterhouse,
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`2018 WL 6981828, at *2 (“Plaintiff must further allege how the screenshots meet the text of the
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`exemplary claim . . . . Accordingly, as to direct infringement of the ’087, ’989, ’356, and ’698
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`Patents, the Court GRANTS the Motion.”) with id. at *4 (“[T]here is no allegation that one entity
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`performs every step . . . . Accordingly, the Court GRANTS the Motion as to the ’356 Patent.”).
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`GTP also argues that Samsung fails to identify any case law requiring the Complaint to “explain
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`how the Accused Instrumentalities infringe the Asserted Patents,” appearing to suggest that GTP
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`has no obligation to plead such allegations. Response at 8. GTP again ignores this Court’s holding
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`in Chapterhouse that the “Plaintiff must further allege how the screenshots meet the text of the
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`exemplary claim . . . .” Chapterhouse, 2018 WL 6981828, at *2 (emphasis added). Chapterhouse
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`is directly on point because, as in Chapterhouse, GTP failed to link its screen shots to the
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`exemplary claim elements for even one Accused Feature, let alone all 24 Accused Features.
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`This conclusion is further supported by the other cases cited in GTP’s Response. First, in
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`those cases, the plaintiffs supplied a greater level of factual detail than GTP’s Complaint and did
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`not merely rely on screen shots to loosely couple a supposedly infringing product or function to
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`an asserted patent. See Iron Oak Techs., LLC v. Acer Am. Corp., No. 6:17-cv-00143-RP-JCM,
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`2017 U.S. Dist. LEXIS 221346, at *9–10 (W.D. Tex. Nov. 28, 2017) (finding the complaint
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`sufficient because it identified the process “that allegedly infringe[d],” “compare[d] the process[]
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`to the [asserted patent], and then gives specific examples of Acer product lines that allegedly
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`directly infringe . . .”); Uniloc USA, Inc. v. Avaya Inc., No. 6:15-cv-1168-JRG, 2016 U.S. Dist.
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`2
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`

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`Case 2:21-cv-00040-JRG Document 34 Filed 05/18/21 Page 4 of 13 PageID #: 334
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`LEXIS 181826, at *17 (E.D. Tex. May 13, 2016) (finding the complaint sufficient in part because
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`the plaintiff “described the accused functionality within these products, and provided descriptive
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`illustrations of these products and the accused functionality”). Unlike the cases GTP cites, GTP
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`does not compare the Accused Features to the Asserted Patents nor explain how any feature
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`allegedly infringes. Instead, GTP generally identifies 24 Accused Features, provides screenshots
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`for only an unspecified four of them, and fails to provide any further information tying the features
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`to the Asserted Patents.
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`Second, many of the cases GTP cites only involved a single accused product, without
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`multiple accused features. See Raytheon Co. v. Cray, Inc., No. 2:16-CV-00423-JRG-RSP, 2017
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`U.S. Dist. LEXIS 56729, at *10 (E.D. Tex. Mar. 12, 2017) (asserting four patents – identifying
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`one product and no accused features); Parity Networks, LLC v. Cisco Sys., No. 6:19-CV-00207-
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`ADA, 2019 U.S. Dist. LEXIS 144094, at *4 (W.D. Tex. July 26, 2019) (asserting four patents –
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`specifically identifying one representative system and representative product for each patent);
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`MAZ Encryption Techs. LLC v. BlackBerry Ltd., 6:15-cv-1167-RWS-JDL, 2016 U.S. Dist. LEXIS
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`191607, at *8–9 (asserting one patent – identifying one system with four specifically identified
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`subcomponents). Unlike such cases with single accused products and where plaintiff specifically
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`identified functions or subcomponents, here GTP accuses at least five different series of Samsung
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`mobile devices, five different individual products, and 24 different camera-related features. Yet,
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`at best, GTP attempts to link (unsuccessfully) only four of the 24 Accused Features to the asserted
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`claims by way of screenshots. GTP says nothing about the other features, many of which are so
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`vague that Samsung is unsure what feature is implicated, let alone how it might infringe.1
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`1 GTP points to its infringement contentions, served on April 28, 2021, as satisfying Samsung’s
`need to “understand more particularly how they [Samsung] infringe the Asserted Patents.”
`Response at 8. GTP’s contentions, however, are equally deficient if not more so. Samsung
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`3
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`

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`Case 2:21-cv-00040-JRG Document 34 Filed 05/18/21 Page 5 of 13 PageID #: 335
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`Contrary to GTP’s assertion that Samsung is “in effect, asking the Court to require that
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`detailed infringement contentions be included in the Complaint,” Response at 4, Samsung is
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`merely asking to enforce the “fair notice” standard that this and other courts have repeatedly
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`upheld. GTP’s own case citations confirm this conclusion. See Raytheon, 2017 U.S. Dist. LEXIS
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`56729, at *10 (“Lyda appears to require factual allegations sufficient to give rise to a plausible
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`inference that a device meets all elements of a specific claim.”) (citation omitted); Iron Oak, 2017
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`U.S. Dist. LEXIS 221346, at *7 (“However, [the ‘fair notice’ standard] does require a showing
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`that ‘each and every limitation set forth in a claim appears in the accused product.’”) (internal
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`citation omitted). GTP has failed to plead facts sufficient to give Samsung “fair notice of what the
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`claim is and the ground upon which it rests.” Disc Disease Sols. Inc. v. VGH Sols., Inc., 888 F.3d
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`1256, 1260 (Fed. Cir. 2018) (emphasis added) (citation omitted).
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`II.
`
`GTP CANNOT PLEAD FACTS TO SUPPORT ITS ALLEGATION THAT
`SAMSUNG KNEW OF, OR WAS WILLFULLY BLIND TO, THE ASSERTED
`PATENTS BEFORE THE PATENTS EXPIRED
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`GTP’s claims under §§ 271(b) and 284 should be dismissed with prejudice because GTP
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`cannot plead facts alleging Samsung’s knowledge of the Asserted Patents before they expired.
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`Mot. at 8–12. It is black letter law that a defendant cannot infringe what the plaintiff does not own,
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`and GTP did not own a present interest in the Asserted Patents’ claimed invention when it filed
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`the Complaint on February 4, 2021. At most, GTP held an interest in recovery for alleged past
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`infringement of the invention. Thus, alleging Samsung had knowledge of the Asserted Patents
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`“as of the filing of this Complaint” is irrelevant. Because GTP can only speculate that Samsung
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`knew of the Asserted Patents before they expired, and cannot plead any facts in support of such
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`speculation, GTP’s claims for induced infringement and willful infringement must fail.
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`informed GTP of these deficiencies in a letter dated May 7, 2021, five days prior to the filing of
`GTP’s Response. GTP has not yet responded as to the substance of that letter.
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`4
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`

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`Case 2:21-cv-00040-JRG Document 34 Filed 05/18/21 Page 6 of 13 PageID #: 336
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`A.
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`GTP Cannot Plead Facts to Support Its Allegation That Samsung Knew of
`the Asserted Patents Before the Patents Expired
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`GTP argues that alleging Samsung’s knowledge “as of the filing of th[e] Complaint” is
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`“sufficient at the pleading stage.” Response at 10. GTP is incorrect. To sustain a claim for relief
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`under §§ 271(b) and 284, GTP must plead that Samsung had knowledge of the Asserted Patents
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`“for at least some time during the infringing period.” Lochner Techs., LLC v. AT Labs Inc., No.
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`2:11-cv-242-JRG, 2012 WL 2595288, at *3 (E.D. Tex. July 5, 2012) (emphasis added); Cellular
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`Commc’ns Equip. LLC v. HTC Corp., No. 6:13-cv-507, 2015 WL 11118110, at *6 (E.D. Tex. Mar.
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`27, 2015) (noting that pleading defendant’s knowledge for § 271(b) applies equally to § 284). GTP
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`ignores this legal and factual reality, and instead quotes snippets from inapposite case law to argue
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`that “pre-suit” and “post-suit” claims should not be evaluated separately. Response at 9–10. But
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`the cases cited by GTP all involved patents that had not expired pre-suit, so “post-suit” claims
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`under §§ 271(b) and 284 were still plausible at the pleading stage. In contrast here, Samsung’s
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`alleged culpability cannot possibly arise “post-suit” because the Asserted Patents were already
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`expired. GTP’s claims for relief therefore depend entirely on pleading facts alleging Samsung’s
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`“pre-suit” knowledge of the Asserted Patents—and GTP has none to offer.
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`GTP’s reliance on Lochner Technologies is exemplary of its selective presentation of the
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`case law. There, like GTP in the present case, plaintiff (“Lochner”) alleged that “[e]ach defendant
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`had knowledge of the [asserted patent] at least as early as the filing of the original complaint.” Ex.
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`4 ¶ 19 (No. 2:11-cv-00242-JRG, Dkt. No. 64).2 But unlike GTP, Lochner further alleged that
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`“[e]ach defendant has been and now is jointly and indirectly infringing by way of inducing
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`2 Samsung respectfully requests that the Court take judicial notice of Exhibit 4 and other publicly
`available filings in this District and in those cases cited by GTP in its Response. Innova Hosp. San
`Antonio, Ltd. P’ship v. Blue Cross & Blue Shield of Ga., Inc., 892 F.3d 719, 726 (5th Cir. 2018);
`Mot. at nn.8–9. See also Exs. 5–8.
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`5
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`

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`Case 2:21-cv-00040-JRG Document 34 Filed 05/18/21 Page 7 of 13 PageID #: 337
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`infringement by others.” Id. (emphasis added). As GTP points out in its Response, this Court
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`rejected defendant’s arguments that there was a “pleading deficiency at least with respect to any
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`allegedly infringing activities that pre-date the filing of the Original Complaint.” Response at 9.
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`GTP omitted the next sentence, though, which explained the Court’s reasoning:
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`However, this is not a basis to dismiss Lochner’s indirect infringement claims; as
`it cannot be disputed that Lochner does sufficiently plead that the Moving
`Defendants had knowledge of the asserted patent for at least some time during the
`infringing period.
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`Lochner Techs., 2012 WL 2595288, at *3. In sum, this Court held that, despite the absence of
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`facts as to pre-suit knowledge, Lochner’s allegation of ongoing infringement after the filing of the
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`complaint pled defendant’s knowledge for “at least some time during the infringing period.” Here,
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`on the other hand, alleging Samsung knew of the Asserted Patents “at least as of the filing of this
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`Complaint” does not plead Samsung’s knowledge “for at least some time during the infringing
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`period.” Following the reasoning of Lochner Technologies, GTP’s claims inescapably require
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`facts alleging Samsung’s “pre-suit” knowledge.
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`GTP omits the critical importance of pleading knowledge during the allegedly infringing
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`period when citing its other cases, as well. For example, in Cellular Communications Equipment
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`LLC v. HTC Corp., plaintiff alleged that defendant Dell “continues to directly and/or indirectly
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`infringe,” 3 and that the other defendants “garnered pre-suit knowledge by virtue of their
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`involvements” with 3GPP. 2015 WL 11118110, at *4. See also InMotion Imagery Techs. v. Brain
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`Damage Films, No. 2:11-cv-414-JRG, 2012 WL 3283371, at *1 (E.D. Tex. Aug. 10, 2012) (citing
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`complaint alleging that defendant “continues to infringe”); Estech Sys., Inc. v. Target Corp., No.
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`2:20-cv-00123-JRG-RSP, 2020 WL 6534094, at *4 (E.D. Tex. Aug. 27, 2020) (citing complaint
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`3 Ex. 5 ¶ 16 (No. 6:13-cv-00569-KNM, Dkt. No. 31) (emphasis added).
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`6
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`

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`Case 2:21-cv-00040-JRG Document 34 Filed 05/18/21 Page 8 of 13 PageID #: 338
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`alleging that defendants “are performing these steps”). Indeed, even the plaintiff in Alacritech Inc.
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`v. CenturyLink, Inc. recognized the legal import of expired patents on pleading defendant’s
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`knowledge. There, as in the other cases, plaintiff (“Alacritech”) alleged a plausible claim for relief
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`of post-filing induced infringement. Ex. 6 ¶ 41 (No. 2:16-cv-00696-RWS-RSP, Dkt. No. 29).
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`Alacritech argued this in opposing defendant’s motion to dismiss:
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`[N]one of the asserted patents in this case have expired and they are all enforceable
`against post-filing indirect infringement. . . . [I]t cannot be disputed that Alacritech
`does sufficiently plead that CenturyLink had knowledge of the asserted patent for
`at least some time during the infringing period and, thus, an absence of allegations
`concerning pre-suit knowledge of the asserted patents is not a basis to dismiss . . .
`indirect infringement claims.
`
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`Ex. 7 at 9–10 (No. 2:16-cv-00693-RWS-RSP, Dkt. No. 60) (emphasis in original).
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`Here, “an absence of allegations concerning [Samsung’s] pre-suit knowledge” cannot be
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`saved by the generic allegation GTP sets forth in its Complaint, and which plaintiffs alleged in
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`these other cases cited in GTP’s Response (i.e., that defendant had knowledge based on the filing
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`of the complaint). See also, e.g., Uniloc USA, Inc. v. Motorola Mobility LLC, No. 2:16-cv-992,
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`2017 WL 3721064, at *4 (E.D. Tex. May 15, 2017) (“Uniloc alleges post-filing knowledge of the
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`patents-in-suit as its basis for induced infringement”). Unlike those cases, the Asserted Patents’
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`pre-suit expiration means that GTP cannot possibly state a plausible claim for post-suit
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`infringement. As a result, in order to allege that Samsung knew of the Asserted Patents “for at
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`least some time during the infringing period,” GTP must necessarily plead facts of Samsung’s
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`“pre-suit” knowledge. Compare Mot. at 10 (“Apple had knowledge of the ’924 patent as least as
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`early as June 2016, when GTP contacted Apple in an attempt to license the Asserted Patents.”).
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`GTP’s contrary arguments are unavailing. Response at 1, 9–10.
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`Finally, GTP relies on a 2013 opinion from the Northern District of California for the
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`proposition that knowledge of expired patents can give rise to a claim for willful infringement.
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`7
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`

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`Case 2:21-cv-00040-JRG Document 34 Filed 05/18/21 Page 9 of 13 PageID #: 339
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`But GTP’s Response again addresses only a snippet of that case. FuzzySharp Techs. Inc. v. Nvidia,
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`Corp, No. 3:12-cv-06375-JST, 2013 WL 4766877, at *3 (N.D. Cal. Sept. 4, 2013). In FuzzySharp,
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`defendant (“NVIDIA”) conceded it knew of the asserted patents well before the patents expired.
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`Id.; Ex. 8 at 3 (No. 3:12-cv-06375-JST, Dkt. No. 31). It was against this backdrop that the court
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`stated that “pre-suit expiration of a patent is not dispositive of a claim for willful infringement.”
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`Id. Response at 12. By not providing context to this quote, GTP obfuscates the legal requirement
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`that liability for willful infringement (or induced infringement) requires knowledge of the patent
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`“during the term of the patent.” 35 U.S.C. § 271; Commil USA, LLC v. Cisco Sys., Inc., 575 U.S.
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`632, 642 (2015). Unlike NVIDIA, Samsung never conceded that it knew of the Asserted Patents
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`before their expiration—nor has GTP pled that Samsung had pre-expiration knowledge. GTP’s
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`claims for §§ 271(b) and 284 liability should be dismissed.
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`B.
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`GTP Cannot Plead Facts to Support Its Allegation That Samsung Was
`Willfully Blind to the Asserted Patents Before the Patents Expired
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`GTP argues that it properly alleged Samsung was willfully blind to the Asserted Patents’
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`existence. Response at 11. GTP accuses Samsung of “semantic gymnastics,” and represents that
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`its willful blindness allegation “is directly analogous to the allegations in Motiva Patents that the
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`Court found sufficient.” Id. Not so.
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`In Motiva Patents, plaintiff (“Motiva”) pled the following to support its allegation of
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`defendant’s willful blindness:
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`Furthermore, on information and belief, Defendant has a policy or
`72.
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`practice of not reviewing the patents of others (including instructing its employees
`to not review the patents of others), and thus has been willfully blind of Motiva’s
`patent rights.
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`Defendant’s actions are at least objectively reckless as to the risk of
`73.
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`infringing a valid patent and this objective risk was either known or should have
`been known by Defendant.
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`
`8
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`

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`Case 2:21-cv-00040-JRG Document 34 Filed 05/18/21 Page 10 of 13 PageID #: 340
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`Defendant’s direct and indirect infringement of the Asserted Patents
`74.
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`is, has been, and continues to be willful, intentional, deliberate, and/or in conscious
`disregard of Motiva’s rights under the patent.
`
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`Mot. Ex. 3 ¶¶ 72–74. Of these three allegations, GTP’s allegation is “analogous” to only ¶ 74.
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`Response at 11–12, Mot. at 13 (describing how GTP’s allegation is “nearly identical” to ¶ 74 of
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`the Motiva complaint). But the Court in Motiva Patents determined that it was the facts alleged
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`in ¶ 72 (and not the legal conclusions alleged in ¶ 74) that established “a factual basis for willful
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`blindness.” Motiva Patents, LLC v. Sony Corp., 408 F. Supp. 3d 819, 833 (E.D. Tex. 2019) (“The
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`Complaint includes two factual allegations addressed to willful blindness, each of which is
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`independently sufficient to satisfy the plausibility standard under Twombly.”). This Court noted
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`that in ¶ 72, “Motiva alleges a specific policy which gives rise to willful blindness. . . . Creating a
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`policy prohibiting review of patents is a specific kind of deliberate action to avoid learning of
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`potential infringement.” Id. (internal quotations omitted). Further, the Court determined that
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`Motiva alleged “specific acts to implement and enforce its policy,” which could “plausibly suggest
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`that additional discovery will reveal evidence in support of Motiva’s claim.” Id. at 834 (quoting
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`Motiva’s complaint ¶ 72). As GTP cannot set forth any “factual basis” to allege Samsung’s willful
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`blindness, GTP’s claims for §§ 271(b) and 284 liability should be dismissed.
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`C.
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`GTP Sets Forth Legal Conclusions, Not Facts
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`Lastly, GTP lists three bullet points to argue that it “properly pled” Samsung’s “intent” to
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`induce infringement. Response at 10–11. But these bullet points do not set forth any “factual
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`basis” to allege that Samsung knew of the Asserted Patents to begin with. And if Samsung did not
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`know of the patents, Samsung could not have had any “intent” to induce infringement. Moreover,
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`the bullet points merely recite causes of action for induced infringement and willful infringement,
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`and restate the same legal conclusions GTP made in its Complaint. See Mot. at 9-10, 13. But legal
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`conclusions (i.e., Samsung’s actions were “willful”) must be supported by factual allegations.
`
`9
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`

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`Case 2:21-cv-00040-JRG Document 34 Filed 05/18/21 Page 11 of 13 PageID #: 341
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`Ashcroft v. Iqbal, 556 U.S. 662, 679 (2009). Merely alleging that Samsung acted “with the
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`knowledge of the [Asserted Patents]” is not enough. Cf. Mot. at 10 (“Discussions with Apple”).
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`See also Meetrix IP, LLC v. Cisco Sys., Inc., No. 1:18-cv-309-LY, 2018 WL 8261315, at *3 (W.D.
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`Tex. Nov. 30, 2018) (“Meetrix’s legal conclusion that Cisco ‘was willfully blind to the Patents-in-
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`Suit’ lacks supporting factual allegations”).
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`GTP again selectively quotes snippets from cases to argue that its legal conclusions meet
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`the federal pleading standards. Response at 11. But the Court in Estech Systems found the
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`complaint sufficient not just because plaintiff alleged “the elements” for §§ 271(b) and 284
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`liability, but also because plaintiff “provide[d] facts to support [its] allegations” of defendant’s
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`“knowledge of the patent.” 2020 WL 6534094, at *4–5. Here, unlike the plaintiff in Estech
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`Systems, GTP has not “provide[d] facts to support [its] allegations” of Samsung’s knowledge.
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`GTP’s reliance on Alacritech is similarly misplaced, because there, plaintiff “[did] not contest it
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`did not plead facts concerning pre-suit knowledge.” 2017 WL 4230582, at *2. If GTP takes the
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`same position, its claims for §§ 271(b) and 284 relief will necessarily fail.
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`III. GTP SHOULD NOT BE GRANTED LEAVE TO AMEND
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`GTP has not satisfied its pleading obligations at this stage of the case and has not raised a
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`plausible claim for relief. Samsung respectfully requests that the Court grant its Motion, and
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`dismiss GTP’s claims of patent infringement with prejudice. Alternatively, if the Court finds that
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`GTP’s Complaint may be remedied through Rule 15(a), Response at 13, Samsung requests that
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`the Court permit GTP to amend only its direct infringement claims.
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`IV. CONCLUSION
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`For the foregoing reasons, and the reasons set forth in Samsung’s Motion to Dismiss,
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`GTP’s complaint should be dismissed in its entirety.
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`
`
`10
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`

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`Case 2:21-cv-00040-JRG Document 34 Filed 05/18/21 Page 12 of 13 PageID #: 342
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`DATED: May 18, 2021
`
`
`Respectfully submitted,
`
`
`By: /s/ Christopher W. Kennerly
`Christopher W. Kennerly (TX Bar No. 00795077)
`chriskennerly@paulhastings.com
`Radhesh Devendran (pro hac vice)
`radheshdevendran@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
`
`Melissa R. Smith (TX Bar No. 24001351)
`GILLAM & SMITH, LLP
`303 S. Washington Ave.
`Marshall, TX 75670
`Telephone: (903) 934-8450
`Facsimile: (903) 934-9257
`melissa@gillamsmithlaw.com
`
`Attorneys for Defendants Samsung Electronics
`Co., Ltd and Samsung Electronics America, Inc.
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`Case 2:21-cv-00040-JRG Document 34 Filed 05/18/21 Page 13 of 13 PageID #: 343
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`CERTIFICATE OF SERVICE
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`I hereby certify that a true and correct copy of the foregoing document was filed
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`electronically in compliance with Local Rule CV-5 on May 18, 2021. As of this date, all counsel
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`of record had consented to electronic service and are being served with a copy of this document
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`through the Court’s CM/ECF system under Local Rule CV-5(a)(3)(A).
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` /s/ Christopher W. Kennerly
`Christopher W. Kennerly
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