Case 2:21-cv-00040-JRG Document 51-4 Filed 06/29/21 Page 1 of 6 PageID #: 553
`
`Exhibit 4
`
`
`
`Exhibit 4
`
`
`
`Case 2:21-cv-00040-JRG Document 51-4 Filed 06/29/21 Page 2 of 6 PageID #: 554
`
`From:
`To:
`Cc:
`Subject:
`Date:
`
`Kennerly, Christopher W.
`Fred Williams
`GTP Counsel WSL; Team Samsung GTP; Melissa Smith; "Travis Underwood"
`RE: GTP v. Samsung, et al., No. 2:21-cv-00040-JRG
`Friday, May 28, 2021 1:09:19 PM
`
`Fred,
`
`Thank you for the update and we’ll look forward to reviewing GTP’s amended contentions next week. We understand GTP’s reservation of
`rights, and Samsung similarly reserves its rights.
`
`In the same vein, our ongoing investigation of the Accused Products has revealed an additional issue. We have confirmed with Samsung that
`11 of the Accused Products, listed below, are not sold in the United States and never have been. Therefore, these 11 Accused products
`should also be removed from the list and GTP’s allegations against those products should be withdrawn. Please confirm.
`
`
` Model
`1 Galaxy S6 Edge+ Duos
`2 Galaxy S5 Neo
`3 Galaxy Note Fan Edition
`4 Galaxy Z1
`5 Galaxy Z2
`6 Galaxy Z3
`7 Galaxy Z3 Corporate
`8 Galaxy Z4
`9 Metro 360
`10 S Light Luxury
`11 Xcover 550
`
`
`Best regards,
`Chris
`
`
`From: Fred Williams <fwilliams@wsltrial.com>
`Sent: Friday, May 28, 2021 10:18 AM
`To: Kennerly, Christopher W. <chriskennerly@paulhastings.com>
`Cc: GTP Counsel WSL <gtpcounselwsl@wsltrial.com>; Team Samsung GTP <TeamSamsungGTP@paulhastings.com>; Melissa Smith
`<Melissa@gillamsmithlaw.com>; 'Travis Underwood' <Travis@gillamsmithlaw.com>
`Subject: [EXT] RE: GTP v. Samsung, et al., No. 2:21-cv-00040-JRG
`
`Chris,
`
`We have reviewed the infringement contentions again and continue to believe that they are in compliance with the local rules. However, in
`the interest of avoiding burdening the court with this issue, GTP will be serving amended infringement contentions for Samsung next week.
` These amended contentions are intended to clean up the applications referenced and provide some more insight as to the publicly available
`information. Again to reiterate, we believe that the initial contentions comply with the Rule and are making this effort to avoid unnecessary
`motion practice. In the meantime, have a great holiday weekend.
`
`Fred
`
`
`From: Kennerly, Christopher W. <chriskennerly@paulhastings.com>
`Sent: Tuesday, May 25, 2021 4:21 PM
`To: Fred Williams <fwilliams@wsltrial.com>
`Cc: GTP Counsel WSL <gtpcounselwsl@wsltrial.com>; Team Samsung GTP <TeamSamsungGTP@paulhastings.com>; Melissa Smith
`<Melissa@gillamsmithlaw.com>; 'Travis Underwood' <Travis@gillamsmithlaw.com>
`Subject: RE: GTP v. Samsung, et al., No. 2:21-cv-00040-JRG
`
`You’re correct – update coming
`
`From: Fred Williams <fwilliams@wsltrial.com>
`Sent: Tuesday, May 25, 2021 2:16 PM
`To: Kennerly, Christopher W. <chriskennerly@paulhastings.com>
`
`
`
`Case 2:21-cv-00040-JRG Document 51-4 Filed 06/29/21 Page 3 of 6 PageID #: 555
`
`Cc: GTP Counsel WSL <gtpcounselwsl@wsltrial.com>; Team Samsung GTP <TeamSamsungGTP@paulhastings.com>; Melissa Smith
`<Melissa@gillamsmithlaw.com>; 'Travis Underwood' <Travis@gillamsmithlaw.com>
`Subject: [EXT] RE: GTP v. Samsung, et al., No. 2:21-cv-00040-JRG
`
`Thanks. The calendar invite says 530 central on my calendar. Are we confirmed for 430 central?
`
`From: Kennerly, Christopher W. <chriskennerly@paulhastings.com>
`Sent: Monday, May 24, 2021 4:04 PM
`To: Fred Williams <fwilliams@wsltrial.com>; Matthew Rozier <mrozier@wsltrial.com>
`Cc: GTP Counsel WSL <gtpcounselwsl@wsltrial.com>; Team Samsung GTP <TeamSamsungGTP@paulhastings.com>; Melissa Smith
`<Melissa@gillamsmithlaw.com>; 'Travis Underwood' <Travis@gillamsmithlaw.com>
`Subject: RE: GTP v. Samsung, et al., No. 2:21-cv-00040-JRG
`
`Yes, that works for us. We’ll send an invite.
`
`From: Fred Williams <fwilliams@wsltrial.com>
`Sent: Monday, May 24, 2021 1:49 PM
`To: Matthew Rozier <mrozier@wsltrial.com>; Kennerly, Christopher W. <chriskennerly@paulhastings.com>
`Cc: GTP Counsel WSL <gtpcounselwsl@wsltrial.com>; Team Samsung GTP <TeamSamsungGTP@paulhastings.com>; Melissa Smith
`<Melissa@gillamsmithlaw.com>; 'Travis Underwood' <Travis@gillamsmithlaw.com>
`Subject: [EXT] Re: GTP v. Samsung, et al., No. 2:21-cv-00040-JRG
`
`Thanks, Chris. Are you available on Wednesday at 430 Central?
`
`From: Kennerly, Christopher W. <chriskennerly@paulhastings.com>
`Sent: Friday, May 21, 2021 11:47:48 AM
`To: Matthew Rozier <mrozier@wsltrial.com>
`Cc: GTP Counsel WSL <gtpcounselwsl@wsltrial.com>; Team Samsung GTP <TeamSamsungGTP@paulhastings.com>; Melissa Smith
`<Melissa@gillamsmithlaw.com>; 'Travis Underwood' <Travis@gillamsmithlaw.com>
`Subject: RE: GTP v. Samsung, et al., No. 2:21-cv-00040-JRG
`
`Matt,
`
`In the meet and confer on Wednesday, May 19 regarding GTP’s infringement contentions, GTP committed to provide a written response to
`my letters of May 7 and May 19. We look forward to GTP’s response early next week. GTP also committed to provide its availability to
`further meet and confer next Wednesday, May 26. Please propose a time so we can get that call scheduled.
`
`Regards,
`Chris
`
`
`From: Matthew Rozier <mrozier@wsltrial.com>
`Sent: Tuesday, May 18, 2021 7:52 PM
`To: Kennerly, Christopher W. <chriskennerly@paulhastings.com>
`Cc: GTP Counsel WSL <gtpcounselwsl@wsltrial.com>; Team Samsung GTP <TeamSamsungGTP@paulhastings.com>; Melissa Smith
`<Melissa@gillamsmithlaw.com>
`Subject: [EXT] Re: GTP v. Samsung, et al., No. 2:21-cv-00040-JRG
`
`Yes, please do.
`
`From: Kennerly, Christopher W. <chriskennerly@paulhastings.com>
`Date: Tuesday, May 18, 2021 at 8:02 PM
`To: Matthew Rozier <mrozier@wsltrial.com>
`Cc: GTP Counsel WSL <gtpcounselwsl@wsltrial.com>, Team Samsung GTP <TeamSamsungGTP@paulhastings.com>, Melissa Smith
`<Melissa@gillamsmithlaw.com>
`Subject: RE: GTP v. Samsung, et al., No. 2:21-cv-00040-JRG
`
`Yes that works. Would you like us to send a calendar invitation?
`
`Thanks,
`Chris
`
`
`
`
`Case 2:21-cv-00040-JRG Document 51-4 Filed 06/29/21 Page 4 of 6 PageID #: 556
`
`From: Matthew Rozier <mrozier@wsltrial.com>
`Sent: Tuesday, May 18, 2021 1:12 PM
`To: Kennerly, Christopher W. <chriskennerly@paulhastings.com>
`Cc: GTP Counsel WSL <gtpcounselwsl@wsltrial.com>; Team Samsung GTP <TeamSamsungGTP@paulhastings.com>; Melissa Smith
`<Melissa@gillamsmithlaw.com>
`Subject: [EXT] RE: GTP v. Samsung, et al., No. 2:21-cv-00040-JRG
`
`Chris,
`
`We are available to talk on this issue at 3pm Central time tomorrow (Wednesday). Would that work for your team?
`
`Thanks,
`
`Matt
`
`From: Kennerly, Christopher W. <chriskennerly@paulhastings.com>
`Sent: Tuesday, May 18, 2021 11:04 AM
`To: Matthew Rozier <mrozier@wsltrial.com>
`Cc: GTP Counsel WSL <gtpcounselwsl@wsltrial.com>; Team Samsung GTP <TeamSamsungGTP@paulhastings.com>; Melissa Smith
`<Melissa@gillamsmithlaw.com>
`Subject: RE: GTP v. Samsung, et al., No. 2:21-cv-00040-JRG
`
`Matt,
`
`Please advise as to Samsung’s request to meet and confer.
`
`Regards,
`Chris
`
`From: Matthew Rozier <mrozier@wsltrial.com>
`Sent: Friday, May 14, 2021 1:21 PM
`To: Kennerly, Christopher W. <chriskennerly@paulhastings.com>
`Cc: GTP Counsel WSL <gtpcounselwsl@wsltrial.com>; Team Samsung GTP <TeamSamsungGTP@paulhastings.com>; Melissa Smith
`<Melissa@gillamsmithlaw.com>
`Subject: [EXT] Re: GTP v. Samsung, et al., No. 2:21-cv-00040-JRG
`
`Chris,
`
`We are coordinating schedules on our end and will provide some availability for next week shortly.
`
`Matt
`
`
`On May 14, 2021, at 1:40 PM, Kennerly, Christopher W. <chriskennerly@paulhastings.com> wrote:
`
`C
`
`ounsel,
`
`
`This is to follow up on my letter of May 7, 2021 (attached). Kindly let me know when GTP is available next Monday or Tuesday
`to meet and confer regarding its infringement contentions and the related issues discussed in the letter.
`
`Regards,
`Chris
`
`From: O'Brien, Karen R. <karenobrien@paulhastings.com>
`Sent: Friday, May 7, 2021 2:46 PM
`To: 'Matthew Rozier' <mrozier@wsltrial.com>
`Cc: GTP Counsel WSL <gtpcounselwsl@wsltrial.com>; Team Samsung GTP <TeamSamsungGTP@paulhastings.com>; Melissa
`Smith <Melissa@gillamsmithlaw.com>
`Subject: GTP v. Samsung, et al., No. 2:21-cv-00040-JRG
`
`Counsel,
`
`
`
`
`Case 2:21-cv-00040-JRG Document 51-4 Filed 06/29/21 Page 5 of 6 PageID #: 557
`
`Attached please find correspondence from Chris Kennerly regarding the above matter.
`
`Regards,
`Karen
`
`<image001.png>
`
`
`Karen O'Brien | Client Service Specialist
`Paul Hastings LLP | 4747 Executive Drive, Twelfth Floor, San Diego, CA 92121 | Cell: (760) 533-
`8435 | Direct: +1.858.458.2021 | Main: +1.858.458.3000 | Fax: +1.858.458.3005 |
`karenobrien@paulhastings.com | www.paulhastings.com
`
`
`
`
`
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`<2021-05-07 GTP v. Samsung re Plaintiffs Disclosure of Asserted Claims and Infringement Contentions.pdf>
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`Case 2:21-cv-00040-JRG Document 51-4 Filed 06/29/21 Page 6 of 6 PageID #: 558
`
`email and delete this email from your system. Thank You.
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