`
`Exhibit 9
`
`
`
`Case 2:21-cv-00040-JRG Document 51-9 Filed 06/29/21 Page 2 of 3 PageID #: 664
`
`Fred I. Williams
`Williams Simons & Landis PLLC
`Direct: 512.543.1356
`fwilliams@wsltrial.com
`
`June 28, 2021
`
`Chris Kennerly
`Paul Hastings LLP
`1117 S. California Avenue
`Palo Alto, CA 94304
`
`Re: Gesture Technology Partners LLC v. Samsung Electronics Co. LTD., et al., Plaintiff’s
`Amended Infringement Contentions
`
`Dear Mr. Kennerly,
`
`On behalf of Gesture Technology Partners LLC (“GTP”), we write in response to Samsung
`Electronics Co., Ltd. and Samsung Electronics America, Inc.’s (collectively, “Samsung”) letter
`dated June 21, 2021, regarding GTP’s Amended Infringement Contentions with respect to U.S.
`Patents 8,194,924 (“’924 Patent”); 7,933,431 (“’431 Patent”); 8,878,949 (“’949 Patent”); and
`8,553,079(“’079 Patent”) (collectively, the “Asserted Patents”).
`
`Again, we disagree with your assertion that GTP has failed to comply with local Patent
`Rule 3-1(b) regarding GTP’s Amended Infringement Contentions. GTP has provided ample
`information in its Amended Infringement Contentions to place Samsung on notice of GTP’s
`allegations under any proper reading of the local patent rules.
`
`After reviewing the Samsung Galaxy Note Fan Edition, GTP agrees that it should not have
`been included and should no longer be considered part of GTP’s operative infringement
`contentions. Regarding the Samsung Galaxy S5, GTP does not believe that its addition is
`improper. The complaint accuses the entire Galaxy S line, and GTP’s original infringement
`contentions included the Galaxy S5 Neo, a variation of the Galaxy S5, but unintentionally excluded
`the Galaxy S5. The addition of the Galaxy S5 does not prejudice Samsung.
`
`Regarding “Live Masks Track/Apply” and the other listed feature, the features are merely
`examples. Samsung is again attempting to categorize GTP’s infringement theories using “Accused
`Features,” but GTP has not labeled anything as an “Accused Feature” in its infringement
`contentions. GTP’s Amended Infringement Contentions make it clear that it is the “gestures
`associated with” the example listed features, along with hardware and software components, that
`meet the claim limitations. Furthermore, GTP has provided numerous example links, including
`links from Samsung’s website, that discuss how gestures are used with the Accused Products.
`
`327 Congress Avenue, Suite 490, Austin, Texas 78701
`
`
`
`Case 2:21-cv-00040-JRG Document 51-9 Filed 06/29/21 Page 3 of 3 PageID #: 665
`
`June 28, 2021 Page 2
`
`GTP has made good faith efforts to satisfy Samsung’s concerns about GTP’s infringement
`contentions yet, Samsung continues to improperly demand that GTP marshal all its evidence and
`layout its infringement case at this juncture of the case. GTP has adequately satisfied the local
`patent rules and is not under any obligation to continue to amend its infringement contentions at
`this time.
`
`Sincerely,
`
`Fred I. Williams
`
`
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