Case 2:21-cv-00040-JRG Document 54-3 Filed 07/14/21 Page 1 of 3 PageID #: 794
`Case 2:21-cv-00040-JRG Document 54-3 Filed 07/14/21 Page 1 of 3 PageID #: 794
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`EXHIBIT 3
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`EXHIBIT 3
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`Case 2:21-cv-00040-JRG Document 54-3 Filed 07/14/21 Page 2 of 3 PageID #: 795
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`May 19, 2021
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`
`VIA E-MAIL
`
`Fred Williams
`Williams Simons & Landis PLLC
`327 Congress Ave., Suite 490
`Austin, TX 78701
`
`
`Re:
`
`Gesture Technology Partners LLC v. Samsung Electronics Co. LTD., et al., Plaintiff’s Disclosure
`of Asserted Claims and Infringement Contentions
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`Counsel:
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`On behalf of Samsung Electronics Co., Ltd. and Samsung Electronics America, Inc. (together,
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`“Samsung”), we write to follow up on our letter of May 7, 2021 regarding certain additional deficiencies in
`GTP’s infringement contentions.
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`At least two of the Accused Features identified by GTP in its infringement contentions appear to be
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`features of products sold by other companies. For example, for Claim 27 of the ’431 Patent, GTP identifies
`websites describing Google’s Motion Sense technology, which was released only on the Google Pixel 4
`series, not on Samsung phones nor on Android phones generally. See ’431 Patent claim chart at 21 (citing
`https://venturebeat.com/2019/10/21/googles-motion-sense-hands-on-controlling-games-and-apps-with-
`gestures/ (“Google’s Motion Sense hands-on: Controlling games and apps with gestures … After a little
`over four years in development, Soli emerged in the Pixel 4 series as the gesture-detecting Motion Sense.
`… The Pixel 4 series implementation is a bit more conservative than that used in onstage demos to date,
`for better or worse. … Swiping a finger above the Pixel 4’s or Pixel 4 XL’s screen prompts a reaction from
`one of five selectable Pokémon, while an upward swipe reveals a dashboard with each one’s height, weight,
`type, and ability stats. …”)). Please confirm that GTP will promptly withdraw all infringement allegations
`with respect to Google’s Motion Sense technology, including dropping its allegations as to Claim 27 of the
`’431 Patent, which relies solely on Google’s Motion Sense technology.
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`Similarly, the Smile Shutter feature appears to be a feature of Sony cameras, not Samsung phones
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`nor Android phones generally.1 Please confirm that GTP will promptly withdraw all infringement allegations
`with respect to the Smile Shutter feature.
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`We also note that GTP’s complaint identifies the “Galaxy M Series,” yet none of the 35 Accused
`Products are from the M Series. Please confirm that GTP will promptly withdraw all infringement allegations
`with respect to the Galaxy M series.
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`Finally, GTP accuses at least two products—the Samsung Metro 360 and Samsung Xcover 550—
`that it concedes do not have two cameras or a light source, and thus cannot meet the claims of at least the
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`1 See
`https://www.google.com/search?q=%22smile+shutter%22&rlz=1C1GCEJ_enUS844US844&oq=%22smil
`e+shutter%22&aqs=chrome.0.69i59j0j0i22i30l3.2014j0j7&sourceid=chrome&ie=UTF-8.
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`Case 2:21-cv-00040-JRG Document 54-3 Filed 07/14/21 Page 3 of 3 PageID #: 796
`Case 2:21-cv-00040-JRG Document 54-3 Filed 07/14/21 Page 3 of 3 PagelD #: 796
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`PAUL
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`HASTINGS
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`Fred Williams
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`May 19, 2021
`Page 2
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`’924. '079, and ‘949 Patents. Please confirm that GTF' is not alleging infringement of any of these patents
`with respect to these two products.
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`As noted previously, Samsung would strongly prefer to resolve these issues without seeking the
`Court’s assistance. We look forward to meeting and conferring with you this afternoon regarding the issues
`raised in our letters.
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`Regards.
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`5/ f-..
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`Chris Kennerly
`of PAUL HASTINGS LLP
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`