`
`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.
`
`DECLARATION OF DAVID M. FOX IN SUPPORT OF DEFENDANTS’ REPLY IN
`SUPPORT OF MOTION FOR LEAVE TO AMEND INVALIDITY CONTENTIONS
`
`I, David M. Fox, hereby declare as follows:
`
`1.
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`I am an attorney at the law firm Paul Hastings LLP, counsel of record for Samsung
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`Electronics Co., Ltd. and Samsung Electronics America, Inc. (collectively, “Samsung”) in this
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`action. I have personal knowledge of the facts herein and, if called as a witness, I could and would
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`testify competently as to their truth.
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`2.
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`Attached hereto as Exhibit C is a true and correct version of the video file produced
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`by Mitsubishi Electric Research Laboratories, Inc. in response to Samsung’s subpoena.
`
`
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`Case 2:21-cv-00040-JRG Document 94-1 Filed 10/12/21 Page 2 of 2 PageID #: 2227
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`3.
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`Attached hereto as Exhibit D are true and correct copies of five publications
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`produced by the Beckman Institute, University of Illinois at Urbana-Champaign, in response to
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`Samsung’s subpoena.
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`I declare under penalty of perjury under the laws of the State of California that the
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`foregoing is true and correct. Executed this 12th day of October, 2021 in Palo Alto, California.
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`
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`/s/ David M. Fox
`David M. Fox
`
`
`
`
`
`-2-
`
`