`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE WESTERN DISTRICT OF TEXAS
`WACO DIVISION
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`GESTURE TECHNOLOGY PARTNERS,
`LLC,
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`Plaintiff,
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`v.
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`APPLE INC.,
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`Civil Action No. 6:21-cv-00121-ADA
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`JURY TRIAL DEMANDED
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`Defendant.
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`JOINT NOTICE OF VENUE AND JURISDICTIONAL DISCOVERY REGARDING
`APPLE INC.’S OPPOSED MOTION TO TRANSFER VENUE
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`Plaintiff Gesture Technology Partners, LLC (“GTP” or “Plaintiff”) and Defendant Apple
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`Inc. (“Apple” or “Defendant”) file this Joint Notice of Venue and Jurisdictional Discovery
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`Regarding Apple Inc.’s Opposed Motion to Transfer Venue Pursuant To 28 U.S.C. § 1404(a) (Dkt.
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`No. 21) (the “Motion to Transfer”), as follows:
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`Defendant filed the Motion to Transfer on July 30, 2021. Under the governing rules, GTP’s
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`response would be due on August 13, 2021. However, GTP has notified Defendant that, in order
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`to adequately respond to the Motion to Transfer, it intends to conduct venue and jurisdictional
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`discovery in accordance with the Court’s Amended Standing Order Regarding Venue and
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`Jurisdictional Discovery Limits for Patent Cases dated June 8, 2021 (the “Standing Order”).
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`Venue and jurisdictional discovery will end on November 1, 2021, and Plaintiff’s Response to
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`Defendants’ Motion will be due on November 15, 2021. Defendant’ Reply will be due on
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`December 6, 2021. The parties will attempt to agree concerning the scope for venue and
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`jurisdictional discovery. If they are unable to do so, they will seek a telephonic conference with
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`the Court pursuant to the Standing Order.
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`Case 6:21-cv-00121-ADA Document 23 Filed 08/13/21 Page 2 of 4
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`Dated: August 13, 2021
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`Respectfully submitted,
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`By: /s/ Fred I. Williams
`Fred I. Williams
`Texas State Bar No. 00794855
`Michael Simons
`Texas State Bar No. 24008042
`WILLIAMS SIMONS & LANDIS PLLC
`327 Congress Ave., Suite 490
`Austin, TX 78701
`Tel: 512-543-1354
`fwilliams@wsltrial.com
`msimons@wsltrial.com
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`Todd E. Landis
`State Bar No. 24030226
`WILLIAMS SIMONS & LANDIS PLLC
`2633 McKinney Ave., Suite 130 #366
`Dallas, TX 75204
`Tel: 512-543-1357
`tlandis@wsltrial.com
`
`John Wittenzellner
`Pennsylvania State Bar No. 308996
`WILLIAMS SIMONS & LANDIS PLLC
`1735 Market Street, Suite A #453
`Philadelphia, PA 19103
`Tel: 512-543-1373
`johnw@wsltrial.com
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`Attorneys for Plaintiff
`Gesture Technology Partners, LLC
`
`/s/ John M. Guaragna
`John M. Guaragna
`Texas Bar No 24043308
`DLA PIPER LLP (US)
`303 Colorado Street, Suite 3000
`Austin, TX 78701
`Phone: (512) 457-7000
`john.guaragna@us.dlapiper.com
`
`Sean Cunningham (pro hac vice)
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`2
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`Case 6:21-cv-00121-ADA Document 23 Filed 08/13/21 Page 3 of 4
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`Catherine Huang (pro hac vice)
`DLA PIPER LLP (US)
`401 B Street, Suite 1700
`San Diego, CA 92101-4297
`Tel: 619.699.2700
`Fax: 619.699.2701
`sean.cunningham@us.dlapiper.com
`catherine.huang@us.dlapiper.com
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`Michael D. Jay (pro hac vice)
`DLA PIPER LLP (US)
`2000 Avenue of the Stars
`Suite 400 North Tower
`Los Angeles, CA 90067
`Tel: 310.595.3000
`Fax: 310.595.3300
`michael.jay@us.dlapiper.com
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`Christopher Deck (pro hac vice)
`DLA PIPER LLP (US)
`33 Arch Street, 26th Floor
`Boston, MA 02110-1447
`Tel: 617.406.6000
`Fax: 617.406.6100
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`Attorneys for Defendant
`Apple Inc.
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`3
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`Case 6:21-cv-00121-ADA Document 23 Filed 08/13/21 Page 4 of 4
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`CERTIFICATE OF SERVICE
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`The undersigned hereby certifies that on August 13, 2021, the undersigned caused a copy
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`of the foregoing document to be served on all counsel of record via the Court’s CM/ECF system,
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`pursuant to the Federal Rules of Civil Procedure.
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`/s/ Fred I. Williams
`Fred I. Williams
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`CERTIFICATE OF CONERENCE
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`The undersigned hereby certifies that counsel for Gesture Technology Partners, LLC and
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`counsel for Apple Inc. met and conferred, and all parties agree to filing the foregoing document as
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`a joint notice.
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`/s/ Fred I. Williams
`Fred I. Williams
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