Samsung admits that the website cited in Paragraph 15 Footnote 1 of the First Amended Complaint, when accessed on April 5, 2022, stated that SEA’s “Mobile hub in Plano centralizes innovation and enhances cross-functional collaboration for all teams dedicated to their largest mobile product line: smartphones” and its “[d]ivisions includ[e] Networks, Mobile Marketing, Computing and Wearables, and Product Management.” Samsung further admits that the April 6, 2018 website cited in Paragraph 15 Footnote 2 of the First Amended Complaint, when accessed on April 5, 2022, stated that as of the date of that article, “Samsung Electronics America’s North Texas offices will now be located in a newly redeveloped 216,000 square foot building” and “more than 1,000 regional employees from two current locations in Richardson and Plano will be relocated to the new location.” Samsung denies the remaining allegations in Paragraph 15 of the First Amended Complaint.
Samsung admits that the third-party website cited in Paragraph 45 Footnote 12, when accessed on April 5, 2022, stated on its face the principal office of the Wi-Fi Alliance was 10900-A Stonelake Boulevard Suite 195, Austin, TX 78759 USA and that it included the quoted language “the specific purpose of the corporation is to promote multi- vendor interoperability for markets including the enterprise, small office, and home and in particular the development, adoption and use of Wi-Fi technology and products and services relating thereto.” Samsung admits SEC became a Sponsor member of the Wi-Fi Alliance in 2011.
Samsung admits that the third-party website cited in Paragraph 46 Footnote 17 of the First Amended Complaint, when accessed on April 5, 2022, purported to be a certification identifying a date of June 16, 2020 for the SM-F707U product.
Samsung admits that the third-party website cited in Paragraph 47 Footnote 18 of the First Amended Complaint, when accessed on April 5, 2022 purported to be a certification identifying a date of September 4, 2019 for the SM-N976U product.
Samsung admits the third- party website cited in Paragraph 47 Footnote 18 of the First Amended Complaint, when accessed on April 5, 2022, included the terms “Wi-Fi CERTIFIED 6™” and “Wi-Fi CERTIFIED™ ac.” Samsung further admits the third-party website cited in Paragraph 47 Footnote 18 of the First Amended Complaint, when accessed on April 5, 2022, included the language “LDPC Rx” and “LDPC Tx” under the “Wi-Fi CERTIFIED 6™” and “Wi-Fi CERTIFIED™ ac” headings on the fourth page.