IN THE UNITED STATES DISTRICT COURT

FOR THE EASTERN DISTRICT OF TEXAS

MARSHALL DIVISION

HEADWATER RESEARCH LLC,

Plaintiff,

v.

SAMSUNG ELECTRONICS CO., LTD. and

SAMSUNG ELECTRONICS AMERICA, INC.,

Defendants.

Case No. 2:23-cv-00103-JRG-RSP

JURY TRIAL DEMANDED

DECLARATION OF KRISTOPHER DAVIS IN SUPPORT OF PLAINTIFF 

HEADWATER RESEARCH LLC’S MOTIONS FOR SUMMARY JUDGMENT 

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1. I, Kristopher Davis, declare as follows.

2. I am counsel for Headwater Research LLC (“Headwater”) in the above-captioned 

action. I provide this declaration in support of Headwater’s Motions for Summary Judgment. I 

have personal knowledge of the facts set forth herein, and if called upon to testify, could and would 

testify competently thereto.

3. Attached as Exhibit 1 is a true and correct copy of the Report and Recommendation 

on Standing in Headwater Research LLC v. Samsung Electronics Co. Ltd., No. 2:22-cv-00422-

JRG-RSP, Dkt. 399 (E.D. Tex.), dated August 2, 2024.

4. Attached as Exhibit 2 is a true and correct copy of the Transcript of Evidentiary 

Hearing in Headwater Research LLC v. Samsung Electronics Co. Ltd., No. 2:22-cv-00422-JRGRSP, dated July 25, 2024.

5. Attached as Exhibit 3 is a true and correct copy of the USPTO assignment records 

for the asserted ’117 patent.

6. Attached as Exhibit 4 is a true and correct copy of the USPTO assignment records 

for the asserted ’192 patent.

7. Attached as Exhibit 5 is a true and correct copy of the USPTO assignment records 

for the asserted ’733 patent.

8. Attached as Exhibit 6 is a true and correct copy of excerpts from the Opening 

Report of Samsung’s technical expert, Dr. Ian Foster, dated September 26, 2024.

9. Attached as Exhibit 7 is a true and correct copy of the Invention Disclosure, 

Confidentiality & Proprietary Rights Agreement, signed by Dr. Gregory Raleigh, dated December 

18, 2006.

10. Attached as Exhibit 8 is a true and correct copy of Qualcomm employment record 

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of Dr. Gregory Raleigh, dated February 21, 2024.

11. Attached as Exhibit 9 is a true and correct copy of Qualcomm’s objections and 

responses to Samsung’s subpoena in Headwater Research LLC v. Samsung Electronics Co. Ltd., 

No. 2:22-cv-00422-JRG-RSP, dated January 23, 2024.

12. Attached as Exhibit 10 is a true and correct copy of Qualcomm’s objections and 

responses to Samsung’s subpoena in this action, dated February 19, 2024.

13. Attached as Exhibit 11 is a true and correct copy of the deposition transcript of Dr. 

Gregory Raleigh, dated September 10, 2024.

14. Attached as Exhibit 12 is a true and correct copy of excerpts from the Initial

Determination in ITC Inv. No. 337-TA-1100, dated July 12, 2019.

15. Attached as Exhibit 13 is a true and correct copy of a letter from Qualcomm to Dr. 

Gregory Raleigh, dated April 4, 2022.

16. Attached as Exhibit 14 is a true and correct copy of Samsung’s Amended Second 

Supplemental Objections and Responses to Headwater Research LLC’s First Set of Interrogatories 

(Nos. 1-17).

I declare under penalty of perjury that the foregoing is true and correct. 

Executed on October 25, 2024 at Los Angeles, California

By: /s/ Kristopher Davis

Kristopher Davis

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CERTIFICATE OF SERVICE

I hereby certify that on October 25, 2024, all counsel of record who are deemed to have 

consented to electronic service are being served with a copy of this document via the Court’s 

CM/ECF System per Local Rule CV-5(a)(3).

/s/ Kristopher Davis

Kristopher Davis

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