EXHIBIT I 

PUBLIC VERSION

Case 2:23-cv-00103-JRG-RSP Document 84-9 Filed 04/04/24 Page 1 of 6 PageID #: 3067
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From: Jason Wietholter <jwietholter@raklaw.com>

Sent: Thursday, March 14, 2024 4:14 PM

To: Jonathan Bright

Cc: rak_headwater@raklaw.com; [SERVICE FR] Samsung-Headwater; qe-headwater103

@quinnemanuel.com

Subject: Re: Headwater v. Samsung Case No. 2:22-cv-103: 2024-01-12 CONF Samsung Suppl Resp to HW 1st 

Set of ROGs No 1

[This email originated outside of F&R.]  

Jonathan,

Headwater does not oppose your motion for leave to amend invalidity contentions in the ‐103 matter for the amended

contentions linked in your March 8, 2024 email.

Regards,

Jason Wietholter

Russ, August & Kabat

12424 Wilshire Boulevard, 12th Floor | Los Angeles, California 90025

Main +1 310 826 7474 | jwietholter@raklaw.com | www.raklaw.com

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This communication shall not create, waive or modify any right, obligation or liability, or be construed to contain or

be an electronic signature. This communication may contain information that is legally privileged, confidential or exempt

from disclosure, and is intended only for the named addressee(s). If you are not the intended recipient, please note that

any dissemination, distribution, or copying of this communication is prohibited.

On Mar 14, 2024, at 10:35 AM, Jason Wietholter <jwietholter@raklaw.com> wrote:

Hi Jonathan,

Can you please let us know what additional third party discovery or art you intend to add beyond the

contentions identified in your March 8 email, if any?

Regards,

Jason Wietholter

Russ, August & Kabat

12424 Wilshire Boulevard, 12th Floor | Los Angeles, California 90025

Main +1 310 826 7474 | jwietholter@raklaw.com | www.raklaw.com

‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐ 

This communication shall not create, waive or modify any right, obligation or liability, or be construed to

contain or be an electronic signature. This communication may contain information that is

legally privileged, confidential or exempt from disclosure, and is intended only for

the named addressee(s). If you are not the intended recipient, please note that any

dissemination, distribution, or copying of this communication is prohibited.

PUBLIC VERSION

Case 2:23-cv-00103-JRG-RSP Document 84-9 Filed 04/04/24 Page 2 of 6 PageID #: 3068
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On Mar 14, 2024, at 8:31 AM, Jonathan Bright <jbright@fr.com> wrote:

Counsel,

  

Despite our multiple emails, you have yet to provide any response to our multiple

emails regarding Samsung’s motion for leave to amend invalidity contentions in the ‐103

matter.  We ask for a fourth time, does Headwater oppose our request to amend these

invalidity contentions?  Headwater’s continued silence on this issue prejudices Samsung.

  

We are available to meet and confer today at 3PM ET and will open the following Zoom

link at that time:  https://fish.zoom.com/j/9293566268

  

Regards,

  

Jonathan

  

From: Jonathan Bright <jbright@fr.com>  

Sent: Tuesday, March 12, 2024 8:38 PM

To: rak_headwater@raklaw.com

Cc: [SERVICE FR] Samsung‐Headwater <SERVICEFRSamsung‐Headwater@fr.com>; qe‐

headwater103@quinnemanuel.com

Subject: RE: Headwater v. Samsung Case No. 2:22‐cv‐103: 2024‐01‐12 CONF Samsung

Suppl Resp to HW 1st Set of ROGs No 1

  

Counsel,

  

It has been over two weeks since we notified you of our planned motion for leave to

amend invalidity contentions in the ‐103 matter and requested your position as to

whether Headwater opposes this motion.  Please provide Headwater’s position

promptly.  If Headwater intends to oppose, please also provide your availability this

week for a meet‐and‐confer.

  

Best,

  

Jonathan

  

  

From: Jonathan Bright <jbright@fr.com>

Sent: Friday, March 8, 2024 10:35 PM

To: rak_headwater@raklaw.com

Cc: [SERVICE FR] Samsung‐Headwater <SERVICEFRSamsung‐Headwater@fr.com>; qe‐

headwater103@quinnemanuel.com

Subject: RE: Headwater v. Samsung Case No. 2:22‐cv‐103: 2024‐01‐12 CONF Samsung

Suppl Resp to HW 1st Set of ROGs No 1

  

Counsel,

  

Following up on our emails below, please let us know whether Headwater will oppose

Samsung’s motion for leave to amend Invalidity Contentions in the 103 case.  These

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Case 2:23-cv-00103-JRG-RSP Document 84-9 Filed 04/04/24 Page 3 of 6 PageID #: 3069
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amended invalidity contentions are available at the following

link: https://send.fr.com/link/jDydAonxbmg3dAdNbApNYB.

  

Password to follow separately.

  

Best,

  

Jonathan

  

From: Jonathan Bright  

Sent: Friday, February 23, 2024 9:09 PM

To: Rae Crisler <crisler@fr.com>; rak_headwater@raklaw.com

Cc: [SERVICE FR] Samsung‐Headwater <SERVICEFRSamsung‐Headwater@fr.com>; qe‐

headwater103@quinnemanuel.com

Subject: RE: Headwater v. Samsung Case No. 2:22‐cv‐103: 2024‐01‐12 CONF Samsung

Suppl Resp to HW 1st Set of ROGs No 1

  

Counsel,

  

Following up on our emails below, Samsung hereby notifies Headwater that it plans to

move for leave to amend its Invalidity Contentions (previously served on November 30,

2023) to incorporate material specified in Samsung’s supplemental responses to

Headwater Interrogatory No. 1, including third party discovery served since Samsung’s

supplemental responses.  

   

Please provide Headwater’s position on Samsung’s forthcoming motion for leave to

amend its Invalidity Contentions.  

  

Best,

  

Jonathan

  

From: Rae Crisler <crisler@fr.com>

Sent: Monday, February 12, 2024 11:30 AM

To: rak_headwater@raklaw.com

Cc: [SERVICE FR] Samsung‐Headwater <SERVICEFRSamsung‐Headwater@fr.com>; qe‐

headwater103@quinnemanuel.com

Subject: RE: Headwater v. Samsung Case No. 2:22‐cv‐103: 2024‐01‐12 CONF Samsung

Suppl Resp to HW 1st Set of ROGs No 1

  

Counsel,

  

We write to further advise that Samsung has continued to diligently pursue third party

discovery as reflected in its Second Supplemental Response to Plaintiff’s Interrogatory

No. 1 served on February 6, 2024, that incorporates content from Nokia and Google.   

  

As noted below, for purposes of notice and status as to third party discovery, Samsung

expects to receive additional third party discovery responses in the coming weeks and

may well further supplement its interrogatory No. 1 as well as its Invalidity Contentions

with additional documents and things obtained as a result of that discovery.   

  

Best regards,

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Case 2:23-cv-00103-JRG-RSP Document 84-9 Filed 04/04/24 Page 4 of 6 PageID #: 3070
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Rae

  

Rae Crisler :: Fish & Richardson P.C. :: 214-760-6138 direct

  

From: Jonathan Bright <jbright@fr.com>

Sent: Friday, January 12, 2024 9:59 PM

To: rak_headwater@raklaw.com

Cc: [SERVICE FR] Samsung‐Headwater <SERVICEFRSamsung‐Headwater@fr.com>; qe‐

headwater103@quinnemanuel.com; Jeannet Santos <jsantos@fr.com>

Subject: RE: Headwater v. Samsung Case No. 2:22‐cv‐103: 2024‐01‐12 CONF Samsung

Suppl Resp to HW 1st Set of ROGs No 1

  

Counsel:

  

In relation to the supplemental response to Plaintiff’s interrogatory No.  1 referenced

below, Samsung has diligently pursued third party discovery and we notify you that

Defendant Samsung intends to supplement its Invalidity Contentions with content from

third party OpenWave specified in that supplemental response.   

  

For purposes of notice and status as to third party discovery, Samsung expects to

receive additional third party discovery responses in the coming weeks and may well

further supplement its interrogatory No. 1 as well as its  Invalidity Contentions with

additional documents and things obtained as a result of that discovery.   

  

Regards,

  

Jonathan

  

  

From: Jeannet Santos <jsantos@fr.com>

Sent: Friday, January 12, 2024 4:55 PM

To: rak_headwater@raklaw.com

Cc: [SERVICE FR] Samsung‐Headwater <SERVICEFRSamsung‐Headwater@fr.com>

Subject: Headwater v. Samsung Case No. 2:22‐cv‐103: 2024‐01‐12 CONF Samsung Suppl

Resp to HW 1st Set of ROGs No 1

  

Counsel:

Attached for service, please find:

 DEFENDANTS’ SUPPLEMENTAL OBJECTIONS AND RESPONSES TO

HEADWATER RESEARCH LLC’S FIRST SET OF INTERROGATORIES (NO. 1)

The password to this document will be sent in a separate email.

Thank you,

Jeannet T. Santos, Sr. Litigation Paralegal

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Case 2:23-cv-00103-JRG-RSP Document 84-9 Filed 04/04/24 Page 5 of 6 PageID #: 3071
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Supporting: Ashley A. Bolt, Brian P. Boyd, Erin P. Alper, Noah C. Graubart, & Steffen C.

Lake

FISH & RICHARDSON P.C.

1180 Peachtree Street NE, 21st Floor, Atlanta, GA 30309

404.724.2758 direct :: 770.276.8661 mobile :: jsantos@fr.com :: fr.com

  

“The Strength of the Team is each Member.  The Strength of each Member is the

Team.” –Phil Jackson

  

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Case 2:23-cv-00103-JRG-RSP Document 84-9 Filed 04/04/24 Page 6 of 6 PageID #: 3072