EXHIBIT G

Case 2:23-cv-00379-JRG-RSP Document 81-7 Filed 09/05/24 Page 1 of 3 PageID #: 4898
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Sim, Charlie

From: Sim, Charlie

Sent: Wednesday, September 4, 2024 4:42 PM

To: rak_headwater@raklaw.com

Cc: *** GDCVerizon-Headwater; HLVerizon Headwater; [EXT] Dacus, Deron; melissa@gillamsmithlaw.com

Subject: Headwater v. Verizon (-352) & Headwater v. T-Mobile (-377, 379) - Summary of September 4 

conference

Counsel, 

We write to memorialize the parties’ lead-and-local conference earlier today: 

Headwater’s Motion to Compel – Defendants explained that we intend to collect and produce 

documents relevant to Headwater’s network-side allegations to the extent Defendants are able to 

understand those allegations. Specifically, Defendants stated that we will collect and produce 

documents related to Headwater’s allegations regarding the 3GPP “attach” message (i.e. the references 

to 3GPP TS 24.301 in Headwater’s contentions), QCI levels, and the components specifically identified in 

Headwater’s cover pleadings, i.e. “FOTA Update Server,” “FOTA,” and “OTA Server” (for T-Mobile) and 

“OTADM,” “PROPOTA,” “VZOTADM,” “FOTA,” “SDM,” and/or “DM” (for Verizon). Defendants expressed 

a belief that this production would moot Headwater’s motion to compel. Headwater disagreed and 

stated that this production would be insufficient because it purportedly excluded information regarding 

“PCO” and “Bearer Resource Allocation Requests.” Both of those terms appear, in Headwater’s 

contentions, in the context of Headwater’s citations to 3GPP TS 24.301. Headwater did not otherwise 

articulate deficiencies with Defendants’ proposed production or why it would not moot Headwater’s 

motion, but confirmed that the parties were at an impasse. 

Defendants’ Motion to Strike and Compel Supplementation – Headwater explained that its proposed 

comprise position was already articulated in its opposition to Defendants’ motion to strike. Defendants 

confirmed that Headwater’s generalized offered to “further supplement” did not reach the level of relief 

sought by Defendants’ motion. The parties thus confirmed they were at an impasse. 

Discovery Topics 

Expert Reports from Samsung Litigation – Defendants explained that Samsung has now agreed to 

cross-production of expert reports from the 22-cv-422 (E.D. Tex.) litigation to both T-Mobile and 

Verizon. Headwater stated that it believed that it could shortly produce these expert reports and 

committed to following up with Defendants to confirm. Defendants stressed that the only objection 

Headwater previously raised to this cross-production was confidentiality of Samsung information, which 

is now resolved. 

Filings from Samsung Litigation – Headwater committed to following up shortly to confirm that it will 

produce the remaining sealed filings from the docket of the 22-cv-422 (E.D. Tex.) litigation. 

Identification of ESI Custodians – The parties discussed beginning the process for identification of ESI 

custodians and search terms. Defendants committed to investigating further and responding to 

Headwater early next week. 

Case 2:23-cv-00379-JRG-RSP Document 81-7 Filed 09/05/24 Page 2 of 3 PageID #: 4899
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Headwater’s Responses to Defendants’ Interrogatory Nos. 6, 17, and 18 – Defendants reiterated that 

these interrogatories call for a clear narrative response that Headwater has failed to 

provide. Specifically, Defendants explained that Interrogatory No. 6 calls for a narrative response 

outlining the facts of each sale or offer for sale by Headwater and any response thereto; Interrogatory No. 

17 calls for a chart or narrative explanation of which products purportedly embody which patents in 

connection with Headwater’s allegations of copying; and Interrogatory No. 18 calls for a narrative 

description of each inventor’s individual contribution to each of the Asserted Patents. Headwater 

committed to supplementing its responses to these interrogatories. 

Headwater’s Responses to the Remaining Identified Interrogatories – Headwater confirmed that it 

intended to supplement “most if not all” of its responses to Defendants’ Interrogatory Nos. 2, 3, 8, 11, 

13, and 15, and committed to following up with Defendants promptly regarding a date for that 

supplementation. 

Best, 

Charlie 

Charlie Sim 

Associate Attorney 

T: +1 212.351.6274 | M: +1 607.339.1652 

CSim@gibsondunn.com 

GIBSON DUNN

Gibson, Dunn & Crutcher LLP 

200 Park Avenue, New York, NY 10166-0193 

Case 2:23-cv-00379-JRG-RSP Document 81-7 Filed 09/05/24 Page 3 of 3 PageID #: 4900