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 

SAMSUNG’S OPPOSITION TO HEADWATER’S MOTION (DKT. 173) TO EXCLUDE 

OR STRIKE CERTAIN REBUTTAL EXPERT OPINIONS OF PHILIP W. KLINE

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TABLE OF CONTENTS 

I. LEGAL STANDARD ......................................................................................................... 1

II. ARGUMENT ...................................................................................................................... 2

A. Mr. Kline is Qualified to Critique Dr. Groehn’s Survey as It Affects Overall 

Economic Reliability of Dr. Groehn’s Opinions .................................................... 2

B. Mr. Kline’s Econometric Opinions Are Distinct From, and Consistent With, 

Dr. Simonson and Dr. Perryman’s Opinions. ......................................................... 6

III. CONCLUSION ................................................................................................................... 9

 

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TABLE OF AUTHORITIES 

Cases .................................................................................................................................... Page(s) 

Brown v. Progressive Mountain Insurance Co., 

No. 3:21-cv-175-TCB, 2024 WL 3565314 (N.D. Ga July 26, 2024) ........................................5 

Convolve, Inc. v. Dell, Inc., 

No. 2:08-CV-244-CE, 2011 WL 13091767 (E.D. Tex. July 8, 2011) .......................................6 

Droplets, Inc. v. Yahoo! Inc., 

No. 12-CV-03733-JST, 2021 WL 9038355 (N.D. Cal. Aug. 9, 2021) ......................................5 

Marquette Transportation Co. Gulf-Inland, LLC v. Navigation Mar. Bulgarea, 

No. CV 19-10927, 2022 WL 158681 (E.D. La. Jan. 18, 2022) .................................................8 

Metaswitch Networks Ltd. v. Genband US LLC, 

No. 2:14-CV-744-JRG-RSP, 2016 WL 874775 (E.D. Tex. Mar. 7, 2016) ...............................2 

Niblock v. Univ. of Kentucky, 

No. CV 5:19-394-KKC, 2023 WL 4842315 (E.D. Ky. July 28, 2023) .....................................5 

Senne v. Kansas City Royals Baseball Corp., 

591 F. Supp. 3d 453 (N.D. Cal. 2022) .......................................................................................5 

State of New York v. United Parcel Serv., Inc., 

No. 15-CV-1136 (KBF), 2016 WL 4735368 (S.D.N.Y. Sept. 10, 2016) ..................................5 

Thomas v. T.K. Stanley, Inc., 

No. 9-12-CV-158, 2014 WL 12814614 (E.D. Tex. Oct. 28, 2014) .......................................8, 9 

Williams v. Manitowoc Cranes, L.L.C., 

898 F.3d 607 (5th Cir. 2018) .....................................................................................................1 

Other Authorities 

Federal Rule of Evidence 403 ......................................................................................................8, 9 

Federal Rule of Evidence 702 ..................................................................................................1, 6, 8 

 

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EXHIBIT INDEX AND NOTES 

Exhibit Description 

1 Excerpts from the Report of Dr. Andreas Groehn, dated Sept. 26, 2024 

2 Excerpts from the Deposition of Philip Kline, taken May 10, 2024 

3 Excerpts from the Deposition of Dr. Andreas Groehn, taken May 13, 2024 

4 Excerpts from the Deposition of Philip Kline, taken Oct. 17, 2024 

5 Excerpts from the Expert Report of M. Ray Perryman, Ph.D., dated Oct. 14, 

2024 

* Emphasis added unless otherwise noted. 

** Form objections are omitted from deposition transcript quotations unless otherwise noted. 

*** In this brief, “Headwater” refers to Plaintiff and its purported predecessors. 

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Headwater voices no complaints with either the robustness or legitimacy of Mr. Kline’s 

opinions. Instead, Headwater seeks to preclude Mr. Kline from discussing his legitimate criticisms 

of Headwater’s expert, Dr. Groehn, by attacking Mr. Kline’s qualifications. Mr. Kline’s rebuttal 

opinions to Dr. Groehn are thoroughly supported by his 17 years of experience providing economic 

analysis of intellectual property, including ample experience using data from surveys and other 

similar modeling in his economic analysis. Headwater also argues that Mr. Kline’s opinions are 

duplicative of Samsung’s other experts, but a comparison reveals that Headwater is wrong. 

Samsung’s experts provide separate opinions. Accordingly, none of Headwater’s requests require 

exclusion of Mr. Kline’s opinions under Fed. R. Evid. 702, but instead can all be properly tested 

on cross-examination. 

I. LEGAL STANDARD 

“The district court has wide latitude when navigating the expert-qualification process,” and 

the Fifth Circuit “will reverse only ‘manifestly erroneous’ determinations.” Williams v. 

Manitowoc Cranes, L.L.C., 898 F.3d 607, 625 (5th Cir. 2018). “[N]o Fifth Circuit case [has] held 

that a district court abused its discretion by qualifying someone as an expert on the basis of an 

imprecise match between the expert’s qualifications and the issue she planned to testify about. 

[Defendant’s] conception of expertise could turn the expert-qualification process into a ‘battle of 

labels’ where expertise is defined so narrowly that qualified experts are irrationally excluded from 

testifying. . . . . We decline to adopt this approach. As long as there are ‘sufficient indicia’ that an 

individual will ‘provide a reliable opinion’ on a subject, a district court may qualify that individual 

as an expert.” Id. (admitting opinion from “a mechanical engineer with a background in warnings 

and small-crane design” and allowing testimony “about warnings for a crawler crane” noting that 

“quibbles about qualifications are better characterized as arguments about the weight . . . not about 

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its admissibility”). “The proponent need not prove to the judge that the expert’s testimony is 

correct, but she must prove by a preponderance of the evidence that the testimony is reliable.” 

Metaswitch Networks Ltd. v. Genband US LLC, No. 2:14-CV-744-JRG-RSP, 2016 WL 874775, 

at *1 (E.D. Tex. Mar. 7, 2016) (quoting Johnson v. Arkema, Inc., 685 F.3d 452, 459 (5th Cir. 

2012)). 

II. ARGUMENT 

A. Mr. Kline is Qualified to Critique Dr. Groehn’s Survey as It Affects Overall Economic 

Reliability of Dr. Groehn’s Opinions 

Mr. Kline offers only rebuttal opinions to Dr. Groehn. Mr. Kline’s opinions are well within 

the scope for which Mr. Kline’s extensive academic and professional experience qualifies him. 

Dr. Groehn designed and conducted a conjoint survey, then provided a conjoint analysis using the 

survey data together with other tools such as regressions to calculate purported incremental values. 

Ex. 1 (Groehn Rep.) ¶¶ 21-25. Samsung offers Dr. Itamar Simonson’s opinions to respond to Dr. 

Groehn’s survey specifically, and further offers Mr. Kline’s opinions to respond to Dr. Groehn’s 

larger economic conjoint analysis, including the underlying survey data on which the conjoint 

analysis relies.1

 Headwater’s motion does not identify any issue on which Mr. Kline is not 

qualified to opine or has gone beyond his qualifications. 

At the outset, Mr. Kline is qualified. Mr. Kline has experience performing and using 

econometric analyses such as conjoint analysis and regressions in the intellectual property context, 

of which he has substantial experience. Dkt. 173-3 at Appen. A (CV). Based on this experience, 

Mr. Kline explains that the economic calculations output from Dr. Groehn’s conjoint analysis is 

rendered unreliable by his underlying survey choices. As an economist who regularly uses survey 

1

 Mr. Kline also provides opinions in response to some of Mr. Dell’s opinions, which Headwater 

does not seek to exclude. 

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and other modeling data, Mr. Kline understands what attributes such data must have in order to be 

reliable for use in econometric analysis, such as conjoint analysis. As his deposition testimony 

and reports make readily clear, Mr. Kline has more than sufficient experience, evidence, and 

analysis to permit him to provide his opinions to the jury on issues of survey design that alter the 

reliability of Dr. Groehn’s survey. 

Mr. Kline has a degree in economics and is a certified public accountant. Dkt. 173-3 at 

Appendix A (CV). Mr. Kline has been working in the field of “intellectual property (IP) valuation, 

licensing support, litigation consulting, strategy,and transactional services” for “over 17 years.” 

Dkt. 173-3 at ¶¶ 1-2; see also Ex. 2 (Kline 5/10/2024 Dep.) at 17:14-22. Mr. Kline studied 

“statistical sampling techniques – of which surveys are an example – in the course work for [his] 

degree in Economics” at University of Southern California. Dkt. 173-3 at ¶ 4; see also Ex. 4 (Kline 

10/17/2024 Dep.) at 8:19-23; Ex. 2 (Kline 5/10/2024 Dep.) at 9:25-11:2; see also Ex. 3 (Groehn 

5/13/2024 Dep.) at 211:9-24 (confirming Ph.D. not required to design or conduct surveys). During 

Mr. Kline’s career working at different economic consulting firms focusing on intellectual 

property licensing, valuation, and IP damages, he has worked on projects where he “was involved 

with projects in which surveys were performed” and “advis[ed] as to the nature of the issues which 

we were interested in understanding in relation to valuing the IP and . . . ensuring that the data that 

would come out of the survey would be useful to the application to which it was to be applied.” 

Ex. 4 (Kline 10/17/2024 Dep.) at 10:2-14; see also Ex. 2 (Kline 5/10/2024 Dep.) at 13:4-14:1. He 

has also advised clients on the appropriate use of consumer surveys. Ex. 4 (Kline 10/17/2024 

Dep.) at 10:2-14, 11:18-25, 12:10-16; Ex. 2 (Kline 5/10/2024 Dep.) at 15:14-25. Mr. Kline was 

clear that, in several instances, he has “worked with others to develop consumer surveys,” Ex. 2 

(Kline 5/10/2024 Dep.) at 18:3-8, including advising on survey design “as someone who would be 

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using the survey data” that was output from the survey. Id. at 18:9-22. In fact, when Headwater 

specifically asked Mr. Kline about his qualifications during deposition, Mr. Kline confirmed “I 

have both academic and professional experience in the use of survey data and the limitations that 

come into play” with use of such data. Id. at 20:18-21:1. Mr. Kline also added that he has “worked 

with a lot of sampling techniques and sample data in the past,” similar to the sample data sets 

generated by a conjoint survey. Id. at 46:5-12. Headwater appears unaware that econometrics 

regularly uses survey data because Headwater implies an academic background in economics 

would not have any relation to surveys. Not so, and Mr. Kline confirmed working with survey 

data was included even in his undergraduate course work. Dkt. 173 at 3-4; Ex. 2 (Kline 5/10/2024 

Dep.) at 9:25-11:1. Moreover, Mr. Kline was readily able to answer all questions posed to him 

during deposition regarding requirements, use of, and attributes of conjoint survey and conjoint 

analysis. See, e.g., id. at 25:21-26:19, 31:6-33:15, 36:6-37:10, 47:10-49:5, 96:14-98:17, 121:20-

123:11. 

Mr. Kline does not go beyond these qualifications by critiquing aspects of Dr. Groehn’s 

underlying survey and conjoint analysis that relies on the data from that survey. Mr. Kline has 

“both academic and professional experience in the use of survey data and the limitations that come 

into play” with use of such data. Ex. 2 (Kline 5/10/2024 Dep.) at 20:18-21:1. He opines on the 

“use” and “limitations” of Dr. Groehn’s survey and conjoint analysis by critiquing the design 

aspects of the survey that impact the economic reliability, usability, and applicability of the data 

output from the survey and conjoint analysis. 

For example, in Mr. Kline’s critique of Dr. Groehn’s failure to include key control variables 

from the conjoint survey, Mr. Kline observes that “many of the variables omitted from Dr. 

Groehn’s data are known to impact consumer demand.” Dkt. 173-3 at ¶ 59; see also id. ¶ 68 

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(discussing how “econometric techniques may be employed to adjust for the [population] data

being skewed”). These underlying design errors by Dr. Groehn are relevant to Dr. Groehn’s 

economic calculations based on the survey results, and therefore is appropriate for inclusion in Mr. 

Kline’s opinions critiquing the economic/econometric reliability of Dr. Groehn’s report. 

Mr. Kline is distinguishable from the expert excluded in the class action matter of Senne v. 

Kansas City Royals Baseball Corp., 591 F. Supp. 3d 453, 487 (N.D. Cal. 2022), where the offered 

expert directly “concedes that she is not an expert in ‘survey design’ or ‘fielding’ surveys,” she 

could not “provide[ ] any details” as to her coursework on surveys, and she did not appear to be 

further supported by any other survey expert offered by defendants. See also Droplets, Inc. v. 

Yahoo! Inc., No. 12-CV-03733-JST, 2021 WL 9038355, at *12 (N.D. Cal. Aug. 9, 2021) 

(excluding expert who opined on survey and human perception abilities “[b]ecause Dr. Mody 

specifically disclaims any expertise in these areas, the opinions are not admissible”); Niblock v. 

Univ. of Kentucky, No. CV 5:19-394-KKC, 2023 WL 4842315, at *4 (E.D. Ky. July 28, 2023) 

(“Lopiano’s expertise in other areas of Title IX does not render her an expert on survey 

methodology—a fact she admitted.”) Headwater’s citation to State of New York v. United Parcel 

Serv., Inc., No. 15-CV-1136 (KBF), 2016 WL 4735368, at *4 (S.D.N.Y. Sept. 10, 2016), is 

similarly not applicable as the excluded expert “designed a consumer survey” and offered his own 

affirmative survey despite that he had “never before designed a consumer survey,” which Mr. 

Kline does not do. See also Brown v. Progressive Mountain Insurance Co., No. 3:21-cv-175-TCB, 

2024 WL 3565314, at *8 (N.D. Ga July 26, 2024) (excluding surveys conducted by an expert who 

was “not sufficiently qualified in survey design or execution.”) 

Here, Mr. Kline certainly did not admit that he is not a survey expert, and he did not 

concede he is not qualified to offer the survey-related opinions in his report. In fact, this Court has 

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previously confirmed that econometric experts may similarly rely on and offer parallel surveyrelated opinions if supported by an additional survey expert. See Convolve, Inc. v. Dell, Inc., No. 

2:08-CV-244-CE, 2011 WL 13091767, at *1 (E.D. Tex. July 8, 2011) (limiting challenged 

econometrics expert Dr. Kaplan to survey opinions “identified by Convolve’s survey expert, Dr. 

Gelb,” but holding “Dr. Kaplan is not, however, precluded from relying on deficiencies identified 

by Dr. Gelb to opine that the alleged deficiencies render Dr. Leonard’s econometric analysis 

unreliable or invalid.”) 

Accordingly, Headwater has not identified any issue on which Mr. Kline is not qualified 

or has gone beyond his area expertise. Thus, all of Mr. Kline’s opinions should be permitted to be 

provided to the jury as “specialized knowledge [that] will help the trier of fact to understand the 

evidence.” Fed. R. Evid. 702. 

B. Mr. Kline’s Econometric Opinions Are Distinct From, and Consistent With, Dr. 

Simonson and Dr. Perryman’s Opinions. 

Headwater further complains that Mr. Kline’s opinions are duplicative of Dr. Simonson’s 

and Dr. Perryman’s opinions. However, Headwater conflates each expert’s opinion, noting only 

at a high level that they discuss related topics and glosses over the details. 

Regarding Dr. Simonson, whom Headwater does not move to exclude on any basis, 

Headwater ignores that the experts are responding to different aspects of Dr. Groehn’s multi-part 

conjoint report. Dr. Simonson and Mr. Kline each respond to aspects of Dr. Groehn’s report based 

on their areas of expertise. Dr. Simonson opines on the survey from a surveyor’s perspective. Mr. 

Kline opines on the flaws in the survey that impact the economic analysis (e.g., the regression 

analysis) that relies on the survey data from an econometrics-based perspective. 

Tellingly, Headwater’s motion only lists high-level aspects of Dr. Groehn’s survey that 

both Mr. Kline and Dr. Simonson discuss, Dkt. 173 at 4—Headwater does not list the many 

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different survey-based or econometrics-based conclusions that Dr. Simonson and Mr. Kline each 

separately drew from these high-level aspects. For example, Headwater alleges Dr. Simonson and 

Mr. Kline proffer “duplicative and cumulative” opinions regarding the “control variables” or 

“decoy attributes” noted in Dr. Groehn’s conjoint survey. Dkt. 173 at 4. Not so. Dr. Simonson’s 

conclusion relates to survey design—that the failure to account for important attributes generates 

“focalism bias” or the artificial inflation of the importance of certain attributes that the survey 

sponsor emphasizes. Dkt. 173-5 at ¶ 38. Mr. Kline’s opinions, however, relate to the econometric 

impact of Dr. Groehn’s omission of key attributes—the “impact [on] consumer demand.” Dkt. 

173-3 at ¶ 59. 

Similarly, Headwater further alleges cumulative opinions regarding “the way ‘battery life’ 

is defined and presented in the survey.” Dkt. 173 at 4. However, Dr. Simonson explains from a 

survey perspective that Dr. Groehn’s failure to clearly define ‘battery life’ and the relating levels 

creates two primary problems. First, it forces respondents to deal with the burdensome task of 

independently defining a subjective concept because battery life varies across different users and 

depends on the individual’s usage patterns. Dkt. 173-5 at ¶¶ 22-28. Second, Dr. Simonson 

explains that when consumers are presented with meaningless, ill-defined levels like those used in 

Dr. Groehn’s survey, respondents tend to replace the levels with mental shortcuts like ‘low,’ 

‘medium,’ and ‘high,’ to simplify the task of the survey, undermining the reliability of the 

responses. 

Mr. Kline, however, separately critiques Dr. Groehn’s presentation of battery life from an 

economic and market perspective emphasizing that Dr. Groehn’s survey does not present battery 

life in such a way as actual purchasers would encounter in the smartphone marketplace. Dkt. 173-

3 at ¶¶ 75-91. Mr. Kline’s opinion rests on several conjoint analysis articles (cited by Dr. Groehn 

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himself) and real-world marketing materials from smartphone manufacturers, including Samsung. 

See, e.g., id. at ¶¶ 82-83. These are not cumulative or duplicative opinions critiquing Dr. Groehn 

and each opinion is offered from their respective area of expertise to provide the jury with helpful 

information to weigh the credibility of Dr. Groehn’s opinions. 

Regarding Dr. Perryman, Headwater makes largely the same argument. However, Dr. 

Perryman’s discussion of Mr. Kline and Dr. Simonson is simply to disclose his reliance on each 

of these experts respectively as part of the basis for his own opinions, as required by Federal Rule 

of Evidence 702. Ex. 5 (Perryman Report) ¶ 293 (“In my analysis of the opinions of Mr. Dell and 

Dr. Groehn, which are described below, I also relied upon the analysis by Professor Simonson and 

Mr. Kline.”). Dr. Perryman does not intend to offer at trial any opinions duplicative of those of 

Mr. Kline or Dr. Simonson. 

Headwater also claims that Mr. Kline’s allegedly duplicative opinions violate Federal Rule 

of Evidence 403. Dkt. 173 at 5. “The Fifth Circuit instructs that ‘[t]he exclusion of evidence under 

Rule 403 should occur only sparingly’ [and] a decision to reject ‘expert testimony is the exception 

rather than the rule.’” Marquette Transportation Co. Gulf-Inland, LLC v. Navigation Mar. 

Bulgarea, No. CV 19-10927, 2022 WL 158681, at *4 (E.D. La. Jan. 18, 2022) (declining to 

exclude “overlapping” experts as cumulative, holding any concerns about cumulative evidence 

“can be addressed at trial”). Headwater cites to Thomas v. T.K. Stanley, Inc., No. 9-12-CV-158, 

2014 WL 12814614, at *2 (E.D. Tex. Oct. 28, 2014), which does not support its requested relief. 

In Thomas, a car accident case, the court excluded one of two different damages experts where 

each offered differing “alternative forecasts of the future” for some of the exact same sets of 

damages (“medical damages and household services”). The court excluded the second cumulative 

expert because “the methods that Stevens applied are inaccurate and unreliable,” in addition to 

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finding his testimony unnecessarily cumulative and confusing under Fed. R. Evid. 403. Id. at *2. 

Here, Headwater does not dispute that no such conflict exists between the opinions of Samsung’s 

experts, thus there is no risk of presenting unreliable expert opinion and no risk of confusion as 

was present in Thomas. 

III.CONCLUSION 

For the foregoing reasons, Samsung respectfully submits the Court should deny 

Headwater’s motion to exclude or strike portions of Mr. Kline’s expert opinions. 

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Dated: November 4, 2024 Respectfully submitted, 

By: /s/ Thomas H. Reger 

 Ruffin B. Cordell 

TX Bar No. 04820550 

Michael J. McKeon 

DC Bar No. 459780 

mckeon@fr.com 

Jared Hartzman 

DC Bar No. 1034255 

hartzman@fr.com 

FISH & RICHARDSON P.C. 

1000 Maine Avenue, SW, Ste 1000 

Washington, D.C. 20024 

Telephone: (202) 783-5070 

Facsimile: (202) 783-2331 

Thad C. Kodish 

GA Bar No. 427603 

tkodish@fr.com 

Benjamin K. Thompson 

GA Bar No. 633211 

bthompson@fr.com 

Jonathan B. Bright 

GA Bar No. 256953 

jbright@fr.com 

Christopher O. Green 

GA Bar No. 037617 

cgreen@fr.com 

Noah C. Graubart 

GA Bar No. 141862 

graubart@fr.com 

Sara C. Fish 

GA Bar No. 873853 

sfish@fr.com 

Katherine H. Reardon 

NY Bar No. 5196910 

reardon@fr.com 

Nicholas A. Gallo 

GA Bar No. 546590 

gallo@fr.com 

Vivian C. Keller (pro hac vice) 

GA Bar No. 651500 

keller@fr.com 

FISH & RICHARDSON P.C. 

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1180 Peachtree St. NE, Fl. 21 

Atlanta, GA 30309 

Telephone: (404) 892-5005 

Facsimile: (404) 892-5002 

Leonard E. Davis 

TX Bar No. 05521600 

ldavis@fr.com 

Andria Rae Crisler 

TX Bar No. 24093792 

crisler@fr.com 

Thomas H. Reger II 

Texas Bar No. 24032992 

reger@fr.com 

FISH & RICHARDSON P.C.

1717 Main Street, Suite 5000 

Dallas, TX 75201 

Telephone: (214)747-5070 

Facsimile: (214) 747-2091 

John-Paul R. Fryckman (pro hac vice) 

CA Bar No. 317591 

John W. Thornburgh 

CA Bar No. 154627 

thornburgh@fr.com 

FISH & RICHARDSON P.C. 

12860 El Camino Real, Ste. 400 

San Diego, CA 92130 

Telephone: (858) 678-5070 

Facsimile: (858) 678-5099 

Katherine D. Prescott (pro hac vice) 

CA Bar No. 215496 

prescott@fr.com 

FISH & RICHARDSON P.C. 

500 Arguello Street 

Suite 400 

Redwood City, CA 94063 

Telephone: (650) 839-5180 

Facsimile: (650) 839-5071 

Kyle J. Fleming (pro hac vice) 

NY Bar No. 5855499 

kfleming@fr.com 

FISH & RICHARDSON P.C. 

7 Times Square, 20th Floor, 

New York, NY 10036 

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Telephone: (212) 765-5070 

Facsimile: (212) 258-2291 

Melissa R. Smith 

State Bar No. 24001351 

Melissa@gillamsmithlaw.com 

GILLAM & SMITH, LLP 

303 South Washington Avenue 

Marshall, Texas 75670 

Telephone: (903) 934-8450 

Facsimile: (903) 934-9257 

Andrew Thompson (“Tom”) Gorham 

State Bar No. 24012715 

tom@gillamsmithlaw.com 

GILLAM & SMITH, LLP 

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Telephone: (903) 934-8450 

Facsimile: (903) 934-9257 

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State Bar No. 10929400 

mikejones@potterminton.com 

Shaun W. Hassett 

State Bar No. 24074372 

shaunhassett@potterminton.com 

POTTER MINTON, P.C. 

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Tyler, Texas 75702 

Telephone: (903) 597-8311 

Facsimile: (903) 593-0846 

Lance Lin Yang 

CA. Bar No. 260705

Lanceyang@quinnemanuel.com 

Kevin (Gyushik) Jang 

CA Bar No. 337747 

kevinjang@quinnemanuel.com 

Sean S. Pak 

CA Bar No. 219032 

seanpak@quinnemanuel.com 

QUINN EMANUEL URQUHART &

SULLIVAN, LLP

50 California Street, 22nd Floor 

San Francisco, CA 94111 

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Telephone: (415) 875-6600 

Brady Huynh (admitted pro hac vice) 

CA Bar No. 339441 

bradyhuynh@quinnemanuel.com 

QUINN EMANUEL URQUHART &

SULLIVAN, LLP 

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Grant K. Schmidt 

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HILGERS GRABEN PLLC 

7859 Walnut Hill Lane, Suite 335 

Dallas, Texas 75230 

Telephone: (972) 645-3097 

ATTORNEYS FOR DEFENDANTS

SAMSUNG ELECTRONICS CO., LTD. AND

SAMSUNG ELECTRONICS AMERICA, INC.

 

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CERTIFICATE OF SERVICE 

I hereby certify that a true and correct copy of the foregoing document was filed 

electronically in compliance with Local Rule CV-5 on November 4, 2024. As of this date, all 

counsel of record had consented to electronic service and are being served with a copy of this 

document through the Court’s CM/ECF system under Local Rule CV-5(a)(3)(A). 

/s/ Thomas H. Reger 

Thomas H. Reger 

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