Exhibit 9

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UNITED STATES DISTRICT COURT 

FOR THE EASTERN DISTRICT OF TEXAS 

MARSHALL DIVISION

Headwater Research LLC, 

Plaintiff, 

v. 

Samsung Electronics Co., Ltd., Samsung 

Electronics America, Inc., 

Defendants. 

§ 

§ 

§ 

§ 

§ 

§ 

§ 

§ 

§ 

§ 

Civil Action No. 2:22-cv-00422-JRG-RSP 

NON-PARTY QUALCOMM INCORPORATED’S OBJECTIONS AND RESPONSES TO 

DEFENDANTS’ SUBPOENA DUCES TECUM 

Non-Party Qualcomm Incorporate (“Qualcomm”) hereby serves these Objections and 

Responses (“Responses”), pursuant to Rules 26, 34, and 45 of the Federal Rules of Civil Procedure 

to the document requests propounded by Defendants Samsung Electronics Co., Ltd and Samsung 

Electronics America, Inc. (collectively, “Defendants” or “Samsung”) to the subpoena Duces 

Tecum Defendants served on non-party Qualcomm on December 21, 2023 (“Requests”). 

PRELIMINARY STATEMENT 

The following responses, while based on diligent investigation by Qualcomm and its 

counsel, are necessarily supported only by those facts and writings presently and specifically 

known and readily available. Qualcomm has not completed its investigation of all facts related to 

the subject matter of Defendants’ subpoena. Qualcomm therefore makes these responses without 

prejudice to its right to produce additional evidence of any facts or information that Qualcomm 

may later recall or discover. Qualcomm further reserves the right to amend or supplement any or 

all of the matters contained in these responses with facts or information that it learns were omitted 

by inadvertence. 

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These responses are made solely for the purposes of the above-captioned action (the 

“Litigation”) and are subject to all objections as to competence, authenticity, relevance, 

materiality, privilege, and admissibility. All such objections and grounds are expressly reserved. 

Qualcomm’s response to each individual Request is submitted without prejudice to and 

without waiving the general objections listed below but not expressly set forth in that response. 

The assertion of any objection to a Request in any response is neither intended as, nor shall in any 

way be deemed, a waiver of Qualcomm’s right to assert that or any other objection at a later date. 

Moreover, no incidental or implied admissions are intended by the responses below. The fact that 

Qualcomm has answered or objected to all or part of a Request should not be construed as an 

admission that Qualcomm accepts or admits the existence of any purported facts set forth or 

assumed by such Request or that Qualcomm has waived any part of any objection to the Request. 

GENERAL OBJECTIONS 

Non-Party Qualcomm makes the following General Objections, whether or not separately 

set forth in each response to each instruction, definition, Request, or Topic: 

1. Qualcomm objects to each and every definition, instruction, and Request to 

the extent that it seeks to impose a burden on third-party Qualcomm that the private parties to the 

Litigation have agreed not to apply to themselves. 

2. Qualcomm objects to each and every definition, instruction, and Request to 

the extent that it purports to impose any requirement or discovery obligation upon Qualcomm other 

than as set forth in the Federal Rules of Civil Procedure or the Court’s Local Rules. Qualcomm’s 

responses and obligations are governed by the foregoing rules and not any inconsistent or 

expanded definition or instruction provided by Defendants. 

3. Qualcomm objects to each and every definition, instruction, and Request to 

the extent that it seeks information protected by the attorney-client privilege, the work product 

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doctrine, or any other applicable privilege, rule, or duty of confidentiality that precludes or limits 

the disclosures of such information (hereinafter referred to as “Privileges”). Qualcomm will not 

disclose such information in response to these requests. Inadvertent disclosure of privileged 

information shall not waive any of the Privileges, and Qualcomm expressly reserves the right to 

seek return of any privilege information that is inadvertently produced. 

4. Qualcomm objects to each and every definition, instruction, and Request to 

the extent it seeks information for time periods beyond those relevant to the issues in this Litigation 

as overly broad, unduly burdensome, oppressive, not reasonably calculated to lead to the discovery 

of admissible evidence, and otherwise beyond the scope of permissible discovery under the Federal 

Rules of Civil Procedure. 

5. Qualcomm objects to each and every definition, instruction, and Request to 

the extent it seeks to impose an improper and undue burden or a burden that exceeds that 

contemplated by the Federal Rules of Civil Procedure. 

6. Qualcomm objects to the instructions, definitions, and Requests to the extent 

that they use terms that are not defined or understood, or are vaguely or ambiguously defined, and 

therefore fail to identify with reasonable particularity the information sought. When attempting to 

respond to a vague and ambiguous Request, Qualcomm will respond to the extent that it 

understands the Request. 

7. Qualcomm objects to the Requests to the extent that they are duplicative and 

cumulative to other discovery propounded in this action by Defendants, including discovery 

propounded by Defendants to the Plaintiff. Service of duplicative requests squanders third-party 

Qualcomm’s time and resources and creates an undue burden on Qualcomm in preparing 

responses. 

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8. Qualcomm objects to the Requests to the extent that they seek to impose an 

obligation to identify or search for documents or information at any location other than that at 

which they would be expected to be stored in the ordinary course of business. 

9. Qualcomm objects to each Request to the extent it seeks confidential or 

proprietary information pertaining to Qualcomm’s business, trade secrets, and/or economic 

relationships. Qualcomm will only provide such information subject to the terms of a mutually 

acceptable supplemental protective order specific to Qualcomm’s sensitive confidential business 

information or trade secrets to be entered in this Litigation. 

10. Qualcomm objects to each Request to the extent it purports to require 

Qualcomm to provide information relating to third parties that may potentially violate the privacy 

rights of those third parties, including but not limited to Qualcomm’s employees and former 

employees, based on statutory, California and/or federal constitutional, and/or public policy rights, 

and/or confidentiality agreements, arrangements or understandings between or among Qualcomm 

and its employees and/or other third parties. 

11. Qualcomm objects generally to each Request to the extent it seeks 

confidential, proprietary or trade secret information of third parties. Qualcomm further objects to 

each Request to the extent it seeks disclosure by Qualcomm of any information received from a 

third party under a non-disclosure agreement or subject to the common interest privilege, or the 

content of any part of any agreement between Qualcomm and a third party that, by its terms, may 

not be disclosed by Qualcomm. Qualcomm will seek consent of the third party for disclosure 

pursuant to the Protective Order and/or a mutually acceptable supplemental protective order and 

provide responsive information once consent has been secured. Qualcomm will advise Defendants 

should the third party refuse to permit disclosure. 

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12. Qualcomm objects to the Requests to the extent they seek documents or 

information that are in the public domain or equally available to Defendants on the basis that it is 

equally convenient for Defendants to compile and/or obtain such material. Qualcomm further 

objects to the Requests to the extent that they seek information or documents that are already 

known to or in the possession of Defendants or are discoverable from the Plaintiff. 

13. Qualcomm objects generally to each Request to the extent it seeks 

identification of “all” information or documents that refer or relate to a particular subject as overly 

broad and unduly burdensome. Qualcomm will make reasonable efforts to search for information 

relevant to the issues raised in the Litigation, including searches directed to documents of the types 

that are the subject of the Requests. If any additional non-privileged, non-immune, relevant 

information is discovered in the course of any further or continuing searches, it will be provided 

in accordance with the Federal Rules of Civil Procedure. 

14. Qualcomm objects to each definition, instruction, and Request to the extent 

that it seeks information unknown to Qualcomm or not within Qualcomm’s possession, custody 

or control. 

15. Qualcomm objects generally to each Request to the extent it calls for a legal 

opinion or conclusion. Any response or production of information by Qualcomm shall not be 

construed as providing a legal conclusion regarding the meaning or application of any terms or 

phrases used in the Requests. 

16. Qualcomm further objects to the Requests to the extent they seek the 

identification or production of e-mails or other forms of electronic communications absent: (1) a 

showing of good cause for the production of such communications, (2) a showing that the burden 

and expense of such production is proportional to the needs of the case, and (3) an agreement as 

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to a limited number of custodians, time period, and search terms. 

17. Qualcomm objects to any factual assumptions, implications, and explicit or 

implicit characterizations of facts, events, circumstances, or issues in the instructions, definitions, 

or Requests. Qualcomm’s responses herein are not intended to mean that Qualcomm agrees with 

any factual assumptions, implications, or any explicit or implicit characterization of facts, events, 

circumstances, or issues in the instructions, definitions, or Requests. 

18. Qualcomm’s responses to the Requests are made without in any way waiving 

or intending to waive: (a) any objections as to the competency, relevancy, materiality, privileged 

status, or admissibility as evidence, for any purpose, of any documents or information provided in 

response to the Requests; (b) the right to object on any ground to the documents or information 

produced in response to the Requests at any hearing or trial; or (c) the right to object on any ground 

at any time to a demand for further responses to the Requests. 

OBJECTIONS TO DEFINITIONS 

Qualcomm incorporates its Preliminary Statement and General Objections to each 

definition and further asserts the following Objections in particular to the Definitions. 

19. Qualcomm objects to the definition “Qualcomm,” “You,” and “Your” to the 

extent it includes any corporation, business, entity or individual other than Qualcomm 

Incorporated or its current employees or to the extent the definition includes legal counsel and 

thereby calls for information subject to the attorney-client privilege, work product doctrine, or any 

other privilege, protection or immunity. Qualcomm’s responses are solely on behalf of Qualcomm 

Incorporated. 

20. Qualcomm objects to the definition of “Headwater” as vague, ambiguous, and 

lacking reasonable particularity to the extent it includes any entity other than Headwater Research, 

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LLC and includes “its officers, directors, current and former employees, counsel, agents, 

consultants, representatives, and any other persons acting on behalf of any of the foregoing, and 

all Headwater affiliates, parents, divisions, joint ventures, licensees, franchisees, assigns, 

predecessors and successors in interest, and any other legal entities, whether foreign or domestic, 

that are owned, controlled by, or under common control with Headwater and all predecessors and 

successors in interest to such entities.” Qualcomm further objects to the definition of “Headwater” 

as overbroad because of the numerous categories of unidentified persons and/or entities the 

definition purports to capture. 

21. Qualcomm objects to the definition of “Document,” “documents,” and 

“document(s)” as overly broad, unduly burdensome, vague, ambiguous, and unclear to the extent 

it is seeking information that is neither relevant to the claims or defenses of any party to this action 

nor reasonably calculated to lead to the discovery of admissible evidence, particularly with respect 

to the inclusion of documents that are not within Qualcomm’s possession, custody, or control, or 

require information protected by the attorney-client privilege, work product doctrine, or other 

applicable protection. Qualcomm will respond in accordance with its obligations under the Federal 

Rules of Civil Procedure. 

22. Qualcomm objects to the definition of “person” or “Entity” to the extent it is 

overly broad, unduly burdensome, vague, ambiguous, unclear, and seeking information that is 

neither relevant to the claims or defenses of any party to this action nor reasonably calculated to 

lead to the discovery of admissible evidence, particularly with respect to the inclusion of 

documents that are not within Qualcomm’s possession, custody, or control, or require information 

protected by the attorney-client privilege, work product doctrine, or other applicable protection. 

Qualcomm will respond in accordance with its obligations under the Federal Rules of Civil 

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Procedure. 

OBJECTIONS TO INSTRUCTIONS 

Qualcomm incorporates its Preliminary Statement and General Objections to each 

instruction and further asserts the following Objections in particular to the Instructions. 

23. Qualcomm objects to Instruction No. 1 as overly broad and unduly 

burdensome for exceeding the obligations imposed by the Federal Rules of Civil Procedure 

regarding the production of documents and for not being proportional to the needs of the case. 

24. Qualcomm objects to Instruction No. 2 as overly broad and unduly 

burdensome to the extent it includes any corporation, business, entity or individual other than 

Qualcomm Incorporated or its current employees. 

25. Qualcomm objects to Instruction No. 3 as overly broad and unduly 

burdensome for exceeding the obligations imposed by the Federal Rules of Civil Procedure 

Qualcomm to the extent that it seeks to impose an obligation to identify or search for documents 

or information at any location other than that at which they would be expected to be stored in the 

ordinary course of business. Qualcomm further objects to Instruction No. 3 as not being 

proportional to the needs of the case. 

26. Qualcomm objects to Instruction No. 4 as overly broad and unduly 

burdensome for exceeding the obligations imposed by the Federal Rules of Civil Procedure. 

Qualcomm will only produce non-privileged, relevant documents in its possession, custody, or 

control. 

27. Qualcomm objects to Instruction No. 6 as overly broad and unduly 

burdensome for exceeding the obligations imposed by the Federal Rules of Civil Procedure and 

for not being proportional to the needs of the case. Qualcomm will only produce non-privileged 

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documents in its possession, custody, or control. 

28. Qualcomm objects to Instruction No. 7 as overly broad and unduly 

burdensome for exceeding the obligations imposed by the Federal Rules of Civil Procedure with 

regards to privileged or protected information and for not being proportional to the needs of the 

case. 

SPECIFIC OBJECTIONS TO REQUESTS FOR PRODUCTION 

REQUEST NO. 1: Documents sufficient to determine the dates of employment of 

Gregory Raleigh at Qualcomm, including but not limited to information identifying the start and 

termination dates of Gregory Raleigh. 

RESPONSE TO REQUEST NO. 1: 

Qualcomm incorporates its Preliminary Statement, General Objections, Objections to 

Definitions, and Objections to Instructions to the extent applicable to this Request. 

Qualcomm objects to this Request to the extent that “Documents sufficient to determine 

the dates of employment of Gregory Raleigh at Qualcomm” is interpreted to require more than 

documents sufficient to determine “the start and terminations dates of Gregory Raleigh.” Such 

information would be irrelevant, unrelated to any claim or defense of any party to this Litigation, 

not proportional to the needs of the Litigation, and not reasonably calculated to lead to the 

discovery of admissible evidence. 

Qualcomm objects to this Request to the extent it seeks information involving the 

confidential information of third parties that Qualcomm may not disclose due to confidentiality 

obligations without first obtaining third-party consent for their disclosure. Qualcomm further 

objects to this Request to the extent it purports to require Qualcomm to provide information 

relating to third parties, including but not limited to Qualcomm’s employees and former 

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employees, that may potentially violate the privacy rights of those employees, former employees, 

and/or third parties based on statutory, California and federal constitutional, and/or public policy 

rights, and/or confidentiality agreements, arrangements or understandings between or among 

Qualcomm and its employees, former employees, and/or other third parties. 

Subject to and without waiving the foregoing, and subject to Samsung obtaining any 

necessary consents required by appliable law, Qualcomm will produce documents sufficient to 

show the employment start and termination dates of Gregory Raleigh at Qualcomm. 

REQUEST NO. 2: All documents, communications, and things reflecting the 

employment of Gregory Raleigh by You, including but not limited to any signed: employment 

agreements, termination agreements; invention disclosure agreements, confidentiality agreements, 

and/or proprietary rights agreements between You and Gregory Raleigh. 

RESPONSE TO REQUEST NO. 2: 

Qualcomm incorporates its Preliminary Statement, General Objections, Objections to 

Definitions, and Objections to Instructions to the extent applicable to this Request. 

Qualcomm objects to this Request seeking “[a]ll documents, communications, and things 

reflecting the employment of Gregory Raleigh by You” as irrelevant information that is unrelated 

to any claim or defense of any party to this Litigation, not proportional to the needs of the 

Litigation, and not reasonably calculated to lead to the discovery of admissible evidence. This 

Request has not been narrowly tailored to seek discovery regarding the issues in this Litigation. 

Qualcomm further objects to this Request as overly broad, vague, and ambiguous with respect to 

“reflecting the employment of Gregory Raleigh by You.” Qualcomm objects to this Request 

because the broad and unfocused nature of the Request makes the burden or expense of searching 

for and producing the requested documents greatly outweigh, and not be proportional to, the likely 

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benefit of most, if not all, of the requested documents. Qualcomm further objects to this Request, 

which seeks “[a]ll documents ...” as overly broad and unduly burdensome. 

Qualcomm objects to this Request as unduly burdensome and not proportional to the needs 

of the case to the extent it seeks disclosure of information that is in the public domain, exclusively 

in the possession of third parties, or in the possession of any party in this action. The effort that 

would be required by Qualcomm to reasonably identify and produce documents on this Request 

imposes an improper and undue burden on Qualcomm, a nonparty to this action, particularly so 

where the materials sought may be obtained from other sources, including the Plaintiff and 

Plaintiff’s founder, Gregory Raleigh. Qualcomm further objects to this Request to the extent it 

seeks information involving the confidential information of third parties that Qualcomm may not 

disclose due to confidentiality obligations without first obtaining third-party consent for their 

disclosure. 

Qualcomm objects to this Request to the extent it seeks information involving the 

confidential information of third parties that Qualcomm may not disclose due to confidentiality 

obligations without first obtaining third-party consent for their disclosure. Qualcomm further 

objects to this Request to the extent it purports to require Qualcomm to provide information 

relating to third parties, including but not limited to Qualcomm’s employees and former 

employees, that may potentially violate the privacy rights of those employees, former employees, 

and/or third parties based on statutory, California and federal constitutional, and/or public policy 

rights, and/or confidentiality agreements, arrangements or understandings between or among 

Qualcomm and its employees, former employees, and/or other third parties. 

Subject to and without waiving the foregoing, and subject to obtaining any necessary 

consents required by appliable law, 

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Qualcomm objects to this Request to the extent it seeks information protected by the 

attorney-client privilege, the work product doctrine, and/or another applicable privilege. 

Subject to and without waiving the foregoing, and subject to Samsung obtaining any 

necessary consents required by appliable law, Qualcomm will produce documents sufficient to 

show signed employment agreements, termination agreements, confidentiality agreements, and/or 

proprietary rights agreements between Qualcomm Incorporated and Gregory Raleigh that are 

within Qualcomm Incorporated’s possession, custody, or control. 

REQUEST NO. 3: Documents sufficient to identify which of Your employees or 

former employees were Gregory Raleigh’s supervisors while employed by You, including but not 

limited to information identifying each of Gregory Raleigh’s supervisors during his employment 

to whom Gregory Raleigh directed requests to implement his ideas, creations, inventions, projects, 

and expenditures to, and whether said supervisors are still employed by You. 

RESPONSE TO REQUEST NO. 3: 

Qualcomm incorporates its Preliminary Statement, General Objections, Objections to 

Definitions, and Objections to Instructions to the extent applicable to this Request. 

Qualcomm objects to this Request seeking “[d]ocuments sufficient to identify which of 

Your employees or former employees were Gregory Raleigh’s supervisors while employed by 

You” and “information identifying each of Gregory Raleigh’s supervisors during his employment 

to whom Gregory Raleigh directed requests to implement his ideas, creations, inventions, projects, 

and expenditures to, and whether said supervisors are still employed by You” as irrelevant 

information that is unrelated to any claim or defense of any party to this Litigation, not proportional 

to the needs of the Litigation, and not reasonably calculated to lead to the discovery of admissible 

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evidence. This Request has not been narrowly tailored to seek discovery regarding the issues in 

this Litigation. 

Qualcomm objects to this Request as unduly burdensome and not proportional to the needs 

of the case. The effort that would be required by Qualcomm to reasonably identify and produce 

documents responsive to this Request imposes an improper and undue burden on Qualcomm, a 

nonparty to this action. 

Qualcomm objects to this Request to the extent it seeks information involving the 

confidential information of third parties that Qualcomm may not disclose due to confidentiality 

obligations without first obtaining third-party consent for their disclosure. Qualcomm further 

objects to this Request to the extent it purports to require Qualcomm to provide information 

relating to third parties, including but not limited to Qualcomm’s employees and former 

employees, that may potentially violate the privacy rights of those employees, former employees, 

and/or third parties based on statutory, California and federal constitutional, and/or public policy 

rights, and/or confidentiality agreements, arrangements or understandings between or among 

Qualcomm and its employees, former employees, and/or other third parties. 

Qualcomm objects to this Request to the extent it seeks information protected by the 

attorney-client privilege, the work product doctrine, and/or another applicable privilege. 

Subject to and without waiving the foregoing, Qualcomm is willing to meet and confer 

regarding the scope of this Request. 

REQUEST NO. 4: All documents reflecting any requests by Gregory Raleigh while 

employed by You to implement any ideas, creations, inventions, or projects related to the subject 

matter of the Asserted Patents (for example, managing how applications connect on smartphones; 

resource prioritization for in-focus, foreground, or background applications; differentiated 

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network access; policy-based aggregation of network activity; protecting network capacity; 

wireless network access policies, etc.). 

RESPONSE TO REQUEST NO. 4: 

Qualcomm incorporates its Preliminary Statement, General Objections, Objections to 

Definitions, and Objections to Instructions to the extent applicable to this Request. 

Qualcomm objects to this Request seeking “[a]ll documents reflecting any requests by 

Gregory Raleigh while employed by You to implement any ideas, creations, inventions, or projects 

related to the subject matter of the Asserted Patents” as irrelevant information that is unrelated to 

any claim or defense of any party to this Litigation, not proportional to the needs of the Litigation, 

and not reasonably calculated to lead to the discovery of admissible evidence. Qualcomm further 

objects to this Request as overly broad, vague, and ambiguous with respect to “related to the 

subject matter of the Asserted Patents” and “managing how applications connect on smartphones; 

resource prioritization for in-focus, foreground, or background applications; differentiated 

network access; policy-based aggregation of network activity; protecting network capacity; 

wireless network access policies, etc.” Qualcomm objects to this Request because the broad and 

unfocused nature of the Request makes the burden or expense of searching for and producing the 

requested documents greatly outweigh, and not be proportion to, the likely benefit of most, if not 

all, of the requested documents. This Request has not been narrowly tailored to seek discovery 

regarding the issues in this Litigation. Qualcomm further objects to this Request, which seeks 

“[a]ll documents ...” as overly broad and unduly burdensome. 

Qualcomm further objects to this Request to the extent it calls for lay opinions, expert 

opinions, legal opinions or conclusions, or other non-factual responses or interpretations regarding 

“the subject matter of the Asserted Patents” or the scope of the asserted claims. 

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Qualcomm objects to this Request to the extent it seeks information involving the 

confidential information of third parties that Qualcomm may not disclose due to confidentiality 

obligations without first obtaining third-party consent for their disclosure. 

Qualcomm objects to this Request as unduly burdensome and not proportional to the needs 

of the case to the extent it assumes facts that have not been established. 

Qualcomm objects to this Request to the extent it calls for legal conclusions or seeks 

information that is protected by the attorney-client privilege, the work product doctrine, and/or 

another applicable privilege. 

Subject to and without waiving the foregoing, Qualcomm is willing to meet and confer 

regarding the scope of this Request. 

REQUEST NO. 5: All documents, communications, and things reflecting any 

investigation, determination, inquiry, belief, opinion, or position as to whether the subject matter 

of the Asserted Patents (for example, managing how applications connect on smartphones; 

resource prioritization for in-focus, foreground, or background applications; differentiated 

network access; policy-based aggregation of network activity; protecting network capacity; 

wireless network access policies, etc.) was related to Your business, products, intellectual property, 

or services in the 2008 to 2010 timeframe. 

RESPONSE TO REQUEST NO. 5: 

Qualcomm incorporates its Preliminary Statement, General Objections, Objections to 

Definitions, and Objections to Instructions to the extent applicable to this Request. 

Qualcomm objects to this Request seeking “[a]ll documents, communications, and things 

reflecting any investigation, determination, inquiry, belief, opinion, or position as to whether the 

subject matter of the Asserted Patents ... was related to Your business, products, intellectual 

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property, or services in the 2008 to 2010 timeframe” as irrelevant information that is unrelated to 

any claim or defense of any party to this Litigation, not proportional to the needs of the Litigation, 

and not reasonably calculated to lead to the discovery of admissible evidence. Qualcomm further 

objects to this Request as overly broad, vague, and ambiguous with respect to “subject matter of 

the Asserted Patents,” “managing how applications connect on smartphones; resource 

prioritization for in-focus, foreground, or background applications; differentiated network access; 

policy-based aggregation of network activity; protecting network capacity; wireless network 

access policies, etc.,” and “related to Your business, products, intellectual property, or services.” 

Qualcomm objects to this Request because the broad and unfocused nature of the Request makes 

the burden or expense of searching for and producing the requested documents greatly outweigh, 

and not be proportion to, the likely benefit of most, if not all, of the requested documents. This 

Request has not been narrowly tailored to seek discovery regarding the issues in this Litigation. 

Qualcomm further objects to this Request, which seeks “[a]ll documents ...” as overly broad and 

unduly burdensome. 

Qualcomm further objects to this Request to the extent it calls for lay opinions, expert 

opinions, legal opinions or conclusions, or other non-factual responses or interpretations regarding 

“the subject matter of the Asserted Patents” or the scope of the asserted claims. 

Qualcomm objects to this Request to the extent it seeks information involving the 

confidential information of third parties that Qualcomm may not disclose due to confidentiality 

obligations without first obtaining third-party consent for their disclosure. 

Qualcomm objects to this Request as unduly burdensome and not proportional to the needs 

of the case to the extent it assumes facts that have not been established. 

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Qualcomm objects to this Request to the extent it calls for legal conclusions or seeks 

information that is protected by the attorney-client privilege, the work product doctrine, and/or 

another applicable privilege. 

Subject to and without waiving the foregoing, Qualcomm will not search for or produce 

documents responsive to this Request. 

REQUEST NO. 6: All documents, communications, and things reflecting any usage of 

Qualcomm equipment, supplies, facilities, or trade-secret information by Gregory Raleigh to 

develop technology related to the subject matter of the Asserted Patents (for example, managing 

how applications connect on smartphones; resource prioritization for in-focus, foreground, or 

background applications; differentiated network access; policy-based aggregation of network 

activity; protecting network capacity; wireless network access policies, etc.). 

RESPONSE TO REQUEST NO. 6: 

Qualcomm incorporates its Preliminary Statement, General Objections, Objections to 

Definitions, and Objections to Instructions to the extent applicable to this Request. 

Qualcomm objects to this Request seeking “[a]ll documents, communications, and things 

reflecting any usage of Qualcomm equipment, supplies, facilities, or trade-secret information by 

Gregory Raleigh to develop technology related to the subject matter of the Asserted Patents” as 

irrelevant information that is unrelated to any claim or defense of any party to this Litigation, not 

proportional to the needs of the Litigation, and not reasonably calculated to lead to the discovery 

of admissible evidence. Qualcomm further objects to this Request as overly broad, vague, and 

ambiguous with respect to “technology related to the subject matter of the Asserted Patents” and 

“managing how applications connect on smartphones; resource prioritization for in-focus, 

foreground, or background applications; differentiated network access; policy-based aggregation 

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of network activity; protecting network capacity; wireless network access policies, etc.” 

Qualcomm objects to this Request because the broad and unfocused nature of the Request makes 

the burden or expense of searching for and producing the requested documents greatly outweigh, 

and not be proportion to, the likely benefit of most, if not all, of the requested documents. This 

Request has not been narrowly tailored to seek discovery regarding the issues in this Litigation. 

Qualcomm further objects to this Request, which seeks “[a]ll documents ...” as overly broad and 

unduly burdensome. 

Qualcomm further objects to this Request to the extent it calls for lay opinions, expert 

opinions, legal opinions or conclusions, or other non-factual responses or interpretations regarding 

“the subject matter of the Asserted Patents” or the scope of the asserted claims. 

Qualcomm objects to this Request to the extent it seeks information involving the 

confidential information of third parties that Qualcomm may not disclose due to confidentiality 

obligations without first obtaining third-party consent for their disclosure. 

Qualcomm objects to this Request as unduly burdensome and not proportional to the needs 

of the case to the extent it assumes facts that have not been established. 

Qualcomm objects to this Request to the extent it calls for legal conclusions or seeks 

information that is protected by the attorney-client privilege, the work product doctrine, and/or 

another applicable privilege. 

Subject to and without waiving the foregoing, Qualcomm is willing to meet and confer 

regarding the scope of this Request. 

REQUEST NO. 7: Documents sufficient to determine the various dates of employment 

of Alireza Raissinia at Qualcomm, including but not limited to information identifying any start 

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and termination dates of Alireza Raissinia relating to at least his two separate time periods as a 

Qualcomm employee. 

RESPONSE TO REQUEST NO. 7: 

Qualcomm incorporates its Preliminary Statement, General Objections, Objections to 

Definitions, and Objections to Instructions to the extent applicable to this Request. 

Qualcomm objects to this Request to the extent that “Documents sufficient to determine 

the various dates of employment of Alireza Raissinia at Qualcomm” is interpreted to require more 

than documents sufficient to show “any start and termination dates of Alireza Raissinia relating to 

at least his two separate time periods as a Qualcomm employee.” Such information would be 

irrelevant, unrelated to any claim or defense of any party to this Litigation, not proportional to the 

needs of the Litigation, and not reasonably calculated to lead to the discovery of admissible 

evidence. 

Qualcomm objects to this Request to the extent it seeks information involving the 

confidential information of third parties that Qualcomm may not disclose due to confidentiality 

obligations without first obtaining third-party consent for their disclosure. Qualcomm further 

objects to this Request to the extent it purports to require Qualcomm to provide information 

relating to third parties, including but not limited to Qualcomm’s employees and former 

employees, that may potentially violate the privacy rights of those employees, former employees, 

and/or third parties based on statutory, California and federal constitutional, and/or public policy 

rights, and/or confidentiality agreements, arrangements or understandings between or among 

Qualcomm and its employees, former employees, and/or other third parties. 

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Subject to and without waiving the foregoing, and subject to Samsung obtaining any 

necessary consents required by appliable law, Qualcomm will produce documents sufficient to 

show the employment start and termination date(s) of Alireza Raissinia at Qualcomm. 

REQUEST NO. 8: All documents, communications, and things reflecting the 

employment of Alireza Raissinia by You, including but not limited to any signed: employment 

agreements, termination agreements; invention disclosure agreements, confidentiality agreements, 

and/or proprietary rights agreements between You and Alireza Raissinia, including relating to his 

time as a Qualcomm employee ending in 2009. 

RESPONSE TO REQUEST NO. 8: 

Qualcomm incorporates its Preliminary Statement, General Objections, Objections to 

Definitions, and Objections to Instructions to the extent applicable to this Request. 

Qualcomm objects to this Request seeking “[a]ll documents, communications, and things 

reflecting the employment of Alireza Raissinia by You” as irrelevant information that is unrelated 

to any claim or defense of any party to this Litigation, not proportional to the needs of the 

Litigation, and not reasonably calculated to lead to the discovery of admissible evidence. 

Qualcomm further objects to this Request as overly broad, vague, and ambiguous with respect to 

“reflecting the employment of Alireza Raissinia by You.” Qualcomm objects to this Request 

because the broad and unfocused nature of the Request makes the burden or expense of searching 

for and producing the requested documents greatly outweigh, and not be proportional to, the likely 

benefit of most, if not all, of the requested documents. This Request has not been narrowly tailored 

to seek discovery regarding the issues in this Litigation. Qualcomm further objects to this Request, 

which seeks “[a]ll documents ...” as overly broad and unduly burdensome. 

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Qualcomm objects to this Request as unduly burdensome and not proportional to the needs 

of the case to the extent it seeks disclosure of information that is in the public domain, exclusively 

in the possession of third parties, or in the possession of any party in this action. The effort that 

would be required by Qualcomm to reasonably identify and produce documents on this Request 

imposes an improper and undue burden on Qualcomm, a nonparty to this action, particularly so 

where the materials sought may be obtained from other sources, including the Plaintiff. 

Qualcomm objects to this Request to the extent it seeks information involving the 

confidential information of third parties that Qualcomm may not disclose due to confidentiality 

obligations without first obtaining third-party consent for their disclosure. Qualcomm further 

objects to this Request to the extent it purports to require Qualcomm to provide information 

relating to third parties, including but not limited to Qualcomm’s employees and former 

employees, that may potentially violate the privacy rights of those employees, former employees, 

and/or third parties based on statutory, California and federal constitutional, and/or public policy 

rights, and/or confidentiality agreements, arrangements or understandings between or among 

Qualcomm and its employees, former employees, and/or other third parties. 

Qualcomm objects to this Request to the extent it seeks information protected by the 

attorney-client privilege, the work product doctrine, and/or another applicable privilege. 

Subject to and without waiving the foregoing, and subject to Samsung obtaining any 

necessary consents required by appliable law, Qualcomm will produce documents sufficient to 

show signed employment agreements, termination agreements, confidentiality agreements, and/or 

proprietary rights agreements between Qualcomm Incorporated and Alireza Raissinia that are 

within Qualcomm Incorporated’s possession, custody, or control. 

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REQUEST NO. 9: Documents sufficient to identify which of Your employees or 

former employees were Alireza Raissinia’s supervisors while employed by You before Alireza 

Raissinia left Qualcomm in 2009, including but not limited to information identifying each of 

Alireza Raissinia’s supervisors during his employment to whom Alireza Raissinia directed 

requests to and/or suggestions for implementing his ideas, creations, inventions, projects, and 

expenditures, and whether said supervisors are still employed by You. 

RESPONSE TO REQUEST NO. 9: 

Qualcomm incorporates its Preliminary Statement, General Objections, Objections to 

Definitions, and Objections to Instructions to the extent applicable to this Request. 

Qualcomm objects to this Request seeking “[d]ocuments sufficient to identify which of 

Your employees or former employees were Alireza Raissinia’s supervisors while employed by 

You” and “information identifying each of Alireza Raissinia’s supervisors during his employment 

to whom Alireza Raissinia directed requests to and/or suggestions for implementing his ideas, 

creations, inventions, projects, and expenditures, and whether said supervisors are still employed 

by You” as irrelevant information that is unrelated to any claim or defense of any party to this 

Litigation, not proportional to the needs of the Litigation, and not reasonably calculated to lead to 

the discovery of admissible evidence. This Request has not been narrowly tailored to seek 

discovery regarding the issues in this Litigation. 

Qualcomm objects to this Request to the extent it seeks information involving the 

confidential information of third parties that Qualcomm may not disclose due to confidentiality 

obligations without first obtaining third-party consent for their disclosure. Qualcomm further 

objects to this Request to the extent it purports to require Qualcomm to provide information 

relating to third parties, including but not limited to Qualcomm’s employees and former 

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employees, that may potentially violate the privacy rights of those employees, former employees, 

and/or third parties based on statutory, California and federal constitutional, and/or public policy 

rights, and/or confidentiality agreements, arrangements or understandings between or among 

Qualcomm and its employees, former employees, and/or other third parties. 

Qualcomm objects to this Request to the extent it seeks information protected by the 

attorney-client privilege, the work product doctrine, and/or another applicable privilege. 

Subject to and without waiving the foregoing, Qualcomm is willing to meet and confer 

regarding the scope of this Request. 

REQUEST NO. 10: All documents reflecting any requests by Alireza Raissinia while 

employed by You to implement any ideas, creations, inventions, or projects related to the subject 

matter of the Asserted Patents (for example, managing how applications connect on smartphones; 

resource prioritization for in-focus, foreground, or background applications; differentiated 

network access; policy-based aggregation of network activity; protecting network capacity; 

wireless network access policies, etc.). 

RESPONSE TO REQUEST NO. 10: 

Qualcomm incorporates its Preliminary Statement, General Objections, Objections to 

Definitions, and Objections to Instructions to the extent applicable to this Request. 

Qualcomm objects to this Request seeking “[a]ll documents reflecting any requests by 

Alireza Raissinia while employed by You to implement any ideas, creations, inventions, or 

projects related to the subject matter of the Asserted Patents” as irrelevant information that is 

unrelated to any claim or defense of any party to this Litigation, not proportional to the needs of 

the Litigation, and not reasonably calculated to lead to the discovery of admissible evidence. 

Qualcomm further objects to this Request as overly broad, vague, and ambiguous with respect to 

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“related to the subject matter of the Asserted Patents” and “managing how applications connect on 

smartphones; resource prioritization for in-focus, foreground, or background applications; 

differentiated network access; policy-based aggregation of network activity; protecting network 

capacity; wireless network access policies, etc.” Qualcomm objects to this Request because the 

broad and unfocused nature of the Request makes the burden or expense of searching for and 

producing the requested documents greatly outweigh, and not be proportion to, the likely benefit 

of most, if not all, of the requested documents. This Request has not been narrowly tailored to 

seek discovery regarding the issues in this Litigation. Qualcomm further objects to this Request, 

which seeks “[a]ll documents ...” as overly broad and unduly burdensome. 

Qualcomm further objects to this Request to the extent it calls for lay opinions, expert 

opinions, legal opinions or conclusions, or other non-factual responses or interpretations regarding 

“the subject matter of the Asserted Patents” or the scope of the asserted claims. 

Qualcomm objects to this Request to the extent it seeks information involving the 

confidential information of third parties that Qualcomm may not disclose due to confidentiality 

obligations without first obtaining third-party consent for their disclosure. 

Qualcomm objects to this Request as unduly burdensome and not proportional to the needs 

of the case to the extent it assumes facts that have not been established. 

Qualcomm objects to this Request to the extent it calls for legal conclusions or seeks 

information that is protected by the attorney-client privilege, the work product doctrine, and/or 

another applicable privilege. 

Subject to and without waiving the foregoing, Qualcomm is willing to meet and confer 

regarding the scope of this Request. 

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REQUEST NO. 11: All documents, communications, and things reflecting any usage of 

Qualcomm equipment, supplies, facilities, or trade-secret information by Alireza Raissinia to 

develop technology related to the subject matter of the Asserted Patents (for example, managing 

how applications connect on smartphones; resource prioritization for in-focus, foreground, or 

background applications; differentiated network access; policy-based aggregation of network 

activity; protecting network capacity; wireless network access policies, etc.). 

RESPONSE TO REQUEST NO. 11: 

Qualcomm incorporates its Preliminary Statement, General Objections, Objections to 

Definitions, and Objections to Instructions to the extent applicable to this Request. 

Qualcomm objects to this Request seeking “[a]ll documents, communications, and things 

reflecting any usage of Qualcomm equipment, supplies, facilities, or trade-secret information by 

Gregory Raleigh to develop technology related to the subject matter of the Asserted Patents” as 

irrelevant information that is unrelated to any claim or defense of any party to this Litigation, not 

proportional to the needs of the Litigation, and not reasonably calculated to lead to the discovery 

of admissible evidence. Qualcomm further objects to this Request as overly broad, vague, and 

ambiguous with respect to “technology related to the subject matter of the Asserted Patents” and 

“managing how applications connect on smartphones; resource prioritization for in-focus, 

foreground, or background applications; differentiated network access; policy-based aggregation 

of network activity; protecting network capacity; wireless network access policies, etc.” 

Qualcomm objects to this Request because the broad and unfocused nature of the Request makes 

the burden or expense of searching for and producing the requested documents greatly outweigh, 

and not be proportion to, the likely benefit of most, if not all, of the requested documents. This 

Request has not been narrowly tailored to seek discovery regarding the issues in this Litigation. 

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Qualcomm further objects to this Request, which seeks “[a]ll documents ...” as overly broad and 

unduly burdensome. 

Qualcomm further objects to this Request to the extent it calls for lay opinions, expert 

opinions, legal opinions or conclusions, or other non-factual responses or interpretations regarding 

“the subject matter of the Asserted Patents” or the scope of the asserted claims. 

Qualcomm objects to this Request to the extent it seeks information involving the 

confidential information of third parties that Qualcomm may not disclose due to confidentiality 

obligations without first obtaining third-party consent for their disclosure. 

Qualcomm objects to this Request as unduly burdensome and not proportional to the needs 

of the case to the extent it assumes facts that have not been established. 

Qualcomm objects to this Request to the extent it calls for legal conclusions or seeks 

information that is protected by the attorney-client privilege, the work product doctrine, and/or 

another applicable privilege. 

Subject to and without waiving the foregoing, Qualcomm is willing to meet and confer 

regarding the scope of this Request. 

REQUEST NO. 12: All documents, communications, and things relating to or 

corresponding with the conception, reduction to practice, and filing of US Patent No. 8,856,798 

and European Patent No. 2215873B1, to which Qualcomm is the assignee. 

RESPONSE TO REQUEST NO. 12: 

Qualcomm incorporates its Preliminary Statement, General Objections, Objections to 

Definitions, and Objections to Instructions to the extent applicable to this Request. 

Qualcomm objects to this Request seeking “[a]ll documents, communications, and things 

relating to or corresponding with the conception, reduction to practice, and filing of US Patent No. 

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8,856,798 and European Patent No. 2215873B1, to which Qualcomm is the assignee” as irrelevant 

information that is unrelated to any claim or defense of any party to this Litigation, not proportional 

to the needs of the Litigation, and not reasonably calculated to lead to the discovery of admissible 

evidence. 

Qualcomm further objects to this Request as overly broad, vague, and ambiguous with 

respect to “relating to or corresponding with the conception, reduction to practice, and filing of US 

Patent No. 8,856,798 and European Patent No. 2215873B1.” Qualcomm objects to this Request 

because the broad and unfocused nature of the Request makes the burden or expense of searching 

for and producing the requested documents greatly outweigh, and not be proportion to, the likely 

benefit of most, if not all, of the requested documents. This Request has not been narrowly tailored 

to seek discovery regarding the issues in this Litigation. Qualcomm further objects to this Request, 

which seeks “[a]ll documents ...” as overly broad and unduly burdensome. 

Qualcomm objects to this Request as unduly burdensome and not proportional to the needs 

of the case as it is unlimited in time and not narrowly tailored to the facts of the case. 

Qualcomm objects to this Request to the extent it calls for legal conclusions or seeks 

information that is protected by the attorney-client privilege, the work product doctrine, and/or 

another applicable privilege. 

Subject to and without waiving the foregoing, Qualcomm is willing to meet and confer 

regarding the scope of this Request. 

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Dated: January 23, 2024 Respectfully submitted, 

/s/ Daniel A. Prati 

Richard S. Zembek 

State Bar No. 00797726 

richard.zembek@nortonrosefulbright.com 

Daniel A. Prati 

State Bar No. 24070446 

daniel.prati@nortonrosefulbright.com 

1301 McKinney, Suite 5100 

Houston, TX 77010-3095 

Telephone: (713) 651-5151 

Facsimile: (713) 651-5246 

COUNSEL FOR NON-PARTY 

QUALCOMM INCORPORATED 

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