EXHIBIT 7

Case 2:23-cv-00397-JRG-RSP Document 53-8 Filed 04/11/24 Page 1 of 5 PageID #: 1021
From: Kristopher Davis

To: Nicholas Mathews

Cc: Clare Churchman; rak_headwater@raklaw.com; ATT_Headwater; Ddacus@dacusfirm.com; Melissa Kalka

Subject: Re: Headwater/AT&T: Discovery and Correspondence

Date: Friday, February 2, 2024 11:33:36 AM

Nick,

Following up on our discussion of asserted claim and prior art narrowing, please find below

Headwater’s proposal:

1. No later than 14 days after submission of the parties’ Joint Claim Construction Statement,

Headwater would serve its First Election of Asserted Claims, identifying no more than 128

total asserted claims across all patents.

2. No later than 14 days after Headwater’s First Election, AT&T would serve its First Election

of Prior Art, identifying no more than 64 total references across all patents.

3. No later than 28 days before the service of opening expert reports, Headwater would serve its

Second Election of Asserted Claims, identifying no more than 64 total asserted claims across

all patents.

4. No later than 28 days after Headwater’s Second Election, AT&T would serve its Second

Election of Prior Art, identifying no more than 32 total references across all patents.

Regards,

Kris

Kristopher Davis

Russ August & Kabat

12424 Wilshire Boulevard, 12th Floor

Los Angeles, CA 90025

(310) 826-7474

kdavis@raklaw.com

On Jan 30, 2024, at 9:53 AM, Kristopher Davis <kdavis@raklaw.com> wrote:

Nick,

2:00 pm CT today works for us. Talk to you then.

Regards,

Kris

Kristopher Davis

Russ August & Kabat

12424 Wilshire Boulevard, 12th Floor

Los Angeles, CA 90025

(310) 826-7474

kdavis@raklaw.com

Case 2:23-cv-00397-JRG-RSP Document 53-8 Filed 04/11/24 Page 2 of 5 PageID #: 1022
On Jan 29, 2024, at 2:48 PM, Nicholas Mathews

<nmathews@McKoolSmith.com> wrote:

Hi Kris -- looks like we weren't able to connect on Friday. I'm going to

send you an invite for 2p central time tomorrow, but please let me know if

another time works better. And please feel free to forward the invite to

anyone else on your side who should be participating. Thanks, Nick

NOTICE OF CONFIDENTIALITY: The information contained in and transmitted with this e-mail is SUBJECT TO THE

ATTORNEY-CLIENT and ATTORNEY WORK PRODUCT PRIVILEGE and is CONFIDENTIAL. It is intended only for the

individual or entity designated above. You are hereby notified that any dissemination, distribution, copying, use or

reliance upon the information contained in and transmitted with this e-mail by or to anyone other than the addressee

designated above by the sender is unauthorized and strictly prohibited. If you have received this e-mail in error, please

notify the sender by reply immediately. Any e-mail erroneously transmitted to you should be immediately destroyed.

From: Nicholas Mathews <nmathews@McKoolSmith.com>

Sent: Thursday, January 25, 2024 7:03 PM

To: Kristopher Davis <kdavis@raklaw.com>

Cc: Clare Churchman <cchurchman@mckoolsmith.com>;

rak_headwater@raklaw.com <rak_headwater@raklaw.com>;

ATT_Headwater <ATT_Headwater@mckoolsmith.com>;

Ddacus@dacusfirm.com <Ddacus@dacusfirm.com>; Melissa Kalka

<mkalka@McKoolSmith.com>

Subject: Re: Headwater/AT&T: Discovery and Correspondence

Yes. 

Get Outlook for iOS

McKool Smith | Nicholas Mathews

Principal | Dallas | (214) 978-4914

From: Kristopher Davis <kdavis@raklaw.com>

Sent: Thursday, January 25, 2024 6:17 PM

To: Nicholas Mathews <nmathews@McKoolSmith.com>

Cc: Clare Churchman <cchurchman@mckoolsmith.com>;

rak_headwater@raklaw.com <rak_headwater@raklaw.com>;

ATT_Headwater <ATT_Headwater@mckoolsmith.com>;

Ddacus@dacusfirm.com <Ddacus@dacusfirm.com>; Melissa Kalka

<mkalka@McKoolSmith.com>

Subject: Re: Headwater/AT&T: Discovery and Correspondence

Nick,

Case 2:23-cv-00397-JRG-RSP Document 53-8 Filed 04/11/24 Page 3 of 5 PageID #: 1023
Are you available tomorrow at 3:00 pm CT / 1:00 pm PT to discuss? 

Regards,

Kris

Kristopher Davis

Russ August & Kabat

12424 Wilshire Boulevard, 12th Floor

Los Angeles, CA 90025

(310) 826-7474

kdavis@raklaw.com

On Jan 25, 2024, at 9:43 AM, Nicholas Mathews

<nmathews@McKoolSmith.com> wrote:

Counsel – Please let me know your availability to

meet and confer on claim narrowing later this

afternoon or tomorrow. If we can’t reach

agreement soon on meaningful claim narrowing we

intend to move forward with a motion. Thanks,

Nick

NOTICE OF CONFIDENTIALITY: The information contained in and transmitted with this e-mail is SUBJECT TO THE ATTORNEY-CLIENT

and ATTORNEY WORK PRODUCT PRIVILEGE and is CONFIDENTIAL. It is intended only for the individual or entity designated above.

You are hereby notified that any dissemination, distribution, copying, use or reliance upon the information contained in and

transmitted with this e-mail by or to anyone other than the addressee designated above by the sender is unauthorized and strictly

prohibited. If you have received this e-mail in error, please notify the sender by reply immediately. Any e-mail erroneously

transmitted to you should be immediately destroyed.

From: Clare Churchman <cchurchman@mckoolsmith.com> 

Sent: Monday, January 22, 2024 3:17 PM

To: rak_headwater@raklaw.com

Cc: ATT_Headwater <ATT_Headwater@mckoolsmith.com>;

Ddacus@dacusfirm.com; Melissa Kalka

<mkalka@McKoolSmith.com>

Subject: RE: Headwater/AT&T: Discovery and Correspondence

Counsel,

Following up on this correspondence. Please let us know if you

are amenable to the proposed approach to narrowing this case.

Best,

Case 2:23-cv-00397-JRG-RSP Document 53-8 Filed 04/11/24 Page 4 of 5 PageID #: 1024
McKool Smith | Clare Churchman

Associate | Dallas | (214) 978-6336

From: Melissa Kalka <mkalka@McKoolSmith.com> 

Sent: Friday, January 12, 2024 6:21 PM

To: rak_headwater@raklaw.com

Cc: ATT_Headwater

<ATT_Headwater@mckoolsmith.com>;Ddacus@dacusfirm.com

Subject: Headwater/AT&T: Discovery and Correspondence

Counsel,

Please see attached:

1. AT&T’s First set of Interrogatories to Headwater (Nos. 1-

18).

2. AT&T’s First Request for Production of Documents

3. Letter from Nick Mathews

 Best regards,

McKool Smith | Melissa Kalka

Senior Paralegal | Dallas | (214) 978-6394

Case 2:23-cv-00397-JRG-RSP Document 53-8 Filed 04/11/24 Page 5 of 5 PageID #: 1025