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 

DEFENDANTS’ RESPONSE IN OPPOSITION TO PLAINTIFF’S 

OMNIBUS MOTIONS IN LIMINE

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TABLE OF CONTENTS 

Headwater MIL 1: To Preclude Evidence or Argument Decided Upon in 

Headwater I .........................................................................................................................1

Headwater MIL 2: To Preclude Evidence or Argument Regarding the Success or 

Failure of ItsOn and the ItsOn Software, Where Both Parties Agree That ItsOn 

Software Does Not Practice Any Asserted Patent in This Case ..........................................1

Headwater MIL 3: To Exclude Evidence of Headwater Corporate Culture and 

Non-Practicing Entity Status................................................................................................3

Headwater MIL 4: To Exclude Evidence or Argument Regarding an Expert’s 

Record ..................................................................................................................................5

Headwater MIL 5: To Exclude References to Dr. Groehn’s Errors in 

Headwater I Where He Reuses the Same Survey in This Case ...........................................8

 

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TABLE OF EXHIBITS 

Exhibit Description 

1 Curriculum Vitae of Erik de la Iglesia

2 Excerpts from the Trial Transcript from Ecofactor, Inc. vs. Ecobee, Inc., Case No. 

6:20-CV-78/6:21-CV-428 

3 Expert Declaration of Erik de la Iglesia in Support of Plaintiff Parking Technology 

Holdings LLC’s Opening Claim Construction Brief from Parking Tech. Holdings 

LLC vs. Park Assist, LLC, Civil Action No. 1:20-cv-03156-PGG 

4 Excerpts from the Deposition Transcript of Dr. Andres Groehn, taken October 18, 

2024 

*Emphasis added unless otherwise noted. 

Abbreviations Used 

CMIL Court MIL set forth in Standing Order on Motions in Limine in Cases Involving, 

Allegations of Patent Infringement and/or Breach of FRAND Obligations, as well 

as Declaratory Judgment Actions Which Relate to the Same, dated August 11, 

2023 

Headwater Plaintiff and its purported predecessors 

Headwater I Headwater Research LLC v. Samsung Elecs. Am., Inc., Case No. 22-cv-00422-

JRG-RSP (E.D.Tex.) 

Headwater II This case 

RAK Russ August & Kabat 

Samsung Defendants 

 

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TABLE OF AUTHORITIES 

 Page(s) 

Cases 

Collins v. Wayne Corp., 

621 F.2d 777 (5th Cir. 1980) .....................................................................................................6 

Mobile Equity Corp. v. Walmart Inc., 

Case No. 2:21-cv-00126-JRG-RSP, Dkt. 384 (E.D. Tex. Oct. 3, 2022) ...................................6 

Mobile Telecomms. Techs. v. ZTE United States, Inc., 

Case No. 2:13-CV-946-JRG, 2016 U.S. Dist. LEXIS 184653 

(E.D. Tex. July 21, 2016) ...........................................................................................................5 

Optis Wireless Tech., LLC v. Apple Inc., 

Case No. 2:19-CV-00066-JRG, Dkt. 350 (E.D. Tex. July 17, 2020) ........................................5 

Rembrandt Wireless Techs., LP v. Samsung Elecs. Co., 

853 F.3d 1370 (Fed. Cir. 2017)..................................................................................................9 

Other Authorities 

Fed. R. Evid. 401 .............................................................................................................................3 

Fed. R. Evid. 402 .............................................................................................................................4 

Fed. R. Evid. 403 .............................................................................................................................4 

Fed. R. Evid. 404 .............................................................................................................................4 

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HEADWATER MIL 1: To Preclude Evidence or Argument Decided Upon in 

Headwater I

Samsung stipulates to not present “evidence or argument regarding any alleged breach of 

ethical or fiduciary duties, allegations of improper shifting of funds, embezzlement, threats, or 

violations of Bar rules, including in the context of determining an appropriate damages amount” 

as ordered by the Court in Headwater I. Headwater I, Dkt. 350 at 2-3. To minimize the parties’ 

disputes in this case, Samsung further stipulates (1) not to introduce testimony, evidence, or 

argument regarding the amount of offers from or , and (2) not to offer 

speculation as to why the was not consummated. To be clear, 

Samsung understands the Court’s prior Headwater I rulings to permit full discussion and use of 

other evidence relating to the , which Samsung understands will remain 

available to it in this case. Samsung believes that these stipulations resolve Headwater’s MIL 1. 

HEADWATER MIL 2: To Preclude Evidence or Argument Regarding the Success 

or Failure of ItsOn and the ItsOn Software, Where Both Parties Agree That ItsOn 

Software Does Not Practice Any Asserted Patent in This Case 

Headwater’s MIL 2 should be denied because Headwater cannot pick and choose which 

parts of ItsOn’s “contextual” history are revealed to the jury and which remain hidden. 

To be clear, Samsung does not believe that ItsOn is relevant to the present case, Headwater 

II. During the parties’ meet and confer, Samsung was willing to agree that ItsOn is wholly 

irrelevant for largely the same reasons Headwater advances in its MIL: ItsOn is a long-defunct 

third party whose technology (the ItsOn Solution) never practiced the Asserted Patents. Prescott 

Decl. ¶ 2. But Headwater did not agree. Id. Instead, as stated in MIL 2, Headwater plans to 

introduce evidence and argument about ItsOn “to provide the jury with context as to:” (1) 

“Headwater’s background as a company,” (2) “its efforts to license its patented technology,” and 

(3) “Dr. Raleigh’s experience in the industry.” Dkt. 240 at 3. 

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Headwater cannot have it both ways. If Headwater is permitted to introduce this 

“contextual” background evidence, then the jury might incorrectly conclude that: (1) ItsOn was a 

successful company and partner of Headwater (i.e., that ItsOn and Headwater succeeded at 

marketing/selling commercial embodiments of Headwater’s “patented technology”); (2) the 

“patented technology”―the ItsOn Solution―that Headwater licensed to ItsOn actually used the 

Asserted Patents in this suit, (3) ItsOn’s use of the Asserted Patents was a success/had value; and 

(4) Headwater’s ownership of other patents means ItsOn/Dr. Raleigh was innovative. Such 

inferences would unjustifiably lend credibility to Dr. Raleigh’s allegedly extensive and/or 

successful “experience in the industry.” Samsung should be able to introduce competing evidence, 

including (1) that ItsOn failed/went bankrupt, and Headwater terminated ItsOn’s licenses for 

nonpayment of royalties, as well as (2) that the “patented technology”―the ItsOn Solution―did 

not make use of the asserted patents and further that it was unsuccessful (e.g., evidence and 

testimony that it was not well received and did not practice the patents asserted in this case, a 

Georgia-Pacific factor). Headwater cannot introduce its subjective version of events as to 

ItsOn―leaving the jury with the misimpression that ItsOn was successful and giving Headwater 

and Dr. Raleigh industry credibility―while using its in limine motion to shield itself from a 

competing version of events revealed through extensive discovery. Samsung must be permitted 

to present a full picture. 

Headwater wants to pick and choose which ItsOn “contextual” facts and evidence it gets 

to introduce and exclude Samsung from disclosing the rest. Samsung’s position is simply that 

once Headwater opens the door to ItsOn’s allegedly relevant “background” and “history” with 

Headwater, then Headwater cannot select which facts about this “background” and “history” come 

into evidence. A contrary holding would unfairly prejudice Samsung and mislead the jury. 

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HEADWATER MIL 3: To Exclude Evidence of Headwater Corporate Culture and 

Non-Practicing Entity Status 

Headwater’s MIL 3 should be denied. Evidence of Dr. Gregory Raleigh 

 is relevant to rebutting secondary considerations of 

nonobviousness and it is not propensity evidence. Samsung does not intend to argue that Dr. 

Raleigh acted in a specific manner on a particular occasion. Instead, the disputed testimony 

highlights the general conditions under which Headwater employees operated and speaks directly 

to invalidity 

Former Headwater employee testified about Headwater’s corporate culture 

. For instance, when asked why he did not 

enjoy working at Headwater, Mr. Modlin stated: 

 

Dkt. 240-9 ( Tr.) at 53:01–09. Headwater’s argument that such testimony is irrelevant lacks 

merit. First, the bar for relevance is minimal. Evidence is relevant if “it has any tendency to make 

a fact more or less probable.” Fed. R. Evid. 401. Second, such testimony is highly probative as it 

directly addresses the strength of the Asserted Patents. The process by which Headwater evaluated 

prior art is probative of the robustness and purported inventiveness of its patent claims. A jury is 

entitled to weigh whether undermines 

the patents’ alleged nonobviousness. Third, secondary considerations, such as solving a long-felt 

need or achieving commercial success, are weakened if . 

Evidence of systemic issues in patent vetting—such as a corporate culture of 

—is relevant to the jury’s evaluation of the patents’ invalidity. 

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Unable to prevail under Rule 402, Headwater next argues that the testimony is prejudicial 

but fails to identify any specific prejudice. At most, Headwater vaguely claims the testimony 

would prejudice Headwater by “inviting the jury to find against Headwater for reasons unrelated 

to the merits of the disputed issues.” Dkt. 240 at 4. Headwater does not explain, however, why 

the jury would conflate this testimony with issues of merit, such as Samsung’s alleged 

infringement. More importantly, testimony that may influence the jury’s determination of patent 

validity is not prejudicial—it is probative of a fact of consequence. Rule 403 does not bar evidence 

merely because it carries some risk of prejudice; rather, it requires that the risk of prejudice 

“substantially outweighs” the probative value. Headwater cannot meet this standard. 

Headwater then attempts to frame this issue under Rule 404, claiming the testimony “serves 

no purpose other than to improperly disparage and attack the character of Dr. Raleigh.” Dkt. 240 

at 5. However, Headwater misapplies the rule. There is no basis to assert that Samsung intends 

to present evidence that Dr. Raleigh acted in a specific manner on a particular occasion related to 

the Asserted Patents. Instead, testimony offers the jury insight into Headwater’s 

general practices and the conditions under which its prior art searchers operated, including 

. This context is relevant to the jury’s evaluation of 

nonobviousness of the Asserted Patents. Thus, the first portion of Headwater’s MIL 3 should be 

denied. 

Skirting this Court’s limit of five MILs, Headwater’s MIL 3 also seeks to exclude 

testimony regarding “Headwater’s status as an alleged NPE.” Dkt. 240 at 5. This request should 

be denied. Headwater admittedly does not practice the Asserted Patents and CMIL No. 11 

explicitly allows use of the term “non-practicing entity.” Samsung will abide by CMIL No. 11, 

which precludes evidence referencing NPEs using disparaging language (e.g., “patent troll” or 

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“pirate”). The limited testimony designated by Samsung, however, merely explains Headwater’s 

business function as a non-practicing entity and does not disparage Headwater in a way that could 

be deemed prejudicial. As Headwater has not identified any testimony exceeding the bounds of 

CMIL No. 11, Headwater’s request on this issue should be denied as well. 

HEADWATER MIL 4: To Exclude Evidence or Argument Regarding an Expert’s 

Record 

Headwater’s MIL 4 seeking to preclude evidence and argument about Mr. de la Iglesia’s 

record should be denied. 

Evidence and argument about the unique nature of Mr. de la Iglesia’s relationship with 

RAK goes to Mr. de la Iglesia’s propensity to tell the truth under oath. Mr. de la Iglesia has been 

involved in over 50 patent infringement cases on behalf of litigants represented by RAK. See Ex. 

1. Therefore, this case is far from a situation where Samsung is cherry-picking Mr. de la Iglesia’s 

experience working with a law firm. Moreover, at deposition, Mr. de la Iglesia could not even 

answer , despite 

having addressed a similar line of questioning in an earlier jury trial. Dkt. 240-3 at 74:1-76:17; 

Ex. 2 (Ecofactor Jury Tr.) at 207:9-210:24. 

This Court has previously approved lines of questioning about experts past engagements 

with law firms. See, e.g., Mobile Telecomms. Techs. v. ZTE United States, Inc., Case No. 2:13-

CV-946-JRG, 2016 U.S. Dist. LEXIS 184653, at *10-11 (E.D. Tex. July 21, 2016) (setting forth 

“express guidance/directives” that the “parties are permitted to generally question experts 

concerning their prior engagements with the parties and law firms in this lawsuit”); Optis Wireless 

Tech., LLC v. Apple Inc., Case No. 2:19-CV-00066-JRG, Dkt. 350 at 2 (E.D. Tex. July 17, 2020) 

(explicitly ordering the production of “total composite gross dollar amount billed or invoiced by 

each expert for [plaintiff] to [law firms] and related to litigation in which [defendant] is named as 

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a party”) . The Fifth Circuit has also found that “cross-examination of an expert about fees earned 

in prior cases is not improper” and explained that “a showing of a pattern of compensation in past 

cases raises an inference of the possibility that the witness has slanted his testimony in those cases 

so he would be hired to testify in future cases.” See Collins v. Wayne Corp., 621 F.2d 777, 784 

(5th Cir. 1980). Headwater’s cited cases are inapposite. In Mobile Equity Corp. v. Walmart Inc., 

this Court permitted some questioning about the expert’s past representations, noting that the MIL 

“does not preclude the Parties from questioning experts about how often they are retained by 

plaintiffs vs defendants” or “whether the experts have been retained by the current parties ... in 

the past.” Case No. 2:21-cv-00126-JRG-RSP, Dkt. 384 at 9 (E.D. Tex. Oct. 3, 2022). And 

Headwater provides no evidence that IPCom GmbH & Co. KG, CEATS Inc., and Ericsson involved 

a situation where, as here, an expert was repeatedly engaged by the same firm in cases that involve 

a wide range of technical subject matter. 

Mr. de la Iglesia’s record also shows that he holds himself out as an expert in a broad 

variety of subject matters. Here, he twists his education and experience to claim to be an expert 

on push notification technology. In the past, he has done the same to proclaim expertise ranging 

from “embedded systems and HVAC control,” (Dkt. 240-3 at 76:18-79:24 (questioning in 

Ecofactor); Ex. 2 at 103:18-21) to “remote sensor and algorithms for processing data collected by 

such [remote] sensors.” (Dkt. 240-3 at 86:23-89:19 (questioning on Park Assist); Ex. 3 at 1. The 

AlmondNet case highlighted in Headwater’s MIL (Dkt. 240 at 7-8), where Mr. de la Iglesia 

wholesale incorporated another expert’s report when the other expert had to withdraw from the 

case, is just another of these examples. Evidence of the broad range of Mr. de la Iglesia’s alleged 

expertise is relevant to where his actual expertise lies. The jury deserves to consider this evidence 

to form their own opinion as to how much weight to give Mr. de la Iglesia’s testimony. 

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Headwater’s attempts to mischaracterize evidence of Mr. de la Iglesia’s record as violating 

the CMILs (id. at 8) should be rejected. As discussed above, Samsung seeks to introduce Mr. de 

la Iglesia’s record to allow the jury to assess his expertise and credibility. Samsung does not seek 

to use that evidence to make any characterization of Headwater’s counsel, let alone to characterize 

its counsel “as a rich, large, and successful patent litigation firm who is a serial patent litigator” in 

violation of CMIL No. 31

 or as “a patent troll, shakedown artist, pirate, or similar concepts 

disparaging of its legal representation of patent owners in violation” in violation of CMIL No. 112

. 

Moreover CMIL No. 14’s prohibition of “evidence, testimony, or argument regarding the size of

the parties’ law firms or the number of attorneys representing the parties,” is not applicable here 

because the evidence relating to Mr. de la Iglesia’s record has no bearing on RAK’s size. Finally, 

Headwater claims that “Samsung’s intended questioning of Mr. de la Iglesia is designed to argue 

that there is something legally improper about RAK filing patent infringement lawsuits or helping 

its clients enforce their patent rights granted by the patent system.” Dkt. 240 at 8. It is unclear 

which of the CMILs, Headwater is attempting to reference, but regardless, Samsung does not seek 

to make such an argument. 

Samsung assures this Court that it will operate within the confines of its CMILs, including 

CMIL 15, which prohibits “evidence, testimony, or argument regarding the fact that testimony or 

opinions offered by any expert may have been criticized, excluded, or found to be unreliable in 

any other forum.” Samsung has no intention of “march[ing] through each case number in which 

1

 Moreover, CMIL No. 3 prohibits “evidence, testimony, or argument concerning any party’s

overall financial size, wealth, or executive compensation,” and does not address the wealth of 

counsel. 

2

 CMIL No. 11 is targeted at excluding use of specific disparaging terms, and is not related to a 

law firm’s actions, whether or not those actions are suggestive of behavior consistent with a “nonpracticing entity.” 

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Mr. de la Iglesia has ever been retained” and eliciting testimony about whether the expert opinion 

in that case has been deemed unreliable. However, granting Headwater’s motion seeking a blanket 

prohibition on evidence or argument regarding an expert’s prior work for, retention by, or 

affiliation with trial counsel would prevent Samsung from eliciting brief testimony from Mr. de la 

Iglesia about the various (and broad) subject matters he has claimed to be an expert in, and how 

his education and experience have allegedly supported such expertise. Such testimony is useful to 

the jury to determine the weight that should be accorded to Mr. de la Iglesia’s opinions. 

Thus, Headwater’s MIL4 should be denied. 

Headwater MIL 5: To Exclude References to Dr. Groehn’s Errors in Headwater I

Where He Reuses the Same Survey in This Case 

Headwater chose to inject Headwater I into this case (Headwater II) by having its expert, 

Dr. Andreas Groehn, reuse his pilot study and conjoint survey from Headwater I. Ex. 4 (Groehn 

Tr.) at 46:17-24 ( ); 47:2-6 ( 

); 47:7-11 ( ); 47:12-48:22 ( ); and 48:23-

49:4 ( ). While ordinarily CMIL Nos. 13 and 15 preclude 

introduction of evidence related to a party’s other litigation and past criticisms of experts, here, 

because Headwater itself injected Dr. Groehn’s Headwater I opinions into this case, Samsung 

seeks leave of Court to respond with evidence related to that case. Dr. Groehn’s Headwater I

errors are relevant to the reliability of his methodology used in this case, the care with which he 

applies that methodology in this case, and the extreme fluctuations of his results in this case. 

Discussion of these issues creates no more confusion than Headwater already introduced by having 

its expert reuse a study and survey prepared for another case, Headwater I, before that expert was 

even retained for this case. Ex. 4 at 49:5-17. Samsung will not unnecessarily explore details or 

circumstances of the other litigation and will hew closely to the Court’s standing order, but 

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Samsung must be permitted to fully cross-examine Dr. Groehn before the jury on all relevant 

evidence reflecting his reliability and credibility. See Rembrandt Wireless Techs., LP v. Samsung 

Elecs. Co., 853 F.3d 1370, 1378 (Fed. Cir. 2017) (permitting the jury to credit one expert’s 

testimony while rejecting another, because “the jury is permitted to make credibility 

determinations and believe the witness it considers more trustworthy”) (citing MobileMedia Ideas 

LLC v. Apple Inc., 789 F.3d 1139, 1168 (Fed. Cir. 2015)). In the circumstances here, the prejudice 

and confusion of evidence about Dr. Groehn’s errors in Headwater I does not outweigh its 

relevance. Accordingly, Headwater’s MIL 5 should be denied. 

Dated: November 25, 2024 Respectfully submitted, 

By: /s/ Katherine D. Prescott 

 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 

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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. 

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 

Thomas H. Reger II 

Texas Bar No. 24032992 

reger@fr.com 

Andria Rae Crisler 

TX Bar No. 24093792 

crisler@fr.com 

FISH & RICHARDSON P.C.

1717 Main Street, Suite 5000 

Dallas, TX 75201 

Telephone: (214)747-5070 

Facsimile: (214) 747-2091 

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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 

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 

102 N. College, Suite 800 

Tyler, Texas 75702 

Telephone: (903) 934-8450 

Facsimile: (903) 934-9257 

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Michael E. Jones 

State Bar No. 10929400 

mikejones@potterminton.com 

Shaun W. Hassett 

State Bar No. 24074372 

shaunhassett@potterminton.com 

POTTER MINTON, P.C. 

102 N. College Ave., Suite 900 

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 

Telephone: (415) 875-6600 

Brady Huynh (admitted pro hac vice) 

CA Bar No. 339441 

bradyhuynh@quinnemanuel.com 

QUINN EMANUEL URQUHART &

SULLIVAN, LLP 

555 Twin Dolphin Drive, 5th Floor 

Redwood Shores, CA 94065 

Telephone: (650) 801-5000 

Facsimile: (650) 801-5100 

Jon Bentley Hyland 

Texas Bar No. 24046131 

jhyland@hilgersgraben.com 

Grant K. Schmidt 

Texas Bar No. 24084579 

gschmidt@hilgersgraben.com 

HILGERS GRABEN PLLC 

7859 Walnut Hill Lane, Suite 335 

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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 

The undersigned hereby certifies that a true and correct copy of the foregoing document 

was served on Plaintiff through its counsel of record via email on November 25, 2024. 

/s/ Katherine D. Prescott 

Katherine D. Prescott 

 

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