IN THE UNITED STATES DISTRICT COURT

FOR THE EASTERN DISTRICT OF TEXAS

MARSHALL DIVISION

HEADWATER RESEARCH LLC,

Plaintiff,

v.

T-MOBILE USA, INC. AND SPRINT CORP.,

Defendants.

Case No. 2:23-cv-00379-JRG-RSP

Lead Case

JURY TRIAL DEMANDED

HEADWATER RESEARCH LLC,

Plaintiff,

v.

T-MOBILE USA, INC. AND SPRINT CORP.,

Defendants.

Case No. 2:23-cv-00377-JRG-RSP

JURY TRIAL DEMANDED

DECLARATION OF JASON M. WIETHOLTER IN SUPPORT OF PLAINTIFF

HEADWATER RESEARCH LLC’S OPPOSITION TO DEFENDANTS’ 

MOTION TO STRIKE AND COMPEL SUPPLEMENTATION OF 

HEADWATER’S AMENDED INFRINGEMENT CONTENTIONS

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I, Jason M. Wietholter, declare as follows:

1. I am counsel for Headwater Research LLC (“Headwater”) in the above-captioned 

action. I provide this declaration in support of Headwater’s Opposition to Defendants’ Motion to 

Strike and Compel Supplementation of Headwater’s Amended Infringement Contentions. I have 

personal knowledge of the facts set forth herein, and if called upon to testify, could and would 

testify competently thereto.

2. Attached as Exhibit A is a true and correct copy of Headwater’s Infringement 

Contention Chart of Apple Representative Product for U.S. Patent 8,589,541, served on March 19, 

2024.

3. Attached as Exhibit B is a true and correct copy of Headwater’s Infringement 

Contention Chart of Samsung Representative Product for U.S. Patent 8,589,541, served on March 

19, 2024.

4. Attached as Exhibit C is a true and correct copy of Headwater’s Infringement 

Contention Chart of Google Representative Product for U.S. Patent 8,589,541, served on March 

19, 2024.

5. Attached as Exhibit D is a true and correct copy of Headwater’s Infringement 

Contention Chart of Motorola Representative Product for U.S. Patent 8,589,541, served on March 

19, 2024.

6. Attached as Exhibit E is a true and correct copy of Headwater’s Infringement 

Contention Chart of Nokia Representative Product for U.S. Patent 8,589,541, served on March 19, 

2024.

7. Attached as Exhibit E is a true and correct copy of Headwater’s Infringement 

Contention Chart of T-Mobile Representative Product for U.S. Patent 8,589,541, served on March 

Case 2:23-cv-00379-JRG-RSP Document 76 Filed 08/21/24 Page 2 of 5 PageID #: 3073
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19, 2024.

8. Attached as Exhibit G is a true and correct copy of Headwater’s Infringement 

Contention Chart for U.S. Patent 8,924,543, served on March 19, 2024.

9. Attached as Exhibit H is a true and correct copy of Headwater’s Infringement 

Contention Chart for U.S. Patent 9,198,042, served on March 19, 2024.

10. Attached as Exhibit I is a true and correct copy of Headwater’s Infringement 

Contention Chart of Apple Representative Product for U.S. Patent 9,215,613, served on March 19, 

2024.

11. Attached as Exhibit J is a true and correct copy of Headwater’s Infringement 

Contention Chart of Samsung Representative Product for U.S. Patent 9,215,613, served on March 

19, 2024.

12. Attached as Exhibit K is a true and correct copy of Headwater’s Infringement 

Contention Chart of Google Representative Product for U.S. Patent 9,215,613, served on March 

19, 2024.

13. Attached as Exhibit L is a true and correct copy of Headwater’s Infringement 

Contention Chart of Motorola Representative Product for U.S. Patent 9,215,613, served on March 

19, 2024.

14. Attached as Exhibit M is a true and correct copy of Headwater’s Infringement 

Contention Chart of Nokia Representative Product for U.S. Patent 9,215,613, served on March 19, 

2024.

15. Attached as Exhibit N is a true and correct copy of Headwater’s Infringement 

Contention Chart of T-Mobile Representative Product for U.S. Patent 9,215,613, served on March 

19, 2024.

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16. Attached as Exhibit O is a true and correct copy of T-Mobile’s Invalidity 

Contention Chart for U.S. Patent 8,589,541, served on January 16, 2024.

17. Attached as Exhibit P is a true and correct copy of T-Mobile’s Invalidity Contention 

Chart for U.S. Patent 8,924,543, served on January 16, 2024.

18. Attached as Exhibit Q is a true and correct copy of T-Mobile’s Invalidity 

Contention Chart for U.S. Patent 9,198,042, served on January 16, 2024.

19. Attached as Exhibit R is a true and correct copy of T-Mobile’s Invalidity 

Contention Chart for U.S. Patent 9,215,613, served on January 16, 2024.

I declare under penalty of perjury that the foregoing is true and correct. 

Executed on August 21, 2024 at Los Angeles, California.

By: /s/ Jason M. Wietholter

Jason M. Wietholter

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CERTIFICATE OF SERVICE

I hereby certify that all counsel of record who are deemed to have consented to electronic 

service are being served this 21st day of August 2024, with a copy of this document via the Court’s 

CM/ECF system per Local Rule CV-5(a)(3).

/s/ Jason M. Wietholter

Jason M. Wietholter

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