EXHIBIT G 

PUBLIC VERSION

Case 2:23-cv-00103-JRG-RSP Document 84-7 Filed 04/04/24 Page 1 of 3 PageID #: 3063
1

From: Jonathan Bright

Sent: Friday, February 23, 2024 9:09 PM

To: Rae Crisler; rak_headwater@raklaw.com

Cc: [SERVICE FR] Samsung-Headwater; qe-headwater103@quinnemanuel.com

Subject: RE: Headwater v. Samsung Case No. 2:22-cv-103: 2024-01-12 CONF Samsung Suppl Resp to HW 1st 

Set of ROGs No 1

Counsel,

Following up on our emails below, Samsung hereby notifies Headwater that it plans to move for leave to amend its

Invalidity Contentions (previously served on November 30, 2023) to incorporate material specified in Samsung’s

supplemental responses to Headwater Interrogatory No. 1, including third party discovery served since Samsung’s

supplemental responses.  

Please provide Headwater’s position on Samsung’s forthcoming motion for leave to amend its Invalidity Contentions.  

Best,

Jonathan

From: Rae Crisler <crisler@fr.com>  

Sent: Monday, February 12, 2024 11:30 AM

To: rak_headwater@raklaw.com

Cc: [SERVICE FR] Samsung‐Headwater <SERVICEFRSamsung‐Headwater@fr.com>; qe‐

headwater103@quinnemanuel.com

Subject: RE: Headwater v. Samsung Case No. 2:22‐cv‐103: 2024‐01‐12 CONF Samsung Suppl Resp to HW 1st Set of ROGs

No 1

Counsel,

We write to further advise that Samsung has continued to diligently pursue third party discovery as reflected in its

Second Supplemental Response to Plaintiff’s Interrogatory No. 1 served on February 6, 2024, that incorporates content

from Nokia and Google.   

As noted below, for purposes of notice and status as to third party discovery, Samsung expects to receive additional

third party discovery responses in the coming weeks and may well further supplement its interrogatory No. 1 as well as

its Invalidity Contentions with additional documents and things obtained as a result of that discovery.   

Best regards,

Rae

Rae Crisler :: Fish & Richardson P.C. :: 214-760-6138 direct

From: Jonathan Bright <jbright@fr.com>  

Sent: Friday, January 12, 2024 9:59 PM

To: rak_headwater@raklaw.com

PUBLIC VERSION

Case 2:23-cv-00103-JRG-RSP Document 84-7 Filed 04/04/24 Page 2 of 3 PageID #: 3064
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Cc: [SERVICE FR] Samsung‐Headwater <SERVICEFRSamsung‐Headwater@fr.com>; qe‐

headwater103@quinnemanuel.com; Jeannet Santos <jsantos@fr.com>

Subject: RE: Headwater v. Samsung Case No. 2:22‐cv‐103: 2024‐01‐12 CONF Samsung Suppl Resp to HW 1st Set of ROGs

No 1

Counsel:

  

In relation to the supplemental response to Plaintiff’s interrogatory No.  1 referenced below, Samsung has diligently

pursued third party discovery and we notify you that Defendant Samsung intends to supplement its Invalidity

Contentions with content from third party OpenWave specified in that supplemental response.   

  

For purposes of notice and status as to third party discovery, Samsung expects to receive additional third party discovery

responses in the coming weeks and may well further supplement its interrogatory No. 1 as well as its  Invalidity

Contentions with additional documents and things obtained as a result of that discovery.   

  

Regards,

  

Jonathan

From: Jeannet Santos <jsantos@fr.com>  

Sent: Friday, January 12, 2024 4:55 PM

To: rak_headwater@raklaw.com

Cc: [SERVICE FR] Samsung‐Headwater <SERVICEFRSamsung‐Headwater@fr.com>

Subject: Headwater v. Samsung Case No. 2:22‐cv‐103: 2024‐01‐12 CONF Samsung Suppl Resp to HW 1st Set of ROGs No

1

Counsel:

Attached for service, please find:

 DEFENDANTS’ SUPPLEMENTAL OBJECTIONS AND RESPONSES TO HEADWATER RESEARCH LLC’S FIRST

SET OF INTERROGATORIES (NO. 1)

The password to this document will be sent in a separate email.

Thank you,

Jeannet T. Santos, Sr. Litigation Paralegal

Supporting: Ashley A. Bolt, Brian P. Boyd, Erin P. Alper, Noah C. Graubart, & Steffen C. Lake

FISH & RICHARDSON P.C.

1180 Peachtree Street NE, 21st Floor, Atlanta, GA 30309

404.724.2758 direct :: 770.276.8661 mobile :: jsantos@fr.com :: fr.com

“The Strength of the Team is each Member.  The Strength of each Member is the Team.” –Phil Jackson

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Case 2:23-cv-00103-JRG-RSP Document 84-7 Filed 04/04/24 Page 3 of 3 PageID #: 3065