EXHIBIT F

Case 2:23-cv-00379-JRG-RSP Document 81-6 Filed 09/05/24 Page 1 of 8 PageID #: 4890
1

Sim, Charlie

From: Jason Wietholter <jwietholter@raklaw.com>

Sent: Friday, August 2, 2024 9:50 AM

To: Sim, Charlie

Cc: Isaacs, Cameron Fredriksen; Marc Fenster; Kristopher Davis; headwater@raklaw.com; *** 

GDCVerizon-Headwater; HLVerizon Headwater

Subject: Re: Headwater v. Verizon (23-cv-352) (E.D. Tex.) - Correspondence

[WARNING: External Email]

Counsel, 

Following up on the meet and confer from yesterday, we disagree with Verizon and T-Mobile’s positions 

that Headwater's infringement contentions are deficient. And while Headwater does not believe that any 

further detail is necessary to put defendants on notice of Verizon and T-Mobile’s infringement of the 

Asserted Patents, and in an effort to avoid unnecessary motion practice, Headwater will provide further 

amendments by noon PT on August 6th. 

We also discussed Verizon and T-Mobile’s ongoing failure to meet its obligations under Local Patent Rule 

3-4 as well as the Discovery Orders entered in the respective cases and which Headwater has addressed 

in written correspondence and on various meet and confers since discovery opened. We understand that 

Verizon and T-Mobile continue to refuse to produce documents in accordance with the Local Patent 

Rules and the Discovery Orders. As discussed, Headwater thus intends to move to compel production of 

these documents. 

Regards, 

Jason Wietholter

Russ, August & Kabat

12424 Wilshire Boulevard, 12th Floor | Los Angeles, California 90025 

Main +1 310 826 7474 | jwietholter@raklaw.com | www.raklaw.com

----------------------------------- 

This communication shall not create, waive or modify any right, obligation or liability, or be construed to 

contain or be an electronic signature. This communication may contain information that is 

legally privileged, confidential or exempt from disclosure, and is intended only for 

the named addressee(s). If you are not the intended recipient, please note that any 

dissemination, distribution, or copying of this communication is prohibited. 

On Jul 31, 2024, at 9:29 PM, Sim, Charlie <CSim@gibsondunn.com> wrote: 

Hi Jason, 

 

Let’s do 1:00 PM / 4:00 ET tomorrow. I’ll send around a Zoom link in a moment. 

 

Thanks, 

Charlie 

Case 2:23-cv-00379-JRG-RSP Document 81-6 Filed 09/05/24 Page 2 of 8 PageID #: 4891
2

 

Charlie Sim 

Associate Attorney 

T: +1 212.351.6274 | M: +1 607.339.1652

CSim@gibsondunn.com

GIBSON DUNN

Gibson, Dunn & Crutcher LLP 

200 Park Avenue, New York, NY 10166-0193 

From: Jason Wietholter <jwietholter@raklaw.com> 

Sent: Wednesday, July 31, 2024 4:03 PM 

To: Sim, Charlie <CSim@gibsondunn.com> 

Cc: Isaacs, Cameron Fredriksen <CIsaacs@gibsondunn.com>; Marc Fenster <mfenster@raklaw.com>; 

Kristopher Davis <kdavis@raklaw.com>; headwater@raklaw.com; *** GDCVerizon-Headwater 

<GDCVerizon-Headwater@gibsondunn.com>; HLVerizon Headwater 

<HLVerizonHeadwater@hoganlovells.com> 

Subject: Re: Headwater v. Verizon (23-cv-352) (E.D. Tex.) - Correspondence

 

[WARNING: External Email]

Counsel, 

 

Headwater can be available Thursday, August 1 during 1-2 PM PT, or else on Friday, August 

2 during 2:30-4:00 PM PT. 

 

Please let us know which of those slots work for you and please send around a dialin/meeting invite. 

 

Thanks, 

Jason Wietholter

Russ, August & Kabat

12424 Wilshire Boulevard, 12th Floor | Los Angeles, California 90025 

Main +1 310 826 7474 | jwietholter@raklaw.com | www.raklaw.com

----------------------------------- 

This communication shall not create, waive or modify any right, obligation or liability, 

or be construed to contain or be an electronic signature. This communication may 

contain information that is legally privileged, confidential or exempt from disclosure, and 

is intended only for the named addressee(s). If you are not the intended recipient, please 

note that any dissemination, distribution, or copying of this communication is prohibited. 

On Jul 31, 2024, at 7:43 AM, Sim, Charlie <CSim@gibsondunn.com> wrote: 

 

Counsel, 

 

Case 2:23-cv-00379-JRG-RSP Document 81-6 Filed 09/05/24 Page 3 of 8 PageID #: 4892
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Following up on our request below, please provide your availability for a 

lead-and-local conference this week to discuss the issues raised in our June 

12 letter. 

 

Best, 

Charlie 

 

Charlie Sim 

Associate Attorney 

T: +1 212.351.6274 | M: +1 607.339.1652

CSim@gibsondunn.com

GIBSON DUNN

Gibson, Dunn & Crutcher LLP 

200 Park Avenue, New York, NY 10166-0193 

From: Jason Wietholter <jwietholter@raklaw.com> 

Sent: Tuesday, July 23, 2024 6:49 AM 

To: Sim, Charlie <CSim@gibsondunn.com> 

Cc: Isaacs, Cameron Fredriksen <CIsaacs@gibsondunn.com>; Marc Fenster 

<mfenster@raklaw.com>; Kristopher Davis 

<kdavis@raklaw.com>; headwater@raklaw.com; *** GDCVerizon-Headwater 

<GDCVerizon-Headwater@gibsondunn.com>; HLVerizon Headwater 

<HLVerizonHeadwater@hoganlovells.com> 

Subject: Re: Headwater v. Verizon (23-cv-352) (E.D. Tex.) - Correspondence

 

[WARNING: External Email]

Hi Charlie, 

 

Our lead counsel is in trial this week. We can be available to meet and confer 

tomorrow without lead counsel between 9AM-12PM ET. What availability do 

you have during that window? 

 

Thanks, 

Jason Wietholter

Russ, August & Kabat

12424 Wilshire Boulevard, 12th Floor | Los Angeles, California 90025 

Main +1 310 826 7474 | jwietholter@raklaw.com | www.raklaw.com

----------------------------------- 

This communication shall not create, waive or modify any right, obligation or 

liability, or be construed to contain or be an electronic signature. 

This communication may contain information that is legally privileged, 

confidential or exempt from disclosure, and is intended only for 

the named addressee(s). If you are not the intended recipient, please 

note that any dissemination, distribution, or copying of this communication 

is prohibited. 

Case 2:23-cv-00379-JRG-RSP Document 81-6 Filed 09/05/24 Page 4 of 8 PageID #: 4893
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On Jul 22, 2024, at 11:38 AM, Sim, Charlie 

<CSim@gibsondunn.com> wrote: 

 

Counsel, 

 

Following up, we are available tomorrow after 4pm ET for a 

lead and local conference. Please confirm whether 

Headwater is available during that time. 

 

Thanks, 

Charlie 

 

Charlie Sim 

Associate Attorney 

T: +1 212.351.6274 | M: +1 607.339.1652

CSim@gibsondunn.com

GIBSON DUNN

Gibson, Dunn & Crutcher LLP 

200 Park Avenue, New York, NY 10166-0193 

From: Sim, Charlie <CSim@gibsondunn.com> 

Sent: Sunday, July 21, 2024 6:52 PM 

To: Jason Wietholter <jwietholter@raklaw.com> 

Cc: Isaacs, Cameron Fredriksen <CIsaacs@gibsondunn.com>; Marc 

Fenster <mfenster@raklaw.com>; Kristopher Davis 

<kdavis@raklaw.com>; headwater@raklaw.com; *** GDCVerizonHeadwater <GDCVerizon-Headwater@gibsondunn.com>; HLVerizon 

Headwater <HLVerizonHeadwater@hoganlovells.com> 

Subject: Re: Headwater v. Verizon (23-cv-352) (E.D. Tex.) - 

Correspondence

 

Counsel, 

 

We are not available to confer on Monday due to a hearing. We 

request a lead and local conference, and are investigating our 

availability later this week. 

 

Please propose some additional times this week (after 

Monday) when Headwater’s lead and local counsel are 

available. 

 

Thanks, 

Charlie 

 

Charlie Sim 

Case 2:23-cv-00379-JRG-RSP Document 81-6 Filed 09/05/24 Page 5 of 8 PageID #: 4894
5

GIBSON DUNN

Gibson, Dunn & Crutcher LLP 

200 Park Avenue, New York, NY 10166-0193 

Tel +1 212.351.6274 • Fax +1 212.817.9374 

CSim@gibsondunn.com • www.gibsondunn.com

On Jul 19, 2024, at 12:10 PM, Jason Wietholter 

<jwietholter@raklaw.com> wrote: 

[WARNING: External Email]

Hi Charlie, 

 

We disagree with the characterizations in Verizon’s letter. We 

can be available to meet and confer on Monday at 8:00AM PT 

or 9:00AM PT. 

 

Regards, 

Jason Wietholter

Russ, August & Kabat

12424 Wilshire Boulevard, 12th Floor | Los Angeles, California 

90025 

Main +1 310 826 7474 

| jwietholter@raklaw.com | www.raklaw.com

----------------------------------- 

This communication shall not create, waive or modify 

any right, obligation or liability, or be construed to contain or 

be an electronic signature. This communication may 

contain information that is legally privileged, confidential 

or exempt from disclosure, and is intended only for 

the named addressee(s). If you are not the intended recipient, 

please note that any dissemination, distribution, or copying of 

this communication is prohibited. 

On Jul 2, 2024, at 10:43 AM, Sim, Charlie 

<CSim@gibsondunn.com> wrote: 

 

Counsel, 

 

Following up on the below correspondence. We 

have not heard back from you on our request for 

a lead and local conference on the many 

deficiencies in Headwater’s infringement 

Case 2:23-cv-00379-JRG-RSP Document 81-6 Filed 09/05/24 Page 6 of 8 PageID #: 4895
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contentions. Please provide your availability to 

confer. 

 

Best, 

Charlie 

 

Charlie Sim 

Associate Attorney 

T: +1 212.351.6274 | M: +1 607.339.1652

CSim@gibsondunn.com

GIBSON DUNN

Gibson, Dunn & Crutcher LLP 

200 Park Avenue, New York, NY 10166-0193 

From: Isaacs, Cameron Fredriksen 

<CIsaacs@gibsondunn.com> 

Sent: Wednesday, June 12, 2024 9:39 AM 

To: Jason Wietholter <jwietholter@raklaw.com>; Marc 

Fenster <mfenster@raklaw.com>; Kristopher Davis 

<kdavis@raklaw.com>; headwater@raklaw.com

Cc: *** GDCVerizon-Headwater <GDCVerizonHeadwater@gibsondunn.com>; HLVerizon Headwater 

<HLVerizonHeadwater@hoganlovells.com> 

Subject: Headwater v. Verizon (23-cv-352) (E.D. Tex.) - 

Correspondence

 

Counsel,

Please see the attached correspondence.

Regards,

Cameron

Cameron Fredriksen Isaacs 

Paralegal 

T: +1 212.351.5382

CIsaacs@gibsondunn.com

GIBSON DUNN

Gibson, Dunn & Crutcher LLP 

200 Park Avenue, New York, NY 10166-0193 

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immediately delete this message. 

Case 2:23-cv-00379-JRG-RSP Document 81-6 Filed 09/05/24 Page 7 of 8 PageID #: 4896
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Please see our website 

at https://www.gibsondunn.com/ for information 

regarding the firm and/or our privacy policy.

 

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and/or our privacy policy.

 

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recipient. Any review, disclosure, distribution by others or forwarding without express permission is strictly 

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immediately delete this message. 

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Case 2:23-cv-00379-JRG-RSP Document 81-6 Filed 09/05/24 Page 8 of 8 PageID #: 4897