IN THE UNITED STATES DISTRICT COURT

FOR THE EASTERN DISTRICT OF TEXAS

MARSHALL DIVISION

HEADWATER RESEARCH LLC,

Plaintiff,

v.

CELLCO PARTNERSHIP D/B/A VERIZON 

WIRELESS AND VERIZON CORPORATE 

SERVICES GROUP INC.,

Defendants.

Case No. 2:23-cv-00352-JRG-RSP

JURY TRIAL DEMANDED

HEADWATER RESEARCH LLC,

Plaintiff,

v.

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

Defendants.

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

(Member Case Under -379 Action)

JURY TRIAL DEMANDED

HEADWATER RESEARCH LLC,

Plaintiff,

v.

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

Defendants.

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

JURY TRIAL DEMANDED

DECLARATION OF JAMES S. TSUEI IN SUPPORT OF 

PLAINTIFF HEADWATER RESEARCH LLC’S 

OPENING CLAIM CONSTRUCTION BRIEF

Case 2:23-cv-00379-JRG-RSP Document 90-1 Filed 10/08/24 Page 1 of 3 PageID #: 4995
1

I, James S. Tsuei, declare and state as follows:

1. I am a member of the State Bar of California, an attorney at the firm of Russ August 

& Kabat, and counsel of record for Plaintiff Headwater Research LLC in the above-captioned 

action. I submit this declaration in support of Plaintiff’s Opening Claim Construction Brief. 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 1 is a true and correct copy of U.S. Patent No. 8,589,541.

3. Attached as Exhibit 2 is a true and correct copy of U.S. Patent No. 9,198,042.

4. Attached as Exhibit 3 is a true and correct copy of U.S. Patent No. 9,215,613.

5. Attached as Exhibit 4 is a true and correct copy of T-Mobile’s Patent Rule 4-2 

Identification of Claim Constructions and Extrinsic Evidence, Exhibit A, in Case 2:23-cv-00379-

JRG-RSP (E.D. Tex.), dated July 19, 2024.

6. Attached as Exhibit 5 is a true and correct copy of Verizon’s Patent Rule 4-2 

Identification of Claim Constructions and Extrinsic Evidence, Exhibit A, in Case 2:23-cv-00352 

(E.D. Tex.), dated August 6, 2024.

7. Attached as Exhibit 6 is a true and correct copy of the Declaration of Dr. Donald 

Turnbull for T-Mobile, in Case 2:23-cv-00379-JRG-RSP (E.D. Tex.), dated August 9, 2024.

8. Attached as Exhibit 7 is a true and correct copy of the Declaration of Dr. Donald 

Turnbull for Verizon, in Case 2:23-cv-00352 (E.D. Tex.), dated August 24, 2024.

9. Attached as Exhibit 8 is a true and correct copy of the Declaration of Dr. Donald 

Turnbull for AT&T, in Case 2:23-cv-00397 (E.D. Tex.), dated September 11, 2024.

10. Attached as Exhibit 9 is a true and correct copy of the Deposition Transcript of Dr. 

Donald Turnbull, in Case 2:23-cv-00379-JRG-RSP (E.D. Tex.), dated August 30, 2024.

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11. Attached as Exhibit 10 is a true and correct copy of Defendants’ Petition for Inter 

Partes Review of U.S. Patent No. 8,589,541, Paper 1, IPR2024-00942, dated June 7, 2024.

12. Attached as Exhibit 11 is a true and correct copy of Defendants’ Petition for Inter 

Partes Review of U.S. Patent No. 9,198,042, Paper 4, IPR2024-00809, dated April 19, 2024.

13. Attached as Exhibit 12 is a true and correct copy of Defendants’ Petition for Inter 

Partes Review of U.S. Patent No. 9,215,613, Paper 1, IPR2024-00945, dated June 7, 2024.

14. Attached as Exhibit 13 is a true and correct copy of the Claim Construction Order, 

Dkt. 107, Case 2:22-cv-00422-JRG-RPS (E.D. Tex.), dated February 20, 2024.

Executed on October 8, 2024.

/s/ James S. Tsuei

James S. Tsuei

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