Case 2:21-cv-00105-JRG Document 62 Filed 10/23/21 Page 1 of 15 PageID #: 1305
`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE EASTERN DISTRICT OF TEXAS
`MARSHALL DIVISION
`
`SOLAS OLED LTD.,
`
`Plaintiff,
`
`v.
`
`SAMSUNG ELECTRONICS CO., LTD., et
`al.,
`
`Defendants.
`
`§
`§
`§
`§
`§
`§
`§
`§
`§
`
`Case No. 2:21-CV-00105-JRG
`
`P.R. 4-3 JOINT CLAIM CONSTRUCTION AND PREHEARING STATEMENT
`
`Plaintiff Solas OLED Ltd. (“Solas” or “Plaintiff”) and Defendants Samsung Electronics
`
`Co., Ltd., and Samsung Electronics America, Inc. (collectively “Samsung” or “Defendants”)
`
`respectfully submit this Joint Claim Construction and Prehearing Statement.
`
`The parties anticipate that two hours will be necessary for the Claim Construction Hearing.
`
`There are no agreed constructions.
`
`The disputed claim terms, and the parties’ respective proposed constructions and intrinsic
`
`and extrinsic evidence citations, are as follows:
`
`Term
`“plurality of gesture-
`interpretation-state modules”
`(Claim 2, Claim 3, Claim 6)
`
`Plaintiff
`No construction necessary;
`plain and ordinary meaning.
`
`Specification at 3:11-5:46,
`7:19-15:9, Figs. 1-7
`
`Nov. 19, 2012 Applicant
`Arguments/Remarks
`July 19, 2012 Final Rejection
`April 26, 2012 Amendment
`and Applicant
`Arguments/Remarks
`January 26, 2021 Non-Final
`Rejection
`
`Defendants
`“two or more state modules
`for interpreting touch position
`and timing data to determine
`gestures”
`
`’767 Patent at Abstract, 1:10-
`3:7, 3:11-6:43, 6:47-7:15,
`7:19-63, 7:64-8:35, 8:36-
`10:50, 10:51-11:60, 11:61-
`14:19, 14:20-24, 14:25-33,
`14:34-56, 14:57-15:13,
`15:14-17:3, 17:4-34, 17:35-
`18:9, 18:10-19:16, 19:17-
`
`- 1 -
`
`SAMSUNG V. SOLAS
`IPR2021-01254
`Exhibit 2008
`Page 1
`
`
`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE EASTERN DISTRICT OF TEXAS
`MARSHALL DIVISION
`
`SOLAS OLED LTD.,
`
`Plaintiff,
`
`v.
`
`SAMSUNG ELECTRONICS CO., LTD., et
`al.,
`
`Defendants.
`
`§
`§
`§
`§
`§
`§
`§
`§
`§
`
`Case No. 2:21-CV-00105-JRG
`
`P.R. 4-3 JOINT CLAIM CONSTRUCTION AND PREHEARING STATEMENT
`
`Plaintiff Solas OLED Ltd. (“Solas” or “Plaintiff”) and Defendants Samsung Electronics
`
`Co., Ltd., and Samsung Electronics America, Inc. (collectively “Samsung” or “Defendants”)
`
`respectfully submit this Joint Claim Construction and Prehearing Statement.
`
`The parties anticipate that two hours will be necessary for the Claim Construction Hearing.
`
`There are no agreed constructions.
`
`The disputed claim terms, and the parties’ respective proposed constructions and intrinsic
`
`and extrinsic evidence citations, are as follows:
`
`Term
`“plurality of gesture-
`interpretation-state modules”
`(Claim 2, Claim 3, Claim 6)
`
`Plaintiff
`No construction necessary;
`plain and ordinary meaning.
`
`Specification at 3:11-5:46,
`7:19-15:9, Figs. 1-7
`
`Nov. 19, 2012 Applicant
`Arguments/Remarks
`July 19, 2012 Final Rejection
`April 26, 2012 Amendment
`and Applicant
`Arguments/Remarks
`January 26, 2021 Non-Final
`Rejection
`
`Defendants
`“two or more state modules
`for interpreting touch position
`and timing data to determine
`gestures”
`
`’767 Patent at Abstract, 1:10-
`3:7, 3:11-6:43, 6:47-7:15,
`7:19-63, 7:64-8:35, 8:36-
`10:50, 10:51-11:60, 11:61-
`14:19, 14:20-24, 14:25-33,
`14:34-56, 14:57-15:13,
`15:14-17:3, 17:4-34, 17:35-
`18:9, 18:10-19:16, 19:17-
`
`- 1 -
`
`SAMSUNG V. SOLAS
`IPR2021-01254
`Exhibit 2008
`Page 1
`
`
`
`Case 2:21-cv-00105-JRG Document 62 Filed 10/23/21 Page 2 of 15 PageID #: 1306
`
`Defendants
`20:3, 20:4-49, Figures 1-13,
`Claims 1-14.
`
`’767 Patent Prosecution
`History at October 20, 2008
`Application, January 26, 2012
`Non-Final Rejection, April
`26, 2012
`Amendment/Request for
`Reconsideration After Non-
`Final Rejection, July 19, 2012
`Applicant Initiated Interview
`Summary, July 19, 2012
`Final Rejection, November
`19, 2012 Request for
`Continued Examination,
`December 24, 2012 Notice of
`Allowance, December 24,
`2012 Examiner Initiated
`Interview Summary,
`December 24, 2012 Applicant
`Initiated Interview Summary,
`March 20, 2013 Request for
`Continued Examination,
`April 10, 2013 Notice of
`Allowance, July 10, 2013
`Amendment After Notice of
`Allowance, August 1, 2013
`Response to Amendment.
`
`Provisional Patent
`Application No. 61/049,453.
`
` A
`
` Dictionary of Computing
`(Sixth Edition) (2008):
`defining “gesture” as “A type
`of input to a computer where
`the meaning depends on the
`time-related positions input
`from the device. For
`example, using a *dataglove
`the user might beckon with a
`finger to indicate a zoom in
`on the display.”
`
`
`Term
`
`Plaintiff
`
`Provisional patent application
`no. 61/049,453, specification
`at 4-18 and Figs. 1-3
`
`- 2 -
`
`SAMSUNG V. SOLAS
`IPR2021-01254
`Exhibit 2008
`Page 2
`
`
`
`Case 2:21-cv-00105-JRG Document 62 Filed 10/23/21 Page 3 of 15 PageID #: 1307
`
`Term
`
`Plaintiff
`
`Defendants
`Wiley Electrical and
`Electronics Engineering
`Dictionary (2004): defining
`“gesture recognition” as “The
`ability of a computer system
`to detect and comprehend
`gestures such as hand and
`head movements. The term
`specifically excludes the use
`of haptic devices or
`interfaces. Used, for
`instance, for entering data
`using sign language.”
`
`Merriam-Webster’s
`Advanced Learner’s English
`Dictionary (2008): defining
`“gesture” as “a movement of
`your body (especially of your
`hands and arms) that shows
`or emphasizes an idea or a
`feeling … something said or
`done to show a particular
`feeling or attitude … to move
`your hands, arms, etc., to
`express an idea or feeling.”
`
`The American Heritage
`Dictionary of the English
`Language (Fourth Edition)
`(2006): defining “gesture” as
`“A motion of the limbs or
`body made to express or help
`express thought or to
`emphasize speech … The act
`of moving the limbs or body
`as an expression of thought or
`emphasis … An act or a
`remark made as a formality or
`as a sign of intention of
`attitude.”
`
`Testimony of Dr. Jacob
`Baker. Dr. Baker will explain
`the technology, the
`
`- 3 -
`
`SAMSUNG V. SOLAS
`IPR2021-01254
`Exhibit 2008
`Page 3
`
`
`
`Case 2:21-cv-00105-JRG Document 62 Filed 10/23/21 Page 4 of 15 PageID #: 1308
`
`Term
`
`Plaintiff
`
`“the position-processing logic
`being accommodated in, and
`running on, a first integrated
`circuit and the gesture-
`processing logic being
`accommodated in, and
`running on, one or more
`separate integrated circuits”
`(Claim 11)
`
`No construction necessary;
`plain and ordinary meaning.
`
`Specification at 3:11-5:38,
`18:38-19:16, Figs. 11-12
`
`Nov. 19, 2012 Applicant
`Arguments/Remarks
`July 19, 2012 Final Rejection
`January 26, 2021 Non-Final
`Rejection
`
`Provisional patent application
`no. 61/049,453, specification
`at 3-5
`
`- 4 -
`
`Defendants
`state of the art at the time the
`patent
`application was filed, the
`meaning of claim terms or
`phrases as they would be
`understood by those of
`ordinary skill in the art at the
`time of the invention in the
`context of the patent
`specification and other
`intrinsic/extrinsic evidence,
`how those of ordinary skill in
`the art at the time of the
`invention would have
`understood statements made
`by the patentee during
`prosecution of the
`applications, and the level of
`ordinary skill in the relevant
`art. Dr. Baker may also offer
`a declaration, if necessary, to
`respond to Plaintiff’s
`contentions, any expert
`testimony on behalf of
`Plaintiff, or for the Court’s
`benefit.
`
`Indefinite.
`
`’767 Patent at Abstract, 1:10-
`3:7, 3:11-6:43, 6:47-7:15,
`7:19-63, 7:64-8:35, 8:36-
`10:50, 10:51-11:60, 11:61-
`14:19, 14:20-24, 14:25-33,
`14:34-56, 14:57-15:13,
`15:14-17:3, 17:4-34, 17:35-
`18:9, 18:10-19:16, 19:17-
`20:3, 20:4-49, Figures 1-13,
`Claims 1-14.
`
`’767 Patent Prosecution
`History at October 20, 2008
`Application, January 26, 2012
`Non-Final Rejection, April
`26, 2012
`
`SAMSUNG V. SOLAS
`IPR2021-01254
`Exhibit 2008
`Page 4
`
`
`
`Case 2:21-cv-00105-JRG Document 62 Filed 10/23/21 Page 5 of 15 PageID #: 1309
`
`Term
`
`Plaintiff
`
`Defendants
`Amendment/Request for
`Reconsideration After Non-
`Final Rejection, July 19, 2012
`Applicant Initiated Interview
`Summary, July 19, 2012
`Final Rejection, November
`19, 2012 Request for
`Continued Examination,
`December 24, 2012 Notice of
`Allowance, December 24,
`2012 Examiner Initiated
`Interview Summary,
`December 24, 2012 Applicant
`Initiated Interview Summary,
`March 20, 2013 Request for
`Continued Examination,
`April 10, 2013 Notice of
`Allowance, July 10, 2013
`Amendment After Notice of
`Allowance, August 1, 2013
`Response to Amendment.
`
`Provisional Patent
`Application No. 61/049,453.
`
`Merriam-Webster’s
`Advanced Learner’s English
`Dictionary (2008): defining
`“accommodate” as “to
`provide room for (someone) :
`to provide a place to stay and
`sleep for (someone) … to
`have room for (someone or
`something) … to do
`something helpful for
`(someone) … to get used to
`or become comfortable with
`something : to adapt or adjust
`to something.”
`
`The American Heritage
`Dictionary of the English
`Language (Fourth Edition)
`(2006): defining
`“accommodate” as “To do a
`
`- 5 -
`
`SAMSUNG V. SOLAS
`IPR2021-01254
`Exhibit 2008
`Page 5
`
`
`
`Case 2:21-cv-00105-JRG Document 62 Filed 10/23/21 Page 6 of 15 PageID #: 1310
`
`Defendants
`favor or service for; oblige …
`To provide for; supply with
`… To hold comfortably
`without crowding … To
`make suitable; adapt … To
`allow for; consider … To
`settle; reconcile … To adapt
`oneself; become adjusted …
`To become adjusted, as the
`eye to focusing on objects at
`a distance.”
`
`Dictionary of Computer
`Science (2006): defining
`“integrated circuit (IC)” as
`“A complete electronic circuit
`that is manufactured as a
`single package: all the
`individual devices required to
`realize the function of the
`circuit are fabricated on a
`single CHIP of
`semiconductor, usually
`silicon. Components (mainly
`transistors and diodes) can be
`combined to make a wide
`variety of circuits, including
`LOGIC CIRCUITS and
`SEMICONDUCTOR
`MEMORY.”
`
` A
`
` Dictionary of Computing
`(Sixth Edition) (2008):
`defining “integrated circuit
`(IC)” as “An implementation
`of a particular electronic-
`circuit function in which all
`the individual devices
`required to realize the
`function are fabricated on a
`single *chip of
`semiconductor, usually
`silicon. The individual
`devices normally consist of
`
`Term
`
`Plaintiff
`
`- 6 -
`
`SAMSUNG V. SOLAS
`IPR2021-01254
`Exhibit 2008
`Page 6
`
`
`
`Case 2:21-cv-00105-JRG Document 62 Filed 10/23/21 Page 7 of 15 PageID #: 1311
`
`Term
`
`Plaintiff
`
`Defendants
`semiconductor diodes,
`transistors, and resistors.”
`
`Dictionary of Computer and
`Internet Terms (Ninth
`Edition) (2006): defining
`“integrated circuit (IC)” as
`“an electronic device
`consisting of many miniature
`transistors and other circuit
`elements on a single silicon
`chip …. The ultimate
`integrated circuit is the
`microprocessor, which is a
`single chip that contains the
`complete arithmetic and logic
`unit of a computer, and
`sometimes other parts of the
`computer as well.”
`
`Dictionary of Science and
`Technology (Second Edition)
`(2007): defining “integrated
`circuit” as “COMPUT a
`circuit where all the active
`and passive components are
`formed on one small piece of
`semiconductor, by means of
`etching and chemical
`processes.”
`
`Testimony of Dr. Jacob
`Baker. Dr. Baker will explain
`the technology, the
`state of the art at the time the
`patent
`application was filed, the
`meaning of claim terms or
`phrases as they would be
`understood by those of
`ordinary skill in the art at the
`time of the invention in the
`context of the patent
`specification and other
`intrinsic/extrinsic evidence,
`
`- 7 -
`
`SAMSUNG V. SOLAS
`IPR2021-01254
`Exhibit 2008
`Page 7
`
`
`
`Case 2:21-cv-00105-JRG Document 62 Filed 10/23/21 Page 8 of 15 PageID #: 1312
`
`Term
`
`Plaintiff
`
`“A single integrated circuit
`comprising:” (Claim 13)
`
`No construction necessary;
`plain and ordinary meaning.
`
`Specification at 3:11-5:38,
`18:38-19:16, Figs. 11-12
`
`Nov. 19, 2012 Applicant
`Arguments/Remarks
`July 19, 2012 Final Rejection
`January 26, 2021 Non-Final
`Rejection
`
`Provisional patent application
`no. 61/049,453, specification
`at 3-5
`
`Defendants
`how those of ordinary skill in
`the art at the time of the
`invention would have
`understood statements made
`by the patentee during
`prosecution of the
`applications, and the level of
`ordinary skill in the relevant
`art. Dr. Baker may also offer
`a declaration, if necessary, to
`respond to Plaintiff’s
`contentions, any expert
`testimony on behalf of
`Plaintiff, or for the Court’s
`benefit.
`
`The preamble is limiting.
`
`’767 Patent at Abstract, 1:10-
`3:7, 3:11-6:43, 6:47-7:15,
`7:19-63, 7:64-8:35, 8:36-
`10:50, 10:51-11:60, 11:61-
`14:19, 14:20-24, 14:25-33,
`14:34-56, 14:57-15:13,
`15:14-17:3, 17:4-34, 17:35-
`18:9, 18:10-19:16, 19:17-
`20:3, 20:4-49, Figures 1-13,
`Claims 1-14.
`
`’767 Patent Prosecution
`History at October 20, 2008
`Application, January 26, 2012
`Non-Final Rejection, April
`26, 2012
`Amendment/Request for
`Reconsideration After Non-
`Final Rejection, July 19, 2012
`Applicant Initiated Interview
`Summary, July 19, 2012
`Final Rejection, November
`19, 2012 Request for
`Continued Examination,
`December 24, 2012 Notice of
`Allowance, December 24,
`2012 Examiner Initiated
`
`- 8 -
`
`SAMSUNG V. SOLAS
`IPR2021-01254
`Exhibit 2008
`Page 8
`
`
`
`Case 2:21-cv-00105-JRG Document 62 Filed 10/23/21 Page 9 of 15 PageID #: 1313
`
`Defendants
`Interview Summary,
`December 24, 2012 Applicant
`Initiated Interview Summary,
`March 20, 2013 Request for
`Continued Examination,
`April 10, 2013 Notice of
`Allowance, July 10, 2013
`Amendment After Notice of
`Allowance, August 1, 2013
`Response to Amendment.
`
`Provisional Patent
`Application No. 61/049,453.
`
`Dictionary of Computer
`Science (2006): defining
`“integrated circuit (IC)” as
`“A complete electronic circuit
`that is manufactured as a
`single package: all the
`individual devices required to
`realize the function of the
`circuit are fabricated on a
`single CHIP of
`semiconductor, usually
`silicon. Components (mainly
`transistors and diodes) can be
`combined to make a wide
`variety of circuits, including
`LOGIC CIRCUITS and
`SEMICONDUCTOR
`MEMORY.”
`
` A
`
` Dictionary of Computing
`(Sixth Edition) (2008):
`defining “integrated circuit
`(IC)” as “An implementation
`of a particular electronic-
`circuit function in which all
`the individual devices
`required to realize the
`function are fabricated on a
`single *chip of
`semiconductor, usually
`silicon. The individual
`
`Term
`
`Plaintiff
`
`- 9 -
`
`SAMSUNG V. SOLAS
`IPR2021-01254
`Exhibit 2008
`Page 9
`
`
`
`Case 2:21-cv-00105-JRG Document 62 Filed 10/23/21 Page 10 of 15 PageID #: 1314
`
`Term
`
`Plaintiff
`
`Defendants
`devices normally consist of
`semiconductor diodes,
`transistors, and resistors.”
`
`Dictionary of Computer and
`Internet Terms (Ninth
`Edition) (2006): defining
`“integrated circuit (IC)” as
`“an electronic device
`consisting of many miniature
`transistors and other circuit
`elements on a single silicon
`chip …. The ultimate
`integrated circuit is the
`microprocessor, which is a
`single chip that contains the
`complete arithmetic and logic
`unit of a computer, and
`sometimes other parts of the
`computer as well.”
`
`Dictionary of Science and
`Technology (Second Edition)
`(2007): defining “integrated
`circuit” as “COMPUT a
`circuit where all the active
`and passive components are
`formed on one small piece of
`semiconductor, by means of
`etching and chemical
`processes.”
`
`Testimony of Dr. Jacob
`Baker. Dr. Baker will explain
`the technology, the
`state of the art at the time the
`patent
`application was filed, the
`meaning of claim terms or
`phrases as they would be
`understood by those of
`ordinary skill in the art at the
`time of the invention in the
`context of the patent
`specification and other
`
`- 10 -
`
`SAMSUNG V. SOLAS
`IPR2021-01254
`Exhibit 2008
`Page 10
`
`
`
`Case 2:21-cv-00105-JRG Document 62 Filed 10/23/21 Page 11 of 15 PageID #: 1315
`
`Term
`
`Plaintiff
`
`“the gesture-processing
`logic” (Claim 13)
`
`“the logic”
`
`Specification at 3:11-5:46,
`7:19-19:16, Figs. 1-12
`
`July 10, 2013 Amendment
`and Applicant
`Arguments/Remarks
`Nov. 19, 2012 Amendment
`and Applicant
`Arguments/Remarks
`July 19, 2012 Final Rejection
`April 26, 2012 Amendment
`and Applicant
`Arguments/Remarks
`
`- 11 -
`
`Defendants
`intrinsic/extrinsic evidence,
`how those of ordinary skill in
`the art at the time of the
`invention would have
`understood statements made
`by the patentee during
`prosecution of the
`applications, and the level of
`ordinary skill in the relevant
`art. Dr. Baker may also offer
`a declaration, if necessary, to
`respond to Plaintiff’s
`contentions, any expert
`testimony on behalf of
`Plaintiff, or for the Court’s
`benefit.
`
`Indefinite.
`
`’767 Patent at Abstract, 1:10-
`3:7, 3:11-6:43, 6:47-7:15,
`7:19-63, 7:64-8:35, 8:36-
`10:50, 10:51-11:60, 11:61-
`14:19, 14:20-24, 14:25-33,
`14:34-56, 14:57-15:13,
`15:14-17:3, 17:4-34, 17:35-
`18:9, 18:10-19:16, 19:17-
`20:3, 20:4-49, Figures 1-13,
`Claims 1-14.
`
`’767 Patent Prosecution
`History at October 20, 2008
`Application, January 26, 2012
`Non-Final Rejection, April
`26, 2012
`Amendment/Request for
`Reconsideration After Non-
`Final Rejection, July 19, 2012
`Applicant Initiated Interview
`Summary, July 19, 2012
`Final Rejection, November
`19, 2012 Request for
`Continued Examination,
`December 24, 2012 Notice of
`Allowance, December 24,
`
`SAMSUNG V. SOLAS
`IPR2021-01254
`Exhibit 2008
`Page 11
`
`
`
`Case 2:21-cv-00105-JRG Document 62 Filed 10/23/21 Page 12 of 15 PageID #: 1316
`
`Defendants
`2012 Examiner Initiated
`Interview Summary,
`December 24, 2012 Applicant
`Initiated Interview Summary,
`March 20, 2013 Request for
`Continued Examination,
`April 10, 2013 Notice of
`Allowance, July 10, 2013
`Amendment After Notice of
`Allowance, August 1, 2013
`Response to Amendment.
`
`Provisional Patent
`Application No. 61/049,453.
`
` A
`
` Dictionary of Computing
`(Sixth Edition) (2008):
`defining “gesture” as “A type
`of input to a computer where
`the meaning depends on the
`time-related positions input
`from the device. For
`example, using a *dataglove
`the user might beckon with a
`finger to indicate a zoom in
`on the display.”
`
`Wiley Electrical and
`Electronics Engineering
`Dictionary (2004): defining
`“gesture recognition” as “The
`ability of a computer system
`to detect and comprehend
`gestures such as hand and
`head movements. The term
`specifically excludes the use
`of haptic devices or
`interfaces. Used, for
`instance, for entering data
`using sign language.”
`
`Merriam-Webster’s
`Advanced Learner’s English
`Dictionary (2008): defining
`“gesture” as “a movement of
`
`Term
`
`Plaintiff
`
`- 12 -
`
`SAMSUNG V. SOLAS
`IPR2021-01254
`Exhibit 2008
`Page 12
`
`
`
`Case 2:21-cv-00105-JRG Document 62 Filed 10/23/21 Page 13 of 15 PageID #: 1317
`
`Term
`
`Plaintiff
`
`Defendants
`your body (especially of your
`hands and arms) that shows
`or emphasizes an idea or a
`feeling … something said or
`done to show a particular
`feeling or attitude … to move
`your hands, arms, etc., to
`express an idea or feeling.”
`
`The American Heritage
`Dictionary of the English
`Language (Fourth Edition)
`(2006): defining “gesture” as
`“A motion of the limbs or
`body made to express or help
`express thought or to
`emphasize speech … The act
`of moving the limbs or body
`as an expression of thought or
`emphasis … An act or a
`remark made as a formality or
`as a sign of intention of
`attitude.”
`
`Testimony of Dr. Jacob
`Baker. Dr. Baker will explain
`the technology, the
`state of the art at the time the
`patent
`application was filed, the
`meaning of claim terms or
`phrases as they would be
`understood by those of
`ordinary skill in the art at the
`time of the invention in the
`context of the patent
`specification and other
`intrinsic/extrinsic evidence,
`how those of ordinary skill in
`the art at the time of the
`invention would have
`understood statements made
`by the patentee during
`prosecution of the
`applications, and the level of
`
`- 13 -
`
`SAMSUNG V. SOLAS
`IPR2021-01254
`Exhibit 2008
`Page 13
`
`
`
`Case 2:21-cv-00105-JRG Document 62 Filed 10/23/21 Page 14 of 15 PageID #: 1318
`
`Term
`
`Plaintiff
`
`Defendants
`ordinary skill in the relevant
`art. Dr. Baker may also offer
`a declaration, if necessary, to
`respond to Plaintiff’s
`contentions, any expert
`testimony on behalf of
`Plaintiff, or for the Court’s
`benefit.
`
`Dated: October 23, 2021
`
`Dated: October 23, 2021
`
`Respectfully submitted,
`
`/s/ Christian W. Conkle
`Marc Fenster (CA SB No. 181067)
`Reza Mirzaie (CA SB No. 246953)
`Neil A. Rubin (CA SB No. 181067)
`Christian W. Conkle (CA SB No. 306374)
`RUSS AUGUST & KABAT
`12424 Wilshire Boulevard 12th Floor
`Los Angeles, California 90025
`Telephone: 310-826-7474
`Facsimile: 310-826-6991
`E-mail: mfenster@raklaw.com
`E-mail: rmirzaie@raklaw.com
`E-mail: nrubin@raklaw.com
`E-mail: cconkle@raklaw.com
`
`ATTORNEYS FOR PLAINTIFF
`SOLAS OLED, LTD.
`
`/s/ John Kappos
`Melissa Richards Smith
`Gillam & Smith, LLP
`303 South Washington Avenue
`Marshall, TX 75670
`903-934-8450
`Fax: 903-934-9257
`Email: melissa@gillamsmithlaw.com
`
`- 14 -
`
`SAMSUNG V. SOLAS
`IPR2021-01254
`Exhibit 2008
`Page 14
`
`
`
`Case 2:21-cv-00105-JRG Document 62 Filed 10/23/21 Page 15 of 15 PageID #: 1319
`
`John C Kappos
`O’Melveny & Myers LLP – Newport Beach,
`CA
`610 Newport Center Drive
`17th Floor
`Newport Beach, CA 92660
`949-760-9600
`Fax: 949-823-6994
`Email: jkappos@omm.com
`Nicholas J Whilt
`O'Melveny & Myers LLP - LA
`400 South Hope Street
`18th Floor
`Los Angeles, Ca 90071
`213-430-6000
`Fax: 213-430-6407
`Email: nwhilt@omm.com
`Ryan K Yagura
`O'Melveny & Myers LLP - LA
`400 South Hope Street
`18th Floor
`Los Angeles, Ca 90071
`213/430-6189
`Fax: 213-430-6407
`Email: ryagura@omm.com
`
`COUNSEL FOR DEFENDANTS SAMSUNG
`ELECTRONICS CO., LTD., AND SAMSUNG
`ELECTRONICS AMERICA, INC.
`
`CERTIFICATE OF SERVICE
`
`The undersigned certifies that on October 23, 2021, all counsel of record who are deemed
`
`to have consented to electronic service are being served with a copy of this document via the
`
`Court’s CM/ECF system pursuant to Local Rule CV-5(a)(3)(A).
`
`/s/ Reza Mirzaie_______
`Reza Mirzaie
`
`- 15 -
`
`SAMSUNG V. SOLAS
`IPR2021-01254
`Exhibit 2008
`Page 15
`
`
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