MASSIVELY BROADBAND, IPR2025-01594, Ex.2056, Page 1 of 13
`UNITED STATES DISTRICT COURT
`EASTERN DISTRICT OF TEXAS
`MARSHALL DIVISION
`MASSIVELY BROADBAND LLC
`Plaintiff,
`V.
`SAMSUNG ELECTRONICS CO., LTD.
`AND SAMSUNG ELECTRONICS
`AMERICA, INC.,
`Defendants.
`Case No. 2:25-cv-00608-JRG
`SAMSUNG'S NOTICE OF SUBPOENA
`DUCES TE CUM AND AD TESTIFICANDUM TO OPEN MOBILE ALLIANCE
`PLEASE TAKE NOTICE THAT, pursuant to Rule 45 of the Federal Rules of Civil
`Procedure, Defendants Samsung Electronics, Co., Ltd. and Samsung Electronics America, Inc.
`(collectively, "Samsung") will initiate service of the attached subpoena duces tecum and ad
`testificandum upon Open Mobile Alliance ("OMA"). The subpoena requests the production of
`documents, information, and things described in Exhibit A, and the presentation of a witness
`competent to testify about the topics described in Exhibit B. The documents and witness shall be
`produced or presented at the time and location specified in the subpoena, or alternatively at a
`mutually agreed upon time and location.
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`MASSIVELY BROADBAND, IPR2025-01594, Ex.2056, Page 2 of 13
`Dated: November 12, 2025
`By Isl Chunmeng Yang
`Sean Pak
`California Bar No . 219032 (pro hac vice)
`seanpak@quinnemanuel.com
`QUINN EMANUEL URQUHART & SULLIVAN,
`LLP
`50 California Street, 22nd Floor
`San Francisco, CA 94111
`Tel: 415-875-6600
`Fax:415-875-6700
`Kevin Hardy
`D.C . Bar No. 473941 (admitted in E.D . Tex.)
`kevinhardy@guinnemanuel.com
`QUINN EMANUEL URQUHART & SULLIVAN,
`LLP
`1300 I Street, N .W., Suite 900
`Washington, DC 20005
`Tel: 202.538.8000
`Fax: 202.538.8100
`Matthew Robson
`New York Bar No. 4611505 (pro hac vice)
`matthewrobson@quinnemanuel .com
`QUINN EMANUEL URQUHART & SULLIVAN,
`LLP
`295 5th Avenue , 9th Floor,
`New York , New York 10016
`Tel: (212) 849-7000
`Fax: (212) 849-7100
`Melissa R . Smith
`Texas State Bar No . 24001351
`melissa@gillamsmithlaw.com
`GILLAM & SMITH, LLP
`303 South Washington Avenue
`Marshall, Texas 75670
`Phone : (903) 934-8450
`Fax: (903) 934-9257
`Counsel for Defendants Samsung Electronics Co., Ltd.
`and Samsung Electronics America, Inc.
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`MASSIVELY BROADBAND, IPR2025-01594, Ex.2056, Page 3 of 13
`CERTIFICATE OF SERVICE
`I hereby certify that a true and correct copy of the above and foregoing document has been
`served on November 12, 2025 to all counsel of record who are deemed to have consented to
`electronic service via email.
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`Isl Chunmeng Yang
`Chunmeng Yang
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`AO 88A (Rev. / ) Subpoena to Testify at a Deposition in a Civil Action
`UNITED STATES DISTRICT COURT
`for the
`__________ District of __________
`)
`)
`)
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`)
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`Plaintiff
`v. Civil Action No.
`Defendant
`SUBPOENA TO TESTIFY AT A DEPOSITION IN A CIVIL ACTION
`To:
`(Name of person to whom this subpoena is directed)
`Place: Date and Time:
`The deposition will be recorded by this method:
`Production: You, or your representatives, must also bring with you to the deposition the following documents,
`electronically stored information, or objects, and must permit inspection, copying, testing, or sampling of the
`material:
`The following provisions of Fed. R. Civ. P. 45 are attached – Rule 45(c), relating to the place of compliance;
`Rule 45(d), relating to your protection as a person subject to a subpoena; and Rule 45(e) and (g), relating to your duty to
`respond to this subpoena and the potential consequences of not doing so.
`Date:
`CLERK OF COURT
`OR
`Signature of Clerk or Deputy Clerk Attorney’s signature
`The name, address, e-mail address, and telephone number of the attorney representing (name of party)
`, who issues or requests this subpoena, are:
`Notice to the person who issues or requests this subpoena
`If this subpoena commands the production of documents, electronically stored information, or tangible things before
`trial, a notice and a copy of the subpoena must be served on each party in this case before it is served on the person to
`whom it is directed. Fed. R. Civ. P. 45(a)(4).
`SAMSUNG ELECTRONICS CO., LTD. AND
`SAMSUNG ELECTRONICS AMERICA, INC.
`See Attachment B.
`See Attachment A.
`12/1/2025 9:00 am (or date and time agreed by parties)
`Chunmeng Yang, 1109 1st Ave., Suite 210, Seattle, WA 98101; Phone: (206) 905-7077; Email: chunmengyang@quinnemanuel.com
`MASSIVELY BROADBAND LLC
`2:25-cv-00608-JRG
`Open Mobile Alliance
`Veritext
`550 W C Street, Suite 800
`San Diego, CA 92101
`Video and stenography.
`11/12/2025
`/s/ Chunmeng Yang
`Samsung Electronics Co. Ltd. and Samsung Electronics America, Inc.
`MASSIVELY BROADBAND, IPR2025-01594, Ex.2056, Page 4 of 13
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`Eastern District of Texas
`rf Testimony: YOU ARE COMMANDED to appear at the time, date, and place set forth below to testify at a
`deposition to be taken in this civil action. If you are an organization, you must promptly confer in good faith with the
`party serving this subpoena about the following matters, or those set forth in an attachment, and you must designate one
`or more officers, directors, or managing agents, or designate other persons who consent to testify on your behalf about
`these matters:
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`AO 88A (Rev. 2/ ) Subpoena to Testify at a Deposition in a Civil Action (Page 2)
`Civil Action No.
`PROOF OF SERVICE
`(This section should not be filed with the court unless required by Fed. R. Civ. P. 45.)
`I received this subpoena for (name of individual and title, if any)
`on (date) .
`I served the subpoena by delivering a copy to the named individual as follows:
`on (date) ; or
`I returned the subpoena unexecuted because:
`.
`Unless the subpoena was issued on behalf of the United States, or one of its officers or agents, I have also
`tendered to the witness the fees for one day’s attendance, and the mileage allowed by law, in the amount of
`$ .
`My fees are $ for travel and $ for services, for a total of $ .
`I declare under penalty of perjury that this information is true.
`Date:
`Server’s signature
`Printed name and title
`Server’s address
`Additional information regarding attempted service, etc.:
`2:25-cv-00608-JRG
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`MASSIVELY BROADBAND, IPR2025-01594, Ex.2056, Page 5 of 13
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`AO 88A (Rev. 2/ ) Subpoena to Testify at a Deposition in a Civil Action (Page 3)
`Federal Rule of Civil Procedure 45 (c), (d), (e), and (g) (Effective 12/1/13)
`(c) Place of Compliance.
`(1) For a Trial, Hearing, or Deposition. A subpoena may command a
`person to attend a trial, hearing, or deposition only as follows:
`(A) within 100 miles of where the person resides, is employed, or
`regularly transacts business in person; or
`(B) within the state where the person resides, is employed, or regularly
`transacts business in person, if the person
`(i) is a party or a party’s officer; or
`(ii) is commanded to attend a trial and would not incur substantial
`expense.
`(2) For Other Discovery. A subpoena may command:
`(A) production of documents, electronically stored information, or
`tangible things at a place within 100 miles of where the person resides, is
`employed, or regularly transacts business in person; and
`(B) inspection of premises at the premises to be inspected.
`(d) Protecting a Person Subject to a Subpoena; Enforcement.
`(1) Avoiding Undue Burden or Expense; Sanctions. A party or attorney
`responsible for issuing and serving a subpoena must take reasonable steps
`to avoid imposing undue burden or expense on a person subject to the
`subpoena. The court for the district where compliance is required must
`enforce this duty and impose an appropriate sanction—which may include
`lost earnings and reasonable attorney’s fees—on a party or attorney who
`fails to comply.
`(2) Command to Produce Materials or Permit Inspection.
`(A) Appearance Not Required. A person commanded to produce
`documents, electronically stored information, or tangible things, or to
`permit the inspection of premises, need not appear in person at the place of
`production or inspection unless also commanded to appear for a deposition,
`hearing, or trial.
`(B) Objections. A person commanded to produce documents or tangible
`things or to permit inspection may serve on the party or attorney designated
`in the subpoena a written objection to inspecting, copying, testing, or
`sampling any or all of the materials or to inspecting the premises—or to
`producing electronically stored information in the form or forms requested.
`The objection must be served before the earlier of the time specified for
`compliance or 14 days after the subpoena is served. If an objection is made,
`the following rules apply:
`(i) At any time, on notice to the commanded person, the serving party
`may move the court for the district where compliance is required for an
`order compelling production or inspection.
`(ii) These acts may be required only as directed in the order, and the
`order must protect a person who is neither a party nor a party’s officer from
`significant expense resulting from compliance.
`(3) Quashing or Modifying a Subpoena.
`(A) When Required. On timely motion, the court for the district where
`compliance is required must quash or modify a subpoena that:
`(i) fails to allow a reasonable time to comply;
`(ii) requires a person to comply beyond the geographical limits
`specified in Rule 45(c);
`(iii) requires disclosure of privileged or other protected matter, if no
`exception or waiver applies; or
`(iv) subjects a person to undue burden.
`(B) When Permitted. To protect a person subject to or affected by a
`subpoena, the court for the district where compliance is required may, on
`motion, quash or modify the subpoena if it requires:
`(i) disclosing a trade secret or other confidential research, development,
`or commercial information; or
`(ii) disclosing an unretained expert’s opinion or information that does
`not describe specific occurrences in dispute and results from the expert’s
`study that was not requested by a party.
`(C) Specifying Conditions as an Alternative. In the circumstances
`described in Rule 45(d)(3)(B), the court may, instead of quashing or
`modifying a subpoena, order appearance or production under specified
`conditions if the serving party:
`(i) shows a substantial need for the testimony or material that cannot be
`otherwise met without undue hardship; and
`(ii) ensures that the subpoenaed person will be reasonably compensated.
`(e) Duties in Responding to a Subpoena.
`(1) Producing Documents or Electronically Stored Information. These
`procedures apply to producing documents or electronically stored
`information:
`(A) Documents. A person responding to a subpoena to produce documents
`must produce them as they are kept in the ordinary course of business or
`must organize and label them to correspond to the categories in the demand.
`(B) Form for Producing Electronically Stored Information Not Specified.
`If a subpoena does not specify a form for producing electronically stored
`information, the person responding must produce it in a form or forms in
`which it is ordinarily maintained or in a reasonably usable form or forms.
`(C) Electronically Stored Information Produced in Only One Form. The
`person responding need not produce the same electronically stored
`information in more than one form.
`(D) Inaccessible Electronically Stored Information. The person
`responding need not provide discovery of electronically stored information
`from sources that the person identifies as not reasonably accessible because
`of undue burden or cost. On motion to compel discovery or for a protective
`order, the person responding must show that the information is not
`reasonably accessible because of undue burden or cost. If that showing is
`made, the court may nonetheless order discovery from such sources if the
`requesting party shows good cause, considering the limitations of Rule
`26(b)(2)(C). The court may specify conditions for the discovery.
`(2) Claiming Privilege or Protection.
`(A) Information Withheld. A person withholding subpoenaed information
`under a claim that it is privileged or subject to protection as trial-preparation
`material must:
`(i) expressly make the claim; and
`(ii) describe the nature of the withheld documents, communications, or
`tangible things in a manner that, without revealing information itself
`privileged or protected, will enable the parties to assess the claim.
`(B) Information Produced. If information produced in response to a
`subpoena is subject to a claim of privilege or of protection as
`trial-preparation material, the person making the claim may notify any party
`that received the information of the claim and the basis for it. After being
`notified, a party must promptly return, sequester, or destroy the specified
`information and any copies it has; must not use or disclose the information
`until the claim is resolved; must take reasonable steps to retrieve the
`information if the party disclosed it before being notified; and may promptly
`present the information under seal to the court for the district where
`compliance is required for a determination of the claim. The person who
`produced the information must preserve the information until the claim is
`resolved.
`(g) Contempt.
`The court for the district where compliance is required—and also, after a
`motion is transferred, the issuing court—may hold in contempt a person
`who, having been served, fails without adequate excuse to obey the
`subpoena or an order related to it.
`For access to subpoena materials, see Fed. R. Civ. P. 45(a) Committee Note (2013).
`MASSIVELY BROADBAND, IPR2025-01594, Ex.2056, Page 6 of 13
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`MASSIVELY BROADBAND, IPR2025-01594, Ex.2056, Page 7 of 13
`EXHIBIT A
`Pursuant to Rule 45 of the Federal Rules of Civil Procedure, Samsung requests that OMA
`produce the documents, information, and things set forth below. The requested documents are to
`be produced on or before December 1, 2025, at Veritext San Diego, 550 WC Street, Suite 800,
`San Diego, CA 92101, or at such other time as may be agreed by counsel. A copy of the Protective
`Order entered in this action for the protection of any requested proprietary, confidential, or
`commercially sensitive information is attached hereto as Exhibit C.
`DEFINITIONS
`1. "OMA," "You," or "Your" means Open Mobile Alliance and all of its predecessors
`(merged, acquired, or otherwise), successors, subsidiaries, parents, sisters, divisions, departments,
`partnerships, and affiliates thereof, and all officers, directors, principals, agents, employees,
`attorneys, and other persons acting on its behalf.
`2. "Samsung" means Samsung Electronics, Co., Ltd. and Samsung Electronics
`America, Inc. and all their predecessors ( merged, acquired, or otherwise), successors, subsidiaries,
`parents, sisters, divisions, departments, partnerships, and affiliates thereof, and all officers,
`directors, principals, agents, employees, attorneys, and other person acting on their behalf.
`3. "OMA DM" means the Open Mobile Alliance Device Management software, as
`well as any and all variants, versions, and related software, and any other additional products
`commercialized by OMA incorporating the functionalities of OMA DM, including but not limited
`to the SyncML Device Management Specification.
`4. As used herein, "any" and "all" shall be construed to mean "each and every," so as
`to acquire the broadest possible meaning.
`5. As used herein, "each" and "every" mean "each and every."
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`MASSIVELY BROADBAND, IPR2025-01594, Ex.2056, Page 8 of 13
`6. As used herein, "include" and "including" shall be construed to mean "without
`limitation," so as to acquire the broadest possible meaning.
`7. As used herein, "person" means any natural person or any business, legal, or
`governmental entity or association.
`8. As used herein, "identify" as applied to an event means to provide a description of
`the event, the date of the event, the location of the event, and the individuals and entities
`participating in the event.
`9. As used herein, the term "source code" means any software, HDL, VHDL, Verilog,
`HTML, JavaScript, source code, object code, template file, configuration file or data, or other
`electronic information for directing the operation of a computer, mobile device, website, server,
`or for processing electronic data including but not limited to computer instructions and data
`definitions expressed in a form suitable for input to an assembler, compiler, other translator, or
`other data processing module.
`10. "Document" has the same broad meaning as in Rule 34 of the Federal Rules of
`Civil Procedure, including, without limitation, all written, graphic or otherwise recorded material,
`including without limitation, microfilms or other film records or impressions, electronically stored
`information regardless of the form of storage medium, tape recordings or computer cards, floppy
`disks or printouts, any and all papers, photographs, films, recordings, memoranda, books, records,
`accounts, communications, letters, telegrams, correspondence, notes of meetings, notes of
`conversations, notes of telephone calls, inter-office memoranda or written communications of any
`nature, recordings of conversations either in writings or upon any mechanical or electrical
`recording devices, including email, notes, papers, reports, analyses, invoices, canceled checks or
`check stubs, receipts, minutes of meetings, time sheets, diaries, desk calendars, ledgers, schedules,
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`MASSIVELY BROADBAND, IPR2025-01594, Ex.2056, Page 9 of 13
`licenses, financial statements, telephone bills, logs, and any differing versions of any of the
`foregoing, whether so denominated, formal, informal or otherwise, as well as copies of the
`foregoing which differ in any way, including by the addition of handwritten notations or other
`written or printed matter of any nature, from the original. The foregoing specifically includes
`information stored in a computer database and capable of being generated in documentary form,
`such as electronic mail.
`11. "Reflect," "reflecting," "relate to," "refer to," "relating to," and "referring to" mean
`relating to, referring to, concerning, mentioning, reflecting, pertaining to, evidencing, involving,
`demonstrating, describing, discussing, commenting on, comprising, embodying, responding to,
`supporting, contradicting, containing or constituting (in whole or in part), as the context makes
`appropriate.
`12. Except as specifically provided herein, words imparting the singular shall include
`the plural and vice versa.
`13. Pursuant to any requests herein, You are to produce any and all relevant documents
`within Your possession, custody, or control, including documents located in the files of any
`business entities You own, control, or operate, any persons acting on Your behalf, and any
`professionals who maintain documents for You, including but not limited to Your attorneys,
`accountants, or other representatives.
`14. Produce each document in its entirety without deletions, redactions, or exclusions,
`regardless of whether you deem part of a document outside of the scope of the requests.
`15. Produce documents that identify the file or other source in which each document
`responsive to these requests is found or keep a record of such information.
`16. Documents from any single file should be produced in the same order as they were
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`MASSIVELY BROADBAND, IPR2025-01594, Ex.2056, Page 10 of 13
`found in such file, including any labels, files, folders, and/or containers in in which such documents
`are located or with which such documents are associated. If copies of documents are produced in
`lieu of the originals, such copies should be legible and bound or stapled in the same manner as the
`originals.
`17. All documents that constitute electronically stored information, with that term
`having the meaning ascribed to it by the Federal Rules of Civil Procedure, shall be produced in an
`intelligible format.
`18. If a document once existed, but has been lost, destroyed, erased, or otherwise is no
`longer in your possession, identify the document and state the details concerning the loss or
`destruction of such document, including the name and address of the present custodian of any such
`document known to You.
`19. If, after conducting a reasonable investigation, a full answer cannot be provided for
`any request for the production of documents, state that such is the case and answer to the fullest
`extent possible, stating what responsive documents or information are available, what documents
`or information cannot be provided, and what efforts were made to obtain the unavailable
`documents or information.
`20. If any of the documents requested herein are no longer in Your possession, custody,
`or control, identify for each such document the date, the type of the document, any senders and
`recipients, and any persons receiving any copies of each such document, and provide a summary
`of each such document's pertinent contents.
`21. If any document responsive to these requests has been destroyed, describe the
`contents of the document, identify the location of any copies of the document, and the date of
`destruction of the document.
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`MASSIVELY BROADBAND, IPR2025-01594, Ex.2056, Page 11 of 13
`22. If any document is withheld on a claim of attorney/client privilege or work product
`immunity, provide a detailed privilege log that describes the nature and basis for your claim and
`the subject matter of the document withheld, in a manner sufficient to disclose facts upon which
`You rely in asserting your claim and to identify the grounds and reasons for withholding the
`document. Such description should, at a minimum, include the date of the withheld document, an
`identification of each and every author of the document, an identification of each and every person
`who received the document, an identification of each and every person from whom the document
`was received, a description of the subject of the document, and further information relating to the
`document sufficient to explain the claim of privilege or immunity and to permit the adjudication
`of the propriety of that claim.
`23. The document requests herein shall be deemed continuing, and it is requested that
`You provide supplemental responses and production as additional information or documents
`become available, in accordance with Rule 26(e) of the Federal Rules of Civil Procedure.
`24. If a document is in a language other than English and an English translation exists,
`provide both documents.
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`MASSIVELY BROADBAND, IPR2025-01594, Ex.2056, Page 12 of 13
`DOCUMENTS TO BE PRODUCED
`1. Documents, including specifications, instructions, technical plans, diagrams,
`workbooks, manuals, published articles, publications, and user guides, sufficient to show the
`technical structure, operation, and functionality of OMA DM that were created, developed,
`released, sold, offered for sale, or used prior to February 13, 2008, including documents sufficient
`to show the information collected and stored in databases related to wireless devices and interfaces
`with said databases.
`2. Source code for OMA DM that was created, developed, released, sold, offered for
`sale, or used prior to February 13, 2008, including code relating to collection and storage of
`information related to wireless devices and interfaces with said software.
`3. Documents sufficient to show the sale, offer for sale, or public use in the United
`States prior to February 13, 2008 of OMA DM, including but not limited to functionality for
`managing wireless devices.
`4. Documents sufficient to show publication, including in the form of press releases,
`user guides, specifications, user instructions, etc., prior to February 13, 2008 of OMA DM.
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`MASSIVELY BROADBAND, IPR2025-01594, Ex.2056, Page 13 of 13
`EXHIBITB
`TOPICS FOR DEPOSITION
`1. Specifications, instructions, technical plans, diagrams, workbooks, manuals,
`published articles, publications, and user guides, sufficient to show the technical structure,
`operation, and functionality of OMA DM that were created, developed, released, sold, offered for
`sale, or used prior to February 13, 2008, including documents sufficient to show the information
`collected and stored in databases related to wireless devices and interfaces with said databases.
`2. Source code for OMA DM that was created, developed, released, sold, offered for
`sale, or used prior to February 13, 2008, including code relating to collection and storage of
`information related to wireless devices and interfaces with said software.
`3. The sale, offer for sale, or public use in the United States prior to February 13, 2008
`of OMA DM, including but not limited to functionality for managing wireless devices.
`4. Publication, including in the form of press releases, user guides, specifications, user
`instructions, etc., prior to February 13, 2008 of OMA DM.
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