IN THE UNITED STATES DISTRICT COURT
`FOR THE WESTERN DISTRICT OF TEXAS
`WACO DIVISION
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`TOUCHSTREAM TECHNOLOGIES, INC.,
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` Plaintiff,
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` v.
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`GOOGLE LLC,
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` Defendant.
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`Civil Case No. 6:21-cv-569-ADA
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`JURY TRIAL DEMANDED
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`GOOGLE LLC’S REPLY IN SUPPORT OF ITS MOTION FOR RECONSIDERATION
`OF (A) ITS DAUBERT MOTION TO EXCLUDE CERTAIN OPINIONS OF DAMAGES
`EXPERT MARK J. CHANDLER AND (B) ITS POST-TRIAL MOTIONS
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`TABLE OF CONTENTS
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`TABLE OF AUTHORITIES ......................................................................................................... II
`TABLE OF ABBREVIATIONS ................................................................................................. III
`TABLE OF TRIAL EXHIBITS................................................................................................... IV
`TABLE OF REPLY EXHIBITS .................................................................................................. IV
`I. INTRODUCTION ............................................................................................................. 1
`II. ARGUMENT ..................................................................................................................... 2
`A. EcoFactor Is a Change in Law that Warrants Reconsideration Here..................... 2
`1. EcoFactor changed the law governing admissibility of expert
`testimony under Federal Rule of Evidence 702. ........................................ 2
`2. EcoFactor is directly on point and compels reversal of the Court’s
`earlier orders permitting Mr. Chandler’s testimony. ................................. 4
`B. The Court Should Hold A Hearing To Create A Record Suitable For
`Review ................................................................................................................... 8
`III. CONCLUSION .................................................................................................................. 9
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`TABLE OF AUTHORITIES
` Page
`CASES
`EcoFactor, Inc. v. Google LLC,
`137 F.4th 1333 (Fed. Cir. 2025) (en banc) ...................................................................... passim
`Klee v. Lehigh Valley Hosp.,
`1998 WL 966011 (E.D. Pa. Nov. 30, 1998), aff’d mem., 203 F.3d 817 (3d Cir.
`1999) ..........................................................................................................................................7
`LaserDynamics, Inc. v. Quanta Comput., Inc.,
`694 F.3d 51 (Fed. Cir. 2012)......................................................................................................5
`McSurely v. McClellan,
`753 F.2d 88 (D.C. Cir. 1985) .....................................................................................................8
`Ravo v. Covidien LP,
`55 F. Supp. 3d 766 (W.D. Pa. 2014) ..........................................................................................3
`Sovereign Bank v. Catterton,
`2004 WL 1166591 (E.D. Pa. May 20, 2004) .............................................................................7
`Summit 6, LLC v. Samsung Electronics Co.,
`802 F.3d 1283 (Fed. Cir. 2015)..................................................................................................3
`VirnetX, Inc. v. Cisco Systems, Inc.,
`767 F.3d 1308 (Fed. Cir. 2014)..................................................................................................3
`OTHER AUTHORITIES
`Fed. R. Evid. 702 ................................................................................................................... passim
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`TABLE OF ABBREVIATIONS
`Abbreviation Definition
`Google Google LLC
`Touchstream Touchstream Technologies, Inc.
`ʼ251 patent U.S. Patent No. 8,356,251 (PTX-865)
`ʼ528 patent U.S. Patent No. 8,782,528 (PTX-885)
`ʼ289 patent U.S. Patent No. 8,904,289 (PTX-863)
`asserted patents the ʼ251 patent, the ʼ528 patent, and the ʼ289 patent
`Shodogg Touchstream’s business pseudonym
`Quadriga Quadriga Worldwide Ltd.
`Quadriga agreement Amended and Restated Software Development and License
`Agreement between Touchstream and Quadriga (PTX-567)
`Tr. Trial Transcript, located at:
`Dkt. 259 (Day 1, pp. 1-244);
`Dkt. 260 (Day 2, pp. 245-647);
`Dkt. 262 (Day 3, pp. 648-1028);
`Dkt. 264 (Day 4, pp. 1029-1310); and
`Dkt. 266 (Day 5, pp. 1311-1376).
`Certain portions of the Trial Transcript are and remain under seal.
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`*All emphasis added unless otherwise noted.
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`TABLE OF TRIAL EXHIBITS
`Exhibit Description
`PTX-567 Quadriga agreement
`PTX-863 ’289 patent
`PTX-865 ’251 patent
`PTX-885 ’528 patent
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`TABLE OF REPLY EXHIBITS
`Exhibit Description
`B
`Touchstream’s Complaint in Touchstream Technologies, Inc. v.
`Majd Bakar et al., No. 25CV470032 (Cal. Super. Ct. filed July 7,
`2025)
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`I. INTRODUCTION
`As Google’s motion showed, EcoFactor, Inc. v. Google LLC , 137 F.4th 1333 (Fed. Cir.
`2025) (en banc), warrants reconsideration and a new trial on damages. Dkt. 313 at 2- 3, 5-11. In
`EcoFactor, the en banc Federal Circuit clarified district courts’ critical gatekeeping role for
`damages expert opinion. And in doing so, it condemned legally flawed expert testimony regarding
`license agreements that is on all fours with the unsupported testimony of Touchstream’s damages
`expert, Mr. Chander. Just as the terms of the agreements in EcoFactor contradicted a critical
`predicate of the expert’s testimony there, the plain language of the Quadriga agreement contradicts
`Mr. Chandler’s view that the agreement provides for a $0.48 rate for the asserted patents , which
`was the starting point of his opinion. Dkt. 313 at 5- 11. In view of this new precedent, the Court
`should reconsider its earlier orders finding Mr. Chandler’s damages opinion reliable and order a
`new trial that excludes his testimony.
`Rather than grappling with the clear holdings and implications of EcoFactor, Touchstream
`engages in obfuscation. Touchstream asserts that EcoFactor was not a change in the law even
`though its own arguments underscore that EcoFactor provided new guidance. Touchstream also
`refuses to engage with the substance of Google’s arguments that spotlight the flawed bases of
`Mr. Chander’s opinion. Touchstream’s attempts to evade EcoFactor fail.
`Separately, Touchstream fails to offer any legitimate reason to deny Google’s request for
`a hearing on its post -trial motions. As Google ’s motion explained, a hearing would permit this
`Court to fully explore and evaluate the effects of EcoFactor on Google’s motion for a new trial
`and, for all of Google’s post-trial motions, create a sufficient record suitable for review. Dkt. 313
`at 11.
`1
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`1 Google notes that on July 7, 2025, Touchstream filed a new lawsuit against Google (along with
`its employee Majd Bakar (who testified at the trial of this case) and “JOHN DOES 1 -50”) in the
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`II. ARGUMENT
`A. EcoFactor Is a Change in Law that Warrants Reconsideration Here
`EcoFactor warrants reconsideration and reversal of the Court’s earlier orders that allowed
`Mr. Chandler’s testimony over Google’s objection. Touchstream brushes EcoFactor aside,
`arguing it “created no relevant change in the law,” and that it is of such “exceptionally narrow
`scope” it has no applicability beyond its facts. E.g., Dkt. 320 at 1. Touchstream is wrong on both
`counts.2
`1. EcoFactor changed the law governing admissibility of expert
`testimony under Federal Rule of Evidence 702.
`As Google’s motion explained, EcoFactor changed the law regarding the district court’s
`gatekeeping role in the context of expert testimony on damages for patent infringement. Dkt. 313
`at 2-3, 5-11. In EcoFactor, the full Federal Circuit examined the requirements of the Federal Rules
`of Evidence and provided new guidance on how those Rules should be applied in the context of
`patent damages expert testimony to “distinguish[] the ‘ gatekeeping role of the judge’ under Rule
`702 from the fact finder’s role.” 137 F.4th at 1340. Specifically, EcoFactor held that the question
`whether an expert’s analysis of an allegedly comparable agreement is based on sufficient facts or
`data is a preliminary question of admissibility that must be decided by the court, not left to the
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`Superior Court of California for Santa Clara County. See generally Ex. B. In this new California
`state lawsuit, brought four years after the filing of this case and more than ten years after the
`relevant events, Touchstream alleges trade secret, breach of contract, and other state- law claims
`that arise out of the same or overlapping facts at issue in this case and that were addressed in this
`case, including at trial before this Court. See id. ¶¶ 32-69. Touchstream further alleges that
`information learned in this case serves as the basis of its “new” claims. E.g., id. ¶¶ 32-36. Google
`will address Touchstream’s “new” complaint in that forum, and raise appropriate issues in this
`case, in due course, but informs the Court of this development as it considers the pending motions
`and the utility of argument on them and the previous motions.
`2 In discussing EcoFactor, Touchstream repeatedly invokes statements from a dissenting opinion,
`see EcoFactor, 137 F.4th at 1355 (Stark, J., dissenting), often without acknowledging it is doing
`so and even misrepresenting the dissent as setting forth holdings of “the Federal Circuit” and “the
`Court.” Dkt. 320 at 1, 5, 6, 7, 10. Plainly, the dissenting opinion has no precedential value.
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`jury. Id. at 1346. EcoFactor clarified that, while credibility and competing reasonable royalty
`amounts based on the same set of facts are for the jury, whether an expert’s testimony is consistent
`with the plain language of an agreement “involves the gatekeeping function of the court to ensure
`that there are sufficient facts or data” for the expert’s testimony. Id. at 1340, 1343. And “[w]here,
`as here, the relevant evidence is contrary to a critical fact upon which the expert relied, the district
`court fails to fulfill its responsibility as gatekeeper by allowing the expert to testify at trial.” Id. at
`1346.
`In arguing that EcoFactor did not create new law, Touchstream proffers a “standard of
`admissibility for damages opinions” (Dkt. 320 at 4 (cleaned up)) that is the opposite of what
`EcoFactor held. According to Touchstream, “licenses for related technology are admissible
`regardless of whether patents are included in the license,” and “distinctions and oversights are
`matters for cross-examination.” Id. EcoFactor expressly rejected such blanket admissibility rules.
`See 137 F.4th at 1339 -41; see also id. at 1340 (“While the credibility of an expert’s damages
`calculation is properly left to a jury, a determination of reliability under Rule 702 is an essential
`prerequisite.”). In making its assertion, Touchstream relies on pre-EcoFactor law, demonstrating
`that EcoFactor in fact provided new guidance on the district court’s gatekeeping role to prevent
`the continued incorrect application of Rules 104(a) and 702.
`3
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`3 Touchstream’s cited cases are also inapt on their own terms. The apportionment theory at issue
`in Summit 6, LLC v. Samsung Electronics Co., 802 F.3d 1283, 1296-97 (Fed. Cir. 2015), was based
`on a percentage of production costs, not the use of any allegedly comparable licenses. In VirnetX,
`Inc. v. Cisco Systems, Inc., 767 F.3d 1308, 1330 (Fed. Cir. 2014), the expert relied on six licenses,
`four of which “did indeed relate to the actual patents-in-suit, while the others were drawn to related
`technology” including patent applications “leading to the claimed invention,” unlike the License
`Fee in the Quadriga agreement that was unrelated to patents. And in Ravo v. Covidien LP , 55
`F. Supp. 3d 766, 780- 81 (W.D. Pa. 2014) —an out -of-circuit Western District of Pennsylvania
`case—the district court struck an expert’s opinions for failure to make the required threshold
`showing of comparability.
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`2. EcoFactor is directly on point and compels reversal of the Court’s
`earlier orders permitting Mr. Chandler’s testimony.
`As Google’s motion showed, the holding of EcoFactor is directly relevant to the facts of
`this case. Dkt. 313 at 5-11. In EcoFactor, the expert read several license agreements as reflecting
`an X dollars per unit rate, and his opinion critically relied on that rate. See 137 F.4th at 1341. But
`the agreements did not support that interpretation , so his testimony should have been excluded.
`See id. at 1341-43. That’s exactly the scenario here. Mr. Chandler relied on facts directly refuted
`by the terms of Quadriga agreement.
`As Google has explained, a critical factual basis for Mr. Chandler’s opinions was that the
`$0.48 per month per hotel room “License Fee” from the Quadriga agreement was “akin to a patent
`license” for the three patents -in-suit because that provision allegedly “included intellectual
`property such as patents.” Dkt. 313 at 7- 8. Mr. Chandler used that $0.48 rate as his baseline
`royalty rate. See id. But the plain language of the Quadriga agreement refutes his interpretation.
`As Google pointed out:
`● The Quadriga agreement expressly state d that the $0.48 “License Fee” was
`consideration for “the non- exclusive, non -transferable right to use the Licensed
`Materials and Documentation,” which we re defined as “the Shodogg Modified
`Application”—a specific software deliverable, not any patents, PTX-567.0006, 0013.
`● The agreement references patents only once, simply in a general definition of
`“Intellectual Property Rights,” and that definition was not used by or referenced in
`relation to the $0.48 License Fee. PTX-567.0006.
`● Only one of the three patents-in-suit had even issued at the time of the agreement.
`Dkt. 313 at 6- 7. As in EcoFactor, “[t]he plain language of the [Quadriga agreement] does not
`provide a basis” for Mr. Chandler’s interpretation, and his testimony should have been excluded.
`137 F.4th at 1341.
`Touchstream attempts to avoid the Quadriga agreement’s plain language by attacking straw
`men.
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`a. Touchstream tries to reduce Google’s substantive argument into an issue of
`semantics regarding whether the Quadriga agreement was a “bare patent license” and whether Mr.
`Chandler ever claimed as much. Dkt. 320 at 7-9. These are red herrings. Google does not contend
`that only “bare patent licenses” can be admissible for a reasonable royalty analysis. And
`Touchstream is wrong to im ply that Google ever suggested that Mr. Chandler claimed the
`Quadriga agreement was a bare patent license. Federal Circuit precedent allows use of broader
`agreements in appropriate circumstances, see, e.g., LaserDynamics, Inc. v. Quanta Comput., Inc.,
`694 F.3d 51, 79 (Fed. Cir. 2012), and the Quadriga agreement is broader than a bare patent license.
`But as EcoFactor confirmed, courts must exercise their “gatekeeping function” by making a
`threshold admissibility determination as to whether an expert’s use of a broader agreement is
`supported by sufficient facts or data, see 137 F.4th at 1343, 1345. Thus, the issue for the Court is
`whether Mr. Chandler adequately supported his view that the Quadriga agreement set forth a $0.48
`rate for the asserted patents. As discussed, he did not. The Quadriga agreement’s plain language,
`which provided that the License Fee was for a specific software deliverable, not for use of the
`patents-in-suit, contradicts Mr. Chandler’s assertion. Dkt. 313 at 5-8.
`b. Touchstream argues that other witnesses supported Mr. Chandler’s view. Dkt. 320
`at 8. But the only witness on whom Mr. Chandler purported to rely was Touchstream’s former
`CEO, Herb Mitschele, and as Google already explained, his after -the-fact, self-serving testimony
`cannot support Mr. Chandler. Dkt. 313 at 8- 10; see also Dkt. 225 at 89:11- 16 (Touchstream’s
`counsel explaining that Mr. Chandler “rel[ied] on his discussion with the CEO [Mr. Mitschele]”
`and “on the [Quadriga] agreement itself”). EcoFactor rejected as unreliable, and thus insufficient
`for admissibility, an expert’s reliance on “unsupported assertion[s] from an interested party.” 137
`F.4th at 1344. And that is precisely what Mr. Mitschele’s testimony was. To make matters worse,
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`Mr. Mitschele’s testimony contradicted Mr. Chandler’s opinion because he agreed that
`Touchstream provided a “ software license surrounding our casting product” to Quadriga —not a
`license to use patented technology. Dkt. 313 at 9.4
`As for Touchstream’s attempt to backfill using inventor testimony and its Memorandum of
`Understanding (“MOU”) with Quadriga, Google already explained that Mr. Chandler did not rely
`on this evidence and it thus cannot save his opinion. See Dkt. 313 at 10. EcoFactor held that, in
`its gatekeeping role, “a court examines the evidence on which the expert purports to rely .” 137
`F.4th at 1345. Because Mr. Chandler did not rely on the inventor testimony and the MOU, they
`are not “relevant to the inquiry at hand.” Id. Besides, as Google has explained, “Touchstream’s
`attempted use of the MOU is belied by the plain language of the Quadriga agreement,” which
`“expressly stated that it ‘terminate[d]’ and ‘replaced’ the MOU, PTX-567.0009, and ‘constitute[d]
`the whole agreement between the Parties and supersede[d] any previous arrangement,
`understanding or agreement between’ Touchstream and Quadr iga.” Dkt. 313 at 10 n.1 (quoting
`PTX-567.0030). Touchstream never addresses the Quadriga agreement language that directly
`contradicts its MOU argument. Touchstream’s attempted use of Mr. Strober’s testimony fares no
`better. At best, his testimony wa s just like Mr. Mitschele’s —“an unsupported assertion from an
`interested party.” EcoFactor, 137 F.4th at 1344.
`Touchstream additionally invokes the trial testimony of Google’s damages expert,
`Christopher Martinez. But this effort fails for similar reasons: Mr. Chandler did not rely on Mr.
`Martinez’s testimony in forming his opinion, rendering it irrelevant to the admissibility analysis.
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`4 In a footnote, Touchstream argues that Google “contradicts itself by relying” on Mr. Mitschele’s
`self-serving testimony while “urg[ing] the Court to ignore” any evidence on which Mr. Chandler
`did not rely. Dkt. 320 at 9 n.2. This argument is bizarre. A s discussed, Google does not dispute
`that Mr. Chandler relied on Mr. Mitschele.
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`EcoFactor, 137 F.4th at 1345.
`Touchstream also contends (in a footnote) that Google ’s data-retention policy is “one of
`the reasons [the Quadriga] agreement is the best evidence for a starting point.” Dkt. 320 at 8 n.1.
`But the Court already rejected Touchstream’s attempt to inject this issue into the inquiry of whether
`Mr. Chandler’s testimony is admissible, precluding Mr. Chandler from testifying that he “didn’t
`get access to information during di scovery.” Dkt. 225 at 96:13- 97:18; see also id. at 152:8-11
`(ordering the same in granting Google’s motion in limine).
`c. Touchstream entirely sidesteps Google’s point that Mr. Chandler’s unsupported
`“discounts” “compounded his improper adoption of the unreliable $0.48 rate” because they we re
`also based on insufficient facts or data. Dkt. 313 at 8; see also Dkt. 320 at 7 (Touchstream briefly
`mentioning, but not defending, the discounts). As Google detailed, under EcoFactor these
`so-called “discounts” also have “[n]o factual basis” and likewise violate Rule 702’s admissibility
`requirements. Dkt. 313 at 8. This error is further reason that Mr. Chandler’s testimony is
`inadmissible.
`d. Finally, citing three out -of-circuit cases, Touchstream suggests this Court has
`discretion to prioritize “finality and speedy adjudication of disputes” over reconsideration to
`correct clear error and apply new and relevant law to a case still pending befo re it. See Dkt. 320
`at 3-4, 6-7. That is not what Touchstream’s cases say. Two merely recognize that, given the
`interest in finality and Federal Rule of Civil Procedure 1, the bases on which reconsideration will
`be granted are limited —but nevertheless include a “change in controlling law” and a need “to
`correct a clear error of law.” Sovereign Bank v. Catterton, 2004 WL 1166591, at *2 (E.D. Pa. May
`20, 2004); accord Klee v. Lehigh Valley Hosp., 1998 WL 966011 (E.D. Pa. Nov. 30, 1998), aff’d
`mem., 203 F.3d 817 (3d Cir. 1999) . As Google has shown, both of those grounds for
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`reconsideration apply here. Dkt. 313 at 5- 11. As for Touchstream’s third case, that case had
`previously been before the appellate court, and on its second trip up, the court declined to
`“reconsider the legal issues resolved by the en banc court in 1976” —nine years earlier. See
`McSurely v. McClellan, 753 F.2d 88, 96 (D.C. Cir. 1985). No such circumstances exist here.
`B. The Court Should Hold A Hearing To Create A Record Suitable For Review
`Touchstream offers only two brief responses to Google’s separate request that the Court
`hold a hearing on its post -trial motions. The first is that “[t]he Court has already heard oral
`argument on these issues.” Dkt. 320 at 10. But this neither accurately portrays the record nor
`answers Google’s point. Touchstream cites the post -trial conference, but there was no argument
`on Google’s post-trial motions. See generally Dkt. 302. And although the Court heard argument
`on Google’s Daubert motion at the pretrial conference, Touchstream ignores that the Court’s oral
`ruling denying Google’s motion did not supply any reasoning as to why it viewed the bases of
`Mr. Chandler’s opinion as satisfying Rule 702. Touchstream also ignores that the Court made that
`ruling before the en banc Federal Circuit decided EcoFactor . As Google has explained, oral
`argument on Google’s motion for a new trial is warranted in light of EcoFactor ’s direct
`applicability to Google’s challenge to the admissibility of Mr. Chandler’s testimony, and, more
`broadly, oral argument on all of Google’s post -trial motions is warranted given EcoFactor ’s
`instruction that district courts should provide “reviewable reasoning.” 137 F.4th at 1338; see also
`Dkt. 313 at 11-12.
`Touchstream’s second response is that the Court has “indicated it would issue a written
`decision on Google’s post -trial motions,” which Touchstream says “will satisfy the Federal
`Circuit’s directive from EcoFactor.” Dkt. 320 at 10. This too is non- responsive. Touchstream
`again ignores that the Court never provided its reasoning (oral or written) for denying Google’s
`Daubert motion. And Touchstream fails to answer Google’s point that a hearing on the important
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`issues raised in its post-trial motions is critical for creating a record suitable for review. See Dkt.
`313 at 11-12.
`III. CONCLUSION
`The Court should reconsider its earlier orders finding Mr. Chandler’s damages opinion
`reliable and order a new trial. The Court should also hold a hearing on all of Google’s post -trial
`motions.
`
`Dated: July 9, 2025
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`Respectfully submitted,
` By:/s/ Michael E. Jones with permission for
` Tharan Gregory Lanier
`
`Michael C. Hendershot (admitted Pro Hac Vice)
`Tharan Gregory Lanier (admitted Pro Hac Vice)
`Evan M. McLean (admitted Pro Hac Vice)
`Gurneet Singh (admitted Pro Hac Vice)
`JONES DAY
`1755 Embarcadero Road
`Palo Alto, CA 94303
`(650) 739-3939
`Fax: (650) 739-3900
`mhendershot@jonesday.com
`tglanier@jonesday.com
`emclean@jonesday.com
`gsingh@jonesday.com
`
`Tracy Ann Stitt (admitted Pro Hac Vice)
`Jennifer L. Swize (admitted Pro Hac Vice)
`Edwin O. Garcia (admitted Pro Hac Vice)
`JONES DAY
`51 Louisiana NW
`Washington, DC 20001
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`John R. Boulé III
`CA State Bar No. 322929
`JONES DAY
`555 South Flower St.
`Fiftieth Floor
`Los Angeles, CA 90071
`(213) 489-3939
`jboule@jonesday.com
`
`Michael E. Jones
`TX State Bar No. 10929400
`E-mail: mikejones@potterminton.com
`Shaun W. Hassett
`TX State Bar No. 24074372
`E-mail: shaunhassett@potterminton.com
`POTTER MINTON PC
`102 N. College Ave., Suite 900
`Tyler, TX 75702
`Telephone: (903) 597-8311
`Facsimile: (903) 593-0846
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`Attorneys for Defendant Google LLC
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