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`LATHAM & WATKINS LLP
` Bradley A. Hyde (Bar No. 301145)
`bradley.hyde@lw.com
`650 Town Center Drive - 20th Floor
`Costa Mesa, California 92626-1925
`Telephone: (714) 540-1235
`Facsimile: (714) 755-8290
`
`LATHAM & WATKINS LLP
` Charles H. Sanders (pro hac vice)
`charles.sanders@lw.com
` Anant K. Saraswat (pro hac vice)
`anant.saraswat@lw.com
`200 Clarendon Street
`Boston, Massachusetts 02116
`Telephone: (617) 948-6000
`Facsimile: (617) 948-6001
`
`LATHAM & WATKINS LLP
` Lesley M. Hamming (pro hac vice)
`lesley.hamming@lw.com
`LATHAM & WATKINS LLP
`330 N. Wabash Avenue, Suite 2800
`Chicago, Illinois 60611
`Telephone: (312) 876-7700
`Facsimile: (312) 993-9767
`
`Attorneys for Defendants SEOUL
`SEMICONDUCTOR CO., LTD and
`SEOUL SEMICONDUCTOR, INC.
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`UNITED STATES DISTRICT COURT
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`CENTRAL DISTRICT OF CALIFORNIA
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`SOUTHERN DIVISION
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`Case No. 8:17-cv-00981-JVS-JCG
`
`DECLARATION OF BRADLEY A. HYDE
`IN SUPPORT OF DEFENDANTS’ MOTION
`TO DISMISS PLAINTIFF’S RESTATED
`WILLFUL INFRINGEMENT CLAIM
`
`Judge: Honorable James V. Selna
`Date: February 5, 2018
`Time: 1:30 pm
`Courtroom: 10C
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`DOCUMENT SECURITY SYSTEMS,
`INC., a New York corporation,
`
`
`Plaintiff,
`
`v.
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`SEOUL SEMICONDUCTOR CO.,
`LTD, a Korean corporation, and
`SEOUL SEMICONDUCTOR, INC., a
`California corporation,
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`Defendants.
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`AT T ORNEYS AT L AW
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`CASE NO. 8:17-cv-00981-JVS-JCG
`DECL. OF B. HYDE ISO SEOUL’S MOTION TO
`DISMISS
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`Case 8:17-cv-00981-JVS-JCG Document 45-2 Filed 12/04/17 Page 2 of 3 Page ID #:755
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`I, Bradley A. Hyde, declare as follows:
`1.
`I am an attorney at the law firm of Latham & Watkins LLP and am
`counsel of record for Seoul Semiconductor Co., Ltd. (“SSC”) and Seoul
`Semiconductor, Inc. (“SSI”) (collectively, “Seoul” or “Defendants”) in this matter.
`2.
`I submit this declaration in support of Defendants’ Motion to Dismiss
`Plaintiff’s Restated Willfulness Claim.
`3.
`This declaration is based on my personal knowledge of the facts stated
`below and, if called upon as a witness, I would testify competently to them based
`on such personal knowledge.
`4. Attached hereto as Exhibit A is a true and correct copy of the Second
`Amended Complaint for Patent Infringement (Dkt. No. 40).
`5. Attached hereto as Exhibit B is a true and correct copy of the First
`Amended Complaint (Dkt. No. 18).
`6. Attached hereto as Exhibit C is a true and correct copy of the Order
`Regarding Motion to Dismiss (Dkt. No. 36-1).
`7. Attached hereto as Exhibit D is a true and correct copy of Defendants’
`Notice of Motion and Motion to Dismiss the First Amended Complaint Second
`Amended Complaint (Dkt. No. 23).
`8. Attached hereto as Exhibit E is a true and correct copy of Plaintiff’s
`Opposition to Defendants’ Motion to Dismiss the First Amended Complaint (Dkt.
`No. 29).
`9. Attached hereto as Exhibit F is a true and correct copy of the
`Defendants’ Reply Memorandum of Law in Support of Their Motion to Dismiss
`the First Amended Complaint (Dkt. No. 30).
`10. Attached hereto as Exhibit G is a true and correct copy of the Order
`Granting in Part and Denying in Part Defendants’ Motion to Dismiss First
`Amended Complaint (Dkt. No. 36).
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`CASE NO. 8:17-cv-00981-JVS-JCG
`DECL. OF B. HYDE ISO SEOUL’S MOTION TO
`DISMISS
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`Case 8:17-cv-00981-JVS-JCG Document 45-2 Filed 12/04/17 Page 3 of 3 Page ID #:756
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`I declare under penalty of perjury under the laws of the United States that
`the foregoing is true and correct. Executed this 4th day of December, 2017.
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`/s/Bradley A. Hyde
`Bradley A. Hyde
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`CASE NO. 8:17-cv-00981-JVS-JCG
`DECL. OF B. HYDE ISO SEOUL’S MOTION TO
`DISMISS
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