`
`
`
`Alfred R. Fabricant
`afabricant@fabricantllp.com
`Peter Lambrianakos
`plambrianakos@fabricantllp.com
`Vincent J. Rubino, III
`vrubino@fabricantllp.com
`FABRICANT LLP
`411 Theodore Fremd Avenue, Suite 206 South
`Rye, New York 10580
`Telephone: (212) 257-5797
`Facsimile: (212) 257-5796
`
`Benjamin T. Wang
`bwang@raklaw.com
`Minna Y. Chan
`mchan@raklaw.com
`RUSS AUGUST & KABAT
`12424 Wilshire Boulevard, 12th Floor
`Los Angeles, California 90025
`Telephone: (310) 826-7474
`Facsimile: (310) 826-9226
`
`Attorneys for Defendant
`AGIS Software Development LLC
`
`
`UNITED STATES DISTRICT COURT
`
`NORTHERN DISTRICT OF CALIFORNIA
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`RUSS AUGUST & KABAT
`
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`Plaintiff,
`
`LYFT, INC.,
`
`
`
`
`v.
`
`
`AGIS SOFTWARE DEVELOPMENT LLC,
`
`
`Defendant.
`
` Case No. 5:21-cv-04653-BLF
`
`DECLARATION OF BENJAMIN T.
`WANG IN SUPPORT OF DEFENDANT
`AGIS SOFTWARE DEVELOPMENT
`LLC’S OPPOSED MOTION FOR LEAVE
`TO AMEND INFRINGEMENT
`CONTENTIONS PURSUANT TO
`PATENT LOCAL RULE 3-6
`
`Date: July 28, 2022
`Time: 9:00 A.M. PST
`Location: Courtroom 3
`Judge: Hon. Judge Beth Labson Freeman
`
`
`1
`DECLARATION OF BENJAMIN T. WANG
`
`
`
`5:21-cv-04653-BLF
`
`
`
`Case 5:21-cv-04653-BLF Document 84-1 Filed 04/01/22 Page 2 of 3
`
`
`
`I, Benjamin T. Wang, do hereby declare as follows:
`1.
`I am a partner at the law firm of Russ August & Kabat LLP. I submit this declaration
`in support of Defendant AGIS Software Development LLC’s (“AGIS Software” or “Defendant”)
`Opposed Motion for Leave to Amend Infringement Contentions Pursuant to Patent Local Rule 3-6.
`I am familiar with the facts set forth herein.
`2.
`Attached hereto as Exhibit A is a true and correct copy of AGIS Software’s
`Disclosure of Asserted Claims and Infringement Contentions, served on Lyft on February 25, 2022.
`3.
`Attached hereto as Exhibit B is a true and correct copy of Attachment A to AGIS
`Software’s Disclosure of Asserted Claims and Infringement Contentions, served on Lyft on
`February 25, 2022.
`4.
`Attached hereto as Exhibit C is a true and correct copy of Attachment B to AGIS
`Software’s Disclosure of Asserted Claims and Infringement Contentions, served on Lyft on
`February 25, 2022.
`5.
`Attached hereto as Exhibit D is a true and correct copy of Attachment C to AGIS
`Software’s Disclosure of Asserted Claims and Infringement Contentions, served on Lyft on
`February 25, 2022.
`6.
`Attached hereto as Exhibit E is a true and correct copy of Attachment D to AGIS
`Software’s Disclosure of Asserted Claims and Infringement Contentions, served on Lyft on
`February 25, 2022.
`7.
`Attached hereto as Exhibit F is a true and correct copy of Attachment E to AGIS
`Software’s Disclosure of Asserted Claims and Infringement Contentions, served on Lyft on
`February 25, 2022.
`8.
`Attached hereto as Exhibit G is a true and correct copy of AGIS Software’s proposed
`First Amended Disclosure of Asserted Claims and Infringement Contentions, served on Lyft on
`March 18, 2022.
`
`
`
`
`
`2
`DECLARATION OF BENJAMIN T. WANG
`
`
`
`5:21-cv-04653-BLF
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`RUSS AUGUST & KABAT
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`Case 5:21-cv-04653-BLF Document 84-1 Filed 04/01/22 Page 3 of 3
`
`
`
`9.
`Attached hereto as Exhibit H is a true and correct copy of Attachment A to AGIS
`Software’s proposed First Amended Disclosure of Asserted Claims and Infringement Contentions,
`served on Lyft on March 18, 2022.
`10.
`Attached hereto as Exhibit I is a true and correct copy of Attachment B to AGIS
`Software’s proposed First Amended Disclosure of Asserted Claims and Infringement Contentions,
`served on Lyft on March 18, 2022.
`11.
`Attached hereto as Exhibit J is a true and correct copy of Attachment C to AGIS
`Software’s proposed First Amended Disclosure of Asserted Claims and Infringement Contentions,
`served on Lyft on March 18, 2022.
`12.
`Attached hereto as Exhibit K is a true and correct copy of Attachment D to AGIS
`Software’s proposed First Amended Disclosure of Asserted Claims and Infringement Contentions,
`served on Lyft on March 18, 2022.
`13.
`Attached hereto as Exhibit L is a true and correct copy of Attachment E to AGIS
`Software’s proposed First Amended Disclosure of Asserted Claims and Infringement Contentions,
`served on Lyft on March 18, 2022.
`I declare under the penalty of perjury that the foregoing is true and correct. Executed on
`April 1, 2022 in Morgan Hill, California.
`
`
`
`
`
`_/s/ Benjamin T. Wang_______________
`Benjamin T. Wang, Declarant
`
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`3
`DECLARATION OF BENJAMIN T. WANG
`
`
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`5:21-cv-04653-BLF
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`RUSS AUGUST & KABAT
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