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`DARIN SNYDER (CA S.B. #136003)
`dsnyder@omm.com
`LUANN L. SIMMONS (CA S.B. #203526)
`lsimmons@omm.com
`MARK LIANG (CA S.B. #278487)
`mliang@omm.com
`BILL TRAC (CA S.B. #281437)
`btrac@omm.com
`AMY LIANG (CA S.B. #291910)
`aliang@omm.com
`SORIN ZAHARIA (CA S.B. #312655)
`szaharia@omm.com
`DANIEL SILVERMAN (CA S.B. #319874)
`dsilverman@omm.com
`O’MELVENY & MYERS LLP
`Two Embarcadero Center, 28th Floor
`San Francisco, California 94111-3823
`Telephone:
`+1 415 984 8700
`
`Attorneys for Plaintiff
`Google LLC
`
`
`UNITED STATES DISTRICT COURT
`NORTHERN DISTRICT OF CALIFORNIA
`SAN JOSE DIVISION
`
`GOOGLE LLC,
` Plaintiff,
`v.
`AGIS HOLDINGS, INC., ADVANCED
`GROUND INFORMATION SYSTEMS,
`INC., AND AGIS SOFTWARE
`DEVELOPMENT LLC,
`Defendants.
`
`Case No. 5:23-cv-03624-BLF
`DECLARATION OF MARK LIANG IN
`SUPPORT OF GOOGLE LLC’S
`OPPOSITION TO DEFENDANTS’
`MOTION TO DISMISS, OR IN THE
`ALTERNATIVE, TO TRANSFER
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`LIANG DECL. ISO GOOGLE OPPS TO
`MTD OR TRANSFER
`5:23-CV-03624-BLF
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`Case 5:23-cv-03624-BLF Document 54 Filed 12/29/23 Page 2 of 3
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`I, Mark Liang, hereby declare as follows.
`1.
`I am an attorney licensed to practice law before all courts of the State of California
`and in the Northern District, and I am a partner of O’Melveny & Myers LLP, counsel for Plaintiff
`Google LLC in this litigation. I have personal knowledge of the facts stated herein and if called
`to testify could and would competently testify thereto.
`Attached as Exhibit A is a true and correct copy of the document filed as ECF
`2.
`Document No. 268, in Target Training International, Inc., v. Extended Disc North America, Inc.,
`No. H-10-3550 (S.D. Tex.), dated June 1, 2015, and titled Final Judgment.
`Attached as Exhibit B is a true and correct copy of excerpts of idiCORE
`3.
`Comprehensive Report on Neil Siegel, dated December 18, 2023.
`Attached as Exhibit C is a true and correct copy of excerpts of Accurint
`4.
`Comprehensive Report on Richard Haney, dated December 18, 2023.
`Attached as Exhibit D is a true and correct copy of excerpts of Accurint
`5.
`Comprehensive Report on James Roskind, dated December 15, 2023.
`Attached as Exhibit E is a true and correct copy of excerpts of Accurint
`6.
`Comprehensive Report on Scott Forstall, dated December 15, 2023.
`Attached as Exhibit F is a true and correct copy of excerpts of Accurint
`7.
`Comprehensive Report on Imran Chaudhri, dated December 15, 2023.
`Attached as Exhibit G is a true and correct copy of excerpts of Accurint
`8.
`Comprehensive Report on Marcel van Os, dated December 15, 2023.
`Attached as Exhibit H is a true and correct copy of excerpts of Accurint
`9.
`Comprehensive Report on Stephen Lemay, dated December 15, 2023.
`Attached as Exhibit I is a true and correct copy of excerpts of Accurint
`10.
`Comprehensive Report on Patrick Coffman, dated December 15, 2023.
`Attached as Exhibit J is a true and correct copy of excerpts of Accurint
`11.
`Comprehensive Report on Elizabeth Furches, dated December 15, 2023.
`Attached as Exhibit K is a true and correct copy of excerpts of Accurint
`12.
`Comprehensive Report on Gregory Christie, dated December 15, 2023.
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`LIANG DECL. ISO GOOGLE OPPS TO
`MTD OR TRANSFER
`5:23-CV-03624-BLF
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`Case 5:23-cv-03624-BLF Document 54 Filed 12/29/23 Page 3 of 3
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`Attached as Exhibit L is a true and correct copy of excerpts of Accurint
`13.
`Comprehensive Report on Michael Matas, dated December 15, 2023.
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` I
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` declare under penalty of perjury under the laws of the United States of America that the
`foregoing is true and correct to the best of my knowledge. Executed this 29th day of December,
`2023 at San Francisco, California.
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`By: /s/ Mark Liang
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`Mark Liang
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`ZAHARIA DECL. ISO ADM. MOTION TO
`SEAL – NO. 5:22-CV-04826-BLF
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