`Case 1:12-cv-00574-LPS Document 264-1 Filed 12/04/15 Page 1 of 3 PageID #: 9208
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`EXHIBIT 1
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`EXHIBIT 1
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`Case 1:12-cv-00574-LPS Document 264-1 Filed 12/04/15 Page 2 of 3 PageID #: 9209
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`IN THE UNITED STATES DISTRICT COURT
`FOR THE DISTRICT OF DELAWARE
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`C.A. No. 12-574-LPS
`(consolidated)
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`JURY TRIAL DEMANDED
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`Plaintiff,
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`v.
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`Defendants.
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`ROBERT BOSCH LLC,
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`ALBEREE PRODUCTS, INC.,
`API KOREA CO., LTD.,
`SAVER AUTOMOTIVE PRODUCTS, INC.,
`AND COSTCO WHOLESALE CORPORATION,
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`COSTCO WHOLESALE CORPORATION,
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`ROBERT BOSCH GMBH,
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`Third-Party Plaintiff,
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`v.
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`Third-Party Defendant.
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`DECLARATION OF BETTINA HOLZWARTH
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`I, Bettina Holzwarth, declare as follows:
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`1.
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`I am a citizen of Germany and am over 18 years of age. I am employed as the
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`Deputy Group General Counsel with Robert Bosch GmbH (“Bosch GmbH”). I have held this
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`position since 2009. Through my position and experience with Bosch I have personal knowledge
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`of the statements in this declaration, or make them upon information and belief after appropriate
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`investigation. I am authorized to make this declaration on behalf of Bosch GmbH.
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`2.
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`Bosch GmbH is a limited liability company authorized and organized under the
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`laws of Germany. It has its headquarters in Gerlingen, Germany.
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`1
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`Case 1:12-cv-00574-LPS Document 264-1 Filed 12/04/15 Page 3 of 3 PageID #: 9210
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`3.
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`Bosch GmbH is a separate company from Robert Bosch LLC ("Bosch LLC").
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`Bosch GmbH is Bosch LLC's parent corporation, but Bosch GmbH does not directly own any
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`interest in Bosch LLC; Bosch LLC is an indirect subsidiary of Bosch GmbH.
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`4.
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`Bosch GmbH has its own employees that are separate from the employees of
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`Bosch LLC. Bosch GmbH maintains its own corporate records that are separate from the
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`corporate records of Bosch LLC. With the exception of Dr. Werner Struth, who is the chairman
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`of Bosch LLC and also a member of the management board for Bosch GmbH, the members of
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`the board of management of Bosch GmbH are separate from the board of directors of Bosch LLC.
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`5.
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`Bosch GmbH is not registered to do business in the State of Delaware. Bosch
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`GmbH does not own or maintain any offices or facilities in the State of Delaware. Bosch GmbH
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`does not maintain a post office box or other address, a phone number, or a fax number in the
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`State of Delaware. No member of Bosch GmbH's Board of Directors resides in the State of
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`Delaware.
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`6.
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`Bosch GmbH is not required to and does not maintain a registered agent for
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`service of process in the State of Delaware.
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`7.
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`Bosch GmbH does not maintain a bank account in the State of Delaware. Bosch
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`GmbH has not received a loan of money in the State of Delaware.
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`8.
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`9.
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`Bosch GmbH does not possess any real property in Delaware.
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`Bosch GmbH does not engage in any regular and systematic sale of products into
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`the State of Delaware.
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`I declare under penalty of perjury under the laws ofthe United States that the foregoing is
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`true and correct.
`Executed on: December 3 , 2015
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`Bettina Holzwarth
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`2
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