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`IN THE UNITED STATES DISTRICT COURT
`FOR THE DISTRICT OF DELAWARE
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`GODO KAISHA IP BRIDGE 1,
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`Plaintiff,
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`v.
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`OMNIVISION TECHNOLOGIES, INC., §
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`Defendant.
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`PLAINTIFF’S RESPONSE TO DEFENDANT OMNIVISION
`TECHNOLOGIES, INC.’S STATEMENT PURSUANT TO FED. R. CIV. P. 7.1
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`CIVIL ACTION NO. 1:16-cv-00290-SLR
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`JURY TRIAL DEMANDED
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`The disclosure statement
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`filed by Defendant OmniVision Technologies,
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`Inc.
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`(“OmniVision”) does not comply with Federal Rule of Civil Procedure 7.1 because it fails to
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`“identif[y] any parent corporation … owning 10% or more of its stock” (emphasis added).
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`Defendant OmniVision’s Rule 7.1. disclosure identifies only “that it is a wholly-owned
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`subsidiary of Seagull International Limited.” D.I. 9.
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`Defendant OmniVision does not disclose ownership by Hua Capital Management Co.,
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`Ltd. (“Hua Capital”), CITIC Capital Holdings Limited (“CITIC”), and Goldstone Investment
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`Co., Ltd. (“Goldstone”). In a press release, Defendant OmniVision stated that Hua Capital,
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`CITIC, and Goldstone had completed their acquisition of all publicly traded OmniVision stock as
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`of January 28, 2016. See Exhibit A. Defendant OmniVision’s admission is corroborated by
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`similar press releases by Hua Capital and CITIC. See Exhibits B and C.
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`Moreover, Defendant OmniVision does not disclose ownership by Shanghai Pudong
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`Science & Technology Investment Co., Ltd. (“Shanghai Pudong”), a Chinese government-owned
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`enterprise that exercises its investment in OmniVision through Hua Capital. See Exhibits D
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`and E.
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`Case 1:16-cv-00290-MN Document 15 Filed 05/26/16 Page 2 of 3 PageID #: 734
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`Thus OmniVision’s Rule 7.1 disclosure should have identified Hua Capital, CITIC,
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`Goldstone, and Shanghai Pudong as corporate parents and should have revealed Seagull
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`International Limited as merely the shell holding company through which the corporate parents
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`own OmniVision.
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`Dated: May 26, 2016
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`STAMOULIS & WEINBLATT LLC
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` /s/ Stamatios Stamoulis
`Stamatios Stamoulis (#4606)
`stamoulis@swdelaw.com
`Richard C. Weinblatt (#5080)
`weinblatt@swdelaw.com
`Two Fox Point Centre
`6 Denny Road, Suite 307
`Wilmington, Delaware 19809
`Telephone: (302) 999-1540
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`Michael W. Shore (pro hac vice)
`mshore@shorechan.com
`Alfonso Garcia Chan (pro hac vice)
`achan@shorechan.com
`Joseph F. DePumpo (pro hac vice)
`jdepumpo@shorechan.com
`Jennifer M. Rynell (pro hac vice)
`jrynell@shorechan.com
`Ari Rafilson (pro hac vice)
`arafilson@shorechan.com
`Russell J. DePalma (pro hac vice)
`rdepalma@shorechan.com
`SHORE CHAN DEPUMPO LLP
`901 Main Street, Suite 3300
`Dallas, Texas 75202
`Telephone:
`(214) 593-9110
`Facsimile:
`(214) 593-9111
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`Attorneys for Plaintiff Godo Kaisha IP Bridge 1
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`Case 1:16-cv-00290-MN Document 15 Filed 05/26/16 Page 3 of 3 PageID #: 735
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`CERTIFICATE OF SERVICE
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`I hereby certify that on May 26, 2016, I electronically filed the foregoing document with
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`the Clerk of Court using the CM/ECF system which will send notification of such filing via
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`electronic mail to all counsel of record.
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`/s/ Stamatios Stamoulis
`Stamatios Stamoulis #4606
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