`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`Exhibit A
`
`
`
`Case 1:22-cv-22706-RNS Document 163-1 Entered on FLSD Docket 04/07/2023 Page 2 of 4
`
`IN THE UNITED STATES DISTRICT COTIRT
`FOR THE SOUTHERN DISTRICT OF FLORIDA
`
`Case No. l:22-CY -22706-RNS
`
`BELL NORTHERN RESEARCH, LLC,
`
`Plaintiff,
`
`v
`
`HMD AMERICA, fI.{C., HMD GLOBAL OY,
`SHENZHEN CHIINO-E COMMLINICATION
`CO. LTD., HON HAI PRECISION
`INDUSTRY CO., LTD, TINNO MOBILE
`TECHNOLOGY CORP., SHENZHEN TINNO
`MOBILE CO., LTD., TINNO USA, INC.,
`LINISOC TECHNOLOGIES CO. LTD.,
`SPREADTRUM COMMTINICATIONS USA,
`fNC., WINGTECH TECHNOLOGY CO. L
`WINGTECH INTERNATIONAL, INC.,
`HUAQIN CO. LTD., BEST BUY CO., rNC.,
`BEST BUY STORES L.P., TARGET CORP.,
`WALMART INC.,
`
`Defendants.
`
`DECLARATION OF THEODORE ANGELIS IN SUPPORT OF HON HAI PRECISION
`INDUSTRY CO., LTD'S MOTION FOR EXCEPTIONAL CASE STATUS
`
`I, Theodore Angelis, submit the following declaration in support of Hon Hai Precision
`
`Industry Co., LTD's ("Hon Hai") Motion for Exceptional Case Status:
`1.
`
`I am more than eighteen (18) years of age. I am fully competent to make this
`
`declaration. I have personal knowledge of the facts below, and would testify to such facts under
`
`oath if asked to do so.
`2.
`
`As a partner with the law firm K&L Gates LLP, I represented Hon Hai Precision
`
`Industry Co., Ltd. ("Hon Hai") in the previous lawsuit on the same patents, i.e., Bell Northern
`
`506527184.1
`
`
`
`Case 1:22-cv-22706-RNS Document 163-1 Entered on FLSD Docket 04/07/2023 Page 3 of 4
`
`Research, LLC v. HMD America, Inc., et a/., No. 22-cv-21035. On May 10, 2022 at 11:11 PM, I
`
`contacted Bell Northern Research LLC ("BNR") by sending an email to Paul Richter
`
`(prichter@devlinlawfirm.com) to request a teleconference, believing that BNR might drop Hon
`
`Hai from the lawsuit if it understood that Hon Hai does not manufacture Nokia phones or tablets.
`
`On May I1,2022,I spoke with Paul Richter for the first time.
`3.
`
`During the teleconference on May 11, 2022, I informed Mr. fuchter that Hon Hai
`
`does not manufacture Nokia phones or tablets. Mr. Richter asked me to provide an email
`
`explaining that Hon Hai does not manufacture the accused Nokia devices (made by HMD). During
`
`the call, BNR did not refute that fact or provide an explanation for the allegations against Hon Hai.
`
`On May 12,2022 at 2:06 PM, I sent the requested email to Paul Richter proposing the dismissal
`
`of Hon Hai without prejudice on the basis that it does not manufacture the accused devices.
`4.
`
`On June 27,2022 at 5:13 PM, I sent an email to Paul Richter and Chris Clayton
`
`(cclal.ton@devlinlawfirm.com) reiterating that Hon Hai does not manufacture the accused devices
`
`and should be dismissed. BNR did not respond to that email.
`
`5.
`
`On August 10,2022,I followed up on the previous email by sending another email
`
`to Paul Richter and Chds Clayton, stating that Hon Hai does not manufacture the accused devices
`
`and should be dismissed.
`6.
`
`On August 12,2022,I spoke with Paul Richter by teleconference, stating that Hon
`
`Hai should be dismissed because it does not manufacture the accused devices. Mr. Richter did not
`
`refute that fact or provide an explanation for the allegations against Hon Hai..
`7. On August 23,2022 at 1:00 PM, I spoke with Paul Richter by teleconference,
`
`providing fi.rther detail on the need for dismissal of Hon Hai because it does not manufacture the
`
`5065271 84.1
`
`2
`
`
`
`Case 1:22-cv-22706-RNS Document 163-1 Entered on FLSD Docket 04/07/2023 Page 4 of 4
`
`accused devices. Mr. Richter did not refute that fact or provide an explanation for the allegations
`
`against Hon Hai..
`
`I declare under penalty of perjury under the laws of the United States of America that the
`foregoing is true and correct. Executed on 114<*h Ql
`
`2023 it Seattle, Washington.
`
`Angelis
`
`5065271 84.1
`
`J
`
`
Accessing this document will incur an additional charge of $.
After purchase, you can access this document again without charge.
Accept $ Charge
Still Working On It
This document is taking longer than usual to download. This can happen if we need to contact the court directly to obtain the document and their servers are running slowly.
Give it another minute or two to complete, and then try the refresh button.
A few More Minutes ... Still Working
It can take up to 5 minutes for us to download a document if the court servers are running slowly.
Thank you for your continued patience.
This document could not be displayed.
We could not find this document within its docket. Please go back to the docket page and check the link. If that does not work, go back to the docket and refresh it to pull the newest information.
Your account does not support viewing this document.
You need a Paid Account to view this document. Click here to change your account type.
Your account does not support viewing this document.
Set your membership
status to view this document.
With a Docket Alarm membership, you'll
get a whole lot more, including:
- Up-to-date information for this case.
- Email alerts whenever there is an update.
- Full text search for other cases.
- Get email alerts whenever a new case matches your search.
One Moment Please
The filing “” is large (MB) and is being downloaded.
Please refresh this page in a few minutes to see if the filing has been downloaded. The filing will also be emailed to you when the download completes.
Your document is on its way!
If you do not receive the document in five minutes, contact support at support@docketalarm.com.
Sealed Document
We are unable to display this document, it may be under a court ordered seal.
If you have proper credentials to access the file, you may proceed directly to the court's system using your government issued username and password.
Access Government Site
