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`Exhibit B
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`Case 1:22-cv-22706-RNS Document 163-2 Entered on FLSD Docket 04/07/2023 Page 2 of 4
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`IN THE UNITED STATES DISTRICT COURT
`FOR THE SOUTHERN DISTRICT OF FLORIDA
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`BELL NORTHERN RESEARCH, LLC,
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`Plaintiff,
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`Case No. 1:22-CV-22706-RNS
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`
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`v.
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`HMD AMERICA, INC., HMD GLOBAL OY,
`SHENZHEN CHIINO-E COMMUNICATION
`CO. LTD., HON HAI PRECISION
`INDUSTRY CO., LTD, TINNO MOBILE
`TECHNOLOGY CORP., SHENZHEN TINNO
`MOBILE CO., LTD., TINNO USA, INC.,
`UNISOC TECHNOLOGIES CO. LTD.,
`SPREADTRUM COMMUNICATIONS USA,
`INC., WINGTECH TECHNOLOGY CO. LTD.,
`WINGTECH INTERNATIONAL, INC.,
`HUAQIN CO. LTD., BEST BUY CO., INC.,
`BEST BUY STORES L.P., TARGET CORP.,
`WALMART INC.,
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`Defendants.
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`DECLARATION OF LISA K. NGUYEN IN SUPPORT OF
`HON HAI PRECISION INDUSTRY CO., LTD’S
`MOTION FOR EXCEPTIONAL CASE STATUS
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`I, Lisa K. Nguyen, submit the following declaration in support of Hon Hai Precision
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`Industry Co., Ltd.’s (“Hon Hai”) Motion for Exceptional Case Status:
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`1.
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`I am more than eighteen (18) years of age. I am fully competent to make this
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`declaration. I have personal knowledge of the facts below, and would testify to such facts under
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`oath if asked to do so.
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`
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`Case 1:22-cv-22706-RNS Document 163-2 Entered on FLSD Docket 04/07/2023 Page 3 of 4
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`2.
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`I am a partner with the law firm Allen & Overy LLP, and I represent Hon Hai in
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`this matter. I have reviewed the complaint in this case, and oversaw the investigation into the
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`allegations therein. Based on the facts identified in that investigation, which are set forth in Hon
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`Hai’s Motion to Dismiss Based on Lack of Personal Jurisdiction (Dkt. No. 78), Allen & Overy
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`LLP determined that the Southern District of Florida lacked personal jurisdiction over Hon Hai.
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`On September 30, 2022, I requested a meet and confer with Bell Northern Research (“BNR”) to
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`discuss whether BNR would dismiss Hon Hai without motion practice.
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`3.
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`On October 3, 2022 at approximately 1:00 p.m. ET, I met and conferred with
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`Christopher Clayton and Jose Rojas, counsel for BNR, via Microsoft Teams meeting. I described
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`Hon Hai’s business and lack of presence in Florida. Specifically, I stated that Hon Hai does not
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`do business in Florida. I further stated that Hon Hai sells parts and services to FIH Mobile, not to
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`Nokia. Counsel for BNR asked whether any forum in the United States had jurisdiction over Hon
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`Hai. I responded that Hon Hai has an office located in California.
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`4.
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`It is my typical practice to offer to provide documentation establishing no personal
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`jurisdiction in the forum before filing a motion to dismiss. Consistent with that practice, during
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`the October 3 meet and confer with counsel for BNR, I offered to provide documentation to BNR
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`substantiating that Hon Hai has no relationship with Nokia, and that there is no personal
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`jurisdiction over Hon Hai in Florida. Further, I stated that Hon Hai would be open to discussing
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`these issues at any time before or even after we filed a motion to dismiss to avoid the expense to
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`the parties and the Court.
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`2
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`Case 1:22-cv-22706-RNS Document 163-2 Entered on FLSD Docket 04/07/2023 Page 4 of 4
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`5.
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`Counsel for BNR did not refute any facts that I provided during the call. Nor did
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`counsel for BNR provide any explanation for the allegations against Hon Hai or the basis for
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`jurisdiction. Counsel for BNR stated that it would wait to see Hon Hai’s motion papers.
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`6.
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`Approximately one hour after the meet and confer concluded, I emailed my
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`colleagues with a summary of the meet and confer. A true and correct copy of that email is attached
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`as Exhibit C.
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`I declare under penalty of perjury under the laws of the United States of America that the
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`foregoing is true and correct. Executed on March 28, 2023 in Palo Alto, CA.
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` Lisa K. Nguyen
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`3
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