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`EXHIBIT 13
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`Case 1:22-cv-22706-RNS Document 176-13 Entered on FLSD Docket 05/06/2023 Page 2 of 4
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`IN THE UNITED STATES DISTRICT COURT
`FOR THE SOUTHERN DISTRICT OF FLORIDA
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`Case No. 1:22-cv-22706-RNS
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`BELL NORTHERN RESEARCH, LLC,
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`Plaintiff
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`v.
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`HMD AMERICA, INC.; HMD GLOBAL OY;
`SHENZHEN CHINO-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.; BEST BUY CO., INC.; BEST BUY
`STORES L.P.; TARGET CORP.; WALMART
`INC.,
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`Defendants.
`_______________________________________
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`JURY TRIAL DEMANDED
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`DECLARATION OF PAUL RICHTER IN SUPPORT OF BELL NORTHERN
`RESEARCH LLC’S OPPOSITION TO DEFENDANT HON HAI PRECISION
`INDUSTRY CO., LTD’S MOTION FOR EXCEPTIONAL CASE STATUS
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`I, Paul Richter, declare as follows:
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`1.
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`I am an attorney licensed to practice law and a member in good standing of the
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`New York State Bar. I am a partner with the Devlin Law Firm LLC, and counsel of record for
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`Plaintiff Bell Northern Research LLC (“Plaintiff”) in the above-entitled action. I have personal
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`knowledge of the matters set forth herein and if called, I could competently testify thereto.
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`2.
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`I make this declaration in support of Plaintiff’s Opposition to Defendant Hon Hai
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`Precision Industry Co., Ltd’s Motion for Exceptional Case Status, and I have read that Hon Hai
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`motion and the declarations associated therewith.
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`Case 1:22-cv-22706-RNS Document 176-13 Entered on FLSD Docket 05/06/2023 Page 3 of 4
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`3.
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`The first Complaint against Hon Hai was filed on April 6, 2022 as Bell Northern
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`Research, LLC, No. 1:22-cv-21035-RNS, Dkt. 1 (S.D. Fla. April 6, 2022.) About a month after
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`that -21035 case was filed, I was contacted by counsel for Hon Hai (Mr. Theodore Angelis) and
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`we communicated three times over the phone and several times via email from May 11 until
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`August 24, 2022, as reflected in the email string attached as Ex. 6 to BNR’s opposition brief.
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`4.
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`Part of the foregoing communications were to arrange a 90-day extension on May
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`20 for Hon Hai to respond to the first Complaint in exchange for waiving service, taking its
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`response date to the end of August, 2022. (Ex. 6 at 4–5.)
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`5.
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`During each of the foregoing telephone and email communications, counsel for
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`Hon Hai never raised an issue of alleged lack of personal jurisdiction over Hon Hai in this Court.
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`Rather, counsel for Hon Hai indicated that Hon Hai did not manufacture the accused devices for
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`HMD (another defendant) and should be dismissed for that reason. (Ex. 6 at 1, 6.) However,
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`counsel for Hon Hai never offered any evidence of Hon Hai’s supposed non-involvement in
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`making the accused products, such as a declaration from Hon Hai.
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`6.
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`Just prior to the extended due date for Hon Hai to respond to the first Complaint,
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`on August 25, 2022, the -21035 case was dismissed without prejudice by BNR as against all of
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`the named defendants in that case (including Hon Hai). Bell Northern Research, LLC, No. 1:22-
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`cv-21035-RNS, Dkt. 55 (S.D. Fla. Aug. 25, 2022.)
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`7.
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`BNR’s reasons for dismissing the first Complaint had nothing to do with Hon
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`Hai’s counsel’s foregoing statements.
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`8.
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` Since the filing of the first Complaint on April 6, 2022, BNR has stood by and
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`continues to stand by its infringement allegations as against Hon Hai in the first Complaint in the
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`2
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`Case 1:22-cv-22706-RNS Document 176-13 Entered on FLSD Docket 05/06/2023 Page 4 of 4
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`-21305 action, dismissed without prejudice, and in this case (also dismissed without prejudice)
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`that included those same allegations against the same products and some additional products.
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`I declare under penalty of perjury under the laws of the United States the foregoing is true
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`and correct.
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`Executed this 5th day of May, 2023,
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`/s/ Paul Richter
`Paul Richter
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`3
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