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`EXHIBIT 8
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`Case 1:22-cv-22706-RNS Document 176-8 Entered on FLSD Docket 05/06/2023 Page 2 of 3
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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 CHRISTOPHER CLAYTON 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, Christopher Clayton, declare as follows:
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`1.
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`I am an attorney licensed to practice law and a member of good standing of the
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`Missouri State Bar and the Illinois State Bar. I am an associate with the Devlin Law Firm LLC,
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`and counsel of record for Plaintiff Bell Northern Research LLC (“Plaintiff”) in the above-entitled
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`action. I have personal knowledge of the matters set forth herein and if called, I could
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`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.
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`Case 1:22-cv-22706-RNS Document 176-8 Entered on FLSD Docket 05/06/2023 Page 3 of 3
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`3.
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`On October 3, 2022, I, along with co-counsel Jose I. Rojas, participated in a meet
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`and confer with counsel for Hon Hai Precision Industry Co., Ltd., Lisa K. Nguyen.
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`4.
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`At the outset of the meet and confer, I conveyed that BNR was open to hearing
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`Hon Hai’s position and receiving any information about Hon Hai’s intended motion to dismiss.
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`5.
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`Counsel for Hon Hai indicated that Hon Hai did not sell to Nokia, but did sell to
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`Foxconn International Holdings Mobile.
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`6.
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`7.
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`8.
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`Counsel for Hon Hai conveyed that Hon Hai had an office in California.
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`I requested a draft of Hon Hai’s motion.
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`Counsel for Hon Hai provided a non-committal response and that Hon Hai
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`intended to file its motion on October 24, 2022.
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`9.
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`In response to Hon Hai’s counsel, I indicated that we would see Hon Hai’s motion
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`papers after filing.
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`10.
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`I was involved in conducting a pre-suit investigation regarding the defendants of
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`this case including Hon Hai and reviewed the following public websites prior to BNR filing its
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`first case against Hon Hai:
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`https://asia.nikkei.com/Business/Nokia-brand-returns-under-Foxconn;
`https://www.cdrinfo.com/d7/content/nokia-phones-reborn-india-next-year-hon-hai-manufacture-
`them;
`https://www.prnewswire.com/news-releases/hmd-global-founded-to-create-new-generation-of-
`nokia-branded-mobile-phones-and-tablets-579916811.html
`https://www.foxconn.com/en-us/about/worldwide.
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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/ Christopher Clayton
`Christopher Clayton
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`2
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