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`EXHIBIT 9
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`Case 1:22-cv-22706-RNS Document 176-9 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 JOSE I. ROJAS 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, Jose I. Rojas, 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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`Florida Bar. I am managing partner of ROJASLAW, and counsel of record for Plaintiff Bell
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`Northern Research LLC (“BNR”) in the above-referenced action. I have personal knowledge of
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`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 (“Hon Hai”) Motion for Exceptional Case Status.
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`Case 1:22-cv-22706-RNS Document 176-9 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 Christopher Clayton, participated in
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`a meet 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, Mr. Clayton conveyed that BNR was open to
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`hearing Hon Hai’s position and receiving any information about Hon Hai’s intended motion to
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`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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`Mr. Clayton 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, Mr. Clayton indicated that we would see Hon
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`Hai’s motion papers after filing.
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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/ Jose I. Rojas
`Jose I. Rojas
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`2
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