`
`IN UNITED STATES DISTRICT COURT
`FOR THE SOUTHERN DISTRICT OF FLORIDA
`
`Case No. 1:22-cv-22706-RNS
`
`
`
`BELL NORTHERN RESEARCH, LLC,
`
`Plaintiff,
`
` v.
`
`HMD AMERICA, INC., HMD GLOBAL OY,
`SHENZHEN CHINO-E COMMUNICATION
`CO. LTD., HON HAI PRECISION
`INDUSTRY CO., LTD, TINNO MOBILE
`CORP., SHENZHEN TINNO MOBILE CO., LTD.,
`UNISOC TECHNOLOGIES CO.
`LTD., SPREADTRUM COMMUNICATIONS USA,
`INC., WINGTECH TECHNOLOGY CO.,
`LTD., WINTECH INTERNATIONAL, INC.,
`HUAQIN CO. LTD., BEST BUY CO., INC., BEST
`BUY STORES L.P., TARGET CORP., WALMART
`INC.,
`
`Defendants.
`
`DECLARATION OF ZHANG ZHEN
`
`I, ZHANG Zhen, declare as follow:
`
`1.
`
`I serve as Vice President of Unisoc (Shanghai) Technologies Co., Ltd.
`
`(“Unisoc”).
`
`2.
`
`I am knowledgeable about the facts within this declaration based on personal
`
`knowledge and investigation.
`
`China.
`
`3.
`
`4.
`
`Unisoc is a corporation organized under the laws of the People’s Republic of
`
`Unisoc’s principal place of business is Building 1, Zhanxun Center, Lane 2288,
`
`Zuchongzhi Road, Pudong New Area, Shanghai, China.
`
`5.
`
`Unisoc does not develop, design, manufacture, advertise, market, sell, import, or
`
`distribute products in the United States.
`
`
`
`Case 1:22-cv-22706-RNS Document 91-1 Entered on FLSD Docket 12/19/2022 Page 2 of 5
`
`6.
`
`7.
`
`Unisoc does not provide any post-sales service or support in the United States.
`
`Unisoc has no distributor in the United States for its products and has established
`
`no distribution channel in the United States.
`
`8.
`
`Unisoc is not registered to conduct business in Florida or any other state in the
`
`United States. Unisoc has no employees in the United States.
`
`9.
`
`10.
`
`Unisoc does not own or lease any real or personal property in the United States.
`
`Unisoc does not maintain a bank account in the United States and does not pay
`
`taxes in the United States.
`
`11.
`
`Customers may incorporate Unisoc’s chipsets in downstream products (e.g.,
`
`mobile phones and tablets) and sell such downstream products in China or elsewhere in the
`
`world. Unisoc has no control over the incorporation of its chipsets into any downstream products
`
`and has no control over the distribution or sale of the downstream products. The manufacturers
`
`of downstream products have no obligations to inform Unisoc of the sales of downstream
`
`products.
`
`12.
`
`Unisoc does not specifically design its chipsets to meet the requirements of the
`
`market of United States.
`
` declare under penalty of perjury under the laws of the United States of America that the
`
`
`
` I
`
`foregoing is true and correct.
`
`
`
`Executed on December 15, 2022
`
`______[Signature: ZHANG Zhen]__________
`ZHANG Zhen
`
`2
`
`
`
`Case 1:22-cv-22706-RNS Document 91-1 Entered on FLSD Docket 12/19/2022 Page 3 of 5
`
`Acta Chinese Language Services, LLC
`www.actalanguage.com | (202)618-2307 | info@actalanguage.com | Gaithersburg, MD
`
`
`
`
`
`
`CERTIFICATE OF ACCURACY
`
`
`
`I, Evelyn Garland, am competent to translate from English into Chinese and Chinese into
`English, and certify that the English language document, Declaration of ZHANG Zhen, is a
`true and accurate translation of the Chinese language document, and vice versa, to the best of
`my abilities.
`
`
`
`
`
`
`
`
`Date: December 15, 2022
`
`
`Evelyn Yang Garland
`
`ATA Certified Translator, English<->Chinese
`Maryland Court Certified Interpreter, English<->Mandarin
`Chinese
`
`
`President
`Acta Chinese Language Services, LLC
`
`PO Box 3884
`Gaithersburg, MD 20885
`egarland@actalanguage.com, (202) 618-2307
`www.actalanguage.com
`
`
`
`
`
`
`
`
`Case 1:22-cv-22706-RNS Document 91-1 Entered on FLSD Docket 12/19/2022 Page 4 of 5
`
`
`
`Case 1:22-cv-22706-RNS Document 91-1 Entered on FLSD Docket 12/19/2022 Page 5 of 5
`
`
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