`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE EASTERN DISTRICT OF TEXAS
`MARSHALL DIVISION
`
`ALACRITECH, INC. A California corporation,
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`Plaintiff,
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`v.
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`DELL INC., a Delaware corporation,
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`Defendants.
`
`Case No. 2:16-cv-693
`(Lead Case)
`JURY TRIAL DEMANDED
`
`DECLARATION OF S. CHRISTOPHER KYRIACOU
`
`1.
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`I am an attorney in the Litigation Group at Intel Corporation (“Intel”). I submit
`
`this declaration in support of Intel’s Motion to Intervene in this case. I have personal knowledge
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`of the facts stated below and, if called upon to do so, would testify competently thereto.
`
`2.
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`Defendant Dell Inc. (Dell) has asked that Intel indemnify, defend, and hold it
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`harmless from Alacritech Inc.’s (“Alacritech”) claims in this action concerning Intel products,
`
`based on an indemnity agreement relating to Dell’s purchases of Intel products.
`
`3.
`
`Based on the nature of the claims at issue in this suit, Intel has agreed to defend
`
`and partially indemnify Dell against Alacritech’s allegations against Dell products with Ethernet
`
`controllers provided by Intel.
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`I declare under penalty of perjury of the laws of the United States that the foregoing is
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`true and correct.
`
`1
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`Alacritech Ex. 2054, Page 1
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`
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`Case 2:16-cv-00693-JRG-RSP Document 71-5 Filed 10/31/16 Page 2 of 2 PageID #: 1800
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`Dated: October 27, 2016
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`S. Christopher Kyriacou
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`_________
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`2
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`Alacritech Ex. 2054, Page 2
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`
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