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`IN THE UNITED STATES DISTRICT COURT
`FOR THE EASTERN DISTRICT OF TEXAS
`MARSHALL DIVISION
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`Plaintiff,
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`AGIS SOFTWARE DEVELOPMENT LLC,
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`v.
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`HUAWEI DEVICE USA INC., HUAWEI
`DEVICE CO., LTD. AND HUAWEI
`DEVICE (DONGGUAN) CO., LTD.,
`HTC CORPORATION,
`LG ELECTRONICS INC.,
`APPLE INC.,
`ZTE CORPORATION, ZTE (USA), INC.,
`AND ZTE (TX), INC.,
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`Defendants.
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`Civil Action No. 2:17-CV-513-JRG
`(Lead Case)
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`Civil Action No. 2:17-CV-514-JRG
`Civil Action No. 2:17-CV-515-JRG
`Civil Action No. 2:17-CV-516-JRG
`Civil Action No. 2:17-CV-517-JRG
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`DECLARATION OF JAMES BLACKBURN IN SUPPORT OF MOTION TO STAY
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`Case 2:17-cv-00513-JRG Document 102-1 Filed 03/22/18 Page 2 of 3 PageID #: 5116
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`I, James Blackburn, declare as follows:
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`1.
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`I am an attorney at the law firm of Arnold & Porter Kaye Scholer LLP, counsel
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`for Defendants Huawei Device USA Inc. (“Huawei USA”), Huawei Device Co., Ltd. (“Huawei
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`Device”), and Huawei Device (Dongguan) Co., Ltd. (“Huawei Dongguan”) (collectively, the
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`“Huawei”) and LG Electronics Inc. (“LGEKR”). I am a member of the Bar of the State of
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`California and have been admitted to practice in the United States District Court for the Eastern
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`District of Texas. I provide this declaration in support of Huawei’s and LGEKR’s motion to
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`stay. I have personal knowledge of the matters stated in this declaration and would testify
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`competently and truthfully to them if called upon to do so.
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`2.
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`I understand from counsel for Apple, HTC, and ZTE that none of the parties
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`oppose the instant Motion to Stay.
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`3.
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`On February 15, 2018, counsel for ZTE informed counsel for Apple, HTC,
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`Huawei, and LGEKR that AGIS had requested that all Defendants agree to the same Docket
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`Control Order. As a result, on February 21, 2018, AGIS, Huawei, and LGEKR jointly
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`requested that the Court amend the existing Docket Control Order to align it with the schedule
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`adopted in the HTC and ZTE litigations. Dkt. No. 87.
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`4.
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`On January 8, 2018, AGIS served first sets of interrogatories on both Huawei
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`and LGEKR. Huawei and LGEKR each answered on February 22, 2018, and are in the process
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`of collecting documents for production in response to the interrogatories.
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`5.
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`On January 16, 2018, AGIS served letters regarding “opening discovery” which
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`identified more than fifty categories of documents it expected Huawei and LGEKR to produce.
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`Huawei and LGEKR have completed their Patent L.R. 3-4 productions and are in the process of
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`identifying additional relevant documents for collection and production.
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`6.
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`On February 20, 2018, AGIS served notices of deposition pursuant to Rule
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`30(b)(6) on Huawei and LGEKR, which each identified at least sixty topics for deposition.
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`2
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`Case 2:17-cv-00513-JRG Document 102-1 Filed 03/22/18 Page 3 of 3 PageID #: 5117
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`Huawei and LGEKR are in the process of reviewing and responding to their respective notices,
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`and soon will need to identify and prepare appropriate witnesses for deposition, several of
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`whom are located and will be deposed in Asia.
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`I declare under penalty of perjury that the foregoing is true and correct. Executed on
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`this 22nd day of March 2018, in Los Angeles, California.
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`/s/ James Blackburn
`James Blackburn
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`3
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