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`Case 2:17-cv-00513-JRG Document 36-4 Filed 11/14/17 Page 1 of 4 PageID #: 435
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`IN THE UNITED STATES DISTRICT COURT
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`FOR THE EASTERN DISTRICT OF TEXAS
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`MARSHALL DIVISION
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`AGIS SOFTWARE DEVELOPMENT, LLC
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`Plaln’flffa
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`V.
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`CIVIL ACTION NO. 2: 1 7-cv-513—JRG
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`HUAWEI DEVICE USA INC, HUAWEI
`DEVICE CO., LTD. AND I-IUAWEI DEVICE
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`(DONGGUAN) CO., LTD.
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`Defendants.
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`JURY TRIAL DEMANDED
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`DECLARATION OF ANDREW OPLINGER REGARDING HUAWEI DEVICE USA
`INC., HUAWEI DEVICE CO., LTD. AND HUAWEI DEVICE (DONGGUANI CO.,
`LTD.’S MOTION TO TRANSFER VENUE TO THE NORTHERN DISTRICT OF
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`CALIFORNIA
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`1, Andrew Oplinger, state and declare as follows:
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`1.
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`I am a Technical Lead Manager for Google Product Infrastructure and work out of
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`Google LLC’s (“Google”) Mountain View, California office.
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`I submit this declaration based
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`upon my knowledge of the corporate structure of Google, and my investigation of the location of
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`witnesses and evidence related to the Google Maps for Mobile application (“GMM”). If called
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`as a witness, I could and would testify competently to the information contained herein.
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`2.
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`Google’s Mountain View headquarters, which includes offices in neighboring
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`Sunnyvale (collectively referred to as Mountain View herein), is where engineers, product
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`managers, executives, and staff perform work related to GMM. The most significant design and
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`release decisions that impact Android and GMM are made in Mountain View, California or San
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`Francisco, California, by product leads as well as managers and engineering teams there.
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`Case 2:17-cv-00513-JRG Document 36-4 Filed 11/14/17 Page 2 of 4 PageID #: 436
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`Case 2:17-cv-00513-JRG Document 36-4 Filed 11/14/17 Page 2 of 4 PageID #: 436
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`3.
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`Googie provides GMM to various Android mobile device providers, including
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`Huawei, LG, HTC, and ZTE. GMM was initially developed in Google’s Mountain View
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`headquarters, and much of GMM’S ongoing design, development, and other technical activities
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`take place in Mountain View and in San Francisco, where many of the engineers are located,
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`including those responsible for Location Sharing. There are also engineers responsible for
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`GMM’s Location Sharing feature located in Googie’s office in Sydney, Australia.
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`4]
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`Based on my knowledge and investigation to date, at least the following
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`individuals have knowledge regarding the design, development, and operation of Location
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`Sharing used on Android mobile devices:
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`0 Myself and a team of engineers working in the Mountain View office responsible for
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`Google Location Sharing functionality.
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`0 Daniel Resnick, Technical Lead Manager, is located in Google’s Sydney, Australia
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`Office.
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`I understand that Mr. Resnick works with engineers and project leads related
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`to GMM and its Location Sharing functionality in California, and is able to perform
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`his work functions when traveling to Google’s headquarters in California.
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`0 Tom Green, Technical Program Manager, is located in Google’s San Francisco,
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`California office. Mr. Green is responsible for GMM releases.
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`5.
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`I am currently aware of no Googie employees with relevant knowledge regarding
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`GMM or Location Sharing features residing or working in the Eastern District of Texas.
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`6.
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`Nearly all the documents relating to GMM, including highly proprietary
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`information and source code, are either physically present in or electronically accessible from
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`San Francisco, California; Mountain View, California; or Sydney, Australia, as that is where the
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`Case 2:17-cv-00513-JRG Document 36-4 Filed 11/14/17 Page 3 of 4 PageID #: 437
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`Case 2:17-cv-00513-JRG Document 36-4 Filed 11/14/17 Page 3 of 4 PageID #: 437
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`persons most qualified to identify and locate such documents reside.
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`I am aware of no
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`documents described in this paragraph being located in the Eastern District of Texas.
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`I declare under penalty of perjury that the foregoing is true and correct. Executed in
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`+ '9“
`Mountain View, Caiifornia on November fl, 5017
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`Case 2:17-cv-00513-JRG Document 36-4 Filed 11/14/17 Page 4 of 4 PageID #: 438
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`Case 2:17-cv-00513-JRG Document 36-4 Filed 11/14/17 Page 4 of 4 PageID #: 438
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