`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE EASTERN DISTRICT OF TEXAS
`MARSHALL DIVISION
`
`AGIS SOFTWARE DEVELOPMENT, LLC
`
`Plaintiff,
`
`v.
`
`HUAWEI DEVICE USA INC., HUAWEI
`DEVICE CO., LTD. AND HUAWEI DEVICE
`(DONGGUAN) CO., LTD.
`
`Defendants.
`
`LEAD CASE NO. 2:17-cv-513-JRG
`
`JURY TRIAL DEMANDED
`
`AGIS SOFTWARE DEVELOPMENT, LLC
`
`MEMBER CASE NO. 2:17-cv-515-JRG
`
`Plaintiff,
`
`v.
`
`LG ELECTRONICS, INC.
`
`Defendant.
`
`JURY TRIAL DEMANDED
`
`DECLARATION OF NICHOLAS H. LEE IN SUPPORT OF DEFENDANT LG
`ELECTRONICS, INC.’S MOTION TO DISMISS FOR LACK OF PERSONAL
`JURISDICTION OR, IN THE ALTERNATIVE, TO TRANSFER VENUE TO THE
`NORTHERN DISTRICT OF CALIFORNIA
`
`I, Nicholas H. Lee, state and declare as follows:
`
`1.
`
`I am a member of Arnold & Porter Kaye Scholer, LLP (“APKS”), counsel of
`
`record for Defendant LG Electronics, Inc. (“LGEKR”). I am a member of the Bar of the State of
`
`California and have been admitted to practice in the United States District Court for the Eastern
`
`District of Texas (“EDTX”). I provide this declaration in support of Defendant LG Electronics,
`
`Inc.’s motion to dismiss for lack of personal jurisdiction or, in the alternative, to transfer the
`
`above-captioned action to the United States District Court for the Northern District of California
`
`1
`
`
`
`Case 2:17-cv-00513-JRG Document 46-2 Filed 11/27/17 Page 2 of 3 PageID #: 1050
`
`(“NDCA”). I have personal knowledge of the matters stated in this declaration and would testify
`
`competently and truthfully to them if called upon to do so.
`
`2.
`
`Attached hereto as Exhibit 1 is a true and correct copy of the declaration of
`
`Cecilia Son in support of LG Electronics MobileComm U.S.A., Inc.’s (“LGEMU”) Motion to
`
`Transfer Venue to the Northern District of California, filed in Porto Technology Co., Ltd. v. LG
`
`Electronics MobileComm U.S.A., Inc., D.I. 15-2, Case No. 2:15-cv-00458-JRG-RSP (E.D. Tex.)
`
`(“Porto Declaration”).
`
`3.
`
`Attached hereto as Exhibit 2 is a true and correct copy of the declaration of
`
`Hongsun Yoon on behalf of LG Electronics, Inc., LG Electronics MobileComm U.S.A., Inc., and
`
`LG Electronics U.S.A., Inc., filed in Ryujin Fujinomaki v. Google Inc. et al., D.I. 80-1, Case No.
`
`2:15-cv-01381-JRG-RSP (E.D. Tex.) (“Fujinomaki Declaration”).
`
`4.
`
`An online search of Expedia reveals that there are numerous flights from Incheon
`
`International Airport (“ICN”) to San Francisco International Airport (“SFO”) with a non-stop
`
`flight time of 10 hours and 25 minutes. ICN is the most convenient international airport to
`
`LGEKR’s principal place of business as it offers the most non-stop flights and shortest flight
`
`times to the United States. Attached hereto as Exhibit 3 is a true and correct copy of the search
`
`results on Expedia for flights from ICN to SFO, with the results sorted by shortest duration. By
`
`contrast, an online search of Expedia reveals that flights from ICN to Shreveport, Louisiana
`
`require at least 1 stop and has as its shortest flight time 16 hours and 55 minutes. Flying to
`
`Shreveport is the most convenient destination to get to EDTX from ICN as there are more flights
`
`and Shreveport is roughly equidistant to the EDTX courthouse when compared with Longview
`
`East Texas Regional Airport. Attached hereto as Exhibit 4 is a true and correct copy of the
`
`2
`
`
`
`Case 2:17-cv-00513-JRG Document 46-2 Filed 11/27/17 Page 3 of 3 PageID #: 1051
`
`search results on Expedia for flights from ICN to Shreveport, with the results sorted by shortest
`
`duration.
`
`I declare under penalty of perjury that the foregoing is true and correct. Executed in Los
`
`Angeles, California on November 27, 2017.
`
`/s/ Nicholas H. Lee
`Nicholas H. Lee
`Attorney for Defendant LG Electronics, Inc.
`
`3
`
`
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