Case 2:17-cv-00513-JRG Document 46-3 Filed 11/27/17 Page 1 of 5 PageID #: 1052
`Case 2:17-cv—00513-JRG Document 46-3 Filed 11/27/17 Page 1 of 5 PageID #: 1052
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`EXHIBIT 1
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`EXHIBIT 1
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`Case 2:17-cv—00513-JRG Document 46-3 Filed 11/27/17 Page 1 of 5 PageID #: 1052
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`EXHIBIT 1
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`EXHIBIT 1
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`Case 2:17-cv-00513-JRG Document 46-3 Filed 11/27/17 Page 2 of 5 PageID #: 1053
`Gm 2:215=CV=00fi8mR$1bcflmflnflfit35-EiIdBIQQ/Qfiflailfii’a‘me 6)ng Pagemtti 1%
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`IN THE UNITED STATES DISTRICT COURT
`FOR THE EASTERN DISTRICT OF TEXAS
`MARSHALL DIVISION
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`PORTO TECHNOLOGY CO, LTD,
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`Plaintiff,
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`v.
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`CASE NO. 2:15-cv-00458—IRG—RSP
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`LG ELECTRONICS MOBILECOMIVI U.S.A.,
`INC,
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`JURY TRIAL DEMANDED
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`Defendants.
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`DECLARATION OF CECILIA SON IN SUPPORT OF
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`LG ELECTRONICS MOBILECOMIVI U.S.A., INC.’S MOTION TO
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`TRANSFER VENUE TO THE NORTHERN DISTRICT OF CALIFORNIA
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`I, Cecilia Son, make the following declaration based on my personal knowledge and
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`investigation, or on information received from someone with knowledge. If called as a witness, I
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`couid and would testify competently to the following facts:
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`1.
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`I am currently empioyed as Director in the Partner Engineering team at LG
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`Electronics Mobile Research USA, LLC (“LGEMR”), which is a wholly-owned subsidiary of
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`2
`a
`i;
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`li
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`LG Electronics MobileCornm U.S.A., Inc. (“LGEMU”).
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`2.
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`I understand that Porto Technoiogy Co, Ltd. (“Piaintiff”) has brought a patent
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`infringement action against LGEMU. {provide this declaration in support of LGEMU’s motion
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`to transfer to the United States District Court for the Northern District of California.
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`Lamina-wan;_-_
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`Case 2:17-cv-00513-JRG Document 46-3 Filed 11/27/17 Page 3 of 5 PageID #: 1054
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`3.
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`Both LGEMU and LGEMR are California companies. My office is located at
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`2540 North First St, Suite #300, San Jose, CA 95131 (the “San Jose Office”). The San Jose
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`Office is leased by LGEMU and is staffed with LGEMU and LGEMR employees.
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`4.
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`LG Electronics, Inc. (“LGEKR”) manufactures LG~branded mobile products sold
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`in the United States. LGEKR is the entity responsible for designing, engineering, sourcing
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`components, and manufacturing LG—branded mobile products sold in the United States. Nearly
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`all of this work is done in South Korea. None of this work is performed within the Eastern
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`District of Texas.
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`5.
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`LGEMU is the only LG entity that imports, tests (including through LGEMR),
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`markets, and sells LG—branded mobile phone products in the United States. LGEMU sells LG-
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`branded mobile products to national carriers and retailers who then sell the LG—branded mobile
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`products to end users nationwide, including throughout the State of California.
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`6.
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`I understand that Plaintiff has accused LG—branded mobile products of
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`infringement based on map-related functionality.
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`7.
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`The LG—branded mobile products accused of infringement run the Android
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`Operating System (“OS”). The Android OS is an open-source operating system for
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`communication devices that was developed and is provided by Google Inc. (“Google”).
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`8.
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`During the manufacturing process, LGEKR obtains the Android OS from the
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`Android Open Source Project (“AOSP”), which is led by Google. Google also provides certain
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`Android OS applications, including Googie Maps.
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`9.
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`As noted earlier, I am a Director in Partner Engineering team in the San Jose
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`Office. Other members of my team include Steven Howard, Bum Suk Bae, Joonhyun Back, Jae
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`WWWVWWWWW
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`Case 2:17-cv-00513-JRG Document 46-3 Filed 11/27/17 Page 4 of 5 PageID #: 1055
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`Week Cho, Jooyong Lee, Jeong Rae Kim, Kush Shn'vastava, and Namrata Suryavanshi. We are
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`all located in the San Jose Office.
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`10.
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`One of the key functions that my team manages out of the San Jose Office is
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`Android OS certification for LG—branded mobile products running Android OS. Android OS
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`certification is a process by which Google and LGEMR ensure that the LG—branded Android
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`Products manufactured by LGEKR and imported and sold by LGEMU adhere to Google’s
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`Android OS compatibility requirements.
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`11.
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`As of April 2015, the San Jose Office employed 65 employees. The office space
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`occupied by these employees is approximately 25,000 square feet, and is leased by LGEMU.
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`Employees in the San Jose Office, including the individuals in my team, have communicated and
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`interacted with Google personnel located at Google’s headquarters in Mountain View, CA in
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`connection with LG—branded Android products.
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`12.
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`Documents and records relating to LG—branded Android Products and Android
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`OS certification are at the San Jose Office. There are no LGE employees in the Eastern District
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`of Texas who are involved in Android OS certification.
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`13.
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`As of April 2015, LGEMU employed approximately EGO employees in its San
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`Diego office, located at 10255 Willow Creek Road, San Diego, CA 92131 (the “San Diego
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`Office”). LGEMU owns the San Diego office as opposed to leasing or renting it. The San Diego
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`office is over 71,000 square feet. The San Diego office shares responsibility for marketing LG—
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`branded mobile products. It is also responsible for testing and quality management of LG—
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`branded phones, including operation of certain applications. For example, Mr. Michael Henson,
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`Senior Director of Quality Management for LGEMU, resides in the San Diego Office.
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`Case 2:17-cv-00513-JRG Document 46-3 Filed 11/27/17 Page 5 of 5 PageID #: 1056
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`Documents and records relating to testing of LG—branded mobile products are at the San Diego
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`Office.
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`I declare under penalty of perjury under the laws of the United States of America that the
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`foregoing facts are true and correct to the best of my personal knowledge.
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`ExeCuted in San Jose, California on July :1, 2015.
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`www_
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`Cecilia Son
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