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`IN THE UNITED STATES DISTRICT COURT
`FOR THE EASTERN DISTRICT OF TEXAS
`MARSHALL DIVISION
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`AGIS SOFTWARE DEVELOPMENT, LLC
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`Plaintiff,
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`v.
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`HUAWEI DEVICE USA INC., HUAWEI
`DEVICE CO., LTD. AND HUAWEI DEVICE
`(DONGGUAN) CO., LTD.
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`Defendants.
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`CIVIL ACTION NO. 2:17-cv-513-JRG
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`JURY TRIAL DEMANDED
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`DECLARATION OF NICHOLAS H. LEE IN SUPPORT OF
`DEFENDANTS’ MOTION TO TRANSFER VENUE
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`I, Nicholas H. Lee, state and declare as follows:
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`1.
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`I am a member of Arnold & Porter Kaye Scholer, LLP (“APKS”), counsel of
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`record for Defendants Huawei Device USA Inc. (“Huawei USA”), Huawei Device Co., Ltd.
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`(“Huawei Device”), and Huawei Device (Dongguan) Co., Ltd. (“Huawei Dongguan”)
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`(collectively, the “Huawei Defendants”). I am a member of the Bar of the State of California
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`and have been admitted to practice in the United States District Court for the Eastern District of
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`Texas. I provide this declaration in support of Defendants’ motion to transfer the above-
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`captioned action to the United States District Court for the Northern District of California (“N.D.
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`Cal.”). 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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`Attached hereto as Exhibit 1 is a true and correct copy of Plaintiff’s Infringement
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`Contentions against Huawei Defendants pursuant to Patent Local Rule 3-1, served on November
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`28, 2017.
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`1
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`Case 2:17-cv-00513-JRG Document 74-1 Filed 01/05/18 Page 2 of 2 PageID #: 1582
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`3.
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`Attached hereto as Exhibit 2 is a true and correct copy of Plaintiff’s Initial
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`Disclosures to Huawei Defendants pursuant to Federal Rule of Civil Procedure 26(a)(1), served
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`on December 22, 2017.
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`4.
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`Plaintiff’s predecessor, Advanced Ground Information Systems, Inc., brought a
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`patent infringement action against Life360, Inc. in 2014 in the Southern District of Florida,
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`captioned Advanced Ground Information Sys., Inc. v. Life360, Inc., No. 9:14-cv-80651 (S.D. Fl.
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`May 16, 2014) (the “Florida Action”). Attached hereto as Exhibit 3 is a true and correct copy of
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`the Declaration of Malcolm K. Beyer, Jr., submitted in the Florida Action (D.I. 32-1).
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`I declare under penalty of perjury that the foregoing is true and correct. Executed in Los
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`Angeles, California on January 5, 2018.
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`/s/ Nicholas H. Lee
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`Nicholas H. Lee
`Attorney for Huawei Defendants
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`2
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