`Case 2:17-cv-00513-JRG Document 74-7 Filed 01/05/18 Page 1 of 2 PageID #: 1706
`
`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.
`
`
`
`
`CIVIL ACTION NO. 2:17-CV-513—JRG
`
`JURY TRIAL DEMANDED
`
`DECLARATION OF JING ZENG IN SUPPORT OF
`DEFENDANTS’ MOTION TO TRANSFER VENUE
`
`I, Jing Zeng, state and declare as follows:
`
`1.
`
`I am a HR Business Partner at Huawei Device USA, Inc. (“Huawei Device
`
`USA”) and work out of Huawei Device USA’s Plano, Texas , office. I have been employed by
`
`Huawei Device USA since 2012. I work in the HR Department of Huawei Device USA.
`
`2.
`
`I provide this supplemental declaration in support of Defendants’ motion to
`
`transfer the above-captioned action to the United States District Court for the Northern District
`
`of California. I submit this declaration based upon my personal knowledge and investigation. If
`
`called as a witness, I would and could testify competently as to the same.
`
`3.
`
`Huawei Device USA has five business locations in the United States, only one of
`
`which is in Texas and three of which are in California. The current headcount for employees at
`
`each location is as follows: Plano, Texas — 46; Santa Clara, California — 32, San Diego,
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`California — 60; Mountain View, California —— 29; and Bellevue, Washington —- 37. The
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`headcounts at each location were approximately the same in June of last year.
`
`Huawei Supplemental Transfer Declaration (AGIS).docx
`
`
`
`Case 2:17-cv-00513-JRG Document 74-7 Filed 01/05/18 Page 2 of 2 PageID #: 1707
`Case 2:17-cv-00513-JRG Document 74-7 Filed 01/05/18 Page 2 of 2 PagelD #: 1707
`
`4.
`
`I have reviewed a job posting by Huawei Device USA for a Test Engineer
`
`position at Huawei Device USA’s business location in Plano, Texas. I have been informed that
`
`AGIS attached this job posting as Exhibit 11 to the Declaration of Vincent J. Rubino, III, in
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`support of AGIS’s opposition to Defendants’ motion to transfer. I have confirmed with my
`
`colleagues at Huawei Device USA that the job posting is for a test engineer who will be
`
`responsible for testing standard requirements of mobile carriers. That job posting was published
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`on or about October 25, 2017. If filled, the position does not involve any responsibility for
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`research and development of the accused devices in this action, or testing of the accused Google
`
`software on those devices.
`
`I declare under penalty of perjury that the foregoing is true and correct. Executed in
`
`Plano, Texas on January 5, 201%.
`I 3!:
`
`W J
`
`
`
`ing Zeng
`
`Huawei Supplemental Transfer Declaration (AGIS).docx
`
`
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