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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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`LEAD CASE NO. 2:17-cv-513-JRG
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`JURY TRIAL DEMANDED
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`MEMBER CASE NO. 2:17-cv-515-JRG
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`JURY TRIAL DEMANDED
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`AGIS SOFTWARE DEVELOPMENT, LLC
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`Plaintiff,
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`v.
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`LG ELECTRONICS, INC.
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`Defendant.
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`
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`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
`
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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 Defendant LG Electronics, Inc. (“LGEKR”). I am a member of the Bar of the State of
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`California and have been admitted to practice in the United States District Court for the Eastern
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`District of Texas (“EDTX”). I provide this declaration in support of Defendant’s motion to
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`dismiss for lack of personal jurisdiction or, in the alternative, to transfer the above-captioned
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`action to the United States District Court for the Northern District of California (“NDCA”). I
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`Case 2:17-cv-00513-JRG Document 77-1 Filed 01/05/18 Page 2 of 2 PageID #: 3312
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`have personal knowledge of the matters stated in this declaration and would testify competently
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`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 LGEKR pursuant to Patent Local Rule 3-1, served on November 28, 2017.
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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 LGEKR pursuant to Federal Rule of Civil Procedure 26(a)(1), served on
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`December 22, 2017.
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`4.
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`Attached hereto as Exhibit 3 is a true and correct copy of BMW Manufacturing
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`Co. LLC’s Motion to Dismiss for Lack of Personal Jurisdiction and Memorandum in Support,
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`filed in MHL Tek, LLC v. Nissan Motor Co., Case No. 2:07-cv-289-TJW (E.D. Tex. Sept. 7,
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`2007), D.I. 48.
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`
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` I
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` 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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`
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`/s/ Nicholas H. Lee
`Nicholas H. Lee
`Attorney for Defendant LG Electronics, Inc.
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