Case 2:17-cv-00513-JRG Document 81-3 Filed 01/12/18 Page 1 of 5 PageID #: 5002
`Case 2:17-cv-00513-JRG Document 81-3 Filed 01/12/18 Page 1 of 5 PagelD #: 5002
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`EXHIBIT 14
`EXHIBIT 14
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`Case 2:17-cv-00513-JRG Document 81-3 Filed 01/12/18 Page 2 of 5 PageID #: 5003
`Case 2:13-cv-01112-JRG Document 110-17 Filed 04/15/14 Page 1 of 4 PageID #: 2021
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`Exhibit 9
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`Case 2:17-cv-00513-JRG Document 81-3 Filed 01/12/18 Page 3 of 5 PageID #: 5004
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`Case 2:13-cv-01112-JRG Document 110-17 Filed 04/15/14 Page 2 of 4 PageID #: 2022
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`UNITED STATES DISTRICT COURT
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`FOR THE EASTERN DISTRICT OF TEXAS
`MARSHALL DIVISION
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`CIVIL ACTION NO. 2:13—CV-1 1 lZ-JRG
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`JURY TRIAL DEMANDED
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`CONTENTGUARD HOLDWGS, INC.
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`Plaintiff;
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`v.
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`AMAZON.COM, INC; APPLE INC.;
`BLACKBERRY LIMITED (F/K/A
`RESEARCH IN MOTION LIMITED);
`BLACKBERRY CORPORATION (WK/A
`RESEARCH IN MOTION
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`CORPORATION; HTC CORPORATION;
`HTC AMERICA, INC.; HUAWEI
`TECHNOLOGIES CO., LTD.; HUAWEI
`DEVICE USA, INC.; MOTOROLA
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`MOBILITY, LLC; SAMSUNG
`ELECTRONICS CO., LTD.; SAMSUNG
`ELECTRONICS AMERICA, INC.; AND
`SAMSUNG TELECOMMUNICATIONS
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`AMERICA, LLC,
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`Defendants.
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`DECLARATION OF JAMES JIANG
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`1, James Jiang, declare as follows:
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`1.
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`I am Executive Vice President, Products and Solution, for Huawei Device USA. My
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`responsibilities include product management and technical sales for Huawei smartphones
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`in the United States. My business address is at 10180 Telesis Court, Suite 220, San
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`Diego, California, 92121, and I reside in the San Diego metro area.
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`2.
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`I have personal knowledge of the facts set forth in this Declaration, and if called as a
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`witness, could and would testify competently to such facts under oath.
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`Active 153779894
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`1
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`Case 2:17-cv-00513-JRG Document 81-3 Filed 01/12/18 Page 4 of 5 PageID #: 5005
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`Case 2:13-cv-01112-JRG Document 110-17 Filed 04/15/14 Page 3 of 4 PageID #: 2023
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`3. Huawei Device USA has been fully responsible for sales and marketing of Huawei
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`smartphones in the United States since December 201 l.
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`4. Huawei Device Co., Ltd. has been fully responsible for the design and manufacture of the
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`Huawei smartphones that Huawei Device USA sells and markets in the United States
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`since December 201 1.
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`5. Huawei Device USA has its headquarters in Plano, Texas. None of the Plano-based
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`employees are involved in the research and development for smartphone technology.
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`Huawei Device USA does not conduct any research or development for smartphone
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`technology in Texas.
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`Instead, any and all research and development for smartphone
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`technology that Huawei Device USA conducts in the United States is performed either in
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`California or Washington state.
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`In particular, Huawei Device USA employs over 50
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`people at
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`the Huawei
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`facility in San Diego who are responsible for research and
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`development for smartphone technology. The Huawei Device USA facility in San Diego
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`includes a laboratory for
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`testing smartphone technology.
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`Huawei Device USA
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`additionally employs one person in Washington state who is involved in research and
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`development for smartphone technology, and over ten people in Cupertino, California,
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`who are responsible for sales and marketing of Huawei smartphones in the United States,
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`as well as some smartphone technology research and development.
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`6. Huawei Device USA’s records and documents relating to development, sales, and
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`marketing of its smartphones are equally accessible in Huawei Device USA’s Plano and
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`California facilities.
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`7. Prior to September 2011, Futurewei was responsible for sales and marketing of Huawei
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`smartphones in the United States. Futurewei has had a facility in Santa Clara, California
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`Active 153779894
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`2
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`Case 2:17-cv-00513-JRG Document 81-3 Filed 01/12/18 Page 5 of 5 PageID #: 5006
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`Case 2:13-cv-01112-JRG Document 110-17 Filed 04/15/14 Page 4 of 4 PageID #: 2024
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`since before Futurewei transferred responsibility for smartphone marketing and sales in
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`the United States to Huawei Device USA.
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`8.
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`I, or a member of my team, anticipate testifying at deposition and at trial on behalf of
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`Huawei Device USA regarding sales and marketing of Huawei smartphones in the United
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`States.
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`9.
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`It is easier for me to travel to San Francisco, California or San Jose, California from San
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`Diego, where I work and live, to provide trial testimony than it is for me to travel to
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`Marshall, Texas. Southwest Airlines provides frequent flights from San Diego to either
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`San Francisco or San Jose, and the flight time is typically less than two hours.
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`I do travel
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`to the Huawei Device USA offices in Plano, Texas for work, but I do not travel
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`to
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`Marshall, Texas. To travel to Marshall, Texas, I would need to take a four-hour flight to
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`Dallas and then drive another two and a half hours.
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`This trip would be far less
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`convenient to me than traveling within my home state of California.
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`Dated: April 14, 2014
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`James J iang
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`Active 153779394
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`3
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