`
`IN THE UNITED STATES DISTRICT COURT FOR
`THE EASTERN DISTRICT OF TEXAS
`MARSHALL DIVISION
`
`CASE NO. 2:17-cv-514-JRG
`(Lead Case)
`
`JURY TRIAL DEMANDED
`
`CASE NO. 2:17-CV-515-JRG
`(Member Case)
`
`JURY TRIAL DEMANDED
`
`§§§§§§§§§
`
`§§§§§§§§§
`
`AGIS SOFTWARE DEVELOPMENT, LLC
`
`Plaintiff,
`
`v.
`
`HTC CORPORATION, et al.
`
`Defendant.
`AGIS SOFTWARE DEVELOPMENT, LLC
`
` Plaintiff,
`
`v.
`
`LG ELECTRONICS INC.
`
` Defendant.
`
`DECLARATION OF NICHOLAS H. LEE IN SUPPORT OF DEFENDANT LG
`ELECTRONICS INC.’S MOTION FOR SUMMARY JUDGMENT THAT U.S. PATENT
`NO. 7,630,724 MAY NOT BE RELIED UPON TO SHOW THAT U.S. APPLICATION
`NO. 14/027,410 PROVIDES WRITTEN DESCRIPTION SUPPORT FOR U.S. PATENT
`NOS. 9,408,055; 9,445,251; AND 9,467,838
`
`I, Nicholas H. Lee, state and declare as follows:
`
`1.
`
`I am a member of Arnold & Porter Kaye Scholer, LLP (“APKS”), counsel of
`
`record for Defendant LG Electronics Inc. (“LGEKR”). I am a member of the Bar of the State of
`
`California and have been admitted to practice in the United States District Court for the Eastern
`
`District of Texas (“EDTX”). I provide this declaration in support of Defendant LGEKR’s
`
`Motion for Summary Judgment that U.S. Patent No. 7,630,724 May Not Be Relied Upon to
`
`Show That U.S. Application No. 14/027,410 Provides Written Description Support for U.S.
`
`Patent Nos. 9,408,055; 9,445,251; and 9,467,838. I have personal knowledge of the matters
`
`1
`
`
`
`Case 2:17-cv-00514-JRG Document 106-2 Filed 01/25/19 Page 2 of 3 PageID #: 4076
`
`stated in this declaration and would testify competently and truthfully to them if called upon to
`
`do so.
`
`2.
`
`Attached hereto as Exhibit 1 is a true and correct copy of U.S. Patent No.
`
`9,408,055.
`
`3.
`
`Attached hereto as Exhibit 2 is a true and correct copy of U.S. Patent No.
`
`9,445,251.
`
`4.
`
`Attached hereto as Exhibit 3 is a true and correct copy of U.S. Patent No.
`
`9,467,838.
`
`5.
`
`Attached hereto as Exhibit 4 is a true and correct copy of U.S. Patent Application
`
`No. 14-027,410.
`
`6.
`
`Attached hereto as Exhibit 5 is a true and correct copy of the Decision Denying
`
`Institution of Inter Partes Review of the ’251 Patent in Apple Inc. v. AGIS Software
`
`Development LLC, IPR2018-00817 (P.T.A.B. Oct. 3, 2018) (Paper 9).
`
`7.
`
`Attached hereto as Exhibit 6 is a true and correct copy of the Decision Instituting
`
`Inter Partes Review of the ’838 Patent in Apple Inc. v. AGIS Software Development LLC,
`
`IPR2018-00819 (P.T.A.B. Nov. 7, 2018) (Paper 9).
`
`8.
`
`Attached hereto as Exhibit 7 is a true and correct copy of the Decision Denying
`
`Institution of Inter Partes Review of the ’055 Patent in Apple Inc. v. AGIS Software
`
`Development LLC, IPR2018-00818 (P.T.A.B. Oct. 3, 2018) (Paper 9).
`
`9.
`
`Attached hereto as Exhibit 8 is a true and correct copy of an excerpt from The
`
`New Oxford American Dictionary (2001) which provides a definition for the term “which.”
`
`2
`
`
`
`Case 2:17-cv-00514-JRG Document 106-2 Filed 01/25/19 Page 3 of 3 PageID #: 4077
`
`I declare under penalty of perjury that the foregoing is true and correct. Executed in Los
`
`Angeles, California on January 25, 2019.
`
`/s/ Nicholas H. Lee
`Nicholas H. Lee
`Attorney for Defendant LG Electronics Inc.
`
`
`
`3
`
`
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