`
`
`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE EASTERN DISTRICT OF TEXAS
`MARSHALL DIVISION
`
`AGIS SOFTWARE DEVELOPMENT LLC,
`
`Plaintiff,
`
`vs.
`
`HTC CORPORATION,
`
`CASE NO. 2:17-CV-514-JRG
`(LEAD CASE)
`
`JURY TRIAL DEMANDED
`
`
`
`Defendant.
`
`
`DECLARATION OF KYLE R. CANAVERA
`IN SUPPORT OF DEFENDANT HTC CORPORATION’S
`MOTION FOR SUMMARY JUDGMENT OF NO DIRECT INFRINGEMENT
`
`
`
`
`
`Case 2:17-cv-00514-JRG Document 123-1 Filed 01/28/19 Page 2 of 3 PageID #: 8568
`
`
`
`
`I, Kyle R. Canavera, hereby declare as follows:
`
`1.
`
`I am an attorney at the law firm of Perkins Coie LLP and counsel of record for
`
`HTC Corporation (“HTC Corp.”) in the above entitled matter. I am a member of good standing
`
`of the California and United States Patent and Trademark Bar and am admitted to practice in the
`
`Eastern District of Texas.
`
`2.
`
`I make this declaration in support of HTC Corp.’s Motion for Summary Judgment
`
`of No Direct Infringement.
`
`3.
`
`Attached hereto as Exhibit 1 is a true and correct copy of excerpts of AGIS’s
`
`Final Election of Asserted Claims, dated August 15, 2018.
`
`4.
`
`Attached hereto as Exhibit 2 is a true and correct copy of excerpts of HTC Corp.’s
`
`Second Set of Interrogatories, dated November 7, 2018.
`
`5.
`
`Attached hereto as Exhibit 3 is a true and correct copy of excerpts of AGIS’s
`
`Responses to HTC Corp.’s Second Set of Interrogatories, dated December 7, 2018.
`
`6.
`
`Attached hereto as Exhibit 4 is a true and correct copy of the November 13, 2018
`
`Letter from Matt Bernstein to Vincent Rubino.
`
`7.
`
`Attached hereto as Exhibit 5 is a true and correct copy of the November 28, 2018
`
`Letter from Vincent Rubino to Matt Bernstein.
`
`8.
`
`Attached hereto as Exhibit 6 is a true and correct copy of excerpts of AGIS’s
`
`Infringement Contentions Cover Pleading, dated January 19, 2018.
`
`9.
`
`Attached hereto as Exhibit 7 is a true and correct copy of excerpts of AGIS’s
`
`Infringement Contentions Cover Pleading, dated December 19, 2018.
`
`10.
`
`Attached hereto as Exhibit 8 is a true and correct copy of excerpts of the Expert
`
`Report of Joseph McAlexander Regarding Infringement, dated December 14, 2018.
`
`
`
`
`2
`
`
`
`Case 2:17-cv-00514-JRG Document 123-1 Filed 01/28/19 Page 3 of 3 PageID #: 8569
`
`
`
`
`Attached hereto as Exhibit 9 is a true and correct copy of excerpts of the
`
`11.
`
`deposition transcript of David Wiggins, taken on July 19, 2018.
`
`12.
`
`Attached hereto as Exhibit 10 is a true and correct copy of excerpts of the
`
`deposition transcript of Tsung-Che Hsu (Tiger Hsu), taken on July 27, 2018.
`
`13.
`
`Attached hereto as Exhibit 11 is a true and correct copy of excerpts of the
`
`deposition transcript of Nigel Newby-House, taken on August 16, 2018.
`
`14.
`
`Attached hereto as Exhibit 12 is a true and correct copy of excerpts of the
`
`deposition transcript of Yu-Ho Teng (Steven Teng), taken on October 5, 2018.
`
`15.
`
`Attached hereto as Exhibit 13 is a true and correct copy of excerpts of the
`
`deposition transcript of Chin-Yin Wang, (Mei Wang) taken on October 5, 2018.
`
`I declare under penalty of perjury that the foregoing is true and correct.
`
`Executed this 25th day of January, 2019, in San Diego, California.
`
`/s/ Kyle R. Canavera
`Kyle R. Canavera
`
`
`
`
`3
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