`
`
`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE EASTERN DISTRICT OF TEXAS
`MARSHALL DIVISION
`
`AGIS SOFTWARE DEVELOPMENT LLC,
`
`Plaintiff,
`
`vs.
`
`HTC CORPORATION,
`
`Defendant.
`
`CASE NO. 2:17-CV-514-JRG
`(LEAD CASE)
`
`JURY TRIAL DEMANDED
`
`
`
`
`DECLARATION OF KYLE R. CANAVERA
`IN SUPPORT OF DEFENDANT HTC CORPORATION’S
`MOTION FOR SUMMARY JUDGMENT OF NO WILLFUL INFRINGEMENT
`
`
`
`
`
`Case 2:17-cv-00514-JRG Document 126-2 Filed 01/28/19 Page 2 of 4 PageID #: 8785
`
`
`
`
`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 Willful Infringement.
`
`3.
`
`Attached hereto as Exhibit 1 is a true and correct copy of excerpts of HTC Corp.’s
`
`First Set of Interrogatories, dated May 18, 2018.
`
`4.
`
`Attached hereto as Exhibit 2 is a true and correct copy of excerpts of AGIS’s
`
`Responses to HTC Corp.’s First Set of Interrogatories, dated June 18, 2018.
`
`5.
`
`Attached hereto as Exhibit 3 is a true and correct copy of excerpts of AGIS’s First
`
`Supplemental Responses to HTC Corp.’s First Set of Interrogatories, dated August 17, 2018.
`
`6.
`
`Attached hereto as Exhibit 4 is a true and correct copy of the November 21, 2018
`
`Letter from Kyle R. Canavera to Vincent Rubino.
`
`7.
`
`Attached hereto as Exhibit 5 is a true and correct copy of excerpts of AGIS’s
`
`Second Supplemental Responses to HTC Corp.’s First Set of Interrogatories, dated December 7,
`
`2018.
`
`8.
`
`Attached hereto as Exhibit 6 is a true and correct copy of excerpts of HTC Corp.’s
`
`Second Set of Interrogatories, dated November 7, 2018.
`
`9.
`
`Attached hereto as Exhibit 7 is a true and correct copy of excerpts of AGIS’s
`
`Responses to HTC Corp.’s Second Set of Interrogatories, dated December 7, 2018.
`
`
`
`2
`
`
`
`Case 2:17-cv-00514-JRG Document 126-2 Filed 01/28/19 Page 3 of 4 PageID #: 8786
`
`
`
`
`Attached hereto as Exhibit 8 is a true and correct copy of excerpts of HTC Corp.’s
`
`10.
`
`First Set of Requests for Admission, dated November 7, 2018.
`
`11.
`
`Attached hereto as Exhibit 9 is a true and correct copy of excerpts of AGIS’s
`
`Responses to HTC Corp.’s First Set of Requests for Admission, dated December 7, 2018.
`
`12.
`
`Attached hereto as Exhibit 10 is a true and correct copy of excerpts of the
`
`deposition transcript of Christopher Rice, taken on October 9, 2018.
`
`13.
`
`Attached hereto as Exhibit 11 is a true and correct copy of excerpts of the
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`deposition transcript of Eric Armstrong, taken on October 11, 2018.
`
`14.
`
`Attached hereto as Exhibit 12 is a true and correct copy of excerpts of the
`
`deposition transcript of Sandel Blackwell Dep. Tr., taken on October 15, 2018.
`
`15.
`
`Attached hereto as Exhibit 13 is a true and correct copy of excerpts of the
`
`deposition transcript of Rebecca Clark, taken on October 16, 2018.
`
`16.
`
`Attached hereto as Exhibit 14 is a true and correct copy of excerpts of the
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`deposition transcript of Ronald Wisneski, taken on October 17, 2018.
`
`17.
`
`Attached hereto as Exhibit 15 is a true and correct copy of excerpts of the
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`deposition transcript of Margaret Beyer, taken on October 23, 2018.
`
`18.
`
`Attached hereto as Exhibit 16 is a true and correct copy of excerpts of the
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`deposition transcript of Malcolm Beyer, taken on October 23, 2018.
`
`19.
`
`Attached hereto as Exhibit 17 is a true and correct copy of excerpts of the
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`deposition transcript of James Fordyce, taken on November 7, 2018.
`
`
`
`3
`
`
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`Case 2:17-cv-00514-JRG Document 126-2 Filed 01/28/19 Page 4 of 4 PageID #: 8787
`
`
`
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`Attached hereto as Exhibit 18 is a true and correct copy of excerpts of the
`
`20.
`
`deposition transcript of Wan-Lin Yu (Lynn Yu), taken on October 4, 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
`
`
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`4
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