Case 2:17-cv-00514-JRG Document 131-2 Filed 01/29/19 Page 1 of 3 PageID #: 9356
`Case 2:17-cv-00514-JRG Document 131-2 Filed 01/29/19 Page 1 of 3 PageID #: 9356
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`IN THE UNITED STATES DISTRICT COURT
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`FOR THE EASTERN DISTRICT OF TEXAS
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`MARSHALL DIVISION
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`AGIS SOFTWARE DEVELOPMENT LLC,
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`Plaintiff,
`
`V-
`HTC CORPORATION,
`
`Case No. 2: 17-cv-00514-JRG
`(Lead case)
`
`Defendant
`
`JURY TRIAL DEMANDED
`
`AGIS SOFTWARE DEVELOPMENT LLC,
`
`Plaintiff»
`
`Case NO. 2: 17-cv-00515-JRG
`
`V
`
`(Member Case)
`
`LG ELECTRONICS INC”
`
`JURY TRIAL DEMANDED
`
`Defendant.
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`DECLARATION OF WILLIAM LUH IN SUPPORT OF
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`LG ELECTRONICS INC.’S MOTION FOR SUMMARY JUDGMENT
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`I, William Luh, state and declare as follows:
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`1.
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`I am the Technical Lead Manager and Software Engineer for the Find My Device
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`application on Android. I work out of Google LLC’s (“Google”) Mountain View, California
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`

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`Case 2:17-cv-00514-JRG Document 131-2 Filed 01/29/19 Page 2 of 3 PageID #: 9357
`Case 2:17-cv-00514-JRG Document 131-2 Filed 01/29/19 Page 2 of 3 PageID #: 9357
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`office.
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`I submit this declaration based upon my best and current knowledge of Find My Device,
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`which I understand was previously branded as Android Device Manager. If called as a witness, I
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`could and would testify competently to the information contained herein.
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`2.
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`Google, not any Android partner, is solely responsible for developing, designing,
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`maintaining, modifying, making available and/or distributing the Find My Device system. Find
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`My Device can be used to locate, ring, secure or lock, and/or wipe another device linked to a
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`Google account. The functionality provided by Find My Device has always been categorized
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`into different parts: (1) the receiver-side; (2) the client-side; and (3) the backend.
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`3.
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`The receiver-side of Find My Device on an Android device is what receives and
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`implements remote instructions. More specifically, the receiver-side on a device is used to report
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`the device location to Google servers and to implement received instructions (as sent from the
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`client-side of the Find My Device) to secure or lock the device, to ring the device, or to wipe
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`itself. This receiver-side is part of GmsCore, which is also known as Google Play Services,
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`meaning every device that has GmsCore will also include only this receiver-side functionality.
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`Moreover, the receiver-side of Find My Device does not include functionality to generate or
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`transmit remote instructions to secure or lock, ring, or wipe a device.
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`4.
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`The client-side of Find My Device is the application and interface that a Google
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`user interacts with to view an account-linked device’s location and to select and create a remote
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`instruction to be transmitted to that device — e.g., to lock or secure the device, to ring the device,
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`or to erase the device. The GmsCore package does not include this client-side application and
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`interface. The client-side Find My Device application is available for download by users of
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`Android phones via the Google Play Store, which is provided, managed, and controlled by
`
`

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`Case 2:17-cv-00514-JRG Document 131-2 Filed 01/29/19 Page 3 of 3 PageID #: 9358
`Case 2:17-cv-00514-JRG Document 131-2 Filed 01/29/19 Page 3 of 3 PageID #: 9358
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`Geogle. Software updates to the client-side Find My Device application are also provided via
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`the Google Fla}.r Store.
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`5.
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`This client—side fitnetionaiity can also be assessed through an}.r generic web
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`browser at the fellowing URL: https:ffwuav.geoglc.corufanflroidffind. Geogle provides and
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`manages this webpage on their owl: servers, and, through that webpage, a user can also select
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`and create the same remote instruction -- securedoek, ring1 or wipe — to be transmitted to a
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`recipient device. To the extent accessed through a generic web browser on a mobile device, the
`J
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`Google webpage functionality"ts never installed an that deviee.
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`6.
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`The backendts the bridge between the eltaot—stdeWM avaiiable fer
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`
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`the receiver-side defiee
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`'_ ,aretaanaged,
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`