`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE EASTERN DISTRICT OF TEXAS
`MARSHALL DIVISION
`
`Case No. 2:17-CV-0514-JRG
`(LEAD CASE)
`
`JURY TRIAL DEMANDED
`
`§§§§§§§§§§
`
`AGIS SOFTWARE DEVELOPMENT LLC,
`
`Plaintiff,
`
`v.
`
`HTC CORPORATION,
`
`Defendant.
`
`DECLARATION OF ALFRED R. FABRICANT IN SUPPORT OF PLAINTIFF
`AGIS SOFTWARE DEVELOPMENT LLC’S OPPOSED MOTION
`TO STRIKE EXPERT REPORT OF DR. ANDREW WOLFE
`
`I, Alfred R. Fabricant, hereby declare as follows:
`
`1.
`
`I am a member of Brown Rudnick LLP, lead counsel of record for Plaintiff AGIS
`
`Software Development LLC (“AGIS”). I am admitted to practice before this Court. I submit this
`
`declaration in support of AGIS Software Development LLC’s Opposed Motion to Strike Portions
`
`of the January 11, 2019 Expert Report of Dr. Andrew Wolfe. I am familiar with the facts set
`
`forth herein.
`
`2.
`
`The exhibits attached to this declaration may contain annotations and/or excerpts
`
`of the originals.
`
`3.
`
`Attached hereto as Exhibit A is a true and correct copy of a Notice of Subpoenas to
`
`Google LLC filed in this case on August 29, 2018.
`
`4.
`
`Attached hereto as Exhibit B is a true and correct copy of email correspondence
`
`between Vincent Rubino and Sean Callagy regarding source code review, dated November 9,
`
`2018.
`
`
`
`Case 2:17-cv-00514-JRG Document 132-1 Filed 01/29/19 Page 2 of 3 PageID #: 9470
`
`5.
`
`Attached hereto as Exhibit C is a true and correct copy of email correspondence
`
`between counsel for AGIS Software Development LLC and counsel for HTC Corporation
`
`regarding source code review, dated November 26, 2018.
`
`6.
`
`Attached hereto as Exhibit D is a true and correct copy of email correspondence
`
`between counsel for AGIS Software Development LLC and counsel for HTC Corporation
`
`regarding source code review, dated December 13, 2018.
`
`7.
`
`Attached hereto as Exhibit E is a true and correct copy of excerpts of the expert
`
`report of Dr. Andrew Wolfe dated January 11, 2019.
`
`8.
`
`Attached hereto as Exhibit F is a true and correct copy of email correspondence
`
`between Daniel Shea and Sean Callagy regarding source code review, dated January 13, 2019.
`
`9.
`
`Attached hereto as Exhibit G is a true and correct copy of email correspondence
`
`between counsel for AGIS Software Development LLC and counsel for HTC Corporation
`
`regarding source code review, dated January 24, 2019.
`
`10.
`
`Attached hereto as Exhibit H is a true and correct copy of email correspondence
`
`between Enrique Iturralde and Bonnie Phan regarding source code produced by Google, dated
`
`January 24, 2019.
`
`11.
`
`Attached hereto as Exhibit I is a true and correct copy of Plaintiff AGIS Software
`
`Development LLC’s First Set of Common Interrogatories to HTC Corporation, dated March 8,
`
`2018.
`
`12.
`
`Attached hereto as Exhibit J is a true and correct copy of Defendant HTC
`
`Corporation’s Supplemental Responses and Objections to AGIS Software Development LLC’s
`
`Interrogatory No. 8, dated December 7, 2018.
`
`2
`
`
`
`Case 2:17-cv-00514-JRG Document 132-1 Filed 01/29/19 Page 3 of 3 PageID #: 9471
`
`13.
`
`Attached hereto as Exhibit K is a true and correct copy of Exhibit B to Dr. Andrew
`
`Wolfe’s expert report listing materials considered.
`
`I declare under penalty of perjury that the foregoing is true and correct to the best of my
`
`knowledge. Executed on January 25, 2019.
`
`/s/ Alfred R. Fabricant
`Alfred R. Fabricant
`
`3
`
`
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