Case 2:17-cv-00514-JRG Document 133-2 Filed 01/29/19 Page 1 of 4 PageID #: 9512
`Case 2:17-cv-00514-JRG Document 133-2 Filed 01/29/19 Page 1 of 4 PageID #: 9512
`
`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
`
`§
`§
`
`§ §
`
`§
`§
`
`§ §
`
`AGIS SOFTWARE DEVELOPMENT, LLC
`
`Plaintiff,
`
`V.
`
`HTC CORPORATION, et al.
`
`Defendant.
`§
`
`
`CASE NO. 2:17-CV-515-JRG
`(Member Case)
`
`JURY TRIAL DEMANDED
`
`§
`§
`§
`
`§ §
`
`§ §
`
`§ §
`
`AGIS SOFTWARE DEVELOPMENT, LLC
`
`Plaintiff,
`
`LG ELECTRONICS INC.
`
`Defendant.
`
`DECLARATION OF JUSTIN CHI IN SUPPORT OF
`
`LG ELECTRONICS INC.’S MOTION FOR SUMMARY JUDGMENT
`
`I, Justin Chi, state and declare as follows:
`
`1.
`
`.
`
`I am an attorney with 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
`
`Texas and have been admitted to practice in the United States District Court for the Eastern
`
`District of Texas.
`
`I provide this declaration in support of Defendant LGEKR’s motion for
`
`summary judgment.
`
`I have personal knowledge of the matters stated in this declaration and
`
`would testify competently and truthfully to them if called upon to do so.
`
`2.
`
`Attached hereto as Exhibit A is a true and correct copy of the June 15, 2017
`
`patent assignment of U.8. Patent Nos. 9,408,055 (the “”055 Patent”), 9,445,251 (the “’251
`
`1
`
`
`Case 2:17-cv-00514-JRG Document 133-2 Filed 01/29/19 Page 1 of 4 PageID #: 9512
`
`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
`
`§
`§
`
`§ §
`
`§
`§
`
`§ §
`
`AGIS SOFTWARE DEVELOPMENT, LLC
`
`Plaintiff,
`
`V.
`
`HTC CORPORATION, et al.
`
`Defendant.
`§
`
`
`CASE NO. 2:17-CV-515-JRG
`(Member Case)
`
`JURY TRIAL DEMANDED
`
`§
`§
`§
`
`§ §
`
`§ §
`
`§ §
`
`AGIS SOFTWARE DEVELOPMENT, LLC
`
`Plaintiff,
`
`LG ELECTRONICS INC.
`
`Defendant.
`
`DECLARATION OF JUSTIN CHI IN SUPPORT OF
`
`LG ELECTRONICS INC.’S MOTION FOR SUMMARY JUDGMENT
`
`I, Justin Chi, state and declare as follows:
`
`1.
`
`.
`
`I am an attorney with 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
`
`Texas and have been admitted to practice in the United States District Court for the Eastern
`
`District of Texas.
`
`I provide this declaration in support of Defendant LGEKR’s motion for
`
`summary judgment.
`
`I have personal knowledge of the matters stated in this declaration and
`
`would testify competently and truthfully to them if called upon to do so.
`
`2.
`
`Attached hereto as Exhibit A is a true and correct copy of the June 15, 2017
`
`patent assignment of U.8. Patent Nos. 9,408,055 (the “”055 Patent”), 9,445,251 (the “’251
`
`1
`
`
`
`Case 2:17-cv-00514-JRG Document 133-2 Filed 01/29/19 Page 2 of 4 PageID #: 9513
`Case 2:17-cv-00514-JRG Document 133-2 Filed 01/29/19 Page 2 of 4 PageID #: 9513
`
`Patent”), and 9,467,838 (the “”838 Patent”) (collectively, the “location sharing patents”) from
`
`Advanced Ground Information Systems, Inc. (“AGIS, Inc”) to AGIS Holdings, Inc., produced in
`
`this litigation as AGISTX_OOOO6025—3 1.
`
`3.
`
`>:1mo:T‘(DD. D‘9 (DHO mm mXE?CT:11 03 a m .—+H:C(D a:5Q. 0O:3(DoH OO
`
`"U‘<
`
`OI
`
`was
`
`produced in this litigation as AGISTX_001 18219-28.
`
`4.
`
`Attached hereto as Exhibit C is a true and correct copy of the June 15, 2017 patent
`
`assignment of the location sharing patents from AGIS Holdings, Inc. to AGIS Software
`
`Development LLC (“AGIS”), produced in this litigation as AGISTX.00006032—38.
`
`5.
`
`Attached hereto as Exhibit D is a true and correct copy of—
`
`was produced in this litigation as
`
`AGISTXM00118229-3 8.
`
`6.
`
`Attached hereto as Exhibit E is a true and correct copy of excerpts of AGIS’s
`
`Supplemental Objections and Responses to LGEKR’S First Set of Interrogatories to Plaintiff
`
`(Nos. 1-13), served on December 6, 2018.
`
`7.
`
`Attached hereto as Exhibit F is a true and correct copy of AGIS’s Second
`
`Supplemental Objections and Responses to LGEKR’s Second Set of Interrogatories to Plaintiff
`
`(N0. 14), served on December 7, 2018.
`
`8.
`
`Attached hereto as Exhibit G is a true and correct copy of excerpts of the
`
`transcript of the deposition of Eric Armstrong, which took place on October 11, 2018.
`
`2
`
`
`
`Case 2:17-cv-00514-JRG Document 133-2 Filed 01/29/19 Page 3 of 4 PageID #: 9514
`Case 2:17-cv-00514-JRG Document 133-2 Filed 01/29/19 Page 3 of 4 PageID #: 9514
`
`9.
`
`Attached hereto as Exhibit H is a true and correct copy of excerpts of LGEKR’s
`
`Supplemental Objections and Responses to AGIS’s First Set of Interrogatories (Nos. 1-10),
`
`served on December 27, 2018.
`
`10.
`
`Attached hereto as Exhibit I is a true and correct copy of LGEKR’s First Set of
`
`Interrogatories to Plaintiff AGIS Software Development LLC (N0s. 1—13), served on June 13,
`
`2018.
`
`11.
`
`Attached hereto as Exhibit J is a true and correct copy of excerpts of the transcript
`
`of the Rule 30(b)(6) deposition of Malcolm K. Beyer, which took place on October 22 and 23,
`
`2018.
`
`12.
`
`Attached hereto as Exhibit K is a true and correct copy of excerpts of the Android
`
`LifeRing Pocket Guide Revision 14, December 2016, produced in this litigation as
`
`AGISTX_00120881~37.
`
`1‘3.
`
`Attached hereto as Exhibit L is a true and correct copy of excerpts of the Android
`
`Full Manual Revision 19B, July 2017, produced in this litigation as AGISTX_00121049—89.
`
`14.
`
`Attached hereto as Exhibit M is a true and correct copy of a printout of
`
`https://www.agisinc.coni/about[p_at§§ts/, accessed on January 24, 2019.
`
`15.
`
`Attached hereto as Exhibit N is a true and correct copy of AGIS’s Initial
`
`Disclosures, served on December 22, 2017.
`
`16.
`
`Attached hereto as Exhibit 0 is a true and correct copy of excerpts of the sourCe
`
`code for the LifeRing product produced in this litigation as AGISTXSRC_LG00000994-995 and
`
`AGISTXSRC~LGOOOO1001-1004.
`
`17.
`
`Attached hereto as Exhibit P is the affidavit of Christopher Butler of the Internet
`
`Archive, executed on January 25, 2019.
`
`
`
`Case 2:17-cv-00514-JRG Document 133-2 Filed 01/29/19 Page 4 of 4 PageID #: 9515
`Case 2:17-cv-00514-JRG Document 133-2 Filed 01/29/19 Page 4 of 4 PageID #: 9515
`
`I declare under penalty of perjury that the foregoing is true and correct. Execute on this
`
`25th day of January 2019 in Los Angeles, California.
`
`Justi 1 Chi
`
`
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