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Case 2:17-cv-00514-JRG Document 134-2 Filed 01/29/19 Page 1 of 2 PageID #: 9642
`Case 2:17-cv-00514-JRG Document 134-2 Filed 01/29/19 Page 1 of 2 PageID #: 9642
`
`IN THE UNITED STATES DISTRICT COURT
`
`FOR THE EASTERN DISTRICT OF TEXAS
`
`MARSHALL DIVISION
`
`CASE NO. 2:]7—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
`
`DA UBERT MOTION TO EXCLUDE THE OPINIONS OF MR. ALAN RATLIFF
`
`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 Daubert motion
`
`to exclude the opinions of Mr. Alan Ratliff relating to damages.
`
`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.
`
`

`

`Case 2:17-cv-00514-JRG Document 134-2 Filed 01/29/19 Page 2 of 2 PageID #: 9643
`Case 2:17-cv-00514-JRG Document 134-2 Filed 01/29/19 Page 2 of 2 PageID #: 9643
`
`2.
`
`Attached hereto as Exhibit A is a true and correct copy of excerpts of the
`
`Damages Expert Report of Alan Ratliff On Behalf of AGIS With Respect To LG Electronics
`
`Inc., dated December 14, 2018, and StoneTurn Exhibit 3.
`
`3.
`
`Attached hereto as Exhibit B is a true and correct copy of excerpts of Mr. W.
`
`Christopher Bakewell’s Rebuttal Expert Report Regarding Damages, dated January 11, 2019.
`
`4.
`
`Attached hereto as Exhibit C is a true and correct copy of excerpts of the Expert
`
`Report of Edward R. Tittel In Rebuttal To the Expert Report of Joseph McAlexander Regarding
`
`Alleged Infringement of U.S. Patent Numbers: 8,213,970; 9,408,055; 9,445,251; and 9,467,838,
`
`dated January 11,2019.
`
`5.
`
`Attached hereto as Exhibit D is a true and correct copy of excerpts of the Expert
`
`Report of Joseph C. McAlexander III Regarding Infringement of US. Patent Numbers:
`
`8,213,970; 9,408,055; 9,445,251; and 9,467,838, dated December 14, 2018.
`
`I declare under penalty of perjury that the foregoing is true and correct. Executed on this
`
`25th day of January 2019 in Los Angeles, California.
`
`
`
`Justin Chi
`
`

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