`Case 2:17-cv-00514-JRG Document 135-2 Filed 01/29/19 Page 1 of 3 PageID #: 9677
`
`IN THE UNITED STATES DISTRICT COURT
`
`FOR THE EASTERN DISTRICT OF TEXAS
`
`MARSHALL DIVISION
`
`AGIS SOFTWARE DEVELOPMENT, LLC
`
`CIVIL ACTION NO. 2: 17-cv-514-JRG
`
`Plaintiff,
`
`(Lead Case)
`
`V-
`
`CIVIL ACTION NO. 2: 17-cv—515-JRG
`
`HTC CORPORATION, LG ELECTRONICS
`INC.
`
`Defendants.
`
`
`(Consolidated Case)
`
`JURY TRIAL DEMANDED
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`DECLARATION OF JUSEONG RYU IN SUPPORT OF
`
`LG ELECTRONICS, INC.’S MOTION FOR SUMMARY JUDGMENT
`
`I, Juseong Ryu, state and declare as follows:
`
`1.
`
`I am a Senior Manager for LG Electronics Inc. (“LGEKR”).
`
`I work out of
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`LGEKR’S IP Center in Seoul, South Korea. As a Senior Manager at LGEKR, my job
`
`responsibilities include patent licensing and patent litigation support.
`
`I submit this declaration
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`based upon my best and current knowledge regarding the subject matters addressed in this
`
`declaration. If called as a Witness, I could and would testify competently to the information
`
`contained herein.
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`2.
`
`I understand that the plaintiff in the above—referenced action has asserted claims
`
`of patent infringement against certain LG-branded mobile devices that utilize the Android
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`operating system (“OS”) developed by Google LLC (“Google”) (the “Accused Devices”).
`
`I also
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`understand that the plaintiff‘s infringement claims are based on the pre-installation by LGEKR
`
`of certain Google Mobile Services (“GMS”) applications on the Accused Devices, including
`
`Google Mobile Maps (the “Accused Applications”).
`
`
`
`Case 2:17-cv-00514-JRG Document 135-2 Filed 01/29/19 Page 2 of 3 PageID #: 9678
`Case 2:17-cv-00514-JRG Document 135-2 Filed 01/29/19 Page 2 of 3 PageID #: 9678
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`3.
`
`LGEKR is a South Korean corporation headquartered in Seoul, South Korea.
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`LGEKR designs, engineers, tests, and manufactures the mobile devices the Accused Devices
`
`outside the United States, mostly in Korea. LGEKR obtains the Android OS and Accused
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`Applications from Google, and installs them on the Accused Devices outside the United-States in
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`Korea. LGEKR does not perform any activities with respect to the Accused Devices within the
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`United States, including, without limitation, manufacturing, marketing, testing, using,
`
`distributing, selling or offering for sale of the Accused Devices within the United States.
`
`4.
`
`LG Electronics MobileComm USA. Inc. (“LGEMU”) was a wholly owned
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`subsidiary of LG Electronics USA, Inc. (“LGEUS”), which is a wholly-owned subsidiary of
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`LGEKR. As of August 1, 2018, LGEMU was merged into LGEUS. LGEMU was a California
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`corporation with offices in California. LGEUS is a Delaware corporation headquartered in
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`Englewood Cliffs, New Jersey.
`
`5.
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`LGEUS is solely responsible for importing, offering for sale, and selling the
`
`Accused Devices in the United States. Prior to its merger with LGEUS, LGEMU was solely
`
`responsible for importing, offering for sale, and selling the Accused Devices in the United States.
`
`6.
`
`LGEUS (and before August 1, 2018, LGEMU) acquires the Accused Devices
`
`from LGEKR outside the United States and imports them into the United States for sale to
`
`national phone carriers, retailers, and distributors, who in turn sell those devices to end users
`
`throughout the United States. LGEUS (and before August 1, 2018, LGEMU) is the only entity
`
`authorized by LGEKR to import, offer to sell, or sell, LG branded mobile devices in the United
`
`States.
`
`7.
`
`LGEKR does not sell or offer to sell any mobile devices, including the Accused
`
`Devices, in the United States. Sales of the Accused Devices in the United States are handled
`
`
`
`Case 2:17-cv-00514-JRG Document 135-2 Filed 01/29/19 Page 3 of 3 PageID #: 9679
`Case 2:17-cv-00514-JRG Document 135-2 Filed 01/29/19 Page 3 of 3 PageID #: 9679
`
`exclusively by LGEUS, including all associated marketing and distribution activities in the
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`United States.
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`8.
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`LGEUS (and, before August 1, 2018, LGEMU) purchases the Accused Devices
`
`
`
`
`
`
`
`
`
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`not have any ownership of or title to the Accused Devices at any point within the United States.
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`I declare under penalty of perjury that the foregoing is true and correct. Executed in
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`Seoul, South Korea on January g 2019
`
`
`
`in S eon?
`
`RYK
`
`Juseong Ryu
`
`
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