`Case 2:17-cv-00514-JRG Document 135-3 Filed 01/29/19 Page 1 of 4 PageID #: 9680
`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE EASTERN DISTRICT OF TEXAS
`MARSHALL DIVISION
`
`AGIS SOFTWARE DEVELOPMENT LI‘C,
`
`V~
`
`IITC CORPORATION.
`
`Plaintiff.
`
`Defendant.
`
`Case No. 2: l 7-cv-00514-JRG
`
`(Lead Case)
`
`JURY TRIAL DEMANDED
`
`AGIS SOFTWARE DEVELOPMENT LLC.
`
`Plaintiffi
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`Case No. 2:17-cv-00515-JRG
`
`V.
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`LG ELECTRONICS INC..
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`(Member Case)
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`JURY TR“
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`L DEM NDED
`A
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`l i
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`Defendant.
`
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`DECLARATION OF YASSER NAFEI IN SUPPORT OF
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`LG ELECTRONICS INC.’S MOTION FOR SUMMARY JUDGMENT
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`I. Yasser Nafei, state and declare as follows:
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`1.
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`I am the Senior Vice President, Go-to-Market Strategy, Sales, and Product
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`Management for LG Electronics USA, Inc. (“LGEU S").
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`I provide this declaration in support of
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`LG Electronics Inc’s (“LGEKR”) motion for summary judgmcnt. and. in particular, related to
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`the process by which LG mobile devices in the United States obtain Android OS software
`
`updates and pre—installed Googlc Mobile Service (“GMS”) application software updates. If
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`called as a witness. I could and would testify competently to the infonnation contained herein.
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`
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`Case 2:17-cv-00514-JRG Document 135-3 Filed 01/29/19 Page 2 of 4 PageID #: 9681
`Case 2:17-cv-00514-JRG Document 135-3 Filed 01/29/19 Page 2 of 4 PageID #: 9681
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`3.
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`My current position as the Senior Vice President. (it's-to-X'larket Strateg) . Sales.
`
`and Product .\-'lanagement is to assess and drive the successl‘ul launch and product marketing ot"
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`l.('. mohile devices in the United States for different carriers. such as \"t‘ri70n Wireless. ,\'| at.
`
`Sprint. 'l'-\-'lohile. LS. Cellular. and retailers. such as Best Buy and \N’almart.
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`in conjunction and
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`coordination with other [.0 account team leaders. my team and l interface with these ILS.
`
`carriers and retailers to determine and ensure proper product portlolios are. selected for the US.
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`market and that appropriate (lo-'l'o-lvlarket ((i'l‘M i acti\ ities including strategy. pricing.
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`promotion schemes. and term sheets lor those products are developed and executed during their
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`life cycles.
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`In in} capacin as a Senior Vice President | haxe become aware ol‘how l.(i mobile
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`devices sold by l.l{(il i8 in the United States \xill receive (ioogle-rclated soi‘tuare updates. as
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`that is a part ol‘the merall (,i'l‘M activities including the communication olinew product Matures
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`and enhanced user experience. the planning ol'joint l’R activities with carriers. the updates to l.(i
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`marketing collaterals or social and digital media. all ol‘these correspond to the many pieces 01'
`
`inlorniation rele\‘ant to the l‘ullillment and exaluation ot‘m)’ job responsibilities,
`
`J.
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`(ioogle l.l.(‘ ("(ioogle") develops and pl‘()\‘i‘LlC.\ Android OS soliware updates as
`
`well as updates to its (iMS applications.
`
`I understand that (iooglc is not a part} in this action.
`
`
`
`
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`Case 2:17-cv-00514-JRG Document 135-3 Filed 01/29/19 Page 3 of 4 PageID #: 9682
`Case 2:17-cv-00514-JRG Document 135-3 Filed 01/29/19 Page 3 of 4 PageID #: 9682
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`Case 2:17-cv-00514-JRG Document 135-3 Filed 01/29/19 Page 4 of 4 PageID #: 9683
`Case 2:17-cv-00514-JRG Document 135-3 Filed 01/29/19 Page 4 of 4 PageID #: 9683
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`8.
`
`I understand that there is a law-201 8 uniclc mentioning a new Hi "Software
`
`Upgrade Ccmcr" in \v'iagok-dung. Scuul. South Korea.
`
`(SI/c, ugh.
`
`httpzfr‘wu \\ .lgncwsronm.cunix'lU1 8:1.)4?Ig-opcns-gIohul-s.oIiwzirc-upgrade-center—for-faster-
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`
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`
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`I declare undcr punally of perjury that the tbrcgoing is lruc and correct.
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`lixcculcd in
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`(Chicago. Illinois mi.lzmu:1r_\' 25. 3010
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